Civil Enforcement Information - HSBC Holdings plc

Date issued: Dec. 11 2012

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TURBOFAC Commentary (343 words)

Notes.

*For further factual information see: Settlement Agreement (OFAC) - HSBC Holdings plc and Deferred Prosecution Agreement - HSBC Holdings plc.

1) With respect to Paragraph 22 of the Settlement Agreement:

"Separately and unrelated to the above matters, on May 24, 2006, the London branch of HBUS acted as a clearing bank in a book entry transfer of 32,000 ounces of gold bullion, valued at $20,560,000, for the ultimate benefit of Bank Markazi, Iran, in apparent violation of the prohibition against the "exportation ... , directly or indirectly, from the United States, ... of any ... services to Iran or the Government of Iran," 31 C.F.R. § 560.204."

Note that, here and in general, when a transaction is effected for the benefit of some beneficiary not otherwise party to the transaction effected on...