Citigroup Inc.

"This license is one of at least three that OFAC issued involving the China Great Wall Industry Corporation. The licenses were issued after the Chinese company was added to the United States' special blacklist for supplying components to Iran's ballistic missile development program and before it was removed from the list on June 19, 2008. In one case, the agency licensed the Chinese company's lawyers, who were challenging the blacklisting, to receive legal fees. Two other cases involved wire transactions to or from China Great Wall. OFAC could have forced Citigroup to seize the funds, but said it chose instead to authorize the bank to return the money because China was unlikely to agree that the funds should be seized and therefore the bank would have almost certainly lost a legal battle to keep the funds blocked." (New York Times, "Licenses Granted to U.S. Companies Run the Gamut," 12/24/10) (http://www.nytimes.com/interactive/2010/12/24/world/24-sanctions.html)

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"When it comes to U.S. sanctions on Iran, no detail is too small to overlook these days. Since February, publicly traded companies have filed nearly 500 disclosure forms about their business ties to Iran…Citibank disclosed that its branch in Bahrain made $4 in profit in the second quarter by processing ATM transactions involving Future Bank, a joint venture whose owners include two Iranian-linked banks barred from doing business with U.S. companies…And though Citibank’s ATM fees were minimal, the bank involved was partly owned by Bank Saderat, which has been on the Treasury Department’s sanctions list since 2006 for being a 'conduit' between Iran and Hezbollah, the militant Shiite Muslim movement based in Lebanon." (Washington Post, "Under new law, companies disclosing even tiniest dealings with Iran," 12/4/13) (http://www.washingtonpost.com/business/economy/under-new-law-companies-disclosing-even-tiniest-dealings-with-iran/2013/12/04/451e6924-5ce6-11e3-bc56-c6ca94801fac_print.html)

"OFAC granted a license on Dec. 27, 2007, to Citibank authorizing it to make good on an agreement its Japanese subsidiary had entered into in October. The bank had agreed to confirm that certain conditions in a letter of credit had been meet, after which a Malaysian exporter of split-system air conditioners to Turkey would be paid. Then the bank discovered that the goods were to be shipped aboard a vessel called the Iran Ilam that was owned by the Iranian government-run shipping line known as Irisl, thus requiring that the transaction be licensed. The license was issued even though the Treasury Department and OFAC suspected that Irisl was being used to smuggle goods into Iran in contravention of various embargoes, including banned technology the government needed for its ballistic missile and nuclear programs. Moreover, at the time the license was issued, the United States had evidence that five months earlier, the Iran Ilam itself had delivered a lathe that could be used to make precise metal parts needed for nuclear centrifuges from China to Iran’s Shahid Bagheri Industrial Group, according to government officials who requested anonymity to speak about an intelligence matter. Indeed, within months of issuing the license, OFAC announced at a news conference that the United States was adding Irisl to a special blacklist, after an investigation found that Irisl had falsified cargo records, relied on front companies and used other trickery to mask the true nature and destination of shipments. At the September 2008 news conference announcing the decision, OFAC's director, Adam J. Szubin, warned that banks and companies worldwide should be aware that they could be unwittingly aiding Iran’s quest for banned technology by doing business with Irisl: 'Irisl’s deceptive practices make it nearly impossible to determine whether its shipments are licit or illicit,' he said. Mr. Szubin acknowledged in an interview that he was under no obligation to issue the license to Citigroup, given that banks were already prohibited generally from doing business with Iranian entities. But he said that OFAC had issued licenses in cases like this in the past in which the bank had no way of knowing that Irisl was involved and Irisl would have been paid by a foreign third party anyway. To depart from that norm in this case, he added, risked opening up his agency charges of unfair treatment and litigation, and tipping off Irisl that it was under investigation."

According to its Annual Report filed with the SEC for fiscal year 2015: "In addition to Citi’s prior disclosures, a subsidiary of Citi, Banco Nacional de México (Banamex), identified that it inadvertently processed five domestic funds transfers to the Embassy of Iran in Mexico during the third quarter of 2015.  The total value of these five funds transfers was approximately MXP 3,320 (approximately $177.00).  Three of the payments were for visa services that are exempt under Office of Foreign Assets Control (OFAC) regulations and two were for consular services that going forward would be permissible under OFAC General License H for Banamex as a non-U.S. subsidiary of Citi.  The transactions, in aggregate, resulted in approximately MXP 10 (approximately $0.53) in revenue for Banamex." (https://www.sec.gov/Archives/edgar/data/831001/000083100116000235/c-12312015x10k.htm)

"New details about the U.S. sanctions-busting case against Huawei Technologies Co. emerged in court filings in Canada, including about the Chinese telecom giant’s alleged dealings in Iran, Syria and Sudan. The filings also detailed discussions Huawei held with Citigroup Inc. C +0.68% and BNP Paribas SA BNPQY +0.08% about its Iran business. The documents released Tuesday allege that Huawei also had discussions with two other banks, Citigroup and BNP, about its Iran business, following the publication by Reuters of articles in 2012 and 2013 alleging that Huawei sold U.S.-made computer equipment in Iran via Skycom in violation of U.S. sanctions. They allege that Huawei representatives—including the company’s treasurer and Ms. Meng—told Citigroup that the company was in compliance with all sanctions, according to a 2017 email described in the filings. They also describe a 2014 BNP document in which Huawei described Skycom as “one of the business partners of Huawei.” HSBC and Standard Chartered have cut business ties with Huawei, deeming working with the company too risky, The Wall Street Journal reported in December. As of the end of last year, Citigroup continued to provide day-to-day banking services with Huawei outside the U.S., the Journal reported. A spokesman for Citigroup declined to comment. A Standard Chartered spokeswoman and a BNP spokeswoman declined to comment. An HSBC spokesman didn’t immediately respond to a request for comment."  (The Wall Street Journal, "Huawei Discussed Iran Business with Citi and BNP Paribas, Court Documents Show," 8/22/2019). (https://store.wsj.com/shop/US/US/wsjuswba20a/?inttrackingCode=aaquwron&icid=WSJ_ON_SPG_ACQ_NA&n2IKsaD9=n2IKsaD9&Pg9aWOPT=Pg9aWOPT&Cp5dKJWb=Cp5dKJWb&APCc9OU1=APCc9OU1&mod=snippetButton)

According to its Annual Report filed with the SEC for fiscal year 2018: " During the fourth quarter of 2018, Citibank Europe plc, a subsidiary of Citibank, acting as an intermediary bank processed a transaction between two Irish banks involving the Iranian Embassy in Ireland. The total value of the payment was EUR 90.00 (USD 104.24). This transaction was for visa-related fees and is exempt pursuant to the travel exemption of the Iranian Transactions and Sanctions Regulations. Citibank Europe plc realized nominal fees for the processing of this payment." (https://www.sec.gov/Archives/edgar/data/831001/000083100119000027/c-12312018x10k.htm)

Over the last three presidential administrations, the United States government has granted Citigroup 37 special licenses to do business in Iran. (New York Times, "Companies with Permission to Bypass Sanctions," 12/24/10) (http://www.nytimes.com/interactive/2010/12/24/world/24-sanctions-list.html)

According to its 2017 SEC filing – “During the third quarter of 2017, Bank Handlowy w Warszawie S.A., a Citibank subsidiary located in Poland, processed three funds transfers involving the Iranian Embassy in Poland.  The value of the funds transfers was EUR 50, EUR 50, and EU 100 (approximately $60.00, $60.00 and $117.00), respectively.  In addition, a branch of Citibank N.A., located in India, processed a funds transfer involving the Iran Consulate General in India.  The total value of this payment was INR 1,368 (approximately $21.00).  These payments were for visa-related fees and Iran-related travel respectively.” (https://www.sec.gov/Archives/edgar/data/831001/000083100117000139/c-9302017x10q.htm#s59E5FBD5016B570EA1BD2AB871CB9FA3)