Deutsche Bank

According to its Annual Report filed with the SEC for fiscal year 2019: "We had a representative office in Tehran, Iran, which we discontinued on December 31, 2007. Our remaining business with Iranian counterparties consisted mostly of participations as lender and/or agent in a few large trade finance facilities arranged before 2007 to finance the export contracts of exporters in Europe and Asia. As of December 31, 2018, those loans were fully paid back, subsequently the majority of the remaining Iranian business consists of legacy contractual obligations related to guarantees. We do not believe our business activities with Iranian counterparties are or had been material to our overall business, with the aforementioned guarantees having notional amounts of substantially less than 0.01 % of our total assets over recent years. As of December 31, 2019, the revenues from such activities represented substantially less than 0.01 % of our total revenues for the year ended December 31, 2019.

Payments Executed. Deutsche Bank continuous to severely restrict its policy on Iran and consequently the execution of such payments.

Incoming Payments. In 2019, we received 10 payments adding up to approximately € 2.0 million in favor of non-Iranian clients of which the majority were channeled through Iranian intermediary banks. Revenues for these incoming payments were less than € 100. These figures include relevant transactions for Iranian Embassy-related offices not included in the section on Iranian Consulates and Embassies below and in favor of our non-Iranian clients.

Outgoing Payments. In 2019, we executed 1 payment with an amount of € 100, in favor of an Iranian Embassy-related office not included in the section on Iranian Consulates and Embassies below. Revenues for this outgoing payment were less than € 10.

Operations of Iranian Bank Branches and Subsidiaries in Germany. Several Iranian banks, including Bank Melli Iran, Bank Saderat, Bank Sepah, and Europäisch-Iranische Handelsbank, have branches or offices in Germany, even though their funds and other economic resources had been frozen earlier under European law. As part of the payment clearing system in Germany and other European countries, when these branches or offices needed to make payments in Germany or Europe to cover their day-to-day operations such as rent, taxes, insurance premia and salaries for their remaining staff, or for any other kind of banking-related operations, fund transfers from these Iranian banks had been accepted through Target2.

In 2019, we executed approximately € 4.2 million in (almost only in-coming) transfers through Target2 across approximately 900 transactions and credited the relevant amounts to our non-Iranian clients. The gross revenues derived from these payments were approximately € 4,500."

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"Germany’s Deutsche Bank passed a new financial policy on Wednesday which will prevent any money transfer to Iran in cash." (8/2/2018)

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"Iran says Germany’s Deutsche Bank has started to provide financial services related to the country’s oil trade – an announcement that could show the ice in doing business with the Islamic Republic in a post-sanctions era is already thawing. Iran’s Deputy Petroleum Minister for International Affairs Amir-Hossein Zamaninia was quoted by domestic media as saying that the new phase of cooperation between Deutsche Bank and Iran had started last week after a halt of about 10 years. Zamaninia added that Iran expects to see several other major European banks to follow suit and resume cooperation with the country over its oil-related financial transactions. “Previously, merely certain small European banks were ready to cooperate with Iran over its oil-related transactions,” the official told Mehr News Agency. Still, a larger number of European banks – particularly major ones – are today approaching Iran, he added. Zamaninia further emphasized that several important European banks are set to start providing services to Iran “within the next few days.” (Press TV, "Iran, Deutsche Bank resume oil partnership," 10/24/2016).

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On October 23, 2016, Iranian press, in quotes attributed to Iran’s Deputy Petroleum Minister for International Affairs Amir-Hossein Zamaninia, had reported a “new phase of cooperation between Deutsche Bank and Iran had started last week after a halt of 10 years.” (Press TV (Tehran), “Iran, Deutsche bank resume oil partnership,” 10/23/2016).

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"Deutsche Bank is bracing for more than 300 million euros (256 million pounds) in charges linked to suspected violations of U.S. sanctions on Iran, a German weekly reported on Sunday. Deutsche Bank, Europe's biggest bank by assets, on Wednesday increased its provisions for litigation by 600 million euros to 2.4 billion euros, citing mortgage-related lawsuits and other regulatory investigations... Deutsche Bank on Wednesday declined to lay out in detail why it had increased provisions. On Sunday, it would not comment on the magazine report... Der Spiegel said that apart from the Iran probe, Deutsche Bank's 2.4-billion-euro legal provisioning included 500 million for a probe of suspected manipulation of interbank lending rates. Several sources familiar with the investigation told Reuters on Thursday that German markets watchdog Bafin is set to rebuke Deutsche Bank over how it supervised its contribution to the setting of the lending rates." (Reuters, "Deutsche Bank braced for £256 million Iran sanctions charges - report," 3/24/2013)

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"Federal and state prosecutors are investigating Deutsche Bank and several other global banks over accusations that they funneled billions of dollars through their American branches for Iran, Sudan and other sanctioned nations, according to law enforcement officials with knowledge of the cases . . . The Deutsche Bank investigation is the latest in a series of cases against global financial firms since 2009 that suggests the practice of transferring money on behalf of Iranian banks and corporations flourished under a loophole in United States policy that ended in 2008. A spokesman for Deutsche Bank declined to comment, but noted that the German bank decided in 2007 that it would “not engage in new business with counterparties in countries such as Iran, Syria, Sudan and North Korea and to exit existing business to the extent legally possible . . . The investigation into Deutsche Bank is still in its very early stages, according to the law enforcement officials. So far, there is no suspicion that the bank moved money on behalf of Iranian clients through its American operations after 2008, the officials said.” (New York Times, "Deutsche Bank’s Business With Sanctioned Nations Under Scrutiny," 8/17/12)

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"President Barack Obama signed into law new sanctions on Iran that, for the first time, will bar from the American market foreign companies that work with Iranian businesses charged with aiding Tehran's nuclear program and the suppression of democracy.

Among those that could face legal challenges and fines are Japan's Big Three banks—Mitsubishi UFJ Financial Group Inc., Sumitomo Mitsui Financial Group and Mizuho Financial Group Inc.—as well as European firms such as Commerzbank Bank AG and Deutsche Bank AG, all of whom have businesses inside Iran.

A Deutsche Bank spokesman said most of its existing contracts in Iran have durations of more than 10 years and the bank is legally obligated to fulfill them.

A recent report by Avi Jorisch, a former Treasury Department intelligence official, details how the Big Three Japanese banks, Deutsche Bank and Commerzbank continue to maintain bank accounts for Bank Sepah, Iran's oldest financial institution.

Bank Sepah has been blacklisted by both the U.N. and the U.S. in recent years for its alleged role in assisting Tehran's development of weapons of mass destruction.

Ronald Weichert, the spokesman for Deutsche Bank, said the bank is or has been 'engaged in a limited amount of business with counterparties, including government-owned or controlled counterparties, in certain countries which the U.S. State Department has designated as state sponsors of terrorism, including Iran.'

He said the bank's 'existing business with Iranian counterparties consists mostly' of participation 'as lender and/or agent in a few large trade finance facilities arranged some years ago to finance the export contracts of exporters in Europe and Asia.'" (Wall Street Journal, "U.S. Adds Its Own Sanctions on Iran," 7/2/2010)

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"Deutsche Bank announced in July 2007 that it had cut all ties to Iran, saying that it had deemed its business there too time consuming and expensive. While the bank was operating in Iran, RREEF Alternative Investments, a global alternative investment management business of Deutsche Bank's Asset Management division, rented properties to the U.S. government." The Company has received $2.6 million from the US government for their investments in Iran during 2000-2009.  They have withdrawn their investments from 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)

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"Another step the Obama administration should take is to sustain American pressure on foreign banks and oil companies to halt their dealings with Iran's energy sector. This effort has led such major firms as Germanys Deutsche Bank and Commerzbank, Englands HSBC, Credit Suisse and Royal Dutch Shell to halt or limit their business with Iran. (The Baltimore Sun, "FACING THE IRANIAN THREAT," 12/9/08)

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"U.S. outreach to foreign banks and to oil companies considering investing in Iran's energy sector has reportedly convinced more than 80 banks and several major potential oil-field investors to cease all or some of their business with Iran. Among them: Germany's two largest banks (Deutsche Bank and Commerzbank), London-based HSBC, Credit Suisse, Norwegian energy company StatoilHydro, and Royal Dutch Shell. (The Wall Street Journal, "How To Put The Squeeze On Iran," 11/13/08)

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"European giants HSBC, Deutsche Bank and Credit Suisse have pulled out of Iran while BNP Paribas, Commerzbank and Dresdner Bank have severely curtailed their business with the Islamic republic." (Gulf Daily News, "US imposes sanctions on major Iran banks," 5/1/08)

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Listed by U.S. Government as doing business in Iran. (U.S. Securities and Exchange Commission, List of Companies Doing Business With State Sponsors Of Terror, Removed from the internet in July of 2007)