CA Indosuez (Switzerland) S.A.

CAIS is a financial institution based in Switzerland that specializes in wealth management and corporate and investment banking. CAIS serves clients worldwide, including during the relevant time period 17 individual clients located in Iran, Syria, Sudan, the Crimea region of Ukraine, and Cuba. Following a periodic oversight review conducted by Compliance, CAIS identified the USD denominated accounts belonging to 17 individual clients ordinarily resident in Iran, Syria, Sudan, Crimea, and Cuba. In 2014, CAIS implemented internal restrictions aimed at preventing certain payments on accounts held by persons ordinarily resident in Cuba, Iran, Sudan, and Syria; Crimea was added to this list in 2015. However, CAIS later discovered that these internal restrictions did not prevent securities-related payments from being credited to the accounts. As a result, CAIS’s customers in sanctioned jurisdictions were able to continue to purchase and sell securities through the U.S. financial system and to receive related dividend and interest payments until CAIS took further steps to prevent such payments. As a result of the conduct described above, between April 2013 and April 2016, CAIS processed 273 transactions totaling approximately $3,076,180 on behalf of individuals ordinarily resident in Cuba, Crimea, Iran, Sudan, and Syria. This conduct resulted in apparent violations of the Iranian Transactions and Sanctions Regulations, 31 C.F.R. §§ 560.203 and 204.