Banking

Jammal Trust Bank (JTB)

Industry
Banking
Country
Lebanon
Sources

"The party failed in its efforts and therefore, now set its sights on the banking sector, he noted. Nader wondered whether Lebanese banks should refuse to abide by the US sanctions and suffer the same fate as the Jammal Trust Bank that liquidated itself last month.The political aspect of Hezbollah’s threats is related to the ongoing US conflict with Iran." (Asharq Al Awsat, "Security, Political Messages behind Hezbollah's Threat to Lebanese Banks," 10/15/2019).

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"In July, the Treasury Department targeted two Hezbollah legislators, Amin Sherri and Mohammad Raad, in the first such move against lawmakers currently seated in Lebanon’s parliament. A month later, the Treasury’s Office of Foreign Assets Control sanctioned Jammal Trust Bank for what it called “knowingly facilitating banking activities.” The bank, which denied the charges, was forced to close afterward." (The Times of Israel, "US sanctions on Iran-backed Hezbollah deepen Lebanon economic crisis," 10/5/2019).

Banco Bilbao Vizcaya Argentaria (BBVA)

Industry
Banking
Symbol
NYSE BBVA
Country
Spain
Sources

According to its Annual Report filed with the SEC for fiscal year 2019: "The BBVA Group discloses the following information pursuant to Section 13(r) of the Exchange Act, which requires an issuer to disclose whether it or any of its affiliates knowingly engaged in certain activities, transactions or dealings relating to Iran or with natural persons or entities designated by the U.S. government under specified executive orders, including activities not prohibited by U.S. law and conducted outside the United States by non-U.S. affiliates in compliance with local law. In order to comply with this requirement, the Company has requested relevant information from its affiliates globally.

The BBVA Group has the following activities, transactions and dealings with Iran requiring disclosure:

Legacy contractual obligations related to counter indemnities. The BBVA Group made a payment of $642 to Bank Melli on July 11, 2019, due to outstanding commissions on the counterindemnity executed on October 16, 2018. Such counterindemnity was issued in April 2000 and has been regulatory reported until its execution in 2018.

Iranian embassy-related activity. The BBVA Group maintains bank accounts in Spain for one employee of the Iranian embassy in Spain. This employee is a Spanish citizen. Estimated gross revenues for the year ended December 31, 2019, from embassy-related activity, which include fees and/or commissions, totaled $2,225. The BBVA Group does not allocate direct costs to fees and commissions and therefore has not disclosed a separate profit measure. 

The BBVA Group is committed to terminating these business relationships as soon as legally possible."

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As of August 27, 2019, Banco Bilbao Vizcaya Argentaria (BBVA) is listed on the Illinois Investment Policy Board Iran Restricted Companies list. 

Response

BBVA closed its Tehran representative office in 2008 (4/16/2018)

Export Import Bank of Korea (Korea Eximbank)

Industry
Banking
Country
South Korea
Sources

"Iran has secured its biggest post credit line deal since the Joint Comprehensive Plan of Action, (JCPOA), Iran’s nuclear deal with world powers, in a deal with South Korea, local media have reported. The $9.4 billion deal between South Korea’s Eximbank and Iranian banks was signed in Seoul on August 24." (Radio Farda, "Iran, South Korea Sign Record Deal," 8/27/2017.)

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"We engage in business related to Iran, including transactions involving as counterparties Iranian banks that may be indirectly owned or controlled by the Iranian government. The U.S. State Department has designated Iran as a state sponsor of terrorism, and U.S. law generally prohibits U.S. persons from doing business in Iran. We are a Korean bank and our activities with respect to Iran have not involved any U.S. person in either a managerial or operational role and have been subject to policies and procedures designed to ensure compliance with applicable Korean laws and regulations. We believe that our activities related to Iran are not subject to the mandatory sanctions administered or enforced by the United States Government (including, without limitation, Section 104 of the U.S. Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 (“CISADA”) and the Iran Financial Sanctions Regulations issued by the U.S. Secretary of the Treasury thereunder (the “IFSR”)).

Our business related to Iran consists solely of extensions of credit and financing provided in connection with exports of Korean goods and services to Iran and our disbursements of Iran-related credits are made directly to Korean suppliers or exporters except certain credits made to Iranian banks. Such activities have involved export-related credits to finance the export contracts of Korean exporters supplying goods and services to Iranian companies, credit line extensions to Iranian banks to finance consumer products exports by Korean exporters, extensions of credit through non-recoursediscounting of export trade bills, and purchases of promissory notes securing export transactions. Our Loans to Iran represented 0.1%, 0.3% and 0.5% of our total assets as of December 31, 2015, 2016 and 2017, respectively, and also represented 0.1%, 0.3% and 0.7% of our Loan Credits as of those respective dates. Our total operating revenues from transactions with Iran in 2015, 2016 and 2017 represented 0.3%, 0.3% and 0.3% of our total operating revenues, respectively.

We are aware, through press reports and other means, of initiatives by governmental entities in the U.S. and by U.S. institutions such as universities and pension funds, to adopt laws, regulations or policies prohibiting transactions with or investment in, or requiring divestment from, entities doing business with Iran, including, without limitation, CISADA and IFSR. It is possible that such initiatives may result in our being unable to gain or retain entities subject to such prohibitions as customers or as investors in our debt securities. In addition, our reputation may suffer due to our association with Iran. Such a result could have significant adverse effects on our business or the price of our debt securities." (6/14/2018; SEC Post Effective Amendment No. 4 to Registration Statement Under Schedule B of the Securities Act of 1933).

Sberbank

Industry
Banking
States
NY
Country
Russia
Response

Response: "at the core of Sberbank's business decisions is a comprehensive and scrupulous process analyzing the bans and limitations in place regarding Iran" (May 30, 2017)

Oman Investment Fund

Industry
Banking
Country
Oman
Sources

"An Omani sovereign wealth fund has signed an understanding with Iran’s biggest auto maker, Iran Khodro Industrial Group, to study a proposal for a $200 million auto plant in Oman, a fund official said on Wednesday. The memorandum of understanding is one of the first signed between a major Iranian company and a Gulf Arab state since international sanctions against Iran were lifted earlier this month. Traditionally, Oman has had closer ties to Iran than its Arab neighbours." (January 27, 2016).