“Corporate responsibility entails more than just acting discreetly on behalf of one’s clients. It means, first and foremost, acting lawfully."

Janice K. Fedarcyk, FBI Assistant Director-in-Charge of the New York Division

OPERATION IRAQI FREEDOM – IRAQ WAR FUND

MM~LAW, together with 5 other law firms from our “Counterterrorism Law Network” filed 8 lawsuits on behalf of over 2,700 Gold Star Families, Veterans, and Veteran families, in federal courts in New York and in Washington D.C. The lawsuits filed in New York are against some of the largest, foreign, international banks in the world, who, as explained below and in the lawsuits filed, each conspired with Iran, the Central Bank of Iran (Bank Markazi) and two mega Iranian banks (Bank Saderat and Bank Melli), to secretly and illegally launder over $900 billion for Iran during Operation Iraqi Freedom (2003-2011). The plaintiffs allege that at least hundreds of millions of these laundered U.S. dollars, were used by Iran to fund thousands of attacks on U.S. forces in Iraq, resulting in the death and injuries of our clients.

MM~LAW, together with law firms within our Counterterrorism Law Network, also filed 6 lawsuits on behalf of the same and additional clients, against the Islamic Republic of Iran and its affiliates, agencies and instrumentalities.

International Bank Defendants Islamic Republic of Iran Defendants

Deutsche Bank A.G. Islamic Republic of Iran

Crédit Suisse S.A. Islamic Revolutionary Guard Corps.

BNP Paribas S.A. Iranian Ministry of Intelligence & Security

Crédit Agricole Corporate and Investment Bank S.A. Bank Markazi (Central Bank of Iran)

Commerzbank A.G. Bank Melli Iran

HSBC Holding Plc. National Iranian Oil Company

Royal Bank of Scotland Plc.

Standard Chartered Bank Plc.

Barclays Bank Plc.

Bank Saderat Plc.

New lawsuits against the international bank defendants cannot be brought because they are now barred by the statute of limitations. However, new lawsuits against Iran and other state sponsors of terrorism may not be barred by the statute of limitations.

MM~LAW will be filing new lawsuits against the Islamic Republic of Iran, and the other Iranian defendants on behalf of Gold Star Families, Veterans and their family members, and Contractors of the U.S. government (who were injured or killed in a terrorist attack during performance of their contract).

Click on this link to request a free, confidential evaluation of your potential claims.

LAWSUITS AGAINST IRAN, ITS CENTRAL BANK, BANK MELLI, AND IRANIAN AGENCIES AND INSTURMETALITIES

In historic, precedent setting rulings, the court found:

“Upon full and careful consideration of Plaintiffs’ Motion Regarding Defendants’ Material Support for the Subject Terrorist Organizations and the memorandum and evidence attached thereto…the relevant factual findings of other federal courts regarding the provision of material support by Iran and certain of its agencies and instrumentalities to the same subject terrorist groups, the Court hereby grants Plaintiffs’ Motion Regarding Defendants’ Material Support for the Subject Terrorist Organizations and finds Plaintiffs have presented evidence satisfactory to the Court pursuant to 28 U.S.C. § 1608(e) that:

The Islamic Republic of Iran, Islamic Revolutionary Guard Corps, and Iranian Ministry of Intelligence & Security provided material support, as that term is used in 28 U.S.C. § 1605A(a)(1), to the Shia terrorist groups the Badr Corps, Jaysh al-Mahdi, the Promised Day Brigade, Asa’ib ahl al Haq, Kata’ib Hizballah, and the Sheibani Network during the relevant time period of 2003-2011.

The provision of said material support by the Islamic Republic of Iran, Islamic Revolutionary Guard Corps, and Iranian Ministry of Intelligence & Security to the above-mentioned Shia terrorist groups was essential to the groups’ operating capacity, and terrorist attacks involving these groups in Iraq during the relevant time period of 2003-2011 were reasonably foreseeable and a natural consequence of that material support.

The Islamic Republic of Iran, Islamic Revolutionary Guard Corps, and Iranian Ministry of Intelligence & Security provided material support, as that term is used in 28 U.S.C. § 1605A(a)(1), to the Sunni terrorist groups Al Qaeda, Al Qaeda in Iraq, and Ansar al Islam during the relevant time period of 2003-2011. “ Opinion and Order re Material support for Subject Terrorist Organizations.

“The Court finds that Defendnats Bank Markazi and Bank Melli provided material support, as that term is used in 28 U.S.C. §1605A(a)(1), to Iran’s terrorist network during the relevant time period of 2003-2011. Further, the Court finds that said material support was a substantial facto in growing the capacity of Iran’s terrorist network, the terrorist attacks involving Iran’s network in Iraq during the relevant time period of 2003-2011 were reasonably foreseeable and a natural consequence of that material support.” Opinion and Order re Bank Markazi, Bank Melli, and NIOC.

In order to efficiently litigate these lawsuits, we presented at trial the evidence for 15 attacks, representing 101 clients holding the various types of claims, as “bell weather” cases. This permits the court to rule on this limited number of cases and apply the judgments in these cases to the claims of all other plaintiffs, saving the substantial time required to hold a trial for each case, and instead submitting each client’s claims before court-appointed “special masters” (usually retired judges or experts).

As of September 1, 2025, the court has awarded the following judgments, with other cases in process:

Compensatory Damages Punitive Damages Total Award

Fishbeck et al. v, Iran et al., (bell weather cases): $ 327,863,455 $ 637,875,455 $ 956,813,183

Fishbeck et al. v, Iran et al.,(waves 1 & 2 case): $ 852,358,963 $ - $ 852,358,963

Total judgments thus far: $ 1,180,222,418 $ 637,875,455 $ 1,809,172,146

The court declined to award punitive damages in the waves 1 and 2 cases, reasoning “that a further award of punitive damages-on top of the staggering damages awards already imposed against Iran over the last 27 years in this and other terrorism-exception cases-would be highly unlikely to deter the Iranian government and its proxies from engaging in similar conduct.” Additional cases are being submitted in waves of approximately 100 clients per wave.

We have detailed below the shocking evidence of widespread criminal money laundering of hundreds of billions of dollars for the Islamic Republic of Iran (“Iran”) and Iranian sanctioned entities – some of which have been designated by the U.S. government as “Specially Designed Terrorists” – “Specially Designated Global Terrorists” - “Foreign Terrorist Organizations” – “Specially Designated Nationals” and/or “State Sponsors of Terrorism.” The highest levels of senior and executive management, as well as tens or hundreds of employees, who, in accordance with specific instructions given in oral and written form, were knowingly and intentionally perpetrating a massive criminal money-laundering operation, which spanned over 15 years. The purpose of the U.S. sanctions, which was known to all of the co-conspirators, is and was to prevent Iran and those Designated and Sanctioned States/Entities/Individuals from obtaining U.S. dollars which would be used to foment, command, underwrite and finance international terrorism directed against the United States, its citizens, soldiers and allies.

Why would some of the largest financial institutions in the world, blatantly engage is such criminal activity? The answer is “corporate impunity.” Until our successful lawsuit against the Arab Bank, no one had ever held international banks responsible for the deaths and injuries that their illegal provision of financial services and money laundering to terrorists and criminals wrought. The connection between money and terrorism cannot be clearer – According to documents captured by British Special Forces operating in Iraq, Iran established and commanded terrorist organizations called by the US military “Special Groups” and funded these terrorists with between $750,000 to $3,000,000 per month; the fee depending upon how many United States, British and Coalition Forces soldiers and civilians were killed or injured. Access to US dollars and the U.S. financial system was a necessary and essential part of this terrorism and these banks provided access to such funds.

How do we know that the above-named foreign banks conspired with Iran to illegally launder over $900 billion while American and Coalition soldiers were fights to stabilize Iraq and give Iraqis a better future during Operation Iraqi Freedom? Each of the European Co-Conspirators entered into Deferral of Prosecution Agreements (or plead guilty to felony charges), admitting, in detail, to the conspiracy and the amounts of U.S. dollars laundered.

In 1984 and every year since, Iran has been designated by the U.S. as a “state sponsor of terrorism” and sanctions were imposed limiting Iran’s access to U.S. dollars and the U.S. financial system. The sanctions were designed to prevent Iran from funding terrorism and distribution of lethal weapons to terrorist worldwide acting as proxies of Iran. Iran developed various ways to circumvent U.S. sanctions in order to utilize hundreds of millions or billions of dollars for illicit purposes, including funding and perpetrating acts of international terrorism directed at the United States, their citizens, soldiers, civil servants and allies.

“In order to accomplish the above, it was necessary for Iran to enlist its state-owned and other Iranian banks and entities (“Iranian Co-Conspirators”) to conspire with large international European banks (European Co-Conspirators”), which agreed to alter, falsify, and process hundreds of billions of dollars illegally. These banks developed and refined criminal schemes for money laundering U.S. dollars for the Iranian Co-Conspirators for the express purpose of concealing Iran’s transactions from detection, scrutiny and monitoring by U.S. regulators, law enforcement and/or depository institutions as well as funneling hundreds of millions of dollars to known and designated terrorist, all the while knowing that these terrorists were targeting, killing and maiming U.S. civilians and soldiers as well as civilians of U.S. allies. Each of the European Co-Conspirators entered into an agreement with Iran and the Iranian Co-Conspirators and were aware of the other European Co-Conspirators having entered into similar agreements/criminal conspiracies. All of the Co-Conspirators actively participated in the conspiracy, with the shared common goal and purpose to provide Iran and the Iranian Co-Conspirators, including known and designated terrorists and Specially Designated Nationals, the ability to transfer billions of dollars undetected through the United States and funnel a portion of those funds to known and designated terrorists. Each of the European Co-Conspirators understood that its conduct was part of a larger scheme engineered by Iran an each knew the participation of the other conspirators was essential to the Conspiracy’s success. Each European Co-Conspirator also knew, or was deliberately indifferent to, the several clearly foreseeable purposes, criminal objectives and consequences of the conspiracy, namely funneling at least hundreds of millions of dollars to Iranian controlled and directed terrorists who were targeting, killing and maiming American civilians and soldiers.”

Through the conspiracy, Iran, via its terrorist proxies, killed, maimed, kidnapped and tortured thousands of U.S. civilians and soldiers. Iran and its sponsored terrorist would not have been able to perpetrate the terrorist acts in the scope they so perpetrated without the participation of the Iranian and European Co-Conspirators. The Conspiracy was a substantial cause in fact and a significant factor in the chain of events leading to the massive loss of live and injuries.

United State District Courts have interpreted the Anti-Terrorism Act to exclude claims of financing international terror via Iran, and limited claims only to cases where the banks direct provide funding to the terrorists, causing the lawsuits against the international banks to be dismissed and preventing the injured veterans and their families, and the Gold Star families, from even having their “day in court” to represent their case.

On September 28, 2016, the Senate voted 97-1 and the House of Representative voted 348-77, pass “JASTA,” Justice Against Sponsors of Terrorism Act. Congress was explicit in why this important law giving American nationals, and members of the U.S. armed forces, employees and contractors of the U.S. government, irrespective of citizenship, the right to hold accountable those who conspire with, or provide substantial assistance to, international terrorists targeting America and Americans.

The Act provides the following:

Sec 2. Findings and Purpose.

(a) FINDINGS.-

(6) Persons, entities, countries that knowingly or recklessly contribute material support or resources, directly or indirectly, to persons or organizations that pose a significant risk of committing acts of terrorism that threaten the security of nationals of the United States or the national security, foreign policy, or economy of the United States, necessarily direct their conduct at the United States, and should reasonably anticipate being brought to court in the United States to answer for such activities.

(7) The United States has a vital interest in providing persons and entities injured as a result of terrorist attacks committed within the United States with full access to the court system in order to pursue civil claims against persons, entities, or countries that have knowingly or recklessly provided material support or resources, directly or indirectly, to the persons or organizations responsible for their injuries.

(b) PURPOSE.—The purpose of this Act is to provide civil litigants with the broadest possible basis, consistent with the Constitution of the United States, to seek relief against persons, entities, and foreign countries, wherever acting and wherever they may be found, that have provided material support, directly or indirectly, to foreign organizations or persons that engage in terrorist activities against the United States.

Despite the clear intention and purpose of the overwhelming bi-partisan majorities in Congress, the courts have taken positions exactly opposite to Congress’ purpose and intention by ruling that the statutory language of the Act does not specifically use the word “indirectly” and therefore there is a loophole for international banks to intentionally and illegally “indirectly” fund terrorists through Iran, until Congress amends the statute. For example, in Freeman et al. v. HSBC Holding Plc. et al, a similar lawsuit brought on behalf of U.S. veterans and Gold Star families by other counsel, the court held:

“The Court recognizes Congress’s apparent intent to provide liability for actions that indirectly assist in the commission of acts of terrorism. The Second Circuit has also acknowledged this congressional intent and has suggested that the provision of indirect assistance may suffice to give rise to aiding-and-abetting liability under § 2333(d). Nevertheless, the plain text of JASTA’s conspiracy liability provision requires that a defendant conspire directly with the person or entity that committed the act of international terrorism that injured the plaintiff. See 18 U.S.C. § 2333(d)(2).”

“Unsatisfying as the Court's decision today may be from a moral or policy perspective, it is up to Congress, and not the judiciary, to authorize terrorism victims to recover damages for their injuries from financial institutions that conspire with state sponsors of terrorism like Iran to evade U.S. sanctions under circumstances such as those presented in this case. In its present form, however, the law does not provide for such recovery.”

MM~LAW and our co-counsel continue to fight to overturn the court’s horrible decisions authorizing the indirect funding of terrorism through Ira, and are working in Congress to pass legislation to set the courts on the right track.

To sign a petition supporting the Gold Star Families and Veterans in this fight, click on this link.

To request a free, confidential evaluation of your potential claims (against Iran and its agencies only) click on this link.

CRIMINAL INDICTMENTS AGAINST THE BANKS

HSBC Holding Group Plc

HSBC Holdings plc and HSBC Bank USA N.A. Admit to Anti-Money Laundering and Sanctions Violations, Forfeit $1.256 Billion in Deferred Prosecution Agreement

U.S. Department of Justice, December 11, 2012

Office of Public Affairs

WASHINGTON—HSBC Holdings plc (HSBC Group)—a United Kingdom corporation headquartered in London—and HSBC Bank USA N.A. (HSBC Bank USA) (together, HSBC)—a federally chartered banking corporation headquartered in McLean, Virginia—have agreed to forfeit $1.256 billion and enter into a deferred prosecution agreement with the Justice Department for HSBC’s violations of the Bank Secrecy Act (BSA), the International Emergency Economic Powers Act (IEEPA) and the Trading with the Enemy Act (TWEA)… The HSBC Group violated IEEPA and TWEA by illegally conducting transactions on behalf of customers in Cuba, Iran, Libya, Sudan, and Burma—all countries that were subject to sanctions enforced by the Office of Foreign Assets Control (OFAC) at the time of the transactions…

A four-count felony criminal information was filed today in federal court in the Eastern District of New York charging HSBC with willfully failing to maintain an effective anti-money laundering (AML) program, willfully failing to conduct due diligence on its foreign correspondent affiliates, violating IEEPA and violating TWEA. HSBC has waived federal indictment, agreed to the filing of the information and has accepted responsibility for the criminal conduct of its employees…

The Sanctions Investigation

According to court documents, from the mid-1990s through September 2006, HSBC Group allowed approximately $660 million in OFAC-prohibited transactions to be processed through U.S. financial institutions, including HSBC Bank USA. HSBC Group followed instructions from sanctioned entities such as Iran…to omit their names from U.S. dollar payment messages … The bank also removed information identifying the countries from U.S. dollar payment messages; deliberately used less-transparent payment messages, known as cover payments; and worked with at least one sanctioned entity to format payment messages, which prevented the bank’s filters from blocking prohibited payments. Specifically, beginning in the 1990s, HSBC Group affiliates worked with sanctioned entities to insert cautionary notes in payment messages including “care sanctioned country,” “do not mention our name in NY,” or “do not mention Iran.”…

“Banks are the first layer of defense against money launderers and other criminal enterprises who choose to utilize our nation’s financial institutions to further their criminal activity,” said Richard Weber, Chief, Internal Revenue Service-Criminal Investigation (IRS-CI). “When a bank disregards the Bank Secrecy Act’s reporting requirements, it compromises that layer of defense, making it more difficult to identify, detect and deter criminal activity. In this case, HSBC became a conduit to money laundering…

Manhattan District Attorney Cyrus R. Vance Jr., said, “New York is a center of international finance, and those who use our banks as a vehicle for international crime will not be tolerated…Sanctions enforcement is of vital importance to our national security and the integrity of our financial system. The fight against money laundering and terror financing requires global cooperation, and our joint investigations in this and other related cases highlight the importance of coordination in the enforcement of U.S. sanctions.

Credit Suisse AG

Credit Suisse Agrees to Forfeit $536 Million

in Connection with Violations of the International Emergency Economic Powers Act

U.S. Department of Justice
Office of Public Affairs

Credit Suisse AG, a Swiss corporation headquartered in Zurich, has agreed to forfeit $536 million to the United States and the New York County District Attorney’s Office in connection with violations of the International Emergency Economic Powers Act (IEEPA) and New York state law.…

According to court documents, beginning as early as 1995 and continuing through 2006, Credit Suisse, in Switzerland and the United Kingdom, altered wire transfers involving U.S. sanctioned countries or persons. Specifically, according to court documents, Credit Suisse deliberately removed material information, such as customer names, bank names, and addresses, from payment messages so that the wire transfers would pass undetected through filters at U.S. financial institutions. Credit Suisse also trained its Iranian clients to falsify wire transfers so that such messages would pass undetected through the U.S. financial system. This scheme allowed U.S. sanctioned countries and entities to move hundreds of millions of dollars through the U.S. financial system.

For its Iranian clients, Credit Suisse promised that no message would leave the bank without being hand-checked by a Credit Suisse employee to ensure that the message had been formatted to avoid U.S. filters. If an Iranian client provided payment messages that contained identifying information, Credit Suisse employees would remove the detectable information so that the message could pass undetected through OFAC filters at U.S. financial institutions. According to court documents, Credit Suisse’s international communications showed a continuous dialogue about the scheme, assessing how to process Iranian transactions better to ensure increased business from existing and future Iranian clients. For example, in 1998, Credit Suisse provided its Iranian customers with a pamphlet entitled, “How to transfer USD payments,” which provided detailed payment instructions on how to avoid triggering U.S. OFAC filters or sanctions…

“This case provides a timely lesson about how Iran seeks to involve others in deceptive conduct to evade legal and regulatory controls,” said Treasury Under Secretary for Terrorism and Financial Intelligence Stuart Levey. “Those who do business with Iran expose themselves to the risk, and the consequences, of participating in transactions supporting proliferation, terrorism or sanctions evasion.”

Commerzbank A.G.

Commerzbank AG Admits to Sanctions and Bank Secrecy Violations, Agrees to Forfeit $563 Million

and Pay $79 Million Fine Combined with Payments to Regulators, Commerzbank to Pay $1.45 Billion

U.S. Department of Justice
Office of Public Affairs

Commerzbank AG, a global financial institution headquartered in Frankfurt, Germany, and its U.S. branch, Commerzbank AG New York Branch (Commerz New York), have agreed to forfeit $563 million, pay a $79 million fine and enter into a deferred prosecution agreement with the Justice Department for violations of the International Emergency Economic Powers Act (IEEPA) and the Bank Secrecy Act (BSA).

In entering the deferred prosecution agreement, Commerzbank admitted and accepted responsibility for its criminal conduct in violation of IEEPA, and Commerz New York admitted its criminal conduct in violation of the BSA..

“Commerzbank concealed hundreds of millions of dollars in transactions prohibited by U.S. sanctions laws on behalf of Iranian and Sudanese businesses,” said Assistant Attorney General Caldwell…

“Sanctions laws are designed to protect the national security of the United States and promote our foreign policy interests,” said U.S. Attorney Machen. “Commerzbank undermined the integrity of our financial system and threatened our national security by hiding the business they were doing with entities in Iran and Sudan. The bank tried to skirt our laws by hiding its illegal business with Iranian banks from its own employees in the United States. Today’s resolution demonstrates that there will be consequences when global banks try to profit from the benefits of the U.S. financial system without respecting our laws.”

According to admissions contained in the deferred prosecution agreement, from 2002 to 2008, Commerzbank knowingly and willfully moved $263 million through the U.S. financial system on behalf of Iranian and Sudanese entities subject to U.S. economic sanctions. Commerzbank engaged in this criminal conduct using numerous schemes designed to conceal the true nature of the illicit transactions from U.S. regulators…

Specifically, in 2003, Commerzbank designated a group of employees in the Frankfurt back office to review and amend Iranian payments so that the payments would not be stopped by U.S. sanctions filters. In doing so, Commerzbank ensured that Iranian payment messages did not mention the Iranian entity, as transactions may have otherwise been stopped pursuant to the U.S. sanctions. ..

For example, in 2003, when two state-owned Iranian banks wanted to begin routing their U.S. dollar clearing business through Commerzbank, a Commerzbank back office employee emailed other Commerzbank employees directing: “If for whatever reason CB New York inquires why our turnover has increase[d] so dramatically, under no circumstances may anyone mention that there is a connection to the clearing of Iranian banks!!!!!!!!!!!!!.”

Commerzbank admitted that this conduct continued even though its senior management was warned that the bank’s practices for Iranian clients “raised concerns.”

Standard Charted Bank

Standard Chartered reaches $340 million settlement with Iran

Karen Freifeld and Carrick Mollenkamp
Reuters 1:40 a.m. CDT, August 15, 2012

NEW YORK (Reuters) – Standard Chartered Plc agreed to pay $340 million to New York’s bank regulator over transactions linked to Iran, in a speedily arranged deal that helped push up the emerging market-focused lender’s shares…

The deal with New York Superintendent of Financial Services Benjamin Lawsky on Tuesday caps a week of transatlantic tension and a furor over why a state agency had upstaged other authorities.

Standard Chartered’s Hong Kong shares rose as much as 6.8 percent to HK$177, still nearly 6 percent below where they were before the allegations hit the bank early last week.

The settlement agreed by the bank is equal to less than 9 percent of its first-half pre-tax profit. At the latest levels, Standard Chartered’s market value is around $3.5 billion less than it was before Lawsky’s allegations…

Lawsky on August 6 called Standard Chartered a “rogue institution” that had broken U.S. sanctions on Iran, saying it hid Iran-linked transactions with a total value of $250 billion from regulators.

In his announcement on Tuesday, Lawsky said Standard Chartered “agreed that the conduct at issue involved transactions of at least $250 billion.” But he gave no details on what protections the deal gave Standard Chartered.

Barclays Bank Plc

Barclays Bank PLC Agrees to Forfeit $298 Million

in Connection with Violations of the International Emergency Economic Powers Act and Trading with the Enemy Act

U.S. Department of Justice
December 11, 2012

Office of Public Affairs

WASHINGTON—Barclays Bank PLC, a United Kingdom corporation headquartered in London, has agreed to forfeit $298 million to the United States and to the New York County District Attorney’s Office in connection with violations of the International Emergency Economic Powers Act (IEEPA) and the Trading with the Enemy Act (TWEA), announced Assistant Attorney General Lanny A. Breuer of the Criminal Division and District Attorney Cyrus R. Vance Jr., of the New York County District Attorney’s Office. The violations relate to transactions Barclays illegally conducted on behalf of customers from Cuba, Iran, Sudan, and other countries sanctioned in programs administered by the Office of Foreign Assets Control (OFAC).…

A criminal information was filed Aug. 16, 2010, in the U.S. District Court for the District of Columbia charging Barclays with one count of violating the IEEPA and one count of violating the TWEA. Barclays waived indictment, agreed to the filing of the information, and has accepted and acknowledged responsibility for its criminal conduct. …

“Banks like Barclays will not be permitted to disregard sanctions put in place by the U.S. government,” said Assistant Attorney General Lanny A. Breuer of the Criminal Division. “Not just once, but numerous times over more than a decade, Barclays stripped vital information out of payment messages that would have alerted U.S. financial institutions about the true origins of the funds.”…

“Criminal activity of the type we found at Barclays does more than deceive our financial institutions, it threatens the security of our country,” said District Attorney Cyrus R. Vance Jr.…

According to court documents, from as early as the mid-1990s until September 2006, Barclays knowingly and willfully moved or permitted to be moved hundreds of millions of dollars through the U.S. financial system on behalf of banks from Cuba, Iran, Libya, Sudan and Burma, and persons listed as parties or jurisdictions sanctioned by OFAC in violations of U.S. sanctions.

According to court documents, Barclays followed instructions, principally from banks in Cuba, Iran, Libya, Sudan, and Burma, not to mention their names in U.S. dollar payment messages sent to Barclays’ branch in New York and other financial institutions located in the United States. Barclays routed U.S. dollar payments through an internal Barclays account to hide the payments’ connection to OFAC-sanctioned entities and amended and reformatted the U.S dollar payment messages to remove information identifying the sanctioned entities. Barclays also deliberately used a less clear method of payment messages, known as cover payments, as another way of hiding the sanctioned entities identifying information.

BNP Paribas S.A.

BNP Paribas Agrees to Plead Guilty and to Pay $8.9 Billion

for Illegally Processing Financial Transactions for Countries Subject to U.S. Economic Sanctions

U.S. Department of Justice
Office of Public Affairs

WASHINGTON—According to court documents submitted today, BNP Paribas S.A. (BNPP), a global financial institution headquartered in Paris, agreed to enter a guilty plea to conspiring to violate the International Emergency Economic Powers Act (IEEPA) and the Trading with the Enemy Act (TWEA) by processing billions of dollars of transactions through the U.S. financial system on behalf of Sudanese, Iranian, and Cuban entities subject to U.S. economic sanctions. …

“By providing dollar clearing services to individuals and entities associated with Sudan, Iran, and Cuba—in clear violation of U.S. law—BNPP helped them gain illegal access to the U.S. financial system,” said Acting Assistant Attorney General Caldwell. “In doing so, BNPP deliberately disregarded U.S. law of which it was well aware and placed its financial network at the services of rogue nations, all to improve its bottom line. Remarkably, BNPP continued to engage in this criminal conduct even after being told by its own lawyers that what it was doing was illegal.”

“BNPP banked on never being held to account for its criminal support of countries and entities engaged in acts of terrorism and other atrocities,” said U.S. Attorney Bharara. “But that is exactly what we do today. BNPP, the world’s fourth largest bank, has agreed to plead guilty and pay penalties of almost $9 billion for performing the hat trick of sanctions violations, unlawfully opening the doors of the U.S. financial markets to three sanctioned countries, Sudan, Iran, and Cuba. For years, BNPP provided access to billions of dollars to these sanctioned countries, as well as to individuals and groups specifically identified and designated by the U.S. government as being subject to sanctions. The bank did so deliberately and secretly, in ways designed to evade detection by the U.S. authorities.

BNPP processed approximately $6.4 billion through the United States on behalf of Sudanese sanctioned entities from July 2006 through June 2007, including approximately $4 billion on behalf of a financial institution owned by the government of Sudan, even as internal e-mails showed BNPP employees expressing concern about the bank’s assisting the Sudanese government in light of its role in supporting international terrorism and committing human rights abuses during the same time period. Indeed, in March 2007, a senior compliance officer at BNPP wrote to other high-level BNPP compliance and legal employees reminding them that certain Sudanese banks with which BNPP dealt “play a pivotal part in the support of the Sudanese government which . . . has hosted Osama Bin Laden and refuses the United Nations intervention in Darfur.”…

Further according to court documents, BNPP engaged in more than $650 million of transactions involving entities tied to Iran, and this conduct continued into 2012—nearly two years after the bank had commenced an internal investigation into its sanctions compliance and had pledged to cooperate with the Government. https://www.fbi.gov/contact-us/field-offices/newyork/news/press-releases/bnp-paribas-agrees-to-plead-guilty-and-to-pay-8.9-billion-for-illegally-processing-financial-transactions-for-countries-subject-to-u.s.-economic-sanctions

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DOWNLOAD KEY LAWSUIT DOCUMENTS

To view or download key documents, clink on the embedded links below:

Fishbeck et al. v, The Islamic Republic of Iran et al.

Fishbeck 2nd Amended Complaint

Trial Transcript-Day 1

Trial Transcript-Day 2

Trial Transcript-Day 3

Proposed Findings of Fact and Law

Proposed Additional Finding of Fact and Law