Barclays PLC
According to its Annual Report filed with the SEC for fiscal year 2019: "Between 1993 and 2006, Barclays entered into several guarantees for the benefit of Iranian banks in connection with the supply of goods andservices by Barclays customers to Iranian buyers. These were counter guarantees issued to the Iranian ban ks to support guarantees issued by these banks to the Iranian buyers. The Iranian banks and a number of the Iranian buyers were subsequently designated as Specially Designated Nationalsand Blocked Persons (“SDN”) by the U.S. Department of the Treasury, Office of Foreign Assets Control (“OFAC”).
Barclays is party to a long - term lease, entered into in 1979, with the National Iranian Oil Company (“NIOC”), pursuant to which Barclays rents partof NIOC House in London for a Barclays bank branch. The lease is for 60 years, contains no early termination clause, and has 20 years remaining.Barclays makes quarterly lease payments in GBP to an entity that is owned by the Government of Iran. The payments are made in accordance with applicable laws and regulations. Barclays attributed no revenue in 2019 in relation to this activity.
A Barclays customer was designated pursuant to the Global Terrorism Sanctions Regulations (“GTSR”) in March 2016. Barclays continues to receive credit card repayments from this customer in accordance with applicable laws and regulations. A block continues to be applied to the card to prevent any further spending. Barclays attributed revenue of approximately GBP 480 in 2019 in relation to this activity. In 2019, Barclays processed three euro payments relating to overflight charges, a portion of which were for the overflight of Iranian airspace. It ispresumed that the ultimate beneficiary of the outbound payments was a Government of Iran owned entity. The payments were made in accordance with applicable laws and regulations. No payments were made directly to Iran or any entity owned or controlled by the Government of Iran. Although OFAC has issued a general license relating to payments for overflights of Iranian airspace, it does not technically apply to aircraft owned by non - U.S. persons, or registered outside of the U.S. Barclays attributed revenue of approximately GBP 30 in 2019 in relation to this activity. Barclays maintains customer relationships with UK - incorporated medical manufacturing companies. In 2018 and 2019, Barclays processed several payments, for the benefit of our customer, relating to the export of medical devices to privately - owned Iranian entities. The end users of these medical devices include hospitals or clinics that may be owned or controlled by the Government of Iran. The payments were made in accordance with applicable laws and regulations. All payments were received from the privately - owned Iranian entities; no payments were received directly from any entity owned or controlled by the Government of Iran. Although OFAC has issued general licenses relating to the sale of medical devices,they do not technically apply to sales of non - U.S. origin items by non - U.S. persons. Barclays attributed revenue of approximately GBP 60 in 2019 in relation to this activity. Barclays maintains customer relationships with several individuals who work for UK - based entities that are ultimately owned by the Government of Iran and are OFAC SDNs."
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"Barclays Plc, BNP Paribas SA, Commerzbank AG, Credit Agricole SA, Credit Suisse Group AG, Deutsche Bank AG, HSBC Holdings Plc , Royal Bank of Scotland Group Plc and Standard Chartered Plc had been sued by military personnel who survived the attacks, and relatives and estates of those killed.
The plaintiffs accused the banks in a 533-page complaint of concealing their work for Iran through such practices as altering wire transfers, and masking the identities of those transferring funds.
But the judge found the complaint “devoid” of allegations that the banks knew they were enabling attacks in Iraq linked to Hezbollah, al Qaeda and other groups that the U.S. government has designated as foreign terrorist organizations.
Swain found no proof, as required under a 2013 decision from the federal appeals court in Manhattan, that the services were a substantial factor in the attacks, and that the plaintiffs’ injuries were a reasonably foreseeable consequence." (April 1, 2019)
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As of August 27, 2019, Barclays plc is listed on the Illinois Investment Policy Board Iran Restricted Companies list.
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In 2018, the U.S. state of Michigan listed Barclays on its state lists of Companies Doing Business with Iran rendering Barclays ineligible for investment and/or state contracting.
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"For Syrian and Iranian citizens living in the Gulf, finding a bank to deal with just became a little tougher. Banks like Barclays and HSBC have begun turning away new customers from countries that are facing sanctions. They are closing down some existing accounts, further isolating Syrian and Iranian citizens from the global financial industry... Also under the new measures, Syrian or Iranian customers with bank balances of less than 100,000 dirhams, or $27,225, will be asked to close their accounts within 30 days. Customers with salaries of less than 15,000 dirhams will also be affected. This is because the cost to the bank of making the enquiries necessary to enforce compliance is higher than the benefit or 'profit potential' of keeping a customer with a small bank balance. It is cheaper for HSBC to close an account or not to open a new one with a balance of less than 100,000 dirhams." (The New York Times, "Sanctions Chill Reaches Banking Clients in the Persian Gulf," 2/13/13)
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"Since 2009, the Justice Department, the Treasury Department and the Manhattan district attorney’s office, working largely in concert, have brought charges against five foreign banks, contending they moved billions of dollars through their American subsidiaries on behalf of Iran, Cuba and North Korea, sponsors of terrorism and drug cartels. The cases against the five banks all included deferred prosecution agreements and required the banks — ABN Amro, Barclays, Credit Suisse, Lloyds and most recently ING — to forfeit a substantial amount of assets. The cases typically have not involved United States banks. Unlike foreign institutions, American banks were prohibited from originating or receiving such transactions from Iran. That enabled them to largely sidestep the conduct that has helped ensnare foreign banks." (New York Times, "Deutsche Bank’s Business With Sanctioned Nations Under Scrutiny," 8/17/12)
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"While operating in Iran, the bank received a small contract from the United States Navy. In 2007, the company disclosed to the Securities and Exchange Commission that it was the subject of a Justice Department investigation into its operations in countries where the United States maintains sanctions, and a spokesperson said the bank terminated all of its business in Iran and other countries subject to sanctions that year. The company, which said in a 2010 disclosure that it was cooperating with the inquiry, declined to comment on the investigation." The company received $47,381 in revenue and benefits from the US government for their business in Iran during 2000-2009. The company has since withdrawn their investments in Iran. (The New York Times, "Profiting from Iran, and the US," 3/6/2010)
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“Evidence of Iran's efforts to acquire sensitive materials also is emerging from investigations by state and federal prosecutors in New York into whether a number of major Western banks illegally handled funds for Iran and deliberately hid Iranian transactions routed through the U.S….Documents detailing Iran's metals acquisition efforts are being reviewed by U.S. law-enforcement and intelligence officials, people involved in the matter said. Manhattan District Attorney Robert Morgenthau said he is conducting a broad inquiry into illegal transactions by Iran. Last week, Lloyds TSB of London agreed to pay $350 million to settle U.S. sanctions-busting charges with Mr. Morgenthau's office and the Justice Department. The bank admitted it violated U.S. law but said the practice has ceased. There are nine other banks that we think were doing this, said Mr. Morgenthau in an interview, including Barclays PLC of the U.K. A Barclays spokesman had no comment beyond a prior disclosure confirming the inquiry. Other banks under scrutiny in the probe include Credit Suisse and Deutsche Bank, people with knowledge of the inquiries said." (The Wall Street Journal, "Fresh Clues of Iranian Nuclear Intrigue," 1/16/09)
No response at this time.
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