Mitsubishi UFJ Financial Group

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-- "Two additional challenges are also in the mix for Tokyo. The first is the financing of oil imports from Iran. Annually, Japan’s oil trade with Iran runs around one trillion yen, or $13.1 billion. On January 19 the Nikkei Shimbun reported that 80 to 90 percent of those transactions are done by the Bank of Tokyo Mitsubishi UFJ, and the remainder by the Sumitomo Mitsui Banking Corporation." (CFR. "Japan's Iran Sanctions Dilemma," 1/31/12) (http://blogs.cfr.org/asia/2012/01/31/japan%E2%80%99s-iran-sanctions-dilemma/?cid=oth_partner_site-atlantic)

Mitsubishi UFJ Financial Group (MUFG) "moved Japanese employees stationed at their representative offices in Tehran to locations outside of the country... and restricted travel to [Iran and Iraq]." (Japan Times, "Japan Firms Pull Staff Out of Iran and limit travel to Iraq amid high tensions," 1/9/20) (https://www.japantimes.co.jp/news/2020/01/09/business/japan-firms-pull-staff-iran-iraq-amid-high-tensions/)

According to its Annual report filed with the SEC for fiscal year 2015: "We have loan transactions with counterparties in or affiliated with Iran, the outstanding balance of which was approximately $1.0 million, representing less than 0.0001% of our total assets, as of March 31, 2015. We do not have any loans outstanding to the financial institutions specifically listed by the U.S. government. In addition to such loan transactions, our other transactions with counterparties in or affiliated with countries designated as state sponsors of terrorism consist of receiving deposits or holding assets on behalf of individuals residing in Japan who are citizens of countries designated as state sponsors of terrorism, processing payments to or from entities in or affiliated with these countries on behalf of our customers, and issuing letters of credit and guarantees in connection with transactions with entities in or affiliated with such countries by our customers. These transactions do not have a material impact on our business or financial condition. For a further discussion of transactions required to be disclosed under the U.S. Iran Threat Reduction and Syria Human Rights Act of 2012, see “Item 4.B. Information on the Company—Business Overview—Supervision and Regulation—United States—Disclosure pursuant to Section 13(r) of the Securities Exchange Act of 1934.”" (https://www.sec.gov/Archives/edgar/data/67088/000095012315007710/d868797d20f.htm)

According to its Annual report filed with the SEC for fiscal year 2019: "During the fiscal year ended March 31, 2019, one of our non-U.S. subsidiaries engaged in business activities with entities in, or affiliated with, Iran, including counterparties owned or controlled by the Iranian government. Specifically, our non-U.S. banking subsidiary, MUFG Bank, issued letters of credit and guarantees and provided remittance and other settlement services mainly in connection with customer transactions related to the purchase and exportation of Iranian crude oil to Japan, and in some cases, in connection with other petroleum-related transactions with Iran by its customers. These transactions did not involve U.S. dollars nor clearing services of U.S. banks for the settlement of payments. For the fiscal year ended March 31, 2019, the aggregate interest and fee income relating to these transactions was less than ¥100 million, representing less than 0.005 percent of our total interest and fee income. Some of these transactions were conducted through the use of non-U.S. dollar correspondent accounts and other similar settlement accounts maintained with MUFG Bank outside the United States by Iranian financial institutions and other entities in, or affiliated with, Iran. In addition to such accounts, MUFG Bank receives deposits in Japan from, and provides settlement services in Japan to, fewer than 10 Iranian government-related entities and fewer than 100 Iranian government-related individuals such as Iranian diplomats in Japan, and maintains settlement accounts outside the United States for certain other financial institutions specified in Executive Order 13382, which settlement accounts were frozen in accordance with applicable laws and regulations. For the fiscal year ended March 31, 2019, the average aggregate balance of deposits held in these accounts represented less than 0.1 percent of the average balance of our total deposits. The fee income from the transactions attributable to these account holders was less than ¥20 million, representing less than 0.005 percent of our total fee income. Although there was no outstanding balance as of March 31, 2019, MUFG Bank had, during the fiscal year ended March 31, 2019, loans that were arranged prior to changes in applicable laws and regulations to borrowers in, or affiliated with, Iran, including entities owned by the Iranian government. For the fiscal year ended March 31, 2019, the agent fee income relating to these loan transactions was less than ¥20 million, representing less than 0.005 percent of our total interest and fee income. (https://www.sec.gov/Archives/edgar/data/67088/000119312519191525/d685488d20f.htm)

Global financial institutions, including us, have become subject to an increasingly complex set of sanctions laws and regulations in recent years, and this regulatory environment is expected to continue. Moreover, the measures proposed or adopted vary across the major jurisdictions, increasing the cost and resources necessary to design and implement an appropriate global compliance program. The U.S. federal government and some state governments in the United States have enacted legislation designed to limit economic and financial transactions with Iran by limiting the ability of financial institutions that may have engaged in any one of a broad range of activities related to Iran to conduct various transactions in the relevant jurisdictions. The U.S. federal government recently strengthened the Iran-related regulations with the enactment in August 2012 of the Iran Threat Reduction and Syria Human Rights Act, which, among other things, imposes additional disclosure requirements. The Japanese government has also implemented a series of measures under the Foreign Exchange and Foreign Trade Act, such as freezing the assets of designated financial institutions and others that could contribute to Iran’s nuclear activities, and our most recently modified policies and procedures take into account the current Japanese regulatory requirements. There remains a risk of potential U.S. regulatory action against us, however, if U.S. regulators perceive the modified policies and procedures not to be in compliance with applicable regulations."

We have loan transactions with counterparties in or affiliated with Iran, the outstanding balance of which was approximately $4.7 million, representing less than 0.001% of our total assets, as of March 31, 2013. We do not have any loans outstanding to the financial institutions specifically listed by the U.S. government. In addition to such loan transactions, our other transactions with counterparties in or affiliated with countries designated as state sponsors of terrorism consist of receiving deposits or holding assets on behalf of individuals residing in Japan who are citizens of countries designated as state sponsors of terrorism, processing payments to or from entities in or affiliated with these countries on behalf of our customers, and issuing letters of credit and guarantees in connection with transactions with entities in or affiliated with such countries by our customers. These transactions do not have a material impact on our business or financial condition. For a further discussion of transactions required to be disclosed under the U.S. Iran Threat Reduction and Syria Human Rights Act of 2012, see “Item 4.B. Information on the Company—Business Overview—Supervision and Regulation—United States—Disclosure under Section 13(r) of the U.S. Securities Exchange Act of 1934.”

"The National Iranian Oil Co., the country’s state-run oil company, will stop Japanese refiners from picking up cargoes until it can find alternative ways to access payments received through accounts at the Bank of Tokyo unit of Mitsubishi UFJ Financial Group Inc. (8306), the officials said, declining to be identified because of company policies... A district court in New York told Mitsubishi UFJ this month to freeze at least $2.6 billion of Iranian assets held at the bank, Tomohiro Kosaka, a Tokyo-based spokesman for Mitsubishi UFJ, said today... Mitsubishi UFJ filed a petition of objection yesterday to the New York court, said Shinya Matsumoto, a spokesman for the lender in Tokyo." (Bloomberg Businessweek, "Iran Crude to Japan Said to Face Blocks After Court Order," 5/17/2012) (http://www.businessweek.com/news/2012-05-17/iran-oil-cargoes-to-japan-said-to-face-blocks-after-court-ruling)

We are aware of initiatives by U.S. governmental entities and non-government entities, including institutional investors such as pension funds, to adopt or consider adopting laws, regulations or policies prohibiting transactions with or investment in, or requiring divestment from, entities doing business with Iran and other countries identified as state sponsors of terrorism. It is possible that such initiatives may result in our being unable to gain or retain entities subject to such prohibitions as customers, counter-parties or investors in our shares. In addition, depending on socio-political developments, our reputation may suffer due to our transactions with counterparties in or affiliated with these countries. The above circumstances could have an adverse effect on our business and financial condition.

"Bank of Tokyo-Mitsubishi UFJ, which handles most of Japan's payments for oil imports from Iran, on Thursday said it had frozen transactions with Iranian banks after being ordered to do so by the New York District Court earlier this month." (Reuters, "Japan looks to central bank to pay for Iran oil: Nikkei," 5/21/2012) (http://www.reuters.com/article/2012/05/18/us-bankofjapan-idUSBRE84H11V20120518)

According to its Annual Report filed with the SEC for fiscal year 2012: "We, through our subsidiaries, engage in business activities with entities in or affiliated with Iran, including transactions with counterparties owned or controlled by the Iranian government, and our banking subsidiary has a representative office in Iran. The U.S. Department of State has designated Iran and other countries as “state sponsors of terrorism,” and U.S. law generally prohibits U.S. persons from doing business with such countries. We currently have business activities with entities in or affiliated with such countries in accordance with our policies and procedures designed to ensure compliance with regulations applicable in the jurisdictions in which we operate. (https://www.sec.gov/Archives/edgar/data/67088/000119312513297023/d564083d20f.htm)

"The Bank of Tokyo-Mitsubishi UFJ Ltd. was ordered to transfer funds belonging to Iran-based entities to the families of 17 U.S. Air Force service members killed in a 1996 attack in Saudia Arabia... The assets at issue total about $357,000 and Bank of Tokyo said it doesn’t oppose releasing them, according to the filing." (Bloomberg, "Bank of Tokyo-Mitsubishi Must Give Iran Funds to U.S. Families," 1/29/2013) (http://www.bloomberg.com/news/2013-01-30/bank-of-tokyo-mitsubishi-must-give-iran-funds-to-u-s-families.html)

According to its Annual report filed with the SEC for fiscal year 2016: "We have loan transactions with counterparties in or affiliated with Iran, the outstanding balance of which was approximately $0.8 million, representing less than 0.0001% of our total assets, as of March 31, 2016. We do not have any loans outstanding to the financial institutions specifically listed by the U.S. government. In addition to such loan transactions, our other transactions with counterparties in or affiliated with countries designated as state sponsors of terrorism consist of receiving deposits or holding assets on behalf of individuals residing in Japan who are citizens of countries designated as state sponsors of terrorism, processing payments to or from entities in or affiliated with these countries on behalf of our customers, and issuing letters of credit and guarantees in connection with transactions with entities in or affiliated with such countries by our customers." (https://www.sec.gov/Archives/edgar/data/67088/000119312516648782/d140673d20f.htm)

"Mitsubishi UFJ Financial Group Inc. agreed to pay $250 million to the state of New York to settle claims it transferred billions of dollars for countries facing U.S. sanctions including Iran, Sudan and Myanmar. Bank of Tokyo-Mitsubishi UFJ Ltd., the main lending unit of Japan's biggest bank by market value, moved an estimated $100 billion through the state for government and privately owned entities on the Specially Designated Nationals list issued by the U.S. Treasury Department's Office of Foreign Assets Control (OFAC) between 2002 and 2007, the New York State Department of Financial Services (DFS) and New York Governor Andrew Cuomo said in a statement yesterday. The transfers involved about 28,000 clearing transactions and the bank routinely stripped information from wire transfer messages that could identify countries and people subject to international sanctions, the department said. The agreement follows HSBC Holdings Plc (HSBA)'s record settlement with the U.S. last year, stemming from sanctions aimed at pressuring Iran to halt its nuclear program. 'We have and will continue to take a hard line in rooting out misconduct at banks that threaten our national security,' Benjamin Lawsky, the superintendent of the department, said in the statement.” (Bloomberg, “Mitsubishi UFJ to Pay $250 million to NY Regulator,” 6/20/13) (tel:2002) (tel:2007) (http://www.bloomberg.com/news/2013-06-20/mitsubishi-ufj-to-pay-250-million-to-n-y-regulator.html)

According to its Annual Report filed with the SEC for fiscal year 2018: We have loan transactions with counterparties in or affiliated with Iran, the outstanding balance of which was less than ¥50 million representing less than 0.0001% of our total assets, as of March 31, 2018. We do not have any loans outstanding to the financial institutions specifically listed by the U.S. government. In addition to such loan transactions, our other transactions with counterparties in or affiliated with countries designated as state sponsors of terrorism consist of receiving deposits or holding assets on behalf of individuals residing in Japan who are citizens of countries designated as state sponsors of terrorism, processing payments to or from entities in or affiliated with these countries on behalf of our customers, and issuing letters of credit and guarantees in connection with transactions with entities in or affiliated with such countries by our customers. These transactions do not have a material impact on our business or financial condition. For a further discussion of transactions required to be disclosed under the U.S. Iran Threat Reduction and Syria Human Rights Act of 2012, see “Item 4.B. Information on the Company—Business Overview—Supervision and Regulation—United States—Disclosure pursuant to Section 13(r) of the Securities Exchange Act of 1934.”" (https://www.sec.gov/Archives/edgar/data/67088/000119312518216433/d528020d20f.htm)

MUFG Bank recognizes that following the withdrawal in May 2018 by the United States from the Joint Comprehensive Plan of Action, the United States has imposed secondary sanctions against non-U.S. persons who engage in or facilitate a broad range of transactions and activities involving Iran. MUFG Bank has taken the recent sanctions related developments into account and monitor any future transactions relating to Iran in order to comply with applicable U.S. and Japanese regulations as well as U.S., Japanese and other international sanctions."

"Will halt all iran transactions to comply with the reimposition of U.S. sanctions against Tehran later this year…" (July 12, 2018).  (https://uk.reuters.com/article/us-japan-iran-mufg/japanese-banks-mufg-mizuho-to-stop-iranian-transactions-idUKKBN1K20X0)

”Three Japanese big banks, namely the Bank of Tokyo-Mitsubishi UFJ, Sumitomo Mitsui Bank and Mizuho Bank, have started interactions in the form of telegraphic transfer—an electronic method of transferring funds—and L/C at sight  with a number of Iranian banks." (May 2017). (https://financialtribune.com/articles/economy-business-and-markets/64304/iran-japan-expanding-banking-ties)

As stated in its 2017 SEC disclosure: "During the quarter ended September 30, 2017, a non-U.S. subsidiary of MUFG engaged in business activities with entities in, or affiliated with, Iran, including counterparties owned or controlled by the Iranian government. Specifically, MUFG’s non-U.S. banking subsidiary, BTMU, issued letters of credit and guarantees and provided remittance and other settlement services mainly in connection with customer transactions related to the purchase and exportation of Iranian crude oil to Japan, and in some cases, in connection with other petroleum-related transactions with Iran by its customers.  In addition to such accounts, BTMU receives deposits in Japan from, and provides settlement services in Japan to, fewer than ten Iranian government-related entities and fewer than 100 Iranian government-related individuals such as Iranian diplomats, and maintains settlement accounts outside the United States for certain other financial institutions specified in Executive Order 13382, which settlement accounts were frozen in accordance with applicable laws and regulations." (https://www.sec.gov/Archives/edgar/data/1011659/000162828017011203/muah10qq32017.htm/)

"Reports issued by U.S. researchers attempting to document activity by multinational companies in Iran have named...units of Japan's three largest banks--Mitsubishi UFJ Financial Group Inc, Sumitomo Mitsui Financial Group and Mizuho Financial Group Inc--as doing business that could possibly run afoul of new U.S. rules... A widely circulated report issued this year by a former U.S. Treasury Department official on global banks doing business with Iranian banks named the Big Three Japanese financial institutions. Spokespeople for the three Japanese banks declined to comment on the accuracy of the report, or how the law might affect their operations in Iran." (Wall Street Journal, "New U.S. Law on Iran May Hurt Japanese Firms," 7/1/2010). (http://online.wsj.com/article/SB10001424052748704525704575340420282516604.html)

The Bank of Tokyo-Mitsubishi UFJ is Japan's largest bank and serves as the core retail and commercial banking arm of the Mitsubishi UFJ Financial Group. (http://www.bk.mufg.jp/global/index.html)

According to its Annual report filed with the SEC for fiscal year 2014: "We have loan transactions with counterparties in or affiliated with Iran, the outstanding balance of which was approximately $4.5 million, representing less than 0.001% of our total assets, as of March 31, 2014. We do not have any loans outstanding to the financial institutions specifically listed by the U.S. government. In addition to such loan transactions, our other transactions with counterparties in or affiliated with countries designated as state sponsors of terrorism consist of receiving deposits or holding assets on behalf of individuals residing in Japan who are citizens of countries designated as state sponsors of terrorism, processing payments to or from entities in or affiliated with these countries on behalf of our customers, and issuing letters of credit and guarantees in connection with transactions with entities in or affiliated with such countries by our customers. These transactions do not have a material impact on our business or financial condition. For a further discussion of transactions required to be disclosed under the U.S. Iran Threat Reduction and Syria Human Rights Act of 2012, see “Item 4.B. Information on the Company—Business Overview—Supervision and Regulation—United States—Disclosure pursuant to Section 13(r) of the Securities Exchange Act of 1934.”" (https://www.sec.gov/Archives/edgar/data/67088/000119312514272193/d691375d20f.htm)

"Japanese trading house Mitsubishi Corp has renewed its annual oil purchase deal with Iran but cut the loading volume to comply with U.S. sanctions against the Islamic nation, trade sources said on Friday…Mitsubishi's new contractual volume from April onwards remained unclear. The company had bought 15,000 barrels of crude per day (bpd), or more, last year."  (Reuters, "Japan's Mitsubishi renews Iran oil imports deal," 6/22/12) (http://www.reuters.com/article/2012/06/22/japan-iran-mitsubishi-idUSL3E8HM3VC20120622)