[Excerpted from full filing]
DISCLOSURE PURSUANT TO SECTION 219 OF THE IRAN THREAT REDUCTION AND SYRIA HUMAN RIGHTS ACT
Pursuant to Section 219 of the Iran Threat Reduction and Syria Human Rights Act of 2012, which added Section 13(r) to the Securities Exchange Act of 1934, as amended, Citi is required to disclose in its annual or quarterly reports, as applicable, whether it or any of its affiliates knowingly engaged in certain activities, transactions or dealings relating to Iran or with individuals or entities that are subject to sanctions under U.S. law. Disclosure is generally required even where the activities, transactions or dealings were conducted in compliance with applicable law. Citi did not have any reportable activities to disclose in the first quarter of 2016 but disclosed reportable activities pursuant to Section 219 in the second quarter of 2016 in the Second Quarter of...
1) Citigroup interpreted Berman Amendment exemption for transactions ordinarily incident to travel to cover, i) payment processing for visa fees, and ii) hotel cancellation refunds, even where the involvement of the person subject to U.S. jurisdiction was limited strictly to a facultative/processing role. Accord 515.560(c), where OFAC characterizes the acquisition of visas as generally licensed (in a program with no travel exemption) as "ordinarily incident" to permitted travel.
2) Citigroup disclosed a similar transaction in its 2018 10-K filing.
DISCLOSURE PURSUANT TO SECTION 219 OF THE IRAN THREAT REDUCTION AND SYRIA HUMAN RIGHTS ACT
Pursuant to Section 219 of the Iran Threat Reduction and Syria Human Rights Act of 2012 (Section 219), which added Section 13(r) to the Securities Exchange Act of 1934, as amended, Citi is required to disclose in its annual...