Banco Bilbao Vizcaya Argentaria (BBVA)

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. (https://www.sec.gov/Archives/edgar/data/842180/000084218020000006/d20f2019.htm)

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.

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

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.

As of August 27, 2019, Banco Bilbao Vizcaya Argentaria (BBVA) is listed on the Illinois Investment Policy Board Iran Restricted Companies list.  (https://www2.illinois.gov/sites/iipb/Pages/ProhibitedInvestmentList.aspx)

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