Banco Santander

"In July 2007, it was reported that Santander “was doing business with Teheran-based Sepah as recently as March [2007]… Trading with businesses that are blacklisted for alleged links to terrorism is a serious breach of US law and can have draconian consequences...Santander is thought to have opened accounts for Sepah in various European countries and in Teheran. Allegations have also been made that Santander had a banking relationship with another Iranian bank that the US is targeting for its alleged links to terrorists. Santander said: ‘Neither of these institutions has an open account with Santander.’ The Spanish bank appears to have ended its relationship with Sepah after March. No details are known about the nature of its contact with the other bank.

The Santander Group has undertaken significant steps to withdraw from the Iranian market such as closing its representative office in Iran and ceasing all banking activities therein, including correspondent relationships, deposit taking from Iranian entities and issuing export letters of credit, except for the legacy transactions described above. The Santander Group is not contractually permitted to cancel these arrangements without either (i) paying the guaranteed amount (in the case of the performance guarantees), or (ii) forfeiting the outstanding amounts due to it (in the case of the export credits). As such, the Santander Group intends to continue to provide the guarantees and hold these assets in accordance with company policy and applicable laws.

Santander is "the third largest bank in the world in terms of profits." In 2008, the Santander Group acquired the US-based Sovereign Bank. (Company Website) (http://www.santander.com/csgs/Satellite?accesibilidad=3&canal=CAccionistas&cid=1148925257148&empr=SANCorporativo&leng=en_GB&pagename=SANCorporativo/Page/SC_ContenedorGeneral)

SAMIH affiliate—Santander U.K. plc—held savings accounts for two SDNs during the year, even as it noted that SAMIH’s activity does not relate to any activity conducted by Laredo or Laredo’s affiliates. (SEC Disclosure) (https://www.shearman.com/Perspectives/2018/01/Dynamics-in-the-Era-Iran-Sanctions)

Santander said: ‘Banco Santander is confident that it complies with all relevant banking regulations in the territories in which it operates, and with international requirements placed on banks, including those concerning money-laundering and the financing of terrorism.’ Sepah, which is owned by the Iranian state, was placed on the US blacklist in January. At the time, Stuart Levey, under-secretary for terrorism and financial intelligence, said: ‘Sepah is the financial linchpin of Iran's missile procurement network and has actively assisted Iran's pursuit of missiles capable of carrying weapons of mass destruction.’" (The Daily Telegraph, "Santander Traded with Blacklist Iranian Bank," 7/23/07) (http://www.telegraph.co.uk/finance/markets/2812719/Santander-traded-with-blacklist-Iranian-bank.html)

Banco Santander is also part of the Royal Bank of Scotland led consortium that owns ABN AMRO, which reportedly has done business with Iran. (ABN AMRO Company Website) (http://www.abnamro.com/about/about.cfm)

According to its Annual Report filed with the SEC: In 2019, the following activities are disclosed in response to Section 13(r) with respect to Santander UK and certain other affiliates of Santander (collectively, the Group). During the period covered by this report: (https://www.sec.gov/Archives/edgar/data/1087711/000119312520083397/d808709d20f.htm#tx808709_75)

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