Item 9B. Other Information.
Iran threat reduction disclosure
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, an issuer 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 designated pursuant to certain Executive Orders. Disclosure may be required even where the activities, transactions or dealings were conducted in compliance with applicable law. Except as set forth below, as of the date of this report, the Firm is not aware of any other activity, transaction or dealing by any of its affiliates during the calendar year 2017 that requires disclosure under Section 219.
As previously disclosed, during the first quarter of 2017, a non-U.S. subsidiary of JPMorgan Chase processed a payment in the amount of EUR 1,466 for its client, a non-U.S. international organization, where the payment originated from entities owned or controlled by the Government of Iran. JPMorgan Chase charged a fee of EUR 2.50 for this transaction. In addition to the previously disclosed transaction, the Firm identified four other payments made in 2017 in the amounts of $68,567, $66,280, $98,143, and $110,831, that were processed by JPMorgan Chase Bank N.A. and a non-U.S. subsidiary of JPMorgan Chase for a client, a U.S.-based international publishing business, where the payments originated from educational institutions owned or controlled by the Government of Iran. JPMorgan Chase charged total fees of $3,930 for these transactions.
Each of the above payments received into both clients’ accounts, were for the purchase of informational materials, and they were therefore exempt transactions pursuant to 31. C.F.R. 560.210(c), and were all processed in compliance with the Iran-related sanctions regulations.
JPMorgan Chase may in the future engage in similar transactions for its clients to the extent permitted by U.S. law
https://www.sec.gov/Archives/edgar/data/19617/000001961718000057/corp10k2017.htm
1) A non-U.S. subsidiary of JP Morgan, subject to the ITSR via 560.215 or otherwise as a branch of a U.S. person, processed a payment for informational materials for an otherwise blocked (560.211) GOI entity. JP Morgan interprets the informational materials exemption to apply to the facilitation of informational materials-related transactions even where, as here, it appears as though no U.S. person is involved with the transaction and the transaction was not in dollars. (refer to IA-2012-299245-1).
Compare Citigroup Inc., Q4 2016 10-Q Filing (2018 10K Filing), similar but with respect to the travel exemption.
*See General Note on Correspondence of Publicly traded Companies with the SEC Concerning Sanctions (System Ed. Note)