Bank of Nova Scotia (Scotiabank)

According to its Annual Report filed with the SEC for fiscal year 2017: "During the year ended October 31, 2017, the Bank received certain incoming and outgoing wire transfer messages on behalf of or for credit to customers of the Bank that, after review and investigation, appear to have involved a party in Iran or related to an underlying transaction with a party in Iran. In one case, the Bank identified that the receiving financial institution was an Iranian state-owned entity. The Bank rejected this Euro payment. In another case, the Bank’s investigation identified that an outgoing Euro payment to a private company in Iran related to work performed by that party at a facility affiliated with the Government of Iran. In addition, during the year ended October 31, 2017, the Bank processed a number of USD bank drafts drawn on a U.S. financial institution and issued to Bank customers payable to the Iranian Interest Section of the Pakistan Embassy, located in Washington, D.C., for official business of the Iranian Interests Section, including payment of Iranian passport fees and visas. The Bank believes that its activity in connection with these wire transfers and bank drafts did not violate any applicable sanctions. As the wire transfers involved interests of the Government of Iran or parties affiliated with the Government of Iran, the Bank is including disclosure in this report because it potentially could be required to be disclosed under Section 13(r).

In addition, in February 2017, the Bank processed an incoming US dollar wire transfer for one of its customers in Canada that originated from a bank in the UAE. After review, the Bank discovered that the wire transfer represented payment for oil and gas services equipment on behalf of a private company based in Iran that is not named on an OFAC sanctions list. The Bank believes that its activity in processing the incoming payment is not required to be disclosed under Section 13(r), but the Bank is providing disclosure because the underlying transaction appears to have related to Iran’s oil and gas sector and thus potentially could be an activity described in subsection (a) or (b) of Section 5 of the Iran Sanctions Act of 1996 that would be required to be disclosed under Section 13(r) for any person who knowingly engages in such activity.

--

According to its Annual Report filed with the SEC for fiscal year 2016: "In February 2016, the Bank processed an incoming Canadian dollar wire transfer for one of its customers in Canada that originated from a bank in Kuwait. The Bank has learned that the wire transfer represented payment from a private company based in Iran that is not named on the OFAC sanctions lists, for oil and gas exploration and extraction equipment that the customer supplied to that entity. After review of the underlying transaction, the Bank has no reason to believe that the wire transfer or the transaction violated any applicable sanctions. Although the Bank believes that its activity in processing the incoming payment is not required to be disclosed under Section 13(r), the underlying transaction, which involved the supply of oil and gas exploration and extraction equipment, potentially could be required to be disclosed under Section 13(r); accordingly, the Bank is including disclosure of this activity in this report. This customer’s banking accounts were closed in August 2016. It is not possible to accurately determine the precise net profit attributable to such wire transfer, and even if revenues and profits from these were calculated, they would be negligible."

--

According to its Annual Report filed with the SEC for fiscal year 2015: "The Bank held one Canadian dollar account for the Embassy of Iran in Canada. This account, used for the purpose of official embassy business, has been frozen since 2013 and was closed on June 1, 2015. In addition, the Bank issued a bank draft payable to the “Interest Section of the Islamic Republic of Iran” (the “Iran Section”) for a visa fee. The Iran Section is part of the Pakistani Embassy in Washington, D.C. The Bank has complied with all applicable laws in connection with this account and bank draft."

--

According to its Annual Report filed with the SEC for fiscal year 2014: "The Bank holds one Canadian dollar account for the Embassy of Iran in Canada. This account, used for the purpose of official embassy business, has been frozen since 2013. A second Canadian dollar account for the Embassy of Iran, used to fund scholarship payments to Iranian students studying in North America, was the subject of a court order requiring the Bank to pay the balance to the judgment creditor as a result of a requirement from the Sherriff’s Office (civil restitution office). This was done in April 2014 and the account was then closed. The Bank has complied with and will continue to comply with all applicable laws in relation to these accounts."

--

According to its Annual Report filed with the SEC for fiscal year 2013: "The Bank holds two Canadian dollar accounts for the Embassy of Iran in Canada. These are for the purpose of official embassy business, including scholarship payments to Iranian students studying in North America. These accounts have been frozen since 2013. The Bank has complied with and will continue to comply with all applicable laws in relation to these accounts.

The Bank holds a Canadian dollar deposit account for a business that received a wire transfer from an entity that is owned or controlled by a person designated on the SDN List with respect to sanctions pertaining to Iran. The wire transfer funds were received and frozen in 2007. The freeze on these funds was released in October 2013 as a result of the issuance of a certificate by Canada’s Minister of Foreign Affairs pursuant to Section 19 of Canada’s Regulations Implementing the United Nations Resolutions on Iran. The Bank has complied with and will continue to comply with all applicable laws in relation to this account."