Sumitomo Mitsui Financial Group

According to its Annual Report filed with the SEC for fiscal year 2019: "During the twelve months ended March 31, 2019, one affiliate of SMFG, SMBC, engaged in activities subject to disclosure under Section 13(r). SMBC conducted these activities consistent with its internal policies and procedures, the policies and procedures of SMFG, and applicable laws and regulations, and to the extent they are not sanctionable under U.S. secondary sanctions. SMBC has discontinued activities that have become impermissible or subject to secondary sanctions as a result of changes in applicable laws and regulations.

SMBC issued letters of credit and provided remittance and other settlement services in connection with customers’ trade transactions between Japan and Iran. These transactions principally involved the importation of oil into Japan or exportation of civilian commercial products from Japan and were conducted with Iranian banks, including the Central Bank of Iran and one other bank owned by the Government of Iran. SMBC supported a Japanese importing company by paying bills of exchange in connection with imports of crude oil from an Iranian oil company owned by the Government of Iran. These transactions did not involve entities or other persons on the SDN List and did not involve the settlement of U.S. dollar-denominated payments cleared through U.S. banks. SMBC has informed SMFG that it intends to continue to engage in these types of transactions only to the extent permitted under applicable regulations and to the extent they are not sanctionable under U.S. secondary sanctions. For the twelve months ended March 31, 2019, the gross revenue related to these transactions was ¥20.4 million, representing about 0.0006% of SMFG’s total interest and fee income. SMFG does not allocate direct costs to interest and fee income and therefore does not calculate net profits with respect to these transactions.

SMBC has issued performance bonds and advance payment bonds that supported various projects, including the construction of petroleum plants in Iran. Some of these bonds had counterparties that were entities controlled by the Government of Iran. Some of these bonds have matured, and SMBC has not renewed and will not renew them unless permitted under applicable regulations and to the extent they are not sanctionable under U.S. secondary sanctions, but SMBC continues to have obligations under the matured performance bonds until they are returned or cancelled by the beneficiaries. SMBC has also received fees from its customers on whose behalf it issued the performance bonds. For the twelve months ended March 31, 2019, the gross revenue relating to these transactions was ¥2.1 million, representing less than 0.0001% of SMFG’s total interest and fee income. As noted above, SMFG does not allocate direct costs to interest and fee income and therefore does not calculate net profits with respect to these transactions. SMBC has informed SMFG that it intends to continue to accept fee income from its customers for whose account the performance bonds were issued and to pay the relevant fees to the Iranian banks, to the extent authorized by the Ministry of Finance of Japan or otherwise permitted under applicable regulations, until the bonds are returned or cancelled. However, SMBC strongly urges the relevant customers to ask the beneficiaries to agree to return or cancel the matured performance bonds.

SMBC has frozen an account of an Iranian bank designated under Executive Order 13224 pursuant to Japanese foreign exchange laws, and has frozen the U.S. dollar accounts of all Iranian banks. SMBC still maintains Japanese yen accounts of government-owned Iranian banks, including an account for the Central Bank of Iran, and certain transactions described in this disclosure were conducted through the use of such accounts. These transactions were conducted in accordance with Japanese law, and we do not believe that the transactions were sanctionable under U.S. sanctions that were in effect at the time the transactions occurred. SMBC has discontinued activities that have become impermissible or subject to secondary sanctions as a result of changes in applicable laws and regulations, including transactions involving the Central Bank of Iran whose account has been frozen. The gross revenue attributable to the accounts of government-owned Iranian banks for the twelve months ended March 31, 2019, was less than ¥5.0 million, representing about 0.0001% of SMFG’s total interest and fee income. SMFG does not allocate direct costs to interest and fee income and therefore does not calculate net profits with respect to these transactions. SMBC has informed SMFG that it intends to continue to maintain the Iranian accounts described above only to the extent permitted under applicable laws and regulations and to the extent the activities are not targeted by secondary sanctions."

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"will carefully consider its response in compliance with the law and based on U.S. sanctions…" (July 12, 2018)

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"Economic relations between Iran and Japan will enter a new phase after a planned $10 billion credit line is opened, said a senior assistant to the dean of Asian Development Bank Institute in Japan.”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 13, 2017)

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"Bank of Tokyo-Mitsubishi UFJ handles the bulk of Japan's oil-related payment to the Islamic nation, with the rest handled by Sumitomo Mitsui Banking Corp, sources said." (The New York Times, "Japan's JX: No Problem With Paying Iran for Oil Now," 5/17/2012)
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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)
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"Sumitomo Mitsui Financial Group Inc., Japan’s second-largest publicly traded bank, has identified transactions that may have violated U.S. economic sanctions, the bank said in a securities filing. The bank said it voluntarily disclosed 'a limited number' of transactions with Cuba, Iran, Sudan and other countries to the Treasury Department’s Office of Foreign Assets Control, which enforces U.S. sanctions....The bank has a representative office in Iran and provides financing to entities there." (Wall Street Journal, "Sumitomo Mitsui Financial Group Discloses Potential Violations of US Sanctions," 10/22/10)
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"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).