Case 1:24-cv-04484-RA-RWL Document 33 Filed 10/29/24 Page 1 of 429

IN THE UNITED STATES DISTRICT COURT

FOR THE SOUTHERN DISTRICT OF NEW YORK

ABRAHAM FRAENKEL, individually, and for the estate

of YAAKOV FRAENKEL, RACHELLE FRAENKEL,
AVIGAIL FRAENKEL, AYALA FRAENKEL, N.F. by
and through her next friend Abraham Fraenkel, NOGA
FRAENKEL, S.F. by and through his next friend Abraham
Fraenkel, TZVI FRAENKEL, KATHLEEN ALT,
individually, and for the estate of KRISTINE LUKEN,
LAWRENCE LUKEN, GERALD LUKEN, MARGARET
LUKEN, SAMUEL BRAUN, individually, and as co- Case No. 24-cv-4484
representative for the estate of CHAYA BRAUN, CHANA
BRAUN, individually, and as co-representative for the
estate of CHAYA BRAUN, ESTHER BRAUN, MURRAY
BRAUN, SARA HALPERIN, SHIMSHON HALPERIN, JURY TRIAL DEMANDED
MICAH LAKIN, individually, and for the estate of
RICHARD LAKIN, MANYA LAKIN, RONEN
BOROCHOV, DEVORA BOROCHOV, JOSEF
BOROCHOV, ELI BOROCHOV, AVRAHAM
BOROCHOV, SHIRA BOROCHOV, SHARI
BOROCHOV, YOAV GOLAN, ROTEM GOLAN,
YEHUDIT GREEN-GOLAN, RAPHAEL GOLAN,
MATAN GOLAN, MENACHEM RIVKIN, BRACHA
RIVKIN, M.R. by and through her next friend Menachem
Rivkin, R.R. by and through her next friend Menachem
Rivkin, S.R. by and through his next friend Menachem
Rivkin, S.Z.R. by and through his next friend Menachem
Rivkin, STERNA RIVKIN, STUART FORCE JR.,
individually, and for the estate of TAYLOR FORCE,
ROBBI FORCE, KRISTEN BOSWELL, RAPHAEL
LISKER, SHOSHANA LISKER, TAMAR GUTMAN,
AVITAL LEJZOR, DANIEL LISKER, JONATHAN
LISKER, STEPHANIE ZOBAY, individually, and for the
estate of STEPHEN EVERHART, HANNAH
EVERHART, LINDSAY EVERHART, and HAYDEN
EVERHART,

Plaintiffs,

v.

STANDARD CHARTERED BANK,

Defendant.
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SHMUEL BRAUNER, NECHAMA BRAUNER, C.B. by

and through his next friend Shmuel Brauner, ESTHER
BRAUNER, MORDECHAI BRAUNER, YEHUDAH
GLICK, individually, and for the estate of YAFFA
GLICK, HALLEL GLICK, NERIA GLICK, SHAHAR Case No. 24-cv-5788
GLICK, SHLOMO GLICK, RACHEL GLICK, TATIANA
GLICK, AVITAL BREUER, NOAM SHAMBA, YANA
SHAMBA, HADAR SHAMBA, M.S. by and through his
next friend Noam Shamba, N.E.S. by and through his next JURY TRIAL DEMANDED
friend Noam Shamba, N.S. by and through her next friend
Noam Shamba, O.S. by and through her next friend Noam
Shamba, T.S. by and through her next friend Noam
Shamba, HADASSAH PRZEWOZMAN, individually, and
for the estate of PINCHAS PRZEWOZMAN, Y.P. by and
through his next friend Hadassah Przewozman, CHAIM
PRZEWOZMAN, CHAYA PRZEWOZMAN,
AVRAOHOM PRZEWOZMAN, F.P. by and through her
next friend Chaim Przewozman, ZVI PRZEWOZMAN,
SARA ROZENBAUM, and YAFA SHECHTER,

Plaintiffs,

v.

STANDARD CHARTERED BANK,

Defendant.

AMENDED COMPLAINT FOR VIOLATIONS OF THE ANTI-TERRORISM ACT

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TABLE OF CONTENTS

INTRODUCTION .......................................................................................................................... 7

THE PARTIES.............................................................................................................................. 13

A. Plaintiffs ................................................................................................................ 13

B. Standard Chartered Bank ...................................................................................... 13

JURISDICTION AND VENUE ................................................................................................... 14

SOURCING .................................................................................................................................. 15

NOMENCLATURE ..................................................................................................................... 16

FACTUAL ALLEGATIONS ....................................................................................................... 23

I. Since 1979, Several Elements Within The Iranian Government Served As The
Regime’s Primary Terrorist Sponsors To Facilitate Terrorist Attacks On Americans
By Iran’s Proxies In The Middle East............................................................................... 23

A. Historical Background .......................................................................................... 24

B. Ayatollah Khamenei and the Supreme Leader’s Office (SLO) ............................ 41

C. The Foundation for the Oppressed (Bonyad Mostazafan) .................................... 62

D. The Islamic Revolutionary Guard Corps (IRGC) ................................................. 77

E. Hezbollah .............................................................................................................. 87

II. The Iranian Regime’s Terrorist Sponsors Led A Global Terrorist Alliance Called The
“Axis Of Resistance,” Each Member Of Which Committed Terrorist Attacks
Targeting The United States ............................................................................................. 90

A. Hamas ................................................................................................................... 93

B. Palestinian Islamic Jihad ....................................................................................... 96

C. Jaysh Al-Mahdi ..................................................................................................... 99

D. North Korean Reconnaissance General Bureau (RGB) ...................................... 100

III. Iran’s Terrorist Sponsors and Proxies Used Multiple Coordination Mechanisms To
Orchestrate Their Attacks Targeting The United States ................................................. 113

A. Joint Cells............................................................................................................ 113

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1. The Khamenei Cell: A Joint IRGC-Hezbollah Leadership Cell in

Iran, Iraq, and Lebanon ........................................................................... 117

2. The Joint Axis of Resistance Logistics Cells (IRGC-LH-Hamas-

PIJ-JAM-RGB) in Iran, Lebanon, Syria, the Palestinian Territories,
and North Korea ...................................................................................... 119

3. Joint Hezbollah-Hamas Operations Cells in Iran, Lebanon, Syria,

and the Palestinian Territories ................................................................ 122

4. Joint Hezbollah-PIJ Operations Cells in Iran, Lebanon, Syria, and

the Palestinian Territories ....................................................................... 124

B. Terrorist Fronts ................................................................................................... 125

1. Khatam al-Anbiya Construction Headquarters (aka GHORB) ............... 125

2. National Iranian Oil Company (NIOC) .................................................. 131

3. National Iranian Tanker Company (NITC)............................................. 140

4. Caspian Petrochemical ............................................................................ 144

5. Euro African Group Ltd. (EAGL) and the Bazzi Network ..................... 145

6. Tajco, Ltd. and the Tajideens .................................................................. 147

IV. Since 1982, Iran’s Terrorist Sponsors Have Partnered With Their Lebanese,
Palestinian, And Iraqi Proxies To Target The United States .......................................... 148

V. Iran’s Terrorist Sponsors Seized Sector-Wide Monopolies In Key Iranian Markets

To Fund Terrorist Attacks ............................................................................................... 167

A. The Energy Sector: Oil, Gas, and Petroleum-Based Products ............................ 172

B. The Construction Sector ..................................................................................... 181

C. The Sanctions Evasion Sector: Black Market, Smuggling, and Shipping .......... 182

D. The Financial Sector: Banks, Currency Exchanges, and Hawalas ..................... 183

E. The Import/Export Sector ................................................................................... 187

F. The Communications Sector: Telecoms, Internet, and Related Technology...... 188

VI. For More Than A Decade, SCB Engaged In An Illegal Scheme To Help Iran’s
Terrorist Sponsors And Their Fronts Access The U.S. Financial System ...................... 190

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VII. SCB’s Scheme Involved Willful, Systemic, Company-Wide Efforts To Provide

Banking Services To Iran’s Terrorist Sponsors And Their Associated Fronts While
Helping Them Evade Counterterrorism Controls ........................................................... 195

A. The U.S. Government’s Counterterrorism Controls ........................................... 196

1. OFAC’s Iran Sanctions ........................................................................... 196

2. Transaction Review and Reporting ......................................................... 205

3. The Terrorist Finance Tracking Program ............................................... 212

B. Between 2001 and 2007, SCB Made a Series of Business Decisions to

Serve Customers with Close Connections to Iran’s Terrorist Sponsors by
Helping Them Subvert Counterterrorism Controls............................................. 214

C. SCB Lied to Regulators about Winding-Down Its Iran Business and

Continued to Process Transactions Through 2015 for Iran’s Terrorist
Sponsors and Their Fronts While Helping Them Evade Counterterrorism
Controls ............................................................................................................... 227

1. SCB’s Dubai Branch ............................................................................... 230

2. SCB Dubai Helped an Iranian Petrochemical Company Operating

as a Front for Iran’s Terrorist Sponsors to Covertly Access the U.S.
Financial System ..................................................................................... 233

3. SCB Dubai Helped IRGC Agent Mahmoud Reza Elyassi Access

the U.S. Financial System to Fund Iran’s Terrorist Sponsors................. 240

4. SCB Dubai Helped Numerous Other Agents and Fronts for Iran’s
Terrorist Sponsors Access the U.S. Financial System to Finance
Their Operations in Several Other Ways ................................................ 245

D. SCB Employed Other Methods to Disguise Its Misconduct and Thwart

Counterterrorism Controls .................................................................................. 252

1. SCB Used a “Sundry Account” to Hide Transactions with Agents

and Fronts for Iran’s Terrorist Sponsors ................................................. 252

2. SCB Maintained a Deliberately Ineffective Anti-Money

Laundering/Combating the Financing of Terrorism Program ................ 254

E. SCB Facilitated Hezbollah Financing in Gambia ............................................... 257

1. SCB Gambia Helped Hezbollah’s Bazzi Network Access the U.S.

Financial System to Finance Terrorist Attacks ....................................... 259

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2. SCB Dubai Helped Hezbollah Front Tajco Ltd. Access the U.S.
Financial System to Finance Terrorist Attacks ....................................... 268

F. SCB Repeatedly Misled and Obstructed U.S. Regulators .................................. 272

1. SCB Willfully Misled NYDFS About Its Anti-Money

Laundering/Combating the Financing of Terrorism Program ................ 272

2. SCB Willfully Misled NYDFS About Its Sanctions Compliance

Efforts ..................................................................................................... 274

3. SCB Promoted a Culture of Illegality by Retaliating Against

Whistleblowers ....................................................................................... 276

G. Plaintiffs’ Allegations Are Corroborated by SCB’s Pattern of Engaging in

a Variety of Other Illicit Behavior ...................................................................... 277

VIII. SCB Knew That Iran-Sponsored Terrorist Attacks Committed By Hezbollah, Hamas,
PIJ, and JAM Were A Foreseeable Result Of Its Culpable Acts .................................... 280

A. SCB Defied Numerous Warnings That Transacting with Fronts for Iran’s
Terrorist Sponsors Facilitated Terrorist Attacks by Hezbollah, Hamas, PIJ,
and JAM .............................................................................................................. 280

B. SCB Knew That Its Assistance to the Iranian Petrochemical Company

Facilitated Terrorist Attacks by Hezbollah, Hamas, PIJ, and JAM .................... 296

1. SCB Knew That a Petrochemical Company Owned by the Iranian

Government Would Fund Terrorism ...................................................... 297

2. Other Evidence Further Shows SCB’s Awareness That the

Petrochemical Company Funded Terrorism ........................................... 316

C. SCB Knew That Its Assistance to Elyassi Facilitated Terrorist Attacks by

Hezbollah, Hamas, PIJ, and JAM ....................................................................... 331

D. SCB’s Other Schemes ......................................................................................... 334

IX. SCB Substantially Assisted The Terrorist Attacks By Hezbollah, Hamas, PIJ, and
JAM That Caused Plaintiffs’ Injuries ............................................................................. 337

A. SCB’s Conduct Flowed Hundreds of Millions of Dollars from the U.S.

Financial System to the Qods Force, Hezbollah, Hamas, PIJ, and JAM ............ 341

1. Foundation for the Oppressed ................................................................. 341

2. The Iranian Petrochemical Company...................................................... 351

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3. Khatam al-Anbiya ................................................................................... 360

4. Elyassi ..................................................................................................... 362

5. Other Fronts ............................................................................................ 365

B. SCB’s Conduct Made a Vital Contribution to IRGC-Sponsored Attacks by

Hezbollah, JAM (Including Kataib Hezbollah), Hamas, and PIJ In Iraq
and Israel ............................................................................................................. 367

1. SCB’s Conduct Enabled Key Lanes of Iranian Regime Financial

Support for Hezbollah’s, Hamas’s, PIJ’s, and JAM’s Attacks ............... 367

2. SCB’s Conduct Financed Thousands of Iranian-Sponsored Attacks

Committed by Hezbollah, Hamas, PIJ, and JAM ................................... 376

C. SCB’s Conduct Contributed to the Individual Attacks That Targeted

Plaintiffs and Their Family Members ................................................................. 379

D. SCB’s Conduct Supplied Long-Lasting Assistance That Continued Aiding

Iranian Regime-Sponsored Terrorist Attacks Committed by Hezbollah,
Hamas, PIJ, and JAM Until at Least 2019 .......................................................... 382

E. The Iranian Regime Used Most of the Profits Generated by SCB’s

Schemes to Directly and Indirectly Sponsor Attacks Committed, Planned,
or Authorized by the IRGC, Hezbollah, Hamas, PIJ, JAM, and Their Axis
of Resistance Allies............................................................................................. 383

F. U.S. Government Findings from 2017 through 2024 Confirm That SCB’s
Illicit Services Funded Iranian Regime-Sponsored Terrorist Attacks by
Hezbollah, Hamas, PIJ, and JAM ....................................................................... 388

X. Plaintiffs’ Claims Are Timely ......................................................................................... 401

XI. Plaintiffs And Their Family Members Were Killed Or Injured In Terrorist Acts
Committed, Planned, Or Authorized By Iran-Sponsored Foreign Terrorist
Organizations .................................................................................................................. 403

A. The December 18, 2010 Kidnapping Attack in Israel (Luken Family) .............. 403

B. The August 19, 2011 Rocket Attack in Israel (Brauner Family) ........................ 404

C. The June 12, 2014 Kidnapping Attack in Israel (Fraenkel Family) ................... 405

D. The October 22, 2014 Vehicle Attack in Israel (Braun Family)......................... 407

E. The October 29, 2014 Assassination Attack in Israel (Glick Family) ................ 409

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F. The October 13, 2015 Shooting and Stabbing Attack in Israel (Lakin
Family) ................................................................................................................ 411

G. The November 6, 2015 Sniper Attack in Israel (Borochov Family)................... 412

H. The December 14, 2015 Vehicle Attack in Israel (Golan and Shamba
Families) ............................................................................................................. 414

I. The January 27, 2016 Stabbing Attack in Israel (Rivkin Family) ...................... 416

J. The March 8, 2016 Stabbing Attack in Israel (Force Family) ............................ 417

K. The December 23, 2016 Stabbing Attack in Israel (Lisker Family) ................... 418

L. The May 5, 2019 Rocket Attack in Israel (Przewozman Family) ...................... 420

M. The June 23, 2011 EFP Attack in Iraq (Everhart/Zobay Family) ....................... 422

CLAIM FOR RELIEF ................................................................................................................ 423

JURY DEMAND ........................................................................................................................ 425

PRAYER FOR RELIEF ............................................................................................................. 425

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INTRODUCTION

1. This lawsuit seeks damages under the federal Anti-Terrorism Act (“ATA”), 18

U.S.C. § 2333, specifically the aiding-and-abetting cause of action created by the Justice Against

Sponsors of Terrorism Act (“JASTA”), Pub. L. No. 114-222, 130 Stat. 852 (2016). As Congress

explained when enacting JASTA, this statute seeks “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.” JASTA § 2(b).

2. Plaintiffs are American civilians, and their families, who were killed or wounded

in terrorist attacks committed, planned, or authorized by Hezbollah, Hamas, Jaysh Al-Mahdi, and

Palestinian Islamic Jihad, all of which were foreign terrorist organizations (“FTOs”) and proxies

for elements of the Iranian government committed to financing terrorist attacks (“Iran’s Terrorist

Sponsors”), including the Islamic Revolutionary Guard Corps (“IRGC”). The attacks occurred in

Israel and Iraq from 2010 through 2019.

3. Plaintiffs seek to hold Standard Chartered Bank (“SCB”) accountable for aiding

and abetting the terrorists’ attacks. From at least 2001 until at least late 2014 or early 2015, SCB

systematically and knowingly enabled fronts and agents for Iran’s Terrorist Sponsors to finance

terrorist operations by transferring billions of dollars on their behalf while helping them evade

counterterrorism controls, including sanctions designed to prevent Iran’s Terrorist Sponsors from

accessing U.S. dollars and mechanisms designed to alert U.S. law enforcement and intelligence

agencies to terrorist activity. Throughout this period, SCB received numerous direct warnings

from U.S. government officials and others that Iran’s Terrorist Sponsors were using fronts and

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agents, particularly in its oil and gas sector, to provide critical financial and logistical support to

anti-American terrorists worldwide. But SCB chose to prioritize its own profits over American

lives. Through a prolonged campaign of deception over more than a decade, SCB served

customers it knew were fronts for Iran’s Terrorist Sponsors and went to shocking lengths to help

them hide their identities. SCB thus enabled Iran’s Terrorist Sponsors to leverage the U.S.

financial system to supply money, weapons, training, technology, and safe haven to terrorists,

who used that support to attack Americans in Israel and Iraq. Given the stockpiling of assets by

Iran’s Terrorist Sponsors, the volume of SCB’s aid, and the nature of the fronts that partnered

with SCB, the bank’s conduct continued powering Iran-sponsored attacks through at least 2019.

4. SCB’s schemes played out over two phases. The first occurred through 2007,

when SCB laundered billions of dollars for major banks affiliated with Iran’s Terrorist Sponsors,

including the Central Bank of Iran (a/k/a Bank Markazi) (“CBI/Markazi”), Bank Saderat, and

Bank Melli, each of which the United States identified as instrumental to Iran’s terrorist

financing. In flagrant violation of U.S. counterterrorism controls, SCB facilitated these banks’

access to New York’s financial system and U.S. dollar clearing while laundering their

transactions to hide Iran’s role. This deceptive conduct involved an extraordinary offshore

system established within the bank to falsify and remove information from tens of thousands of

wire transfer messages (i.e., wire stripping) in order to disable compliance functions that would

have caused U.S. banks or SCB’s own New York branch to scrutinize, report, or block the

transfers. Altogether, SCB moved hundreds of billions of dollars for the terrorists’ favored banks

this way.

5. This phase of SCB’s misconduct was exposed by enforcement actions that

became public in 2012. These included a deferred prosecution agreement with the U.S.

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Department of Justice (“DOJ”); a settlement agreement with the Office of Foreign Assets

Control (“OFAC”) of the U.S. Department of the Treasury (“Treasury”); a settlement with the

Board of Governors of the Federal Reserve; and a consent order with the New York Department

of Financial Services (“NYDFS”).

6. The enforcement actions revealed in vivid detail SCB’s brazen disregard of the

U.S. government’s counterterrorism warnings and controls when they stood in the way of the

lucrative business SCB sought to develop in Iran. Indeed, when SCB’s New York bankers raised

concerns in 2006 that SCB’s Iran business risked “very serious or even catastrophic reputational

damage” to the bank, SCB’s Group Executive Director in London, Richard Meddings, conveyed

SCB’s prevalent attitude, responding: “You fucking Americans. Who are you to tell us, the rest

of the world, that we’re not going to deal with Iranians.”1

7. Consistent with those sentiments, NYDFS concluded in its 2012 Consent Order

that: “SCB acted for at least ten years without any regard for the legal, reputational, and national

security consequences of its flagrantly deceptive actions. Led by its most senior management,

SCB designed and implemented an elaborate scheme by which to use its New York branch as a

front for prohibited dealings with Iran—dealings that indisputably helped sustain a global threat

to peace and stability.” In its settlements with DOJ, Treasury, the Federal Reserve, and NYDFS,

SCB agreed to pay hundreds of millions of dollars and promised that its offending conduct had

ceased in 2007.

8. That promise was false. SCB relocated its Iran business to Dubai, and in the

second phase of SCB’s schemes occurring between 2008 and 2015, SCB—especially its Dubai

1
NYDFS, In re Standard Chartered Bank, New York Branch, Order Pursuant to Banking Law
§39 ¶¶ 7-8 (Aug. 6, 2012) (emphasis added) (“2012 NYDFS Consent Order”).

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branch—continued to covertly move money for fronts and agents of Iran’s Terrorist Sponsors.

As a second wave of enforcement actions revealed, the wire stripping and evasion tactics SCB

had pioneered were put to new use by its Dubai branch, and SCB’s corporate culture of disregard

for U.S. counterterrorism warnings and controls persisted. But SCB’s conduct during this period

was even more shocking, due to the close connection between the petroleum transactions SCB

facilitated for Iran’s Terrorist Sponsors and their consistent funding of terrorist attacks against

Americans—all while the U.S. government was intensifying its warnings to banks that terrorist

attacks were a foreseeable result of such transactions.

9. Most significantly, as U.S. government warnings blared that Iran was using its oil

and gas sector to fund terrorism, and that Iran’s Terrorist Sponsors had effectively seized control

of the sector, SCB moved at least $150 million for an Iranian petrochemical company (a/k/a

Caspian Petrochemical FZE), which SCB knew was a front for Iran’s Terrorist Sponsors. Well

aware of the U.S. government’s warnings about exactly that activity, SCB bankers falsified

customer due diligence documents, stripped wires, lied to OFAC, and coached the company

about how to evade counterterrorism controls, enabling it to move money through the U.S.

financial system and providing covert access to prohibited U.S. dollar services. This

extraordinary and extensive misconduct enabled Iran’s Terrorist Sponsors and its terrorist

proxies to access the resources they needed to carry out vicious terrorist attacks on Americans,

including the attacks that injured Plaintiffs.

10. SCB also provided evasion advice and prohibited financial services to IRGC

agent Mahmoud Reza Elyassi and his companies. Elyassi claimed to operate an import-export

business, but in fact operated a currency exchange that allowed money to flow in and out of Iran

in tremendous quantities. All-in, SCB’s bankers, acting within the scope of their employment,

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helped Elyassi conduct thousands of transactions worth over $240 million during a four-year

period. They did this by coaching Elyassi and his businesses about ways to evade sanctions,

deceiving their own compliance personnel into approving prohibited transactions, and obscuring

who the bank was dealing with. Elyassi’s business activities—all of which occurred in sectors

over which the IRGC had monopolies—likewise fueled terrorist violence against Americans.

11. These additional violations resulted in additional enforcement actions against

SCB, which became public in 2019. In that settlement, SCB agreed to pay approximately

$1.1 billion for violations of multiple sanctions programs running from June 2009 until May

2014. The SCB employee who managed SCB’s relationships with the Iranian petrochemical

company and Elyassi also pleaded guilty to criminal charges, and Elyassi was indicted.

12. As these stiff penalties show, SCB’s violations were not the actions of a few bad

apples. Instead, the employees who committed these violations were acting fully within the

scope of their employment, and SCB admitted in its settlement that it was responsible for all of

their relevant conduct. What is more, SCB’s violations were only possible because the bank

maintained a corporate culture that actively flouted U.S. counterterrorism warnings and controls.

Indeed, time and again, SCB’s business units stymied efforts within the bank, and especially by

its New York branch, to implement even the most basic controls, and SCB’s management

fostered a culture for more than a decade that treated Iranian terrorist financing risk as an

acceptable cost of doing business. Plaintiffs thus believe that the severe misconduct exposed in

the public enforcement actions constitutes only part of the picture, and that a full investigation of

SCB’s business will reveal even more misconduct through which SCB knowingly assisted

terrorist fronts.

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13. The nexus between SCB’s misconduct and the terrorist attacks that killed or

injured Plaintiffs and their loved ones is tight and irrefutable. Iran’s Terrorist Sponsors are—and

SCB knew them to be—the world’s foremost sponsors of anti-American terrorism, and they are

adept at converting their financial resources into American casualties—both directly and through

a robust network of terrorist proxies including Hezbollah, Hamas, Jaysh Al-Mahdi, and

Palestinian Islamic Jihad. By allowing Iran’s Terrorist Sponsors and their fronts to make, move,

and spend hundreds of millions of dollars, SCB willfully enabled terrorist violence against

Americans.

14. In sum, SCB’s misconduct easily constitutes aiding and abetting under JASTA.

SCB acted in a highly culpable manner, committing multiple crimes and thwarting

counterterrorism controls. It did so for over a decade despite warnings from law enforcement

agencies, financial regulators, the United Nations, European governments, terrorism experts, the

media, and others—all of which made it crystal-clear that providing Iran’s Terrorist Sponsors

and their fronts access to the U.S. financial system would fuel anti-American terrorist violence,

including specifically attacks by Hezbollah, Hamas, Jaysh Al-Mahdi, and Palestinian Islamic

Jihad, which were engaged in ongoing campaigns of violence against Americans in the Middle

East. SCB’s misconduct enabled millions of dollars to flow from Iran’s Terrorist Sponsors to

these designated foreign terrorist organizations, arming them with the weapons and other

resources they needed to carry out deadly terrorist attacks. Plaintiffs and their families suffered

enormously as a result. Congress enacted JASTA to address exactly this misconduct.

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THE PARTIES

A. Plaintiffs

15. Plaintiffs are 90 direct and indirect victims of 12 terrorist attacks committed in

Israel from 2010 to 2019, and one attack committed in Iraq in 2011. In this terminology, direct

attack victims are those who were physically injured or killed in the attack. Indirect attack

victims are the direct attack victims’ close family members who suffered financially and

emotionally as a result of the attacks. They include spouses, children, parents, siblings, and other

close relations of the direct attack victims.

16. Each Plaintiff is either a U.S. national or the estate, survivor, or heir of a U.S.

national.2

B. Standard Chartered Bank

17. Non-party Standard Chartered PLC (“SC PLC”) is an international bank with more

than 1,700 branches operating in over 60 countries. SC PLC’s principal place of business is

London, England.

18. Defendant Standard Chartered Bank (“SCB”) is a wholly owned subsidiary of SC

PLC. SCB’s principal place of business is London, England.

19. Pursuant to a license from NYDFS, SCB operates a foreign bank branch in the

State of New York. The main corporate office of SCB in the United States is 1095 Avenue of the

2
The term “estate” as used herein encompasses established estates, anticipated estates, as well as
certain estate-like constructs available under the laws of certain States (such as “heirships”). The
process of establishing certain estates is ongoing, and the identified family members or other
individuals, as the anticipated personal representatives, bring these claims on behalf of the
anticipated estates of such decedents and all heirs thereof. Each person so identified reserves all
rights, including the right pursuant to Fed. R. Civ. P. 25, to seek to substitute for itself the
decedent’s estate, any successor thereto, or any subsequently named and/or designated estate
representative.

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Americas, New York, New York 10036. SCB’s New York branch is referred to in this

Complaint as the “NY Branch.”

20. Among other services, the NY Branch provides U.S. dollar clearing services for

international wire payments, which can involve the conversion of payments from a foreign

currency into U.S. dollars. The NY Branch processes approximately $195 billion per day on the

Clearing House Interbank Payments System (“CHIPS”).

21. SCB also has licensed branches in the United Arab Emirates and The Gambia,

serving customers throughout the UAE, the Middle East, and Africa. As of the events detailed in

this Complaint, SCB’s UAE presence consisted of 14 branches, with its main office in Dubai

(“SCB Dubai”). During the relevant period, SCB’s Gambia presence included several branches,

with its main office in Banjul (“SCB Gambia”).

22. During the relevant period, nearly all of SCB’s relevant transactions were

denominated in U.S. dollars and therefore cleared and settled in New York through the NY

Branch.

JURISDICTION AND VENUE

23. This Court has subject-matter jurisdiction under 28 U.S.C. § 1331, 18 U.S.C.

§§ 2333(a) and (d), and 18 U.S.C. § 2338.

24. SCB is subject to personal jurisdiction pursuant to 18 U.S.C. § 2334(a), N.Y.

C.P.L.R. § 302, and Fed. R. Civ. P. 4(k).

25. SCB entered the United States voluntarily and has maintained a branch in New

York since 1976.

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26. As explained below, SCB’s substantial assistance to the IRGC and its terrorist

proxies was facilitated by the NY Branch because of the latter’s central role in providing U.S.

dollar clearing, foreign exchange, and trade financing services for SCB’s Iranian customers.

27. SCB purposefully availed itself of U.S. jurisdiction to commit the tortious acts

described in this Complaint, including processing financial transactions through the NY Branch

for the benefit of its Iranian customers, knowing those transactions were enabling the IRGC and

its terrorist proxies to carry out terrorist attacks that killed or injured U.S. citizens in the Middle

East, including Plaintiffs.

28. Moreover, SCB made several misrepresentations to New York authorities—

principally NYDFS—about its conduct, and subsequently about its compliance and remediation

efforts. SCB’s deceptive conduct in this District thereby provided substantial ongoing assistance

to the terrorists that killed and injured Plaintiffs by preventing law enforcement from discovering

and putting an end to the full extent of SCB’s malfeasance.

29. Venue in this District is proper pursuant to 18 U.S.C. § 2334(a) because SCB’s

NY Branch is here.

30. Venue in this District is also proper pursuant to 28 U.S.C. § 1391 because a

material and substantial part of SCB’s activity occurred within the District.

SOURCING

31. The allegations herein concerning SCB’s behavior are based in part on settlement

agreements that SCB entered with regulatory authorities to resolve several enforcement actions

against the bank. Those settlement agreements include Deferred Prosecution Agreements

(“DPAs”) with DOJ, Settlement Agreements and Consent Orders entered by NYDFS and OFAC,

and a detailed Decision Notice from the United Kingdom’s Financial Conduct Authority (“U.K.

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FCA”). Each settlement document contains lengthy and detailed factual recitations regarding

SCB’s illegal, sanctions-evading conduct. SCB, moreover, has stipulated to the truth of the

factual allegations and has promised to not dispute those allegations in subsequent litigation.3

32. To resolve those enforcement actions, SCB paid U.S., New York, and U.K. law

enforcement and financial authorities nearly $2 billion in penalties and forfeitures and has been

ordered to substantially overhaul its regulatory compliance efforts.

33. SCB always actively monitored every official United States warning, sanction

designation, press release, report, advisory, and finding, including those relating to American

sanctions and terrorist financing risks regarding Iran, the IRGC, the Supreme Leader’s Office,

Hezbollah, Hamas, and Jaysh al-Mahdi, including those published by Treasury (including OFAC

and FinCEN), and the U.S Department of State (“State”). SCB did so through, inter alia,

automated diligence databases, in-house compliance and intelligence personnel, and SCB’s

thousands of employees and agents in the United States, United Kingdom, United Arab Emirates,

Iran, and elsewhere, each of whose knowledge is imputed to SCB. Accordingly, SCB had actual

knowledge, in real-time, of each United States warning, sanctions designation, press release,

report, advisory, and finding that any component of the U.S. government published when SCB

engaged in the conduct alleged herein.

NOMENCLATURE

34. This Complaint often features nomenclature known to be deployed by Iran’s

Terrorist Sponsors and their proxies, as well as terms that have a widely understood specific

3
See Am. Deferred Prosecution Agreement ¶ 29, United States v. Standard Chartered Bank,
No. 12-cv-262 (S.D.N.Y. Apr. 9, 2019), ECF 16-1 (“2019 Amended DPA”); id. Ex. B ¶ 2
(Supplemental Statement of Facts) (“SOF”); U.K. FCA, Decision Notice to Standard Chartered
Bank § 7.1 (Feb. 5, 2019) (“SCB agreed to settle in relation to all relevant facts and all issues as
to whether those facts constitute breaches”) (“2019 U.K. FCA Decision Notice”).

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meaning in the terrorism setting like “operation.” Ayatollah Khomeini, Ayatollah Khamenei, and

the IRGC revolutionized propaganda and strategic communications as practiced by radical

Islamists and terrorist organizations. Since 1979, under a strategy and nomenclature developed

and practiced by Ayatollah Khomeini himself, the Ayatollahs, regime clerics, and IRGC relied

upon an extremely limited universe of core propaganda nomenclature comprising about 2,000

words, and consequently, each term assumed outsized, specific meaning as used by such Iranian

actors. Thus, words and phrases, as used by the Iran’s Terrorist Sponsors and their clerical

masters, regularly had a well-known, talismanic-like, IRGC-connoted meaning. That was

because Iran’s Terrorist Sponsors directly served the Ayatollah, and both the IRGC and its

associated clerics and imams broadly mimicked Ayatollah Khomeini’s 2,000-word approach.

35. The United States has emphasized the importance of understanding Iran’s terrorist

ideology and nomenclature—for example, key concepts like the United States as the

“Oppressor,” Muslim populations as the “Oppressed,” and “Resistance” as the preferred

euphemism for anti-American terrorist operations—when analyzing the Ayatollahs, IRGC, their

associates, and their proxies. In 2010, for example, the U.S. Department of Defense (“DoD”)

publicly reported:

Goals of Iranian Strategy

Since the revolution, Iran’s first priority has consistently remained the
survival of the regime. Iran also seeks to become the strongest and most
influential country in the Middle East and to influence world affairs. The
theocratic leadership’s ideological goal is to be able to export its theocratic form
of government, its version of Shia Islam, and stand up for the “[O]ppressed”
according to their religious interpretations of the law. …
To ensure regime survival, Iran’s security strategy is based first on … its
asymmetric warfare doctrine [i.e., IRGC-sponsored proxy terrorist attacks outside
Iran] … [and] [the IRGC’s] outreach and support to governments and dissident
groups that oppose U.S. interests … [through] … active sponsorship of terrorist
… groups [as] tools [the IRGC] uses to drive its aggressive foreign policy. In
particular, it uses terrorism to pressure or intimidate other countries …. The most

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notable example of this strategy includes Iran’s support for Lebanese Hizballah as
well as its influence over proxy groups in Iraq. …

Trends in Iranian Strategy

Iran seeks to increase its stature by countering U.S. influence and
expanding ties with regional actors while advocating Islamic solidarity. It also
seeks to demonstrate to the world its “[R]esistance” to the West. Iran is
attempting to secure political, economic, and security influence in Iraq … by …
furnishing lethal aid to Iraqi Shia militants … [via, inter alia, the IRGC Qods
Force and Hezbollah]. In an attempt to increase influence in the Levant, Iran
provides weapons, training and money to Lebanese Hizballah, its strategic
partner.

36. In 2019, similarly, the Office of the Chairman of the Joint Chiefs of Staff reported

that the IRGC was like “[a]ll … revolutionary visions of history – from Marx through Shariati to

Khomeini – [Ayatollah Khomeini, Ayatollah Khamenei, and the IRGC] need an exploitative or

oppressing adversary …[,] [and] the [Iranian] clerical regime’s historical frameworks … [were]:

an ‘Oppressed’ Iranian nation of true Muslims fighting against an ‘Oppressor’ … within a larger

oppressive bipolar international order,” which, in the IRGC’s eyes and under its ideological and

communications narrative, was always led by the United States government (which the IRGC

called the “Great Satan” and the “Global Arrogance”) and U.S. allies, including Israel (which

nation the IRGC, like Iran’s regime, refused to recognize, instead describing it as the “Little

Satan” to America’s “Great Satan”) and U.S.-supported governments in the Middle East that did

not submit to the Ayatollah (which the IRGC invariably described as U.S. “puppets”).

37. Below, Plaintiffs identify nine specific words and phrases that had a specifically

understood meaning when used by Ayatollah- and/or IRGC-affiliated speakers in Iran since

1979. Each such word and phrase had a similar meaning from 1979 through today, as each was

one of the words or phrases that Ayatollah Khomeini deployed, which was modeled throughout

IRGC and clerical ranks ever since. Plaintiffs’ definitions below track regularly published

proclamations, speeches, sermons, and commentaries by the Ayatollah, clerics, and/or the IRGC

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since 1979, as published by both Iranian and Western media. SCB knew the below meanings

because they were regularly published, and SCB was a sophisticated multinational financial

institution with extensive experience in the Middle East, including local agents in Iran, whose

knowledge is imputed to SCB. Unless otherwise indicated, Plaintiffs’ use of the above-identified

terms in this Complaint comports with the definitions in this section.

38. “Asymmetric Warfare”, including analogues like “proxy warfare”, refers to

IRGC-sponsored terrorist attacks targeting the United States. Such nomenclature tracks both

Iranian and U.S. government custom and practice. For example, as one DOD-published analysis

of the IRGC noted in 2011: “The IRGC’s strategy of asymmetric warfare and its open advocacy

of terrorism as a pillar of this strategy have cost Iran in the international political sphere. The

U.S. Department of State, in its 2010 annual country reports on terrorism, re-designated Iran as a

state sponsor of terrorism. This is in keeping with its designation since 1984.”

39. “Jihad” refers to the Ayatollah’s and the IRGC’s purportedly religiously

authorized objective of expelling America from the Middle East through IRGC acts of terrorism.

As used by the Ayatollah and the IRGC, the concept of jihad is inextricably intertwined with

terrorist violence and closely related to the concept of “Resistance” (defined below).

40. “Liberation” refers to any country or community that (a) shared the IRGC’s

hostility towards America and (b) submitted to the Ayatollah’s rule as enforced by the IRGC.

41. “Operation” and “Operations” refer to terrorist attacks. The U.S. government,

United Nations, U.K., E.U., and terrorism scholars agree and follow the same nomenclature.

42. “Oppressed” and “Downtrodden”, including such words’ longer or related

versions—“Oppressed on Earth”; “Oppressed of Earth”; “Downtrodden”; “The Downtrodden on

Earth”; and “The Downtrodden of Earth”—refers to the Muslim populations of any community

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that had not submitted to the Ayatollah’s rule and/or maintains normal relations with the United

States. As Ayatollah Khomeini famously instructed the IRGC, when it came to Iran’s “Foreign

Policy”: “We have a duty to support the Oppressed and be inimical to the Oppressors.”

43. He famously decreed in 1979: “We should try to export our revolution to the

world. We should set aside the thought that we do not export our revolution, because Islam does

not regard various Islamic countries differently and is the supporter of all the [O]ppressed

peoples of the world. On the other hand, … the [United States government, and other foreign

governments] … have risen to destroy us. If we remain in an enclosed environment, we shall

definitely face defeat.”

44. “Oppressor” and related concepts longer versions—the “Great Satan” and the

“Global Arrogance”—refers to the United States government, which the Ayatollah and IRGC

maintained were responsible for oppressing the Islamic community around the world by denying

the rule of the Ayatollah.

45. “Resistance” refers to terrorist attacks targeting the United States (including

through its allies like Israel and Iraq) under the IRGC’s constitutional mandate to export Iran’s

Islamic Revolution. “Resistance” is the preferred euphemism of the IRGC and every IRGC

proxy, many of which, including Hezbollah, Hamas, and Palestinian Islamic Jihad, literally

feature the word “Resistance” in the Arabic version of their “external operations wing” (in the

case of Hezbollah) and name itself (in the case of Hamas). For example, as the Investigative

Project on Terrorism observed on December 3, 2012, the term “‘resistance’” was an infamous

“code word for terrorism.”

46. “Resistance Economy”—including its alternative variant, “Economic Jihad”—

referred to IRGC-related economic activities that inextricably aided the IRGC’s “Resistance”

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against America, i.e., its acts of terrorism targeting the United States. Since the 1990s, a wide

array of terrorist groups has embraced the concept of an “Economic Jihad” as a means through

which such group’s supporters can enable the group’s attacks even if such supporters themselves

do not want to, or cannot, fight for the group. In or about 2011, Ayatollah Khamenei coined the

phrase “Resistance Economy” as a short-hand or euphemism for economic activities that help the

Iranian regime continue to fund and arm Iranian-sponsored proxy terrorist attacks that were in

“resistance” to the United States and it allies in the region, including Israel. From 2012 through

present, Iranian actors affiliated with the Supreme Leader, SLO, and IRGC have routinely

emphasized the inextricable connection between “Resistance Economy” activities and IRHC-

sponsored jihadist attacks targeting the United States. On May 27, 2016, for example, the SLO-

and IRGC-controlled Iranian state media network IRIB reported (as re-reported by BBC) that an

IRGC-linked cleric sermonized on IRIB during Friday Prayers –a key vehicle for the Ayatollah’s

and IRGC’s propaganda—that that those “focused on implementation of [the IRGC’s]

Resistance Economy … described [the IRGC’s] Resistance Economy as ‘a support’ for the

‘jihad’” against “America and its mercenaries,” who “are exerting pressure on Iran…; therefore,

people’s resistance and Jihad are aimed against such pressures’” from the United States. On

January 14, 2019, similarly, U.S. government-published Radio Farda reported: “The IRGC has

been one of Iran’s main economic engines for decades, controlling important sectors,” and the

“IRGC is also an important tool by the regime to implement its ‘Resistance Economy’ doctrine –

aimed at increasing self-reliance of the Iranian economy and decreasing its vulnerability to

external pressures” from the United States, which helped “the IRGC [] fulfill[] its number one

goal – … exporting its revolution to Lebanon, Iraq, Syria, Yemen, and beyond”—i.e., IRGC-

sponsored attacks targeting the United States.

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47. “Resistance Movements”—including its alternative variants, “Jihad

Movements” and “Liberation Movements”—refers to the IRGC’s terrorist proxy members in its

“Axis of Resistance.”

48. “Wilayat-e-Faqih”, including its short-hand or slang variant, “Wilayat”, refers

to two related concepts: (1) the rule of pious Muslims around the world who submit to the rule of

the jurisprudent in the form of the Supreme Leader of the Islamic Republic of Iran as supported

by the IRGC as commanded by the Supreme Leader; and (2) the organizations and individuals

who operationalized the Supreme Leader’s and IRGC’s implementation of such rule, including

the Supreme Leader, Supreme Leader’s Office, IRGC, and individuals or entities under the

control of such persons where such individuals’ or entities’ function includes exporting the

Islamic Revolution to expand the reach of the Supreme Leader and IRGC.

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FACTUAL ALLEGATIONS

I. Since 1979, Several Elements Within The Iranian Government Served As The
Regime’s Primary Terrorist Sponsors To Facilitate Terrorist Attacks On Americans
By Iran’s Proxies In The Middle East

49. Since 1979, radical Shia terrorists of Iranian origin throughout the Middle East

pledged, before Allah, their personal oath of allegiance not to their own nation, but instead to a

Shiite Ayatollah who would eventually, in February 1979, become the first Supreme Leader of

the Islamic Revolution: Ayatollah Ruhollah Khomeini.4 When they did so, one of the things they

pledged was to support the Ayatollah’s embrace of violent jihadist attacks targeting the enemies

of the “Islamic Revolution”—most of all, the United States (the “Great Satan”) and its allies in

the Middle East, including Israel (the “Little Satan”). Their shared objective was to force the

Great Satan to exit the Middle East and abandon its allies there through an unrelenting campaign

of terrorist attacks against Americans.

50. To advance this core objective of the Revolution, the Iranian regime developed

something previously unheard of: a vast infrastructure of institutions organized within the

government to facilitate terrorist attacks by proxies throughout the region. Although these

elements permeated Iran’s government and society in many ways, Plaintiffs focus on certain key

institutions, which Plaintiffs refer to collectively as Iran’s Terrorist Sponsors. These institutions

include (but are not limited to) (1) the Foundation for the Oppressed; (2) the Supreme Leader

4
In this Complaint, Plaintiffs refer to certain religious concepts and describe those concepts from
the perspective of Iran’s Terrorist Sponsors and their supporters and proxies. The terrorists’
understanding of, and use of, religious concepts is vital to understanding their actions, strategies,
ideology, doctrine, motivations, linguistic choices, financial practices, rules, tactics, techniques,
and procedures. For the avoidance of all doubt, however, Plaintiffs wish to emphasize that
nothing in this Complaint should be interpreted as suggesting that the terrorists’ interpretations
of their Islamic faith is correct as a matter of theological doctrine or representative of the views
of the vast majority of Muslims around the world who oppose terrorist violence.

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Ayatollah Ali Khamenei and The Supreme Leader’s Office (SLO); (3) the Islamic Revolutionary

Guard Corps (IRGC); (4) Hezbollah; and (5) the Friday Prayer Leader Organization.

51. To provide context for SCB’s conduct and its consequences, Plaintiffs first

provide a summary of some of the most important historical events, persons, and decisions that

shaped the development of Iran’s terror apparatus during its formative period from the mid-

1970s through the mid-1980s. Plaintiffs then explain the role of each of Iran’s Terrorist

Sponsors.

A. Historical Background

52. In the mid-1970s—years before Iran’s Islamic Revolution—Ayatollah Ali

Khamenei set out to use terrorism to engineer a series of victories, beginning with using attacks

to secure an Islamic safe haven (an “Islamic Republic”) that, in turn, would serve as the

geographic safe haven from which Khamenei and his allies could safely, securely, methodically,

and patiently launch attack after attack against the United States and its allies in the Muslim

world. Through such attacks from their safe haven, Khamenei and his allies would build a

terrorist movement centered on martyrdom, violence, and the promise that martyrs who die while

attacking the United States secure heavenly rewards for themselves and their entire families,

immediate and extended alike. By marrying martyrdom with a messianic Shia narrative and

emphasis on terrorism as the foundational tactic through which the revolution could be secured,

Khamenei hoped to build an alliance of like-minded Islamist terrorists who would, working

together, conduct so many successful attacks targeting the United States that the U.S.

government would elect to withdraw the United States from the Middle East, after which

Khamenei would eventually bring about the final collapse of the United States as a nation,

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followed by the eventual collapse of every other nation-state that would not yield to the terrorism

he sponsored to bring about his global Islamic Revolution.

53. Ayatollah Khamenei’s desired end-state was the formation of what he termed the

“Islamic State”: a single, global, Shia Islam-derived, Shia-led government ruled by a single

(Shia) Supreme Leader, of which his eventual “Islamic Republic of Iran” would be but one

province, and for which all the citizens of the world converted to the Shia faith, swore an oath of

loyalty to the Islamic State, and agreed to sacrifice their own lives for the Leader—or would be

summarily executed as infidels and blasphemers. Khamenei’s desired Islamic State was intended

to topple the entire international nation-state system and erase the borders between national

governments that Khamenei regarded as a creation of infidels.

54. In Ayatollah Khamenei’s violent and fanatical vision, a single sect (Shiism) of a

single faith (Islam) would establish a single government (the Islamic State) that would rule the

entire globe, even though most Shia Muslims rejected such views, Shias were a tiny fraction of

the globe’s population and outnumbered even within the Islamic faith, for which Sunnis were

always the dominant sect. Once Khamenei’s imagined “Islamic State” ruled the world,

Khamenei intended to implement a global genocide in which the only humans anywhere in the

world who would be allowed to live would be those who were “faithful,” i.e., who were Shia

Muslims who swore allegiance to the Supreme Leader of the Islamic State. Infidels,

blasphemers, and those who “corrupted” the world—an Islamic concept that Khamenei

transmogrified into, essentially, anything that was contrary to his views—would be summarily

executed if they refused to convert to Shia Islam.

55. Although Ayatollah Khamenei’s vision sounds absurd to Western ears—and to

the vast majority of Muslims outside his circle of influence—it became a powerful ideological

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motor and organizing doctrine for his followers, as well as a deeply rooted justification for

terrorist attacks. This was so for three reasons.

56. First, the fact that Ayatollah Khamenei’s scheme contemplated revolutionary

stages (first destroy the United States, then take over the world) meant that Khamenei believed,

and taught all who followed him, that no act of terrorist violence that targeted the United States

(directly or through its allies like Israel) was ever out of bounds as long as the attack in question

helped intimidate the U.S. government—the condition precedent to Khamanei’s desired end state

of an Islamic world government.

57. Second, the primacy of terrorist violence to achieving Ayatollah Khamenei’s end-

state meant that Khamenei—and those he controlled—always prioritized sponsoring acts of

terrorism targeting the United States (including though its allies) above every other consideration

as a matter of tactics (use of terrorism), doctrine (belief that attacking the United States was the

single most important variable to the success or failure of the enterprise), and religious faith (the

heavy emphasis on martyrdom). Thus, under Khamenei’s approach—and ideology taught to his

followers—every other consideration was subordinate to bringing about the revolution necessary

to birth a global Islamic State. Accordingly, as a matter of first principles, Khamenei and any

terrorist faithfully following his approach would ordinarily be expected to devote at least the

majority—if not all—of their time, money, work, and even family members to supporting

Khamenei’s efforts to sponsor attacks targeting the United States.

58. Third, Ayatollah Khamenei knew that his ability to sponsor terrorist attacks

targeting the United States that would be so effective as to compel America to leave the Middle

East would require a cross-cutting combination of terrorist groups, tactics, operatives, skill sets,

attack types, geographies, professions, relationships, languages, and more. Khamenei knew, and

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taught his followers, that to meet these conditions precedent to their ability to effectively

terrorize the United States into submission, Khamenei’s terrorist alliance needed vast stores of

money, weapons, recruits, intelligence, safe havens, and networked relationships with

prospective allies and partners. And, Khamenei knew—and taught his followers—that such

operational needs, in turn, meant that his terrorist attacks could only bring about his desired

Islamic State if Khamenei and his allies could sustainably raise, store, move, and spend money—

most of all, U.S. dollars—needed to pay for the fighters, weapons, logistics, and intelligence

upon which every successful attack targeting the United States relied.

59. Ayatollah Khamenei also knew, however, that even with the best of efforts, he

and his terrorist allies would always be outmatched financially and technologically by the United

States and its allies like Israel. Khamenei addressed both challenges with a programmatic

emphasis on the glory of martyrs and martyrdom, which informed the entire terrorist architecture

he built. Khamenei thus sought to change the world through terrorist tactics, and he spent

decades developing, nurturing, financing, arming, and leading a transnational, cross-sectarian,

alliance of anti-American Islamist terrorists in which sworn terrorist “brothers” from Iran, Iraq,

Lebanon, Palestinian territories, Syria, and elsewhere sought to overthrow any government in the

Muslim world that was opposed to their vision.

60. To convert his fantastical ideas into reality, Khamenei would eventually sponsor

proxy terrorist attacks targeting the United States to coerce the U.S. government into fleeing the

Middle East and abandoning its allies there, most of all, Israel. To accomplish this objective,

Khamenei sought to help sworn followers of the Islamic Revolution from Iran, Iraq, Lebanon,

and around the world source the funds, weapons, logistical support, training, haven, intelligence,

and cover and concealment required to attack and kill Americans around the world. This, in turn,

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required that Khamenei build, grow, and sustain a global terrorist coalition united in two

objectives that were inextricably linked in the eyes (and demands) of the terrorists: the

withdrawal of the United States from the Middle East and the destruction of the State of Israel

and forced expulsion and/or murder of any Jews that remained.

61. Ayatollah Khamenei always believed that the U.S. and Israeli governments’ roles

in the Middle East were inextricably linked. Most of all, Khamenei deployed two primary tactics

to accomplish his strategic objective to force the United States out of the Middle East so that the

Islamic Revolution would not wilt under the threat of U.S. intervention and would be free to

overthrow the dozens of U.S. allies and partners throughout the Muslim world. His first tactic

was to sponsor shockingly violent terrorist attacks to kill enough Americans to intimidate the

U.S. government and persons in the United States into exiting the Middle East and abandoning

Israel. His second tactic was to sponsor similarly brutal terrorist attacks specifically designed to

intimidate the U.S. government and U.S. population at large by inflicting unspeakable violence

on America’s closest Middle Eastern ally: Israel.

62. Khamenei believed that what he scorned as the “Zionist regime” (or worse) was

merely an artificial creation of, and an ongoing arm of, the U.S. government such that attacks

that hurt Israel would also terrify U.S. government decisionmakers, demonstrating the

inevitability of Khamenei’s triumph over what he believed to be a figurative organ of the U.S.

government.

63. Ayatollah Khamenei’s grand terrorist ambitions required an equally grand

architecture of terrorist sponsors. In this Complaint, Plaintiffs refer to the network of terrorist

sponsors that Khamenei built and led as the “Iranian Terrorist Sponsors” or “Terrorist Sponsors.”

Among the grandest of Khamenei’s insights was the recognition that the only possible way for

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the terrorists to succeed against the might of the U.S. and Israeli governments was by working

together regardless of their sectarian or ideological differences as long as they were (a) Muslim;

and (b) committed to killing, maiming, kidnapping, raping, torturing, and summarily executing

enough Americans, and victims from nations allied to the United States, to force the U.S. out.

64. What would eventually become Ayatollah Khamenei’s “Axis of Resistance” was

birthed in Palestinian terrorist camps in south Lebanon throughout the 1970s, during which

period radical Shiite and Sunni Islamist groups comprised of Iranians, Iraqis, Lebanese, and

Palestinians lived, trained, and fought together. Future leaders of the IRGC and Hezbollah,

including future IRGC founder and senior leader Mohsen Rafiqdoost, future Hezbollah global

attack cell leader Imad Mugniyeh, future senior JAM leader Abu Mahdi al-Muhandis, and a

coterie of future leaders of Hamas were all co-located in the same camps, at which they built

lifelong relationships that integrated these four terrorist groups into one coordinated alliance. For

example, infamous Hezbollah operations mastermind Imad Mugniyeh was originally Palestinian

terrorist leader Yassir Arafat’s personal bodyguard before he was successfully recruited by the

IRGC to join Hezbollah. From these camps, Iranian terrorists supported Ayatollah Ruhollah

Khomeini’s—who was exiled in France—campaign to overthrow the U.S.- and Israel-supported

Shah of Iran.

65. By 1978, Ayatollah Khamenei’s plan for global conquest through terrorism had

begun to be put in motion: the U.S. government-backed Shah of Iran, Reza Pahlavi, was being

rocked by a wave of Islamist terrorist attacks, kidnappings, assassinations, and acts of

intimidation. In 1978, unlike now, such effective, and frequent, attacks by organized radical

Islamist terrorists against a sitting U.S.-backed Muslim regime in the Middle East were virtually

unheard of. And yet, the attacks that Khamenei and his allies continuously sponsored throughout

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1978 worked. Khamenei and his allies therefore elected to intensify the violence. In coordination

with notorious fanatics like Mohsen Rafiqdoost (who had recently been released from prison for

murder) and Mohsen Rezai (who likely masterminded a sophisticated cross-border assassination

of his own son out of devotion to the Supreme Leader after his son had defected to the United

States and criticized the regime), Khamenei helped spearhead a successful wave of attacks that

accelerated the demise of the Shah’s government.

66. Throughout this period, Ayatollah Khamenei served a single master: Ayatollah

Ruhollah Khomeini, who led what purported to be a broad, democratic, and inclusive movement

in opposition to the Shah while Khomeini was exiled in France. That was, however, a fiction.

Khomeini schemed the entire time to seize power and impose a radical Islamist vision upon

everyone as soon as he could, backed by a robust commitment to terrorism as a first principle for

which Ayatollah Khamenei was Khomeini’s top lieutenant, most committed evangelist, and lead

relationship manger with terrorists inside, and outside, of Iran.

67. Khomeini led his revolution from France, for which he recruited and deployed

jihadists from Iran, Iraq, Lebanon, Palestinian territories, and throughout most of the Middle

East, who were trained in Lebanon by Palestinian Sunni terrorists at camps run by a allied

militias comprising a mix of Lebanese, Syrian, Palestinian, Iranian, and Iraqi terrorists, among

others, including Lebanese militias that Khamenei and his IRGC henchmen would eventually

construct into Hezbollah, which also shared a common theological (Shia), national (mixed-

Lebanese-Iraqi), and familial connection (the Sadr clan), from which future Jaysh al-Mahdi

leader Muqtada al-Sadr would later emerge in 2003. During this pre-revolutionary period in the

late 1970s, cross-pollination between groups was the order of the day. For example, Khamenei’s

lieutenants recruited legendary Hezbollah operations mastermind—and dual-hatted IRGC

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operative—Imad Mugniyeh away from iconic Palestinian Sunni terrorist (and Khamenei ally)

Yassir Arafat, the iconic decades-long leader of the Palestinian Liberation Organization.

Khamenei’s emphasis on extreme violence, martyrdom, and cross-cutting collaboration with

other groups throughout the Middle East worked.

68. On February 1, 1979, Ayatollah Khomeini and his followers returned to Tehran

and commenced their Islamic Revolution. When Khomeini landed, he was accompanied by his

top operations, logistics, and security operative—his personal bodyguard, driver, and assassin,

Mohsen Rafiqdoost. As Khomeini (who was frail) gingerly walked down the stair of the plane,

Rafiqdoost (black turban to Khomeini’s left) physically supported him as he set foot on Iranian

soil, producing what is regularly described as the most iconic—and widely displayed—photo of

the Islamic Revolution:

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This ubiquitous image instantly and permanently cemented Mohsen Rafiqdoost’s intimate

connection to—and key trust from—Khomeini and, by extension, Khamenei.5 Simply put, it

vividly showed Rafiqdoost as the man most trusted to keep Khomeini physically safe in the

literal moment when he was about to return to Iranian soil to launch his revolution. It therefore

ensured that Rafiqdoost was a terrorist with universal name identification in Iran who was

immediately understood—and always known thereafter—to be a key member of both

Ayatollahs’ inner circles. (Rafiqdoost is alive today, and continued directly sponsoring Iranian-

sponsored attacks his entire life, including the attacks that killed and injured Plaintiffs.)

69. On February 11, 1979, ten days after returning to Iran, Khomeini had effectively

secured power. Upon doing so, he and his allies, including Khamenei, Rafiqdoost, and Rezai, set

to work creating the instruments of terror upon which his Islamic Revolution would depend. At

this time, Khamenei was, inter alia, Khomeini’s then-personal representative to external, anti-

American, Islamist, terrorist groups throughout the world, including Lebanese, Palestinian, and

Iraqi terrorist groups and most ideologically zealous proponent of terrorism; simply put,

Khamenei was the first ever Iranian terrorist to whom the regime assigned the role later made

famous by Qasem Soleimani: the Iranian regime’s lead relationship-manager with leadership

elements in other terrorist groups, including Iranian proxies. Similarly, Mohsen Rafiqdoost

served at the time as the Supreme Leader’s then-most senior operations-facing operative with

5
These photos were reportedly two of the most famous, mostly widely viewed, images in Iranian
history. One or both were prominently displayed in most Iranian regime offices, buildings,
markets, and the like, and were sometimes offered, in terms of ubiquity, as the Iranian regime’s
analogue to the United States’ iconic photo of Marines raising the American flag at Iwo Jima
during World War II. That widespread comparison, while offensive to the memory of American
heroes, accurately reflected the universal knowledge of these photos in Iran as well as how, and
where, the Iranian regime deployed the photo. For all these reasons, Mohsen Rafiqdoost was
always – literally, from Day 1 of the Islamic Revolution – an internationally famous (and
infamous) member of Khomeini’s and Khamenei’s inner circle.

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strong pre-existing financial, personal, recruiting, and logistical networks Lebanon, Iraq, and the

Palestinian territories, and Mohsen Rezai served at the time as the Supreme Leader’s then-most

senior ideologically zealous advocate in favor of using intelligence organizations and processes

to power terrorist attacks.

70. Khomeini, Khamenei, Rafiqdoost, and Rezai sought to develop a terrorist arm to

launch attacks outside of Iran from day one because they believed that their Islamic Revolution

would always be in mortal danger if they simply sat back and played defense against what they

expected to be the inevitable pressure from the U.S. and its allies, including Israel. Moreover,

their revolution was only months old, they feared that the forces of the “Great Satan” (i.e., the

United States) could—and likely were about to—invade Iran at any moment to destroy their

Islamic Revolution before it could take root, and replace it with either another monarch like the

freshly deposed Shah or—even worse—securing the birth of an American-style liberal

democracy that was the antithesis of everything that their Islamic Revolution espoused. The

survival of their nascent Islamic Revolution—and potentially, their own life or liberty—

depended on building a robust terrorist capability.

71. Accordingly, Khomeini, Khamenei, Rafiqdoost, and Rezai all believed—and

taught their followers—that protecting the Islamic Revolution required propagating terrorist

violence outside of Iran to prevent the United States from having the space and time to devote its

resources to toppling the regime, as the U.S. previously had done in 1953. Their identified

strategic imperative to attack the United States to protect their Islamic Revolution from being

toppled was in addition to their recognized need to also attack the United States to compel it to

abandon the Middle East so that Khomeini, Khamenei and their allies could then topple other

governments one by one throughout the region.

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72. To that end, Khomeini installed Khamenei as, in effect, his leader for terrorist

coordination, planning, and recruitment: a role that was substantially like that which Khamenei

would assign to Qasem Soleimani about 20 years later. And Khomeini complemented that choice

by installing Rafiqdoost as his top “security” (code for operations) operative and Rezai as his

lead intelligence operative, with Rafiqdoost and Rezai both doing double-duty, in effect, as

Khomeini’s and Khamenei’s two most important logisticians as well. Instructed by Khomeini,

Khamenei, Rafiqdoost, and Rezai set out to build an integrated, sustainable, and effective

infrastructure that addressed each of the three key nodes upon which the Iranian regime relied to

sponsor terrorist attacks by proxies outside of Iran, which Khamenei had identified years earlier.

73. First, Khamenei, Rafiqdoost, and Rezai needed to build an organization that

enabled them to leverage the power of their monopolistic control of the Shia faith in Iran to

imbue their entire terrorist enterprise with religious fervor. They thus used Friday Prayers to

plainly declare Khomeini’s, Khamenei’s, and their allies’ terrorist intentions, issue religious-

based calls for violence, celebrate martyrdom, and source donations and recruits for attacks.

74. Second, Khamenei, Rafiqdoost, and Rezai needed to build a reliable, large,

diverse, and globally distributed terrorist operations system to supply the funds, logistics,

weapons, fronts, and cover needed to plan and execute attacks. This infrastructure required (1)

fighters, including both their person and their budgets, salaries, and martyr payments; (2)

operations budgets; (3) weapons; (4) transportation to the attack site; (5) pre-attack intelligence

expenditures; (6) smuggling operations to facilitate attacks, e.g., moving, securing, and/or hiding

illicit vehicles, vessels, or goods; (7) a global network of fronts comprised of the Foundation’s

offices, charities, affiliates, safe houses, real estate, and business organization, among other

forms of support, to enable the Iranian Terrorist Sponsors to effectively conduct lethal attacks

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targeting the United States and its allies while maintaining plausible deniability to avoid the risk

that such attacks eventually prompt an armed conflict between the nations of the United States

and Iran.6 Accordingly, Khamenei, Rafiqdoost, and Rezai were responsible for building the

Islamic Revolution’s very first purpose-built terrorist operations organization.

75. Third, Khamenei, Rafiqdoost, and Rezai needed to make its terrorist organization

cohesive. This required they consolidate the variety of militant Islamist militias who supported

the Revolution into a single, organized, ideologically zealous, tactically proficient, terrorist

group.

76. From February 1979 through April 1979, Khamenei, Rafiqdoost, and Rezai—

along with a litany of others—knocked out each of Khomeini’s three tasks in rapid order. In so

doing, they built three of the key organizations that the Iranian regime deployed as Terrorist

Sponsors: the Friday Prayer Leader Organization, Foundation for the Oppressed, and IRGC.

77. In or about the February 1979, and befitting Khomeini’s and Khamenei’s

emphasis on leveraging religious faith for terrorist violence, Khamenei, Rafiqdoost, and Rezai

moved to rapidly seize—in Khomeini’s name—control of all Friday Prayers in Iran. In the

Islamic faith, Friday is when the devout attend Mosque for their most important message of the

week from the Imam. Before the shah fell, regime opponents used Friday prayers to mobilize

fighters and funds against him. Having seen the effectiveness of the tactic that they used to

devastating effect, Khomeini and Khamenei understood the critical need to shut the door behind

them, as well as the opportunity afforded by their monopoly on the delivery of, marketing of,

donations sourced, and recruits found, through such services.

6
This aspect of the Iranians’ strategy succeeded: from 1979 through 2024, as there has
never been a direct armed conflict between the nations of the United States and Iran.

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78. After having seized control, in effect, of Iran’s most important venue for

fundraising and recruitment at the time, Khamenei, Rafiqdoost, and Rezai moved onto their

second task: standing up a purpose-built external operations front they could use to sponsor

attacks targeting the United States and its allies, in order to export (and protect) their Islamic

Revolution.

79. On March 5, 1979, Khomeini, Khamenei, Rafiqdoost, and Rezai birthed their

operations front, which Khomeini operationalized through a simple scheme devised by

Khamenei, Rafiqdoost, and Rezai under which the Supreme Leader’s Office and terrorist militias

(that would eventually become the IRGC) seized the Pahlavi Foundation—which was the Shah’s

global charitable foundation that had assets and facilities all over the world—as well as the assets

of Jews, Bahais, and other religious minorities, which they pooled together and renamed “The

Foundation for the Oppressed on Earth” also known as the Bonyad Mostazafan (“Foundation for

the Oppressed”).

80. That name was not a coincidence, but rather, a deliberate choice by Khomeini,

Khamenei, Rafiqdoost, and Rezai to boldly announce the new purpose to which they were

devoting the Shah’s vast commercial, financial, and real estate holdings: exporting their Islamic

Revolution to benefit the “Oppressed of the Earth”—i.e., terrorist attacks targeting the United

States and its allies. For Khomeini, the “Oppressed on Earth” comprised Muslims in countries

who needed to be “liberated” through Khomeini-sponsored terrorist violence, and his newly

seized Foundation was specifically intended for that purpose. To that end, Khomeini installed his

most trusted terrorist henchmen on the board of the Foundation for the Oppressed from

inception, including Ali Khamenei. From inception, and ever since, the Foundation for the

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Oppressed has been inextricably connected to, and a vehicle for, the senior terrorist leaders who

provided the muscle for Khomeini’s terrorist agenda.

81. Accordingly, Khomeini, Khamenei, Rafiqdoost, and Rezai created the Foundation

for the Oppressed to sponsor external terrorist attacks by Iranian proxies before they had even

created the IRGC. Simply put, the Foundation for the Oppressed was as important as the IRGC

to the regime’s ability to sponsor violence, and neither could function without the other. But

before one builds a well-armed transnational terrorist force capable of launching attacks

throughout the world, one first needs stable income streams, corporate fronts to provide cover

and concealment, weapons, logistics, and more. Thus, Khomeini, Khamenei, Rafiqdoost, and

Rezai established their lead external terrorism front—the Foundation for the Oppressed—before

they even established the IRGC.

82. About two months after Khomeini, Khamenei, Rafiqdoost, and Rezai established

the Foundation for the Oppressed as their first terrorist front, they followed up by creating the

organized terrorist group that would be one of—but not the only—intended terrorist groups to be

the beneficiary of the Foundation’s activities: the IRGC.

83. On April 22, 1979, Khomeini ordered Rafiqdoost to organize the various terrorist

militia that had supported him into one integrated organization that was purpose-built to help

Khomeini secure his Islamic Revolution through terrorist violence; Khomeini had his terrorist

front (the Foundation for the Oppressed), and now he wanted the organized terrorist group to go

with it. As Rafiqdoost himself later boasted in an interview with Iranian state media in 2016:

I wrote on a piece of paper: “The Islamic Revolution Guards Corps has been
formed” and then wrote my name and asked everyone else to write down their
names if they wanted to join the corps[] … Then I realized that three other groups
have also formed their own IRGC. I invited their leaders to my office, locked the
door, took out my gun and told them I would kill them and myself if they did not

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join the corps[] I had formed. We held meetings for several days, … [after which
the] IRGC was officially formed.

Thereafter, by his own hand, Rafiqdoost authored the document creating the IRGC:

84. Amongst Khomeini’s, Khamenei’s, Rafiqdoost’s, and the freshly created IRGC’s

first order of business was to create an external operations group that would sponsor terrorist

attacks outside of Iran to secure the “liberation” of the “Oppressed of the Earth” through the

“export” of their “Islamic Revolution,” which Khomeini, Khamenei, and Rafiqdoost dubbed the

“Office of Liberation Movements.”7

85. On November 4, 1979, Iranian students loyal to Khomeini took over the U.S.

Embassy in Tehran, taking 52 Americans hostage and leading the U.S. to sever diplomatic

relations with Iran. Notably, the hostage takers were widely credited with having been instructed

to act by violent calls to action issued by Friday Prayer Leaders in Tehran before the attack. The

7
In 1989, after his ascension to Supreme Leader, Khamenei restructured this effort by
replacing the Office of Liberation Movements with the Qods Force and installing his own inner
circle allies to lead it, including Qasem Soleimani.

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crisis lasted 444 days before Khomeini released the hostages. Rafiqdoost later publicly admitted

to having played a key role in this attack.

86. The Iranian regime perceived that it won its hostage standoff with the United

States—which formed the basis for all future regime strategy towards America. As Khomeini

argued at the time, “this action,” i.e., the seizure of the U.S. Embassy and American hostages,

“has many benefits” given that “taking hostages has increased our credibility” and “we will get

many concessions.” As Secretary of State Pompeo observed four decades later on November 4,

2019: “Forty years later, the revolutionary regime in Tehran has proven, time and again, that its

first acts after gaining power were a clear indication of its evil character. The regime continues to

unjustly detain Americans and to support terrorist proxy groups like Hizballah that engage in

hostage taking.”

87. By 1980, Khomeini and his IRGC praetorian guard had secured their power base

and set out to murder their enemies, real and imagined. To that end, Khomeini signed a decree—

which has been in force ever since—instructing the IRGC that purported enemies of the

Ayatollah and the IRGC “are infidels and worse than blasphemers” who “have no right to life.”

88. On September 22, 1980, Saddam Hussein’s regime in Iraq attacked Iran,

launching the Iran-Iraq war, which the IRGC often called “The Imposed War.” During the Iran-

Iraq war, Khomeini appointed two of his most loyal terrorist lieutenants to command IRGC

forces: IRGC Brigadier General Ali Khamenei had a battlefield command, and IRGC

Commander Mohsen Rafiqdoost was appointed Minister of the IRGC.

89. The Iran-Iraq war solidified the Iranian regime’s enduring alliance with North

Korea, in particular, the tight relationship between North Korea’s Reconnaissance General

Bureau (“RGB”), which functioned as the North Korean regime’s terrorist arm and was highly

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analogous to the Qods Force. By 1982, Khomeini, Khamenei, Rafiqdoost, Rezai, the IRGC, the

Foundation for the Oppressed, and Iran’s national oil monopoly, NIOC, among others, were all

involved in the booming bilateral trade between the Iranian regime (led by the Foundation for the

Oppressed, NIOC, and the IRGC) and the RGB in which the Iranians and North Koreans

maintained what was widely described as an “oil for weapons” partnership in which the Iranian

regime engaged in barter trade with the RGB: the Iranians had lots of gas, the North Koreans had

lots of weapons, and they could both meet the others’ needs without expending precious

currency on the purchase price. Accordingly, their barter relationship furnished a reliable,

efficient, means of converting Iranian oil into North Korean-supplied weapons, training, and

services to the Iranian regime’s terrorist proxies, with the IRGC acting as the intermediary.

90. As an IRGC Brigadier General, Khamenei notoriously sponsored horrific attacks

that were themselves a form of terrorism against children. Under his notorious strategy, the

IRGC deployed hundreds of thousands of children as human mine sweepers, in effect, dressing

them in white (for their funeral) and marching them across minefields to their likely death. As

was widely reported, tens of thousands Iranian children brutally died. As Khomeini said, “Our

leader is that 12-year old boy: who, with his small heart, which is greater than hundreds of our

tongues and pens, with grenade in hand, threw himself under enemy tank and destroyed it and

himself, and thus drank the nectar of martyrdom.” (SCB knew about this because, inter alia, the

Iranian regime plastered imagery of its child “martyrs” on Iran’s currency, the rial, while SCB

had a branch there.)

91. Throughout the Iran-Iraq war’s eight-year duration, Khamenei and Rafiqdoost

served as the IRGC’s two most prominent public faces, became infamous for their close

association with terrorism (including the use of children), and were the subjects of iconic

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photographs that were widely displayed throughout Iran, and known to SCB through its presence

there. For example, below (at left), Khamenei visited his IRGC brothers while serving as a

battlefield commander, (at right) Khamenei “blessing” an IRGC-drafted Iranian child “martyr”

who was about to be sent to his likely death:

92. Even while it fought Saddam Hussein’s army, the Iranian regime remained

singularly dedicated to exporting the Islamic Revolution through acts of terrorism targeting the

United States, including by targeting America’s closest ally in the Middle East: Israel.

93. In 1982, Khomeini dispatched a team of his most trusted IRGC terrorists to

Lebanon, which was led by Mohsen Rafiqdoost, supported by Khomeini’s personal

representatives, and funded by the Foundation for the Oppressed. Their mission: to organize a

loyal Lebanese Shiite terrorist proxy for the IRGC, so that the IRGC could sponsor attacks

targeting the United States (inclusive of its allies like Israel) throughout the Arab world while

having both an Arab face on the attack and plausible deniability for the Iranians. Khomeini, the

IRGC, and the Foundation succeeded; they birthed Hezbollah in 1982 as their loyal proxy.

B. Ayatollah Khamenei and the Supreme Leader’s Office (SLO)

94. Ayatollah Khamenei. From the outset of the Islamic Revolution in 1979 – and

always since – Ali Khamenei has been a notorious IRGC terrorist. After the IRGC was created,

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Ayatollah Khomeini installed Ali Khamenei to supervise the IRGC. Thereafter, Khamenei was

Khomeini’s personal representative to the IRGC and associated bodies. From 1979 onward,

Khamenei intensely cultivated his relationship with IRGC leaders. Khamenei also seized the

spotlight in high-profile events that tightly connected him to the IRGC, like when he – not the

Iran’s president – announced the start of the Iran-Iraq War.

95. Since 1989, Ayatollah Khamenei’s official title has been “Supreme Leader of the

Islamic Revolution,” which reflected his – and the SLO’s – transnational scope. As Iran scholar

Hooman Majd reported in 2008: “The Supreme Leader of the Islamic Revolution, not Republic,

is his official title, but in Iran he is known simply as Rahbar, or ‘Leader.’”

96. On October 3, 2024, for example, BBC reported that Ayatollah Khamenei’s

official title included the designation “Tehran Friday prayer leader.”

97. Ayatollah Khomeini was the IRGC’s founder and leader, but was never an IRGC

“member” who was himself responsible for IRGC-sponsored attacks. In contrast, Ayatollah

Khamenei was always a sworn brother of the IRGC, with the rank of Brigadier General, who led

IRGC forces during the Iran-Iraq war, before he became leader of the Islamic Revolution and

overall commander of the IRGC as the Supreme Leader. As a lifelong IRGC member and

supporter, Khamenei, among other things, previously served as Supervisor of the IRGC, as

Ayatollah Khomeini’s Representative in the High Security Council, and as an active IRGC

commander at the frontlines of the Iran-Iraq War. For example, as Iran Briefing reported on

September 22, 2014: “Khamenei himself is a former IRGC member. His son Mujtaba is the main

link between his office [i.e., the Supreme Leader’s Office] and the IRGC, as well as dozens of

Khamenei’s advisors and [SLO] office staff.”

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98. Unsurprisingly given his IRGC pedigree, Khamenei was widely known as a

staunch supporter of terrorism. On June 29, 2009, for example, Newsweek reported:

Since his early days immersed in scripture and poetry, [Khamenei] had loved to
identify with “the [O]ppressed,” and he built his base of support in those
institutions—the clergy, the military and the bureaucracy …. Since the war years
in the 1980s, he had also forged close relations with the intelligence apparatus,
perhaps convincing himself, as many a revolutionary has done, that the best way
to prevent oppression is to eliminate enemies. In an article published [in 2008] in
Foreign Affairs, Iranian dissident Akbar Ganji claimed that at Khamenei’s very
first meeting with cabinet leaders after taking his post as Supreme Leader in 1989,
he put forth a ‘theory of terror’ that would define his approach to security issues.
“The majority of the people in the state are silent,” he is supposed to have said.
But “a selfless group of individuals can make the state endure by using terror.”

99. Khamenei, like Khomeini, emphasized that “Resistance”—code for IRGC-

sponsored acts of terrorism targeting the United States—was the foundation of the IRGC’s

mission and associated ideology. At a widely covered June 4, 2007 event honoring Khomeini,

for example, Khamenei emphasized that, although “Resistance against bullying powers in order

to attain one’s rights has a price … You should not beg others for your rights. As long as you

retreat and show leniency, the hegemonic nature of the bullying powers will increase their

intimidation. Rights must be achieved through resistance.”

100. At all times, Khamenei was a prominent, and important, direct sponsor of acts of

terrorism in his capacity as leader of the Foundation for the Oppressed, Hezbollah, the IRGC,

and the SLO. To that end, Khamenei appointed representatives who served in key IRGC

divisions and the IRGC’s leadership.

101. Ayatollah Khamenei also had a close, decades-long, inner-circle, personal

relationship with Qassem Soleimani.

102. Ayatollah Khamenei was an infamous supporter of Hezbollah, who personally

met with – and financially supported – Hezbollah’s leadership, including very close, decades-

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long, direct-access relationship with Hassan Nasrallah. As Hezbollah Secretary General Hassan

Nasrallah publicly admitted on October 1, 2019 in an on-the-record interview with an IRGC

media outlet: the “Leader” – i.e., Khamenei – “focused on the issue of resistance and its

progress. He always insisted that resistance should progress, grow, and ultimately take back

occupied lands. Hence, he always diligently encouraged the Resistance to persist on the path it

had taken. … Even inside Hezbollah, there were some of our brothers who were inclined to get

involved with domestic politics. But the Leader always emphasized the need to give priority to

the mission of resistance and Jihadi tasks.”

103. Moreover, Khamenei – and the financial resources he commanded – played an

especially pivotal role sponsoring attacks by Hezbollah and, through Hezbollah.

104. Ayatollah Khamenei was bonded at the hip with Hassan Nasrallah, and went to

great lengths to continually signal that they were fighting America together as one. In 2019, for

example, the Defense Intelligence Agency reported a similar observation to Congress, as

reflected into SLO-funded mobilization rallies featuring imagery of Khamenei and Nasrallah:

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105. Khamenei was also key, and direct, sponsor of attacks committed by Hamas and

PIJ in Israel—and proud of it. On February 27, 2010, for example, Agence France Presse’s

reporting about Hamas noted that “Iranian supreme leader Ayatollah Ali Khamenei told

Palestinian militant chiefs that sustained resistance was the key to liberating their land.” On

August 4, 2014, similarly, IRGC-operated Fars News Agency reported: “A few days ago and

following first-time remarks by Supreme Leader of the Islamic Revolution Ayatollah Seyed Ali

Khamenei, a large number of Iranian Army and IRGC Commanders underlined the necessity for

all Islamic countries to supply weapons and military tools and equipment to the Palestinians to

help them defend themselves against the Israeli attacks.” As Jeffrey Goldberg of The Atlantic

observed on March 9, 2015:

[A]s a reminder to those who argue that Jews should stop worrying so much about
people who threaten to kill them, here is some (just some) of what [Ayatollah Ali
Khamenei] … ha[s] said about Israel: ...

 “It is the mission of the Islamic Republic of Iran to erase Israel from the map
of the region.” (2001) ...
106.
 “The Zionist regime is a cancerous tumor and it will be removed.” (2012) …

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107.
 “This barbaric, wolf like & infanticidal regime of Israel which spares no
crime has no cure but to be annihilated.” (2014) ....

108. The Supreme Leader’s Office. While Ayatollah Khomeini created the Supreme

Leader’s Office in 1979, prior to 1989, the SLO’s terrorism-facing portfolio was focused

primarily on helping Khamenei manage his relationship with Hezbollah and operating the Friday

Prayer Leader Organization, which Khomeini and Khamenei used on a weekly basis to raise

funds and source results to for the stated purpose of helping Hezbollah conduct attacks (after

they helped establish Hezbollah in 1982).

109. The Supreme Leader’s Office was a front for the Qods Force. Among other

reasons, Qods Force operatives worked under cover of SLO employment, Qods Force operatives

used SLO facilities for their operations, and the Qods Force was an indirect beneficiary of the

profits derived by the SLO through the Qods Force’s (including Qasem Soleimani’s) close

relationship with Ayatollah Khamenei.

110. The Supreme Leader’s Office was a front for Hezbollah. Among other reasons,

Hezbollah operatives worked under cover of SLO employment, Hezbollah operatives used SLO

facilities for their operations, and Hezbollah was an indirect beneficiary of the profits derived by

the SLO through the Hezbollah’s (including Hassan Nasrallah’s) close relationship with

Ayatollah Khamenei.

111. In or about 1989 and 1990, Ayatollah Khamenei revolutionized the SLO, turning

it into a behemoth far larger and more powerful than it was under Khomeini, but continuing the

prior roles concerning Hezbollah and the Friday Prayer Leader Organization. Khamenei did so to

optimize the Iranian regime’s financial and logistical support for Hezbollah-sponsored attacks,

including in Israel. Khamenei did so in direct response to concerns that the Iranian regime (most

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of all, the IRGC) was not spending most of its profits on its mission of exporting the revolution.

As such, Khamenei sought to dramatically tighten his personal group on each of the core Terror

Sponsors he controlled: the Foundation for the Oppressed, Hezbollah, the IRGC, and the SLO,

including its Friday Prayer Leader Organization.

112. Accordingly, Khamenei cross-pollinated all the foregoing Terrorist Sponsors

through his newly expanded SLO. For example, he had SLO operatives (who were

simultaneously members of the IRGC) serve as his representatives to Hezbollah, the Foundation

for the Oppressed, and the IRGC, among others. Under Khamanei’s control – exercised through

his IRGC terrorist son, Mojtaba Khamenei, the Ayatollah ordinarily operated the SLO to

maximize the amount of money spent on terrorism committed by Hezbollah, the Qods Force,

Hamas, and PIJ, reflecting Khamenei’s twin obsessions with maximizing his ties to Hezbollah

and the amount of violence he helped inflict on innocent Americans in the Middle East.

113. Ayatollah Khamenei, Mojtaba Khamenei, and the SLO associates did so by

embedding the Supreme Leader’s eyes and ears into every organization of consequence

(government and business alike) in Iran, including all components of the IRGC and Hezbollah

through the Supreme Leader’s “representatives.” The SLO also owned firms and foundations,

which it usually owned and/or operated jointly with the IRGC, Qods Force, and Hezbollah. The

IRGC, Qods Force, and Hezbollah, likewise, had embeds within the SLO. These factors, and

others, distinguished the SLO from nearly all other national-level Iranian groups.

114. At least three differences between the Ayatollahs explains their diametrically

different approached vis-à-vis the SLO. First, While Khomeini embraced terrorism as well, he

had a more fatalistic attitude about the possibility of being killed by his enemies, famously

saying it would not be a big deal because a brother of the IRGC would likely take the reins,

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Khamenei was a paranoid, battle-hardened, sworn brother of the IRGC who believed there were

plots everywhere and sought to apply terrorist tactics as a solution. Second, most of Khomeini’s

tenure was marked by Iran’s catastrophic war with Iraq. Khamenei, in contrast, did not preside

over any armed conflict but, instead, led an unprecedented expansion of the Foundation for the

Oppressed’s, SLO’s, and IRGC’s respective shares of the Iranian economy, which was driven by

Khamenei’s insatiable desire to spend even more money on proxy terrorism year after year.

Third, Khomeini and Khamenei occupied different political positions: the former was revered by

the IRGC from Day 1, while the latter had to buy their trust through sector-wide bribes,

operationalized through the Foundation for the Oppressed, NIOC, NITC, KAA, among others.

115. As a member of the IRGC who built its power to insulate his own, and actively

sponsored its terrorist attacks, Ayatollah Khamenei always emphasized the global nature of his

terrorism, and infamously led the “Axis of Resistance.”

116. Ayatollah Khamenei was an infamous sponsor of Hezbollah and JAM attacks

targeting the United States in Iraq and Afghanistan.

117. Ayatollah Khamenei was an infamous sponsor of Hezbollah, Hamas, and PIJ

attacks targeting the United States in Israel.

118. Ayatollah Khamenei was an infamous supporter of IRGC-sponsored hostage-

taking attacks targeting the United States.

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119. Ayatollah Khamenei was a famous micro-manager, especially with respect to

attacks targeting the United States.8 Among other reasons, Khamenei was obsessed with America

and viewed the U.S. government as the source of all the Iranian regime’s problems.9

120. From the 1990s through the 2015, reports regularly confirmed the Ayatollah’s

personal support of terrorism, including, but not limited to:

a. Blaise Misztal (Bipartisan Policy Center), July 9, 2013: “The Supreme Leader strongly
supports the IRGC and has elevated it to the most powerful entity in the political,
military, and intelligence arenas.”

b. Rep. Ed Royce (Chair, House Committee on Foreign Affairs), April 24, 2015: “Earlier
this month, the Administration and our negotiating partners announced the framework of
a final agreement that is to be hammered out by the end of June [to ease certain sanctions
as part of the JCPOA]. … So today, the ink isn't even dry on this month's announcement,
but we saw two weeks ago … the [chants] led by the supreme leader in Iran. Yes -- he
said, ‘Yes, death to America.’, and then later asserted that Iran would not allow
international inspectors access to Iran's military facilities. This [past] weekend [i.e., on
April 18-19, 2015], the deputy head of the Iranian Revolutionary Guard Corps reiterated,
‘They will not even be permitted to inspect the most normal military site in their -- in
their dreams.’”

c. U.S. Department of State, June 2015: “Although Hamas’s ties to Tehran have been
strained due to the Syrian civil war, in a November 25 speech, Supreme Leader
Khamenei highlighted Iran’s military support to ‘Palestinian brothers’ in Gaza and called
for the West Bank to be similarly armed. In December, Hamas Deputy Leader Moussa
Abu Marzouk announced bilateral relations with Iran and Hamas were ‘back on track.’”

8
See, e.g., Alex Vatanka, The Battle Of The Ayatollahs In Iran: The United States, Foreign
Policy, And Political Rivalry Since 1979, at 146 (I.B. Tauris 2021) (“Khamenei is a micro-
manager and no other issue has mattered to him as much as relations with the United States.”)
9
See, e.g., Alex Vatanka, The Battle Of The Ayatollahs In Iran: The United States, Foreign
Policy, And Political Rivalry Since 1979, at 97 (I.B. Tauris 2021) (“the United States was again
at the heart of Khamenei’s case for Iran’s problems whether at home or abroad. ['Fifteen years
ago the Imam said “America cannot do a damn thing.” Some disagreed and feared America. But
if we look at where we are today, we see that indeed America could not do a damn thing! Fifteen
years later, we have proof. What have they been able to do? So far they were unable to do a
damn thing![']”)

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121. The SLO has regularly, and publicly, touted its close relationship with Qods Force

terrorists, such as a poster depicting Qasem Soleimani as a “freedom fighter” leading protestors:

122. The SLO regularly touted its direct support for Hamas and PIJ sponsored terrorist

attacks in the Middle East. An SLO graphic billboard in Tehran in 2017 – depicting a digital

clock offering a real time “Countdown To Israel’s Destruction” on a main thoroughfare – was

typical of how the SLO loudly and proudly advertised its embrace of terrorism:

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123. The SLO publicly advertised its direct support of terrorist attacks targeting the

United States and its allies, including Israel. In 2019, for example, the SLO published a billboard

in Tehran – and on Ayatollah Khamenei’s official website – depicting a successful IRGC Navy

attack targeting U.S. and Israeli vessels, with the latter ablaze:

124. The SLO also regularly touted its role uniting Hezbollah, Hamas, and PIJ in a

joint cause targeting the United States and its allies, including Israel. In 2020, for example, at the

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SLO=organized and sponsored Qods Day – in which the SLO, IRGC, and Hezbollah coordinate

anti-American and anti-Israeli rallies, recruitment, and fundraising calls in a dedicated day of

action – the SLO’s official English-language poster directly invoked the Holocaust with the tag

line, “Palestine Will Be Free. The final solution: Resistance until referendum”:

125. The SLO also helped coordinate recruitment efforts for the IRGC and Hezbollah.

For example, the SLO sponsored advertisements on behalf of the IRGC that promoted

martyrdom and the deployment of child terrorists, such as the Tehran billboard below from 2008,

which stated, “Our mission is to raise a generation of committed basijis” – i.e., pious Muslim

warriors who have been mobilized to fight for the Ayatollah:

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126. The SLO’s representatives also routinely alerted SCB that they intended to our

their profits into terrorist attacks by Hezbollah, Hamsa, PIJ, and Hamas in the Palestinian

territories and Iraq. In 2012, for example, Ayatollah Khamenei’s personal representative to

IRGC leadership Ali Saeedi Shahroudi publicly stated, as reported by IRGC-controlled Fars

News Agency: “The enemy intends to drag us into its own café, but we have lots of strategic

differences of opinion with the United States, including [Lebanese] Hezbollah, Palestine, the

Shiite governance in Iraq, and the Bahrain issue, none of which can be resolved in the framework

of negotiations.”

127. To optimize its terrorist agenda, the SLO had agents embedded throughout the

IRGC. The SLO relied upon notorious IRGC terrorists like Mohammad Mokhber to personally

support terrorist operations sponsored by the IRGC and its proxies. Mokhber was a sanctioned

IRGC terrorist notorious for his involvement in violence.

128. Like the IRGC, the SLO depended upon the profits it generated from fronts it

controlled to finance the IRGC violence it sponsored. Indeed, the United States made the same

determination when it imposed counterterrorism sanctions against the SLO.

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129. The IRGC, Qods Force, and Hezbollah leveraged the SLO to provide a financial

slush fund for their terrorist activities by, for example, financing attack cells, martyr payments,

bounty payments, weapons purchases, and payments to the leadership of IRGC proxies,

including leadership of Hezbollah, Hamas, PIJ, and JAM.

130. From at least 2000 through present, the Qods Force and Hezbollah used the SLO

to finance terrorist attacks in Israel that were committed by Hezbollah, Hamas, and PIJ. From

2003 through present, the Qods Force and Hezbollah used the SLO to finance terrorist attacks in

Iraq committed by Hezbollah and JAM. Throughout, the SLO was always controlled by a

member of the IRGC for the benefit of the Qods Force and Hezbollah, and used by the IRGC,

Qods Force, and Hezbollah to route money to Hamas and PIJ (through Hezbollah) and JAM

(through Hezbollah) attack cells, to finance terrorist attacks in Israel and Iraq committed by such

groups. At all relevant times, the SLO provided key financial support to Hezbollah and the Qods

Force and, through Hezbollah, to IRGC proxies, including Hamas, PIJ, and JAM.

131. On March 24, 2012, the European Union sanctions that targeted the close

cooperation between the SLO and “members of the … IRGC” to facilitate the use of telecoms,

internet, and social media data to enable the SLO’s and IRGC’s ability to target regime enemies

for kidnapping, torture, and murder, and confirmed (last name first name), inter alia:

a. “MIRHEJAZI Ali ... Deputy Chief of the Supreme Leader's Office and Head of Security.
Part of the Supreme Leader's inner circle, responsible for planning the suppression of
protests which has been implemented since 2009.”

b. “SAEEDI Ali ... Representative of the Guide for the Pasdaran [IRGC] since 1995 after
spending his whole career within the institution of the military, and specifically in the
Pasdaran [IRGC] intelligence service. This official role makes him the key figure in the
transmission of orders emanating from the Office of the Guide [Supreme Leader's Office]
to the Pasdaran's [IRGC's] repression apparatus.”

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132. The SLO played a direct operational role in terrorist attacks and associated

decision making, including with respect to IRGC proxies. For example, according to an analysis

by Dr. Michael Knights as published in 2023 by the U.S. Army’s Combatting Terrorism Center,

the SLO played a direct leadership role with respect to the direction and support that the Iranian

regime provided to JAM Special Group Kataib Hezbollah. The SLO played a similar role with

respect to Hezbollah, Hamas, and PIJ.

133. Given the SLO’s status as a front for the Qods Force, Hezbollah, and those

organizations’ proxies, any funds, weapons (including weapons components), intelligence, cover

and concealment, and logistical support obtained by the SLO through its (or its controlled

companies’ and/or investments’) commercial transactions, resources, and profits with, or

generated by, the SLO inevitably flowed through the SLO to the Qods Force and Hezbollah and,

through them, to Hamas, PIJ, and JAM. Thus, the SLO underwrote the finance, weapons,

intelligence, and logistics of enabled IRGC-sponsored attacks in Israel (committed by Hezbollah

and/or Hamas and/or PIJ) and Iraq (committed by Hezbollah and JAM).

134. SCB always knew the above facts. Among other reasons, decades of reports and

statements published by the United States, Iranian regime, Iranian opposition, mainstream media,

terrorism scholars, and NGOs alerted SCB that its transactions with, and value flow-through to,

the SLO fueled IRGC-sponsored acts of terrorism, including attacks by Hezbollah, Hamas, PIJ,

and JAM. Such reports included, but were not limited to:

a. Ahmad Rezai, Son of IRGC Commander Mohsen Rezai (Reuters), July 5, 1998: “Ahmad
Rezaei, … son of former Revolutionary Guards commander Major-General Mohsen
Rezaei, told the [L.A.] Times he fled to the United States so he would be free to talk about
Iranian-sponsored terrorism …[, including how] the Iranian government gave extremist
groups, such as … Hizbollah, money to purchase weapons, and sometimes it simply sent
weaponry to the groups …[;] [and] the office of supreme leader Ayatollah Ali Khamenei
[i.e., the SLO] was responsible for ordering attacks.”

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b. New Yorker, October 2002: “Until [9/11], [Imad] Mugniyah was considered by American
officials to be the world’s most dangerous terrorist, and many terrorism experts still
believe this to be true. … Mugniyah’s operation—known as the external security
apparatus—is Hezbollah’s most lethal weapon. It is commonly believed that Mugniyah is
behind nearly every major act of terrorism that has been staged by Hezbollah during the
last two decades. … It is believed that Mugniyah takes orders from the office of Iran’s
supreme leader, Ayatollah Khamenei [i.e., the SLO], but that he reports to a man named
[Qasem] Soleimani, the chief of a branch of the [Qods Force]—the arm of the [IRGC]
responsible for sponsoring terror attacks on Israeli targets.”

c. BBC, April 29, 2003: “[SLO-funded Iraqi] radio[] coverage … featured protesters
chanting ‘No to colonialism, no to occupation’ and ‘Death to America, death to Israel.’
… In its commentaries, the radio has contrasted the US-led presence with the popularity
of Iraqi leaders who ‘merge with the people (and) do not have guards and protectors like
the tyrants,’ noting that the Iraqi people will oppose the ‘hirelings, liars, hypocrites and
traitors.’ … On 19 April, the [SLO-funded] radio warned that the Iraqi people would
teach the ‘usurper Americans’ a lesson; it stated two days later that ‘cooperation with the
invading forces is prohibited and rejected’. The new station frequently leads its news
summaries with positive items on Iran’s relationship with Iraq. The lead item in the 18
April bulletin reported a ‘cable of gratitude’ from Abd al-Aziz al-Hakim, chief of
SCIRI’s Jihadist Office, to Iran’s Supreme Leader Khamene’i for ‘his call to the Iranian
people to stand by the Iraqi people and extend assistance to them.’”

d. Islamic Republic News Agency, March 2004: “A memorial ceremony was held for the
martyred founder and spiritual leader of the Islamic Resistance Movement of Palestine
(Hamas) Shaykh Ahmad Yasin at Tehran Ark Mosque on Sunday. … Speaking at the
ceremony, the deputy head of the international department of the supreme leader’s
[Khamene’i’s] office, Hojjat ol-Eslam Mohammad Hasan Akhtari said that Shaykh
Yasin’s martyrdom would reinforce the Palestinians popular uprising (intifadah).”

e. Dr. Michael Rubin (Senior Lecturer, Naval Postgraduate School), July 23, 2009: “Iran’s
… terrorist sponsorship … [is] the purview of the Islamic Revolutionary Guard Corps
and the Office of the Supreme Leader.”

f. Mohammad Hassan Rahimian (SLO), 2010: “We have manufactured missiles that allow
us, when necessary to replace [sic] Israel in its entirety with a big holocaust.”

g. Investor’s Business Daily, September 23, 2010: “Tehran has trained Shiite Iraqi militants
to attack American combat forces [and] supplied Iraqi insurgents with advanced IED
technology …. The [] Revolutionary Guards have even partnered with Hezbollah
terrorists to kill U.S. soldiers, as in Karbala, Iraq, in 2007. … The examples of Iranian-
guided or financed attacks against the U.S. are legion. The late Lebanese-born Imad
Mughniyah, for instance, took orders ‘from the office of Iran’s supreme leader, Ayatollah
Khamenei,’ according to Jeffery Goldberg, writing in the New Yorker in 2002.”

h. DoD, October 12, 2011: “Even though the IRGC is constitutionally directed to coordinate
with Iran’s conventional military forces and is nominally subordinate to a joint

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headquarters that overseas [sic] the security services and Law Enforcement Forces (LEF),
the [IRGC] answers directly only to Ali al Khamenei, [Iran]’s Supreme Leader. This
direct access to the Supreme Leader and his consistent and considerable support for the
IRGC makes the [IRGC] peerless among military, intelligence, law enforcement,
intelligence, and security services in Iran. … The IRGC answers only to the Supreme
Leader rather than an elected official, a higher military command, or any other political
or clerical entity within the government of Iran. The IRGC supports and advocates for the
Supreme Leader and Khamenei responds in kind. During the height of the 1997 student
riots, twenty-four senior IRGC officers sent a letter to reformist president Mohammad
Khatami, issuing an ultimatum that he take action against the protestors, or the IRGC
would take matters into their own hands.”

i. IRGC General Mohsen Rezai, October 12, 2011: “Once someone had asked Imam
[Khomeini] as to why he lends so much support to the IRGC. The Imam had answered
‘why not?’ and the interlocutor had warned him that it may result in staging a coup [if the
IRGC became too strong]. The Imam had answered, ‘It doesn’t matter; it stays in the
family [if they stage a coup]; as they are our own guys.’”

j. Israel National News, December 30, 2011: “Hizbullah … is using American banks …
U.S. Attorney Preet Bhara noted, ‘It puts into stark relief the nexus … [to] terrorism.’ …
The money is allegedly laundered through a complex chain of accounts around the globe
using pseudonyms. Millions of dollars are periodically funneled from the accounts of
Hizbullah leaders or those of their wives, to those of senior members of the Iranian
Revolutionary Guards, the sources said. The money is then transferred back to Hizbullah
from the office of Supreme Leader Ayatollah Ali Khameini.”

k. Hojateleslam Alireza Panahian (SLO), 2013: “The day will come when the Islamic
people in the region will destroy Israel and save the world from this Zionist base.”

l. Islamic Republic of Iran Broadcasting, July 25, 2014: “[A] [r]eport on participation of
people in Quds Day rallies [in Iran] … shows demonstrators marching on the streets and
chanting ‘Death to Israel’ and ‘Death to America’. … Commenting on the International
Quds Day, Deputy Head for the Cultural and Publicity Affairs of Iranian Supreme
Leader’s office at the [IRGC] Mohammad Ali Asudi said that ‘the Zionist regime’ has
been crippled by Hamas as well as Palestinians’ resistance.”

m. National Council of Resistance of Iran, 2018: “The regime’s decision-making and

executive agencies for terrorist operations[:] All decisions on terrorist attacks abroad,
particularly those targeting Iranian dissidents, are made at the highest levels of the Iranian
regime. Such sensitive and sophisticated operations require high levels of intelligence,
coordination, logistics, and operational skills, as well as the political and diplomatic
cover terrorist operatives need. Here are key decision-making and executive agencies
involved for terrorist operations. [28] The Special Affairs Office of the Supreme Leader:
Following the death of the regime’s former Supreme Leader, Ruhollah Khomeini, Ali
Khamenei appointed mullah Ali-Asghar Mirhejazi, then-head of the foreign office of the
Foreign Ministry, to establish a special intelligence and security apparatus called the
“Special Affairs Office” to operate out of Khamenei’s office. The Special Affairs Office

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coordinates the regime’s intelligence, security and terrorist organs within Khamenei’s
office. All terrorist operations are conducted under the supervision of the Special Affairs
Office after Khamenei’s personal approval.”

n. Radio Farda (Voice of America), April 8, 2019: “[T]he IRGC … structure … [includes]
important offices in IRGC … that belong[] to the Supreme Leader’s representative to the
corps (a trusted cleric) and the counter-intelligence office which operates under direct
supervision by Khamenei’s office.”

o. Hossein Abedini (National Council of Resistance of Iran), August 23, 2019: “The Iranian
regime … [has] become more involved in continuing mass killings inside Iran as well as
their aggressive foreign policy in different countries. For example, … supporting …
Hezbollah … The IRGC has to be prescribed as a terrorist organisation … And also, the
supreme leader of the regime, and the office of the supreme leader of the regime, which is
the centre of all these terrorist activities. ... The IRGC is the main force carrying all these
terrorist attacks … in the region.”

p. Secretary of State Michael R. Pompeo, November 4, 2019: “Treasury … act[ed] …

against nine appointees and representatives of Ali Khamenei, the Iranian regime’s
unelected Supreme Leader, whose office is responsible for advancing Iran’s radical
agenda. The designation seeks to block funds from flowing to a shadow network of
Khamenei’s military and foreign affairs advisors who have for decades oppressed …
supported terrorism … around the world. The action specifically targets Ali Khamenei’s
appointees in the Office of the Supreme Leader … Two of the Supreme Leader’s
appointees, who are designated today, have also been linked to the 1983 U.S. Marine
barrack bombing in Beirut that killed 241 U.S. personnel and the 1994 bombing of
Argentine Israelite Mutual Association (AMIA). As recently as October 2019, a
representative of the Supreme Leader directly called on regional Iran-backed militias to
capture Western embassies.”

q. Voice of America, November 18, 2019: “Two days of intense fighting [in] Israel … once
again highlights Iran’s expansionist ambitions in the Middle East, experts say. … Iran has
managed to sponsor both [Hamas and PIJ] at the same time, ‘because both groups are
committed to Israel’s destruction — a goal cherished by … Ayatollah Khamenei and the
… IRGC,’ said Sam Bazzi, director of the Islamic Counterterrorism Institute in
Washington. ... ‘The arrangement in Gaza [for] Hamas and PIJ suits Tehran and fits into
the mold it had frequently applied in the region: Iran-friendly governments accountable in
front of the international community and secretive striking arms directly controlled by the
… Quds Force and the Supreme Leader’s Office,’ said Bazzi.”

r. BBC, May 21, 2020: “[A] poster by the Supreme Leader’s office drew comparisons with
Nazi Germany. The poster, published online on 19 May by Khamenei.ir, contains the
message: ‘Palestine will be free. The final solution: resistance until referendum.’ The
term ‘final solution’ was used by the Nazis to refer to the extermination of Europe’s
Jewish population, and the reference prompted condemnation from US … officials.”

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135. The SLO was never a normal Iranian state entity: it was fully captured by avowed

supporters and financiers of the Qods Force, Hezbollah, Hamas, PIJ, and JAM, and operated for

the benefit of their shared mission to sponsor terrorist attacks targeting the United States to

coerce U.S. government decisionmakers to exit the Middle East and abandon its allies there,

including Israel and Iraq.

136. As SCB well knew, Ayatollah Khomeini and Ayatollah Khamenei always

notoriously used their control of Friday Prayers in Iran to sponsor terrorist attacks committed by

their followers. SCB’s employees in Iran, like all other Iranians, were intimately familiar with

the content of Ayatollah Khomeini’s seminal guide, The Little Green Book. Given that, SCB had

actual knowledge that Friday Prayer Leaders in Iran had one mission: promote terrorism. As

Ayatollah Khomeini himself explained at pages 1-2 of The Little Green Book:

Our one and only remedy is to bring down these corrupt and corrupting systems of
government, and to overthrow the traitorous, repressive, and despotic gangs in
charge. This is the duty of Muslims in all Islamic countries; this is the way to
victory for all Islamic revolutions.
Muslims have no alternative, if they wish to correct the political balance of
society, and force those in power to conform to the laws and principles of Islam, to
an armed Jihad against profane governments. …
Jihad means the conquest of all non-Muslim territories. Such a war may
well be declared after the formation of an Islamic government worthy of that
name, at the direction of the Imam or under his orders. It will then be the duty of
every able-bodied adult male to volunteer for this war of conquest, the final aim of
which is to put Qur'anic law in power from one end of the earth to the other. But
the [2] whole world should understand that the universal supremacy of Islam is
considerably different from the hegemony of other conquerors. It is therefore
necessary for the Islamic government first to be created under the authority of the
Imam in order that he may undertake this conquest, which will be distinguishable
from all other wars of conquest, which are unjust and tyrannical and disregard the
moral and civilizing principles of Islam. …
There are some of us who aren't concerned with developing an Islamic
movement, but, instead, of making the pilgrimage to Mecca with the Muslim
brothers, in peace and understanding. It certainly wasn't that way in the time of the
Prophet. The Friday prayers were the means of mobilizing the people, of
inspiring them to battle. The man who goes to war straight from the mosque is

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afraid of only one thing - Allah. Dying, poverty, and homelessness mean nothing
to him; an army of men like that is a victorious army. (Emphasis Added.)
Islamic faith and justice demand that within the Muslim world, anti-
Islamic governments not be allowed to survive. The installation of lay public
power is equivalent to actively opposing the progress of Islamic order. Any
nonreligious power, whatever form or shape it may take, is necessarily an atheistic
power, the tool of Satan; it is part of our duty to stand in its path and to struggle
against its effects. Such Satanic power can engender nothing but corruption on
earth, the supreme evil which must be pitilessly fought and rooted out. To achieve
that end, we have no recourse other than to overthrow all governments that do not
rest on pure Islamic principles, and are thus traitorous, rotten, unjust, and
tyrannical administrative systems that server them. That is not only our duty in
Iran, but it is also the duty of all Muslims in the world, in all Muslim countries, to
carry the Islamic political revolution to its final victory.

137. In another message, Ayatollah Khomeini also emphasized the violent nature of his

approach to Friday Prayers: “The Friday prayers were an opportunity to bring people together

and call them to arms. The man who goes to war straight from the mosque fears only one thing:

the Almighty. Death, material needs and homelessness are insignificant to him. An army of such

men is an army of heroes.” (Emphasis added.)

138. Moreover, in his 1975 treatise, Velayat-e Faqeeh: Governance Of The Jurist,

Khomeini explained that the purpose of Friday Prayers – as he saw it – was to encourage

jihadists to fight on the battlefield:

The Friday sermon was more than a surah from the Qur’an and a prayer followed
by a few brief words. Entire armies used to be mobilized by Friday sermon and
proceed directly from the mosque to the battlefield—and a man who sets out
from the mosque to go into battle will fear only God, not poverty, hardship, or
his army will be victorious and triumphant. When you look at the Friday
sermons given in that age and the sermons of the Commander of the Faithful (‘a),
you see that their purpose was to set people in motion, to arouse them to fight and
sacrifice themselves for Islam, to resolve the sufferings of the people of this
world. If the Muslims before us had gathered every Friday and reminded
themselves of their common problems, and solved them or resolved to solve them,
we would not be in the position we find ourselves in today. Today we must start
organizing these assemblies in earnest and make use of them for the sake of
propagation and instruction. The ideological and political movement of Islam will
thus develop and advance toward its climax. (Emphasis added.)

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139. The Supreme Leader, SLO, and Hezbollah all had a long and notorious history of

leveraging their control over Friday Prayers to raise money, source recruits, and even launch

attacks. In 1979, for example, Khomeini-backed terrorists seized the U.S. Embassy after having

been encouraged to do by the Tehran Friday Prayer Leader at the time. Similarly, Hezbollah

famously used Friday Prayers as a main tool to grow their ranks and raise funds.

140. The U.S. government has also confirmed that the Ayatollah used his Friday

Prayer Leader Organization to incite attacks targeting American sin Iraq. In 2004, for example,

State reported to Congress: “Shortly after the fall of Saddam Hussein, individuals with ties to the

Revolutionary Guard may have attempted to infiltrate southern Iraq, and elements of the Iranian

Government have helped members of Ansar al-Islam transit and find safehaven in Iran. In a

Friday Prayers sermon in Tehran in May, Guardian Council member Ayatollah Ahmad Jannati

publicly encouraged Iraqis to follow the Palestinian model and participate in suicide operations

against Coalition forces.” As Dr. Ronen Bergman reported in 2011, “The moment the Iranians

reached the conclusion that the U.S. invasion of Iraq was inevitable, they began making

preparations of their own, in a number of spheres. … Supreme Leader Khamenei declared that

Iran would not allow ‘the American highway robbers and savages in civilized clothing to rule

our country again.’ Ayatollah Ahmad Janati, a close associate of Khamenei, whose many roles

include that of Tehran’s Friday prayer leader, attacked the American administration in a sermon

in February 2003, saying, ‘A number of naive people in Congress support the moves of their

administration, which is acting like Stalin and Hitler and Genghis…the people will soon take

care of them.’”

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C. The Foundation for the Oppressed (Bonyad Mostazafan)

141. From 1979 through at least 2019, the Foundation for the Oppressed was the

Iranian regime’s oldest, largest, and most purpose-built terrorist operations front. It was the first

terrorist operations front established by Ayatollah Khomeini and his newly created IRGC in

1979, and has been notorious ever since.

142. When Khamenei, Rafiqdoost, and Rezai created the Foundation for the Oppressed

in 1979, they did so by seizing the Pahlavi Foundation and immediately converting it into one of

the Qods Force’s primary transnational funding and logistics fronts: a custom-built foundation

specifically designed to provide funding, weapons, intelligence support, logistical aid, and a vast

transnational footprint of corporate fronts, shell companies, and real estate to the Qods Force and

Hezbollah.10 This was part of the IRGC’s early efforts to build the financial and logistical

networks needed to export the Islamic Revolution through IRGC-funded terrorist attacks

targeting the United States and its allies, including Israel. Such terrorists controlled the

Foundation for the Oppressed for the same primary purpose: to help the Qods Force, Hezbollah,

and such FTOs’ proxies acquire funds, weapons (including weapons components), intelligence,

10
For the avoidance of all doubt, the Qods Force and Hezbollah did not gradually take control of
the Foundation, nor was the Foundation originally a noble charity that these FTOs eventually
corrupted. Instead, the Foundation was designated as the specific-purpose-built foundation to
enable Qods Force and Hezbollah acts of terrorism targeting the United States. Accordingly,
from day one—and ever since—the Qods Force has structured the Foundation to operate as the
Qods Force’s and Hezbollah’s transnational terrorist operations slush fund. To that end, the
Foundation had a wide global footprint (which facilitated movement of goods and personnel
across borders), thousands of real estate holdings (which provided safe houses and logistics
sites), hundreds of corporate holdings (which offered cover and concealment for Qods Force and
Hezbollah operatives and transactions), and a presence in every strategic industry relevant to the
Qods Force’s and Hezbollah’s transnational jihadist mission to “export the Islamic Revolution”
by sponsoring acts of terrorism targeting the United States.

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cover, concealment, and logistical aid, so that such terrorists could commit terrorist attacks,

enabled by the global resources and charity-cover provided by the Foundation.

143. Most of all, the Foundation for the Oppressed served as—and was known for

serving as—the primary global external operations front that Ayatollah Khomeini, Ayatollah

Khamenei (who ran the Foundation in the 1980s while also managing the IRGC’s proxy terrorist

portfolio), the SLO, and the IRGC used to provide every relevant category of assistance

necessary for an Iranian proxy terrorist in Lebanon or Gaza to successfully attack and kill

Americans. As a result, the Foundation for the Oppressed was fundamentally different from most

other fronts controlled by Ayatollahs, SLO, and IRGC: while most such fronts were operated by

such Iranian Terrorist Sponsors for the benefit of (as indirect beneficiary) of Iranian proxies like

Hezbollah and Hamas, the Foundation was different—and known to be so.

144. In short, the Ayatollahs, SLO, IRGC—and Hezbollah—jointly managed the

Foundation for the Oppressed for Hezbollah’s direct benefit because the Ayatollahs’, SLO’s, and

IRGC’s Foundation-related custom and practice, and such Terrorist Sponsors’ Foundation-

related tactics, techniques, and procedures, ordinarily called for the Foundation to be operated for

the substantial, if not primary, benefit of the Ayatollah’s, SLO’s, and IRGC’s ability to promote

proxy terrorist groups that comprised the jihadists’ analogue to the French foreign legion: a

program to support foreign fighters from all over the world who, instead of serving their own

nation, choose to serve the Supreme Leader of the Islamic Revolution (i.e., Ayatollahs Khomeini

and Khamenei) and his designated revolution-propagation agents (i.e., the IRGC and SLO).

145. Ever since, the Terrorist Sponsors have embedded Hezbollah operatives

throughout the corporate superstructure of the Foundation for the Oppressed, disguised as agents

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and employees of the Foundation.11 From at least 1983 through at least 2019, the Ayatollahs’,

SLO’s, and IRGC’s Foundation-related custom and practice and Foundation-related tactics,

techniques, and procedures ordinarily called for the deployment of Hezbollah operations,

logistics, intelligence, and financial operatives inside of the Foundation as embedded, covert,

terrorists, whom the Terrorist Sponsors caused, as a matter of ordinary practice, to be

comprehensively embedded throughout the organizational structure of the Foundation, including

its affiliates. In so doing, Ayatollah’s, SLO’s, and IRGC’s custom and practice when dealing

with the Foundation was to embed Hezbollah operatives both vertically, i.e., Hezbollah

operatives were embedded throughout the Foundation’s seniority scale, and horizontally, i.e.,

Hezbollah operatives were spread throughout the Foundations geographic, industrial, and

corporate footprint.

146. From 1979 through at least 2019, the Foundation for the Oppressed was always

the most important global operations front in the world for the Qods Force. The Foundation was

always operated for the primary purpose of providing financial, logistical, cover, concealment,

intelligence, and safe haven/ratline support for the Iranian regime’s external terrorist operatives,

including, but not limited to, the IRGC-QF (inclusive of its predecessor, the Office of Liberation

Movements) and IRGC-IO (inclusive of its predecessor, the IRGC Intelligence Bureau), with the

IRGC-IO deployed under the Qods Force’s umbrella when outside Iran.

147. From 1982 through at least 2019, the Foundation for the Oppressed was also a

front for Hezbollah, and always serving as one of Hezbollah’s most important global operations

nodes throughout the world, including, but not limited to, in Lebanon, the Palestinian territories,

11
True, such Hezbollah embeds were, in fact, employed by the Foundation; but they were
engaged in sponsoring and conducting terrorist attacks, not licit commercial activities.

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Iraq, Syria and everywhere else the Foundation had an outpost. Once Hezbollah established itself

as the Iranian Terrorist Sponsors’ lead external terrorist proxy, Khamenei, Rafiqdoost, Rezai, and

others further embedded Hezbollah operatives, finances, logistics, and weapons supply in the

Foundation—on its org chart, in its warehouses, at its ports, on its ships, and in its bank accounts.

During Hezbollah’s first decade of existence, the Iranian Terrorist Sponsors used the

Foundation’s resources to, inter alia: (1) establish Hezbollah in 1982; (2) finance Hezbollah’s

rapid growth thereafter; (3) facilitate Hezbollah’s 1982 suicide bomb attack in Lebanon that

killed 241 Marines; (4) facilitate the Iranian regime’s oil-for-weapons, services, and tunnels

barter agreements throughout the decade from 1982 through 1992, in which the Foundation for

the Oppressed likely facilitated more than $1 billion (in 1980s dollars) worth of weapons,

services, and tunnel construction assistance from the RGB, for which the SLO, Foundation,

NIOC, and IRGC coordinate with RGB, on behalf of Hezbollah in Lebanon, to whom the RGB’s

weapons and services were directly provided as facilitated by the Iranians. All while sheltering

the entire terrorist enterprise through the triple cover provided by Hezbollah and Qods Force

operatives supervision of (as Khamenei’s representative or inner circle confidante), and

coordination with: (1) the SLO, which was completely opaque; (2) the Foundation for the

Oppressed, which was also completely opaque and was, pretextually, held out as a religious

foundation that sought to leverage economic investments to fight poverty economic

conglomerate that serves charitable ends; (3) and NIOC (which provided excellent cover and

concealment for such weapons shipments until the mid-2000s, when a series of high-profile,

highly embarrassing (for Hezbollah and the Qods Force), weapons seizures that revealed,

effectively, NIOC’s then-bumbling concealment tradecraft when it came to weapons.

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148. As explained infra, SCB helped the Foundation for the Oppressed generate at

least several billion dollars in likely profits between 2000 and at least 2019, including at least

several hundred of millions in profits—and likely far more—from 2007 through 2012.

149. As explained infra, SCB’s assistance also directly aided attacks by supplying the

money to fully fund—multiple times over—all five types of the Iranian Terrorist Sponsor’s

attack incentive and reward payments, which powered every category of terrorist attack

committed by Hezbollah, Hamas, PIJ, and JAM as necessary for each such groups to conduct

every attack targeting the United States in Israel, the Palestinian territories, and Iraq that

Hezbollah committed, planned, or authorized from 2010 through 2019 (as all were here), when

every Plaintiff was attacked.

150. Notably, the Foundation for the Oppressed publicly admitted its provision of three

of the five: martyr payments, disability payments, and orphan payments. For example, the

Foundation long stated that one of its main lines of effort was to finance payments to honor

Hezbollah, Hamas, PIJ, JAM, and IRGC martyrs and their families. Similarly, the Foundation

referenced the fact that it provided comprehensive support to Resistance fighters and their

families, or similar such concepts, where the language used, and context of the statements,

compelled the conclusion that the Foundation was describing, at least, Hezbollah, Hamas, PIJ,

and IRGC martyrs and disabled terrorists.

151. With respect to the last two—salary payments and bounty payments—the

Foundation for the Oppressed strained to avoid publicly addressing or admitting its long-standing

role in enabling such payments, but that was merely the Foundation’s ineffective attempt to

maintain cover and concealment. From the 1980s through 2024, government investigations,

NGOs, whistleblowers, and press reports regularly confirmed that the Foundation played a key

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role in the network of Iranian Terrorist Sponsors that coordinated their efforts to meet the

enormous financial burden that such attack incentive and reward payments imposed each year.

Given Hezbollah’s, Hamas’s, PIJ’s, and JAM’s custom and practice, terrorist TTP, and

programmatic emphasis on such payments consistent with their functionally identical IRGC and

Hezbollah training regime, it is highly likely that more than half of all the value of all financial

transfers from the Foundation to Hezbollah, Hamas, and PIJ from 2000 through at least 2019,

and JAM from 2003 through at least 2019.

152. The impact of Foundation money was amplified by the Foundation’s long-

standing coordinating role in facilitating NIOC-RGB oil-for-weapons, services, and tunnels

barter trades, which began in the early 1980s, endured ever since, and resulted in anywhere from

$100 million to several billion dollars per year in bartered oil-for-weapons, services, and tunnels

that the Terrorist Sponsors caused to flow through to were then supplied to Hezbollah, Hamas,

PIJ, and JAM to directly enable such groups’ attacks. This freed up precious U.S. dollars that the

Terrorist Sponsors could—and did, as a matter of each group’s custom and practice, and tactics,

techniques, and procedures—supply to Hezbollah, Hamas, PIJ, and JAM to finance each of their

five types of attack incentive and reward payments.

153. By the mid-1990s, Hezbollah, in turn, operated for the primary purpose of

providing financial, logistical, cover, concealment, intelligence, and safe haven/ratline support

for the Iranian regime’s external terrorist operatives, including, but not limited to, the IRGC-QF

(inclusive of its predecessor, the Office of Liberation Movements) and IRGC-IO (inclusive of its

predecessor, the IRGC Intelligence Bureau), with the IRGC-IO under the Qods Force’s umbrella

while outside Iran.

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154. The Foundation for the Oppressed was the cornerstone of the Iranian regime’s

sponsorship of attacks by Hezbollah from 1983 through at least 2019. To understand why, start

with history. In 1979, Ayatollah Khomeini, Ayatollah Khamenei, Mohsen Rafiqdoost, and

Mohsen Rezai established the Iranian regime’s very first dedicated external terrorist operations

front a month after seizing power, which they named the Foundation for the Oppressed of the

Earth and the Disabled—a direct reference to, and recognition of, the Foundation’s core terrorist

mission. In 1982, likewise, Khomeini, Khamenei, Rafiqdoost, and Rezai collaborated with the

Foundation for the Oppressed to stand up the Iranian Terrorist Sponsors’ first dedicated foreign

terrorist proxy—a Iranian-built, Shia Arabic terrorist group in Lebanon that was comprised of an

Iranian-selected assortment of then-existing radical Islamist Lebanese militias operating in

Lebanon. Once again, they loudly and proudly involved the same naming convention for another

first-of-its-kind terrorist creation: the Lebanese-terrorist-Frankenstein they created and dubbed

“the Organization for the Oppressed of the Earth”—which added an additional brand name

(Hezbollah) in 1985 while never abandoning its original name.

155. Although the Foundation’s inner workings were notoriously opaque, its opacity

only confirmed its terrorist operations purposes; it was the single blackest hole in the entire

Iranian regime, controlled exclusively by the Supreme Leader and his inner circle. U.S.

government reports confirm the point. As Treasury explained when it sanctioned the Foundation

for the Oppressed in 2020: “Bonyads [foundations] are opaque, quasi-official organizations

controlled by current and former government officials and clerics that report directly to the

Supreme Leader. . . . Bonyads receive benefits from the Iranian government, including tax

exemptions, but are not required to have their budgets publicly approved.” Similarly, as U.S.-

government-published Radio Farda reported on February 18, 2022, “The [Iranian regime’s]

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foundations [i.e., bonyads] are widely believed to be used to funnel revenue to groups that

support the regime, including mercenaries working closely with the IRGC’s Quds Force, … for

[] operations abroad.” Likewise, as scholars Engin Sune and Gazi Baki noted in 2019,

“commentators claim[ed] that bonyads assist[ed] in fueling international terrorism,” such as how

“Mohsen Rafiqdoost, who was the minister of the Revolutionary Guards in the 1980s and served

as the head of several bonyads, as a key player in sponsoring Hezbollah in Lebanon.” Indeed,

bonyads—as a category—were amongst the absolute most notorious of all the Iranian regime’s

terrorist fronts. As State publicly warned in a report to Congress on March 1, 2007:

Iran’s “bonyads,” or charitable religious foundations, … stifle entrepreneurs not

affiliated with them due to the bonyads’ favored status, which includes exemption
from taxes, the granting of favorable exchange rates, and lack of accounting
oversight by the Iranian government. … Bonyads have been involved in funding
terrorist organizations and serving as fronts for the procurement of nuclear
capacity and prohibited weapons and technology.
Iran … has not signed the UN International Convention for the
Suppression of the Financing of Terrorism.
The Government of Iran should construct and implement a viable anti-
money laundering and terrorist finance regime that adheres to international
standards. Iran should be more active in countering regional smuggling. Iran
should implement meaningful reforms in bonyads that promote transparency and
accountability. … Iran should not support terrorism or the funding of terrorism.
(Emphasis added.)

156. The Foundation for the Oppressed was the most notorious Iranian bonyad.

157. From 2000 through 2020, the IRGC and SLO directly routed the Foundation for

the Oppressed’s profits to Ayatollah Khamenei’s inner-circle allies—each of whom had a direct,

personal relationship with Khamenei, swore fealty to him, and was directly funded by the IRGC

and Khamenei—including, but not limited: (1) Qasem Soleimani; (2) Mohammad Ali Jafari;

(3) Parviz Fattah; (4) Hassan Nasrallah; (5) Hossein Taeb; (6) Abu Mahdi al-Muhandis;

(7) Mohsen Rafiqdoost; and (8) Mojtaba Khamenei.

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158. As Treasury confirmed in 2020, the Foundation was “an economic conglomerate

controlled by the Supreme Leader” and “presided over by former … IRGC” leaders, and

maintained “subsidiaries in key sectors such as … information technology.” Accordingly, as

Treasury found in 2020, the “Foundation” was “a source of power, wealth, and influence for the

Supreme Leader and his inner circle” that served as “a key patronage network for the Supreme

Leader … used by … Khamenei to enrich” the SLO and “reward” his “allies” in the IRGC.

159. From at least 1979 (in the case of the IRGC), 1982 (in the case of Hezbollah), and

1990 (in the case of the SLO), the Qods Force, Hezbollah, and the SLO have jointly used the

Foundation for the Oppressed to fund, logistically arm, source intelligence for, and provide cover

to, terrorist attacks—including attacks in Israel that were committed by Hezbollah, Hamas, and

PIJ, and funded and supplied by the Qods Force, and attacks in Iraq that were committed by

Hezbollah and JAM and funded and supplied by Hezbollah and the Qods Force. Throughout, the

Foundation was always controlled by the Qods Force and Hezbollah, under the supervision of

the SLO, and used by the Qods Force and Hezbollah to route money to Hamas and PIJ (through

Hezbollah) and JAM (through Hezbollah) attack cells, in order to finance terrorist attacks in

Israel and Iraq committed by such groups. At all relevant times, the Foundation provided key

financial support to Hezbollah and the Qods Force and, through Hezbollah, to IRGC proxies

including Hamas, PIJ, and JAM.

160. The Qods Force and Hezbollah always controlled the leadership of the

Foundation for the Oppressed. The Qods Force and Hezbollah accomplished this through, inter

alia, their appointment of notorious Hezbollah and/or Qods Force leaders to officially, or

unofficially, run the Foundation and its Board of Trustees, also known as its Board of Directors,

including, but not limited to, Mohsen Rafiqdoost, Mohammad Forouzandeh, and Parviz Fattah.

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The IRGC always had at least two senior members installed as leaders of the Foundation, in

effect: (1) Mohsen Rafiqdoost (as the senior most Board of Trustees member); and (2) whomever

was appointed as the then-current director, e.g., Parviz Fattah in 2020.

161. Because Khomeini, Rafiqdoost, and Rezai created the Foundation for the

Oppressed to serve as the Terrorist Sponors’ transnational corporate base, the SLO and IRGC

(including the Qods Force) always had veto rights—based upon Iranian “law” and practice—

over any Foundation-related issue if Ayatollah Khamenei did not disagree with them. This was

accomplished, among other means, through the Ayatollah’s practice of always appointing a

trusted member of the IRGC’s leadership network (and Ayatollah’s inner circle) to head the

Foundation for the Oppressed.

162. The Qods Force and Hezbollah notoriously embedded their operatives throughout

the Foundation for the Oppressed. Such IRGC embeds ensured the Qods Force’s and

Hezbollah’s ability to extract maximum financial, operational, intelligence, and logistical value

from the Foundation.

163. The Foundation for the Oppressed helped the IRGC and SLO operationalize their

shared control over key monopolies in Iran’s economy, including their monopolies over the

energy, communications, import/export, and financial sectors. In 2008 and 2009, for example,

State reported to Congress: “Iran’s ‘bonyads,’ or charitable religious foundations, were originally

established at the time of the Iranian revolution to help the poor. They have rapidly expanded

beyond their original mandate. Although still funded, in part, by Islamic charitable contributions,

today’s bonyads monopolize Iran’s import-export market as well as major industries including

petroleum, automobiles, hotels, and banks.”

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164. In 2006, Treasury counterterrorism personnel conducted a roadshow throughout

Europe and the Middle East where they warned banks, including on information and belief SCB,

about prominent IRGC, Hezbollah, and Qods Force fronts. During this period, the United States

warned European firms—memorialized in a cable, as published by WikiLeaks—that transacting

with the Foundation for the Oppressed was tantamount to transacting with an entity that was

“fully owned by the IRGC”:

Treasury Under Secretary for Terrorism … Stuart Levey … stressed that the U.S.
is trying to … persuade its allies to target [the IRGC’s] bad conduct through
targeted financial measures against supporters of destabilizing policies (such as
terrorism and weapons of mass destruction programs) … [Levey discussed] U.S.
thinking on combating Iran’s use of the international financial system to transfer
funds to terrorists … [A Turkish official] described the important role of
Bonyads, state-linked foundations. He said that the Revolutionary Guard’s share
of Bonyad-controlled business was increasing but that the Revolutionary Guard
did not control the entire economy. Stating increased USG concern about the
IRGC’s resurgence under Ahmadinejad’s authority, U/S Levey cautioned that the
IRGC’s growing role in the Iranian economy was not limited to the public sector,
but included the private sector as well. Levey recalled the IRGC’s interference
with [] major … deals [through the Foundation, including] …the IRGC’s
involvement in … [a] deal … [for] Irancell [controlled by the Foundation and
therefore] … fully owned by the IRGC … (Emphasis added.)

165. The Foundation for the Oppressed was a front for the Qods Force, Hezbollah, and

such FTOs’ proxies. Thus, funds, weapons (including weapons components), intelligence, cover

and concealment, and logistical support obtained by the Foundation through its (or its controlled

companies’ and/or investments’) commercial transactions, resources, and profits with, or

generated by, the Foundation inevitably flowed through the Foundation to reach the Qods Force

and Hezbollah and, through them, to Hamas, PIJ, and JAM, to provide the funding, weapons,

intelligence, and logistics that enabled IRGC-sponsored attacks in Israel (committed by

Hezbollah and/or Hamas and/or PIJ) and Iraq (committed by Hezbollah and JAM).

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166. SCB always knew the above facts about the Foundation for the Oppressed. On

June 22, 2006, for example, senior Treasury counterterrorism official Pat O’Brien testified

publicly that the “Iran [] actively sponsors terrorism and violence across the Middle East …

[through] [t]he Islamic Revolutionary Guard Corps (IRGC),” which was “directly involved in the

planning and support of terrorist acts by non-state actors and continue to sponsor and train a

variety of violent groups that act as surrogates on Iran’s behalf,” which “posed” a “very real

threat” to the United States “by Iran’s sponsorship of terrorism” and depended upon “the lines of

support that fuel terrorist activities” for which the IRGC’s “money flows” from “a large network

of state-owned banks and parastatal companies”—i.e., bonyads or foundations. (As SCB knew,

the Foundation for the Oppressed was always Iran’s largest and most notorious bonyad).

167. U.S. Government enforcement actions confirmed, and alerted SCB, that the

Foundation for the Oppressed on Earth was a direct front for Hezbollah and the Qods Force and,

through them, an indirect front for Hezbollah’s and the Qods Force’s proxies, including Hamas,

PIJ, and Jaysh al-Mahdi. On December 17, 2008, for example, the U.S. government reinforced

its messaging that the Foundation for the Oppressed on Earth was a terrorist front that served to

raise money and source weapons for Hezbollah and the Qods Force. On that date, the U.S.

Departments of Justice, Treasury, and State all announced enforcement actions and sanctions

against the Bonyad Mostazafan, and the U.S. Department of State’s Counterterrorism Office

issued a press release calling attention to U.S. sanctions against entities affiliated with Bonyad

Mostazafan. The heightened U.S. crackdown on the Foundation for the Oppressed on Earth

caused a new round of media coverage drawing attention to its status as a front for terrorists like

the Qods Force and Hezbollah. For example, the Washington Post reported the next day that:

A Fifth Avenue building … is secretly co-owned by an Iranian bank …, Iran’s

Bank Melli …[,] [which] was previously designated by the Treasury Department

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as a key financier of … the [IRGC] and the Quds Force, which has been linked
to terrorist groups. … “This scheme to use a front company … to funnel money
from the United States to Iran is yet another example of Iran’s duplicity,” said
Stuart Levey, the Treasury Department’s undersecretary for terrorism ….

168. On April 17, 2014, similarly, the U.S. Attorney for the Southern District of New

York announced the resolution of its investigation into Foundation holdings, and again called

attention to Ayatollah Khamenei’s use of Foundation assets to persecute IRGC enemies.

169. U.S. Government-funded reports confirmed that the Foundation for the Oppressed

served as a front for Hezbollah and the Qods Force, and alerted SCB to the same. In 2001, for

example, RAND published a U.S. government-funded study confirming that “actors” who

“play[ed] a role in formulating and implementing Iran’s security policy” “include[d] …

parastatal organizations, the bonyads, [which …] play[ed] a role in foreign policy” through

“bonyad leaders [who] ha[d] ties to the security institutions,” “[t]he archetypal example [of

which was] the former head of the Bonyad-e Mostazafan, Mohsen Rafiqdoust, who went from

being Khomeini’s driver to assuming a leading IRGC position before heading the Bonyad-e

Mostazafan.” On October 12, 2011, likewise, an analysis published by DOD warned:

The IRGC’s overt activity in the Iranian economy is only one of the Pasdaran’s
tools for implementing the economic instrument of power. The IRGC influences
or controls a vast network of bonyads, or foundations though which it exerts its
economic and social influence. These foundations account for 20% of Iran’s
Gross Domestic Product. In the regime’s post revolutionary consolidation, it
assumed control of the multiple foundations the Shah had established as informal
and extra-legal networks. While officially a non-governmental organization, the
Foundation for the Oppressed, Bonyad Mostazafan, is the nation’s largest and is
chaired by Mohammad Forouzandeh, a former IRGC officer. This massive
foundation has over 350 subordinate companies and is diversified throughout the
agricultural, transportation, tourism, and industrial sectors of the economy.

170. U.N. Security Council reports confirmed, and alerted SCB, that the Foundation

for the Oppressed was a front used to finance IRGC-sponsored operations. On June 4, 2012, for

example, the U.N. Security Council’s panel of experts relating to the IRGC reported:

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The Islamic Revolutionary Guards Corps is an overwhelmingly important actor

in the Iranian economy and has expanded into various sectors, mainly through its
civilian arms. Although experts find it difficult to determine the extent of its
influence on the economy, conservative estimates suggest that it exercises control
of between 25 and 40 per cent of the Iranian gross domestic product. … Some
Member States have informed the Panel that the Corps also controls informal
economic channels. In particular, some Iranian charitable organizations
(foundations) controlled by the Corps are believed to support the Corps’
economic activities, including provision of informal channels for business
transactions. Such foundations include the [IRGC] Cooperative Foundation
(Bonyad-e Taavon-e Sepah) and the Foundation of the Oppressed (Bonyad-e
Mostazafan), both of which include incumbent and/or former officers of the
Corps as board members. (Emphasis added.)

171. On June 1, 2015, similarly, the U.N.’s panel of IRGC experts reported: “It is well-

known that IRGC is a complex amalgam of military, political and economic forces and has large

financial resources that influence the Islamic Republic of Iran’s economy. Financial wings of

IRGC, IRGC Cooperative Foundation (Bonyad-e Taavon-e Sepah) and the Mostazafan

Foundation (Bonyad-e Mostazafan), are actively pursuing investments in a variety of sectors.”

172. The Foundation for the Oppressed’s public website confirmed that the Foundation

served as a front that sponsored jihadist violence. In 2018, the official website of the Foundation

alerted Defendants, inter alia, as follows:

a. The Foundation’s “Characteristics” were “based on the principles and strategic

objectives derived from the Resistance Economy” and “focus[ed] on empowering the
Oppressed.”

b. The Foundation’s “Slogan” emphasized “commit[ment] to … Jihadi [ideology] in social

and economic arena by relying on [Jihadi] ideals and its existential goals.”

c. The Foundation’s “Outlook” emphasized “the path of achieving the existential goals of
the Foundation for the Oppressed … and the implementation of Resistance Economy
policies and Statutes, the Foundation for the Oppressed [will follow a] Template in the
Landscape [i.e., wherever the Foundation does business] [that] is Institutional” and
emphasized, inter alia, “reducing material, social and cultural deprivations of the
Oppressed,” and “Jihadist … exploit[ation of] human and material capital for the
effectiveness and sustainable growth in scientific and cultural arenas.”

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d. The Foundation’s “Main Strategies” included, inter alia, “providing services to help the
empowerment of the Oppressed,” and “improving organizational skills and culture by
empowering,” “developing,” and “emphasizing … Jihadi spirit.”

173. The Foundation for the Oppressed’s published bylaws, which it published by no

later than 2018, confirmed that the Foundation served to support IRGC operations. Such

Foundation bylaws, included, but were not limited to, as follows:

a. Article 5 purported to govern the Foundation’s “Investment Projects” and provided, inter
alia: “At least 33% of the projected profit share in the budget of the Foundation Group
annually as 100% allocated in capital Social transitions are used to … provide services to
the Oppressed,” i.e., fund Hezbollah, the IRGC-QF, and their proxies.

b. Article 12 purported to govern the Foundation’s “Development of Organizational

Culture” and provided, inter alia: “To achieve the fundamental goals and ideals, methods
for improving organizational culture based on the values of work and Jihadi efforts
including the performance of the commitment, accountability, trustworthiness, order,
precision, speed, partnership, creativity, innovation, and flexibility, and after approval
[by] the head of the Foundation [then such methods] will be implemented.”

c. Article 13 purported to govern the Foundation’s “Development of Human Capital” and

provided, inter alia: “Selecting and applying competent, committed managers and
employees in accordance with organizational culture and Jihadi spirit in companies and
the main unit of the Foundation should be [ensured through] approval of the head of the
Foundation.”

d. Article 15 purported to govern the Foundation’s “Monitoring” of the Foundation-related

activities and provided, inter alia: “The responsibility for the implementation of the
program is the responsibility of the head of the Foundation and it is necessary to present
the program and budget based on an annual basis. The mid-term plan should report the
progress of the program to the [Foundation’s] Board of Trustees. In this regard, to
measure the strength, capacity and effort of the [Foundation’s progress under its Fifth
Medium-Term Program, the Foundation’s] Jihadi units should prepare the relevant
method and be executed after approval of the head of the Foundation.”

174. IRGC admissions also confirmed that the Foundation for the Oppressed’s support

enabled acts of terrorism by Hezbollah and the Qods Force and their proxies, including Hamas.

On November 3, 2012, for example, a “reporter” for IRGC-controlled media outlet Aftab

acknowledged that the Foundation supported IRGC proxies “[i]n countries like Syria and

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Palestine, where Iran’s interests are outside the country... that means the activities of the

Foundation [for the Oppressed] to help [IRGC proxies like] Bashar al-Assad’s government.”

175. The Foundation for the Oppressed was never a normal charity: it was fully

captured by the Qods Force and Hezbollah, led and staffed by outspoken, virulent supporters of

such organization’s terrorist attacks, and operated for the benefit of their shared mission to

sponsor attacks targeting the United States to coerce U.S. government decisionmakers in the

United States to exit the Middle East and abandon its allies there, including Israel and Iraq.

D. The Islamic Revolutionary Guard Corps (IRGC)

176. The IRGC, also known as the “Sepah,” “Pasdaran,” and “Guardians of the Islamic

Revolution,” has operated as a global terrorist organization since 1979.

177. Since 1979, the imagery and text of the IRGC’s flag and logo (below) always

boldly confirmed the IRGC’s primary mission to conduct terrorist attacks to export the Islamic

Revolution in service of the Supreme Leader of the Islamic Revolution, i.e., Ayatollah Ruhollah

Khomeini from 1979 through 1989, and Ayatollah Ali Khamenei from 1989 through present:

178. With respect to the imagery, the IRGC’s flag and logo depicted a clenched fist

grasping an AK-47—the iconic weapon of choice for anti-American groups, including every

Islamist terrorist group in the world, since the 1960s—against the backdrop of a globe. The

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IRGC’s unmistakable message communicated to everyone who saw its flag or logo—including

SCB from at least the 1990s through 2014, through SCB’s agents and employees in Iran, the

United Kingdom, the United States—was that the IRGC would use violence to ensure the

Islamic Revolution it served conquered the entire globe.

179. Ayatollah Khomeini, Ayatollah Khamenei, and the IRGC they commanded were

not subtle in their messaging. Their terrorist propaganda, often featured dramatic, violent,

messianic, anti-American imagery paired with explicit textual calls for terrorist attacks

(sometimes, but not always, using “resistance” or similar euphemisms). Accordingly, and as

SCB always knew, the textual references in the IRGC’s flag and logo were generally translated

and interpreted to mean, in sum and substance: (1) “Islamic Revolutionary Guard Corps”; (2)

“Allah loves those who kill them”—i.e., “unbelievers” who do not submit to the rule of the

Supreme Leader (most of all, Americans, Israelis, and their allies in the Muslim world)—“for the

sake of peace”; (3) “Praise be to Allah”; (4) “Allah will recognize believers as martyrs who die

in the line of jihad against unbelievers”; (5) “He [i.e., Allah] likes them”—i.e., followers of the

Supreme Leader who killed while fighting a jihad and thus became “martyrs”—“very much”;

and (6) “May Allah work against the unbelievers.”

180. The IRGC always targeted the United States for terrorist violence. Iran’s 1979

revolution was militantly anti-American, and Iran’s regime continued such approach ever since.

Since 1979, the IRGC regularly engaged in and supported acts of terrorism directed at the United

States, which targeted the U.S. government in Washington, D.C. by seeking to coerce it into

changing U.S. policy as sought by the IRGC, including by prompting the United States’s exit

from the Middle East and abandonment of its allies there, including Israel.

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181. The IRGC was specifically established to target the United States as its primary

enemy. The IRGC’s doctrinal and institutional targeting of the United States was a product of

Iran’s history with America, and the IRGC founders’ understanding that the United States posed

a direct threat to the viability of their nascent terrorist enterprise. In 2011, for example, the DoD

published a declassified analysis about the IRGC and its proxies that warned: “The terrorism

pillar of [IRGC Commander] Jafari’s strategy relies on intimidating potential adversaries and

their supporters through the threat of terrorist activities against non-military targets in their

territories … [through] an attack [committed by IRGC proxy] … [t]errorist organizations like …

Lebanese Hezballah [and] Khattab Hezballah in Iraq, … [which] act[ed] on behalf of Iran’s [i.e.,

the IRGC’s] interests.” As Qasem Soleimani publicly enthused in his posthumous

autobiography, “All of you loved Imam [i.e., Ayatollah Khomeini] and believed in his path.

[Ayatollah Khomeini’s] path was the path of fighting against the U.S. and supporting the Islamic

Republic and the Muslims, who are [O]ppressed by the Arrogant Powers [i.e., the United States

government and its allies, including Israel], under the flag of Wilayat-e-Faqih [i.e., Ayatollah

Khomeini’s system of rule of the jurisprudent].”

182. Ayatollah Khomeini established the IRGC to target the United States, in line with

his own view that the U.S. government posed the greatest threat to the IRGC’s transnational

terrorist agenda. Representative examples of Ayatollah Khomeini’s pronouncements to that

effect included, but were not limited to, as follows:

a. “Today, America is the number one enemy.”

b. “America is the archenemy of the Oppressed people of the world.”

c. “Let brotherly Arab nations and the Palestinian and Lebanese brothers know that all their
miseries are caused by America.”

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d. “Cold and warm weapons, that is, pens, words and machineguns should all be aimed at
the enemies of mankind, headed by America.”

e. “Confronting America is presently above all our problems. If today our forces become
divided, it benefits America. Right now, America is the enemy and all our equipment
should be aimed at this enemy.”

183. With respect to the IRGC, the preamble of Iran’s constitution—as translated and

interpreted by the Defense Intelligence Agency in a 2019 report to Congress—provided that the

IRGC was “An Ideological Army” and further provided:

In establishing and equipping the defense forces of the country, it shall be taken
into consideration that faith and ideology are the basis and criterion. Therefore,
the Army of the Islamic Republic of Iran and the Revolutionary Guards Corps
will be formed in conformity with the above objective, and will be responsible not
only for protecting and safeguarding the frontiers [of the Islamic Revolution] but
also for the ideological mission, that is, Jihad, for God’s sake and struggle for
promoting the rule of God’s law in the world (“And prepare against them
whatever you are able of power and of steeds of war by which you may terrify the
enemy of Allah and your enemy and others besides them whom you do not know
but whom Allah knows.” [Quran 8:60]).

184. Under Iran’s constitution, as interpreted by the Ayatollah and the IRGC, the

IRGC interprets its sole responsibility for protecting and exporting the Islamic Revolution as the

IRGC’s specific responsibility to sponsor terrorist attacks targeting the United States, which the

IRGC always understood to be the top threat to the Islamic Revolution. For the IRGC, exporting

the revolution meant one thing: IRGC-sponsored terrorist attacks, usually committed by IRGC

proxies, targeting the United States in the Middle East. As an analysis of the IRGC published by

DOD in 2011 confirmed: “The Pasdaran [IRGC] derives its legal authority from Article 150 of

the Islamic Republic of Iran’s constitution. In accordance with Ayatollah Khomeini’s intent,

Iran’s Revolutionary Council tasked the IRGC in [] broad categories [that included, inter alia]:

[1] Apprehending or liquidating counter-revolutionary elements[;] [2] Battling armed

counterrevolutionaries[;] [3] Defending against attacks and the activities of foreign forces inside

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Iran[;] … [4] Training subordinate IRGC personnel in moral, ideological, and politico-military

matters[;] [5] Assisting the Islamic Republic in the implementation of the Islamic Revolution[;]

[6] Supporting liberation movements and their call for justice of the oppressed people of the

world under the tutelage of the leader of the Revolution of the Islamic Republic[;] [and] [7]

Utilizing the human resources and expertise of the IRGC to deal with national calamities and

unexpected catastrophes and supporting the developmental plans of the Islamic Republic to

completely maximize the IRGC’s resources.”

185. The IRGC openly touted its desire to attack America in the most confrontational,

ways possible—all of which were known to SCB given its on-the-ground presence in Iran

through 2012. On November 2, 2009, for example, the IRGC publicly stated, as published by

IRGC-controlled Fars News Agency, as follows: “The honorable nation of the Islamic Iran

considers the U.S.—the Great Satan—as the main contributor to problems in the Muslim world

and source of plots and conspiracies against the Islamic Republic and the Islamic Revolution.”

186. The IRGC also festooned its key buildings with anti-American imagery for any

pedestrians walking by, including SCB’s employees in Tehran through 2012, to see. The Qods

Force, for example, located its headquarters on the former site of the U.S. Embassy in Tehran.

For decades, the IRGC plastered the walls around the Qods Force’s headquarters with anti-

American messages, like the one below (English and Farsi), “WE WILL MAKE AMERICA

FACE A SEVERE DEFEAT”:

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187. The IRGC’s targeting of the U.S. government in the United States through IRGC-

sponsored acts of terrorism against U.S.-linked targets throughout the world continued at all

relevant times. As State reported in 2023, for example, “[t]hroughout 2022, … the IRGC-QF …

provided funding, training, weapons, and equipment to several U.S.-designated terrorist groups

in the region [and] Iran-backed militias continued sporadic attacks on bases hosting U.S. …

forces in Iraq … [while the IRGC] … plotted attacks against dissidents and other perceived

enemies of the regime based abroad.”

188. The IRGC was an integrated terrorist organization. The IRGC had several

divisions, led by an overall command under Mohammad Ali Jafari and his co-equal leadership

partner, IRGC-QF leader Qasem Soleimani. Both reported directly to Ayatollah Khamenei,

shared similar stakes in the same front companies, and relied upon the front companies alleged

herein to finance IRGC terrorist operations.

189. From 2009 through April 2019, Mohammad Ali Jafari served IRGC Commander-

in-Chief. In April 2019, Ayatollah Khamenei appointed Hossein Salami to succeed Jafari as

IRGC Commander-in-Chief, and has served in such role ever since. While in such roles, Jafari

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and Salami were the equal to the Commander of the Qods Force and reported directly to

Ayatollah Khamenei.

190. From 2007 through 2017, the components of the IRGC led by Jafari comprised

one of the IRGC’s primary Iran-based terrorist operations arms. While these regular IRGC units

occasionally acted abroad—always by seconding personnel and resources to the Qods Force or

Hezbollah so that they acted under the Qods Force’s or Hezbollah’s banner—they usually

operated principally inside Iran, supporting IRGC acts of terrorism targeting the United States

outside Iran and U.S. citizens within Iran.

191. From 2011 through 2024, the IRGC had eight branches, all of which were

ultimately accountable to Ayatollah Khamenei, and all of which but the Qods Force also reported

to IRGC Commander-in-Chief Mohammad Ali Jafari (from 2011 through 2019) and Hossein

Salami (from 2019 through present) and their respective deputies (Salami as Jafari’s deputy from

2011 through 2019), and Ali Fadavi as Salami’s deputy from 2019 through present:

a. The IRGC Qods Force was always the IRGC’s primary external operations arm and had
lead responsibility for the IRGC’s terrorist attacks outside Iran. Qassem Soleimani led the
IRGC-QF from 2011 through his death on January 2, 2020, after which Ayatollah
Khamenei handed leadership to Esmail Ghaani, who led the IRGC-QF from 2020
through present. From 1979 through the present, the IRGC’s Qods Force comprised the
IRGC’s primary Iran-based external terrorist operations arm. While the Qods Force often
operated inside Iran, it usually focused on external terrorist attacks even while operating
inside Iran. (Although the Qods Force was technically not created until the late 1980s, its
predecessor organization, the IRGC Office of Liberation Movements, served a
substantially similar role. IRGC-QF and IRGC members and Iran scholars alike often
conflate the two.)

b. The IRGC Intelligence Organization was always the Iranian regime’s largest, most
powerful, and most lethal intelligence arm and played a key role alongside the Qods
Force (for whom it embedded in operations outside of Iran) in IRGC attacks outside Iran,
and had lead responsibility for attacks committed, in part, inside Iran, e.g., hostage taking
of dual nationals. Hossein Taeb led the IRGC-IO from 2009 through June 23, 2022, when
he was transferred to serve as a senior advisor to the SLO and was replaced by
Mohammad Kazemi, who has always led it since.

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c. The IRGC Basij, meaning “mobilization” was the IRGC’s chief recruitment,
propaganda, morality police, and mass mobilization arm, and was commanded by
Gholamreza Soleimani.

d. The IRGC Aerospace Force (or “IRGC-ASF”) was the IRGC’s arm jointly responsible
(alongside the IRGC-QF and IRGC-IO) for executing IRGC-supported missile and
unmanned aerial vehicle attacks, as well as other air attack functions. The IRGC-AF
included the IRGC-Aerospace Force Al-Ghadir Missile Command (or “IRGC-ASF-
AGMC”), which shared responsibility for missile attacks alongside the IRGC-QF and
IRGC-IO. From 2009 through present, Amir Ali Hajizadeh commanded the IRGC-ASF,
Mahmud Bagheri commanded the IRGC-ASF-AGMC, and Mohammad Agha Ja’fari
served as a senior IRGC-ASF-AGMC who helped lead it alongside Bagheri—who were
tasked with optimizing every facet of the IRGC’s development of, logistics for, and
transfer of, IRGC missiles to IRGC branches and IRGC proxies, including Hezbollah and
Hamas.

e. The IRGC Ground Resistance Force was the IRGC’s border and internal armored
organization, and was commanded by Mohammad Pakpour.

f. The IRGC Navy was the IRGC’s naval organization that smuggled terrorists, weapons,
and funds, and harassed of U.S. military vessels, in the Persian Gulf, and was
commanded by Alireza Tangsiri.

g. The IRGC Counterintelligence Organization was the IRGC’s counterintelligence arm

tasked with preventing the U.S. intelligence community, including but not limited to the
CIA and DIA, from acquiring actionable intelligence that could prevent IRGC-sponsored
attacks targeting the United States, and was commanded by Mohammad Kazemi.

h. The IRGC Intelligence Protection Organization (or “IRGC-IPO”), which was

sometimes also called the IRGC Security Force, was the IRGC’s arm responsible for
securing key locations of interest for the IRGC, e.g., airports secured by the IRGC-IPO so
that operatives from the IRGC-IO can maximize the ability of the IRGC to use an airport
as a location to conduct hostage-taking attacks and gather intelligence in support of the
same, and was led by Fathollah Jomeiri.

192. The IRGC did not comprise Iran’s regular armed forces. In 2024, for example, a

FinCEN Advisory described the IRGC as “a parallel organization to Iran’s regular armed forces”

responsible for the Iranian regime’s “Support of Terrorism” through the IRGC’s “numerous

terrorist partners and proxies.”

193. Because the IRGC’s only obligation was to protect the Islamic Revolution, the

IRGC was structured to operate as a transnational terrorist organization to support the Islamic

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Revolution both while the IRGC and its allies controlled the Government and, importantly, if the

Ayatollah and IRGC ever lost control of Iran’s government, to operate as a global terrorist group

armed with the IRGC’s pre-existing transnational infrastructure purpose-built to ensure the

IRGC could mount a terrorist campaign to retake Iran.

194. Ayatollah Khomeini’s instructions to the IRGC confirm Plaintiffs’ allegations.

For example, Ayatollah Khomeini was an open critic of the nation-state, and squarely rejected

the very concept of “nation” as understood in the West, which Khomeini decreed to be “against

the path of Islam and the Qur’an.” Accordingly, Ayatollah Khomeini famously explained, “Our

movement is Islamic before being Iranian.”

195. The IRGC always expressly disclaimed the notion that it was a part of the armed

forces for the nation of Iran. For example, as Qasem Soleimani stated in his autobiography

published in 2023, “I wish to address a brief word in my dear, self-sacrificing brothers in the

Islamic Revolutionary Guard Corps … Naturally, I do not mention Wilayat [i.e., the Supreme

Leader and the IRGC], because Wilayat is not a part or a component of the Armed Forces.”

196. Since 2007, the IRGC was always a U.S.-designated terrorist organization. On

October 25, 2007, the United States designated the Qods Force under Executive Order 13224 for

its support of terrorism, including its sponsorship of acts of international terrorism. In so doing,

the U.S. government confirmed that the Qods Force was “seeking to inflict casualties on U.S. …

forces” and, inter alia, “had a long history of supporting Hizballah’s military, paramilitary, and

terrorist activities, providing it with guidance, funding, weapons, intelligence, and logistical

support” and continued to do so, provided “support to the Taliban to support anti-U.S. … activity

in Afghanistan,” and also provided ongoing key support to “Iraqi Shi’a militants who target and

kill Coalition and Iraqi forces”—all of which efforts relied upon joint Qods Force-Hezbollah

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training cells at which the “Qods Force operate[d] training camps for Hizballah in Lebanon’s

Bekaa Valley and has reportedly trained more than 3,000 Hizballah fighters at IRGC training

facilities in Iran.” That same day the United States also designated every component of the IRGC

for sanctions under Executive Order 13382 for its proliferation-related activities.

197. After 2007, the United States regularly imposed additional sanctions targeting the

IRGC as part of the U.S. government’s broader strategy to impose targeted sanctions against

Iran-related actors to reduce the Iranian regime’s ability to sponsor terrorist attacks targeting the

United States.

198. On October 13, 2017, the United States designated every other component of the

IRGC—including the IRGC Basij and IRGC-IO—as a Specially Designated Global Terrorist

(like the IRGC-QF, an SDGT since 2007) “for providing support to a number of terrorist groups,

including Hizballah and Hamas, as well as to the Taliban” and for “provid[ing] material support

to the IRGC-QF, including by providing training, personnel, and military equipment.”

199. On April 15, 2019, the United States designated every component of the IRGC—

including the IRGC-QF, IRGC Basij, and IRGC-IO—as an FTO. That designation, per State,

was in direct response to, inter alia, the Iranian regime’s historic and “continue[d]” use of the

IRGC to “provide financial and other material support, training, technology transfer, advanced

conventional weapons, guidance, or direction to a broad range of terrorist organizations,

including Hizballah, Palestinian terrorist groups like Hamas and Palestinian Islamic Jihad, [and]

Kata’ib Hizballah in Iraq,” and because “[t]he Iranian regime is responsible for the deaths of at

least 603 American service members in Iraq since 2003”—which “accounts for 17% of all deaths

of U.S. personnel in Iraq from 2003 to 2011.”

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E. Hezbollah

200. In 1982, the IRGC founded Hezbollah (Arabic for “Party of God”). Ever since,

Hezbollah has served as the IRGC’s most important terrorist proxy.

201. From 1982 through 1989, Hezbollah members swore their loyalty to Ayatollah

Khomeini. Ever since, Hezbollah members have sworn their loyalty to Ayatollah Khamenei.

202. From 1982 through 1985, Hezbollah did not call itself Hezbollah. Instead, it

called itself the name the IRGC gave it: “The Organization of the Oppressed on Earth.”

203. In 1985, Hezbollah published what it entitled an “Open Letter Addressed by

Hezbollah to the Oppressed in Lebanon and the World,” which is commonly referred to as

Hezbollah’s Manifesto. In it, Hezbollah announced, among other things:

a. “We, the sons of Hezbollah’s nation, whose vanguard God has given victory in Iran and
which has established the nucleus of the world’s central Islamic state, abide by the orders
of a single, wise, and just command represented by the guardianship of the jurisprudent
(vali-e faqih), currently embodied in the supreme Ayatollah … Khomeini. …”

b. “No one can imagine the importance of our military potential as our military apparatus is
not separate from our overall social fabric.”

c. “[The] first root of vice is America. … Imam Khomeini, our leader, has repeatedly
stressed that America is the cause of all our catastrophes and the source of all malice.”

After this, the group primarily called itself Hezbollah, although it continued to refer to itself as

the Organization for the Oppressed as well as the Islamic Resistance, among other euphemisms.

204. In 2011, Hezbollah General Secretary Hassan Nasrallah publicly stated: “We

must not confuse the enemy with the friend. The enemy is the U.S. administration, and Zionist

regime is its tool in the Middle East. … [T]he regional resistance movements [including

Hezbollah] and deterrent states such [as] Iran … stopped the U.S. government plan for creating a

new Middle East.”

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205. Hezbollah, like its IRGC patrons, viewed attacks targeting Israel and Israeli

civilians as inextricably connected to its efforts to target the United States to withdraw from the

Middle East. Among other reasons, Hezbollah believed that the United States controlled Israel,

that the United States could be punished, in effect, through attacks against its ally, and that—as

Khomeini and Khamenei both emphasized—Israel comprised the “Little Satan” to the America’s

“Great Satan.”

206. Hezbollah General Secretary Nasrallah has publicly admitted, “Hezbollah’s

budget, its income, its expenses, everything it eats and drinks, its weapons and rockets, come

from the Islamic Republic of Iran.” As the U.N. Security Council’s panel of experts reported on

December 30, 2016: “In a televised speech broadcast by Al-Manar television on 24 June 2016,

the Secretary-General of Hizbullah [Hassan Nasrallah] stated that the budget of Hizbullah, its

salaries, expenses, weapons and missiles all came from the Islamic Republic of Iran. … [T]hat

statement … suggests that transfers of arms and related materiel from the Islamic Republic of

Iran to Hizbullah may have been undertaken contrary to the provisions of annex B to resolution

2231 (2015).”

207. Senior U.S. officials confirmed that the Iranian regime, including the IRGC, were

vital to financing Hezbollah’s attacks. On September 29, 2006, for example, Frank C. Urbancic,

Principal Deputy Coordinator at State, testified before Congress as follows:

Iran is the ‘central banker’ of terrorism and a primary funding source for
Hizballah. Because money is a terrorist group’s oxygen, attacking terrorist
financing is an essential element to combating terrorism. In that regard, we have
made progress in impeding Iran’s financial support for Hizballah and in
undermining Hizballah’s own financial network. …
The USG has long assessed that Iran provides technological, operational,
and financial support and guidance to Lebanese Hizballah. The Iranian regime has
for 27 years used its connections and influence with terrorist groups to combat
U.S. interests it perceives as at odds with its own, and Hizballah has acted as a
willing partner.

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208. On May 27, 2009, Treasury imposed sanctions targeting Hezbollah and confirmed

the Iranian regime’s, including the IRGC’s, continued key role in financing Hezbollah attacks:

Treasury [] designated … supporters of … Hizballah …, under E.O. 13224.

E.O. 13224 targets terrorists and those providing support to terrorists or acts of
terrorism by … prohibiting U.S. persons from engaging in any transactions with
them. “We will continue to take steps to protect the financial system from the
threat posed by Hizballah and those who support it,” said Under Secretary for
Terrorism … Stuart Levey. … Iran … provide[s] significant support to Hizballah,
giving money, weapons and training to the terrorist organization. In turn,
Hizballah is closely allied with and has an allegiance to [Iran]. Iran is Hizballah’s
main source of weapons and uses its Islamic Revolutionary Guard Corps to train
Hizballah operatives in Lebanon and Iran. Iran provides hundreds of millions of
dollars per year to Hizballah.

209. The IRGC and the SLO provided most of Hezbollah’s budget, and directly

financed Hezbollah attacks through a range of vehicles, including salary and bonus payment to

Hezbollah leaders and attack cells, bounties for successful attacks, and martyr payments to the

families of dead Hezbollah terrorists. The Iranian regime funded acts of terrorism committed by

Hezbollah through an array of channels, including the SLO, IRGC (including Qods Force),

Foundation for the Oppressed (controlled by the IRGC and the SLO), the National Iranian Oil

Company (“NIOC”), the National Iranian Tanker Company (“NITC”), and Khatam al-Anbiya

(“KAA”), including KAA’s fronts. From 2007 through 2020, the Iranian regime did so by

collectively routing at least $200-$300 million per year—and sometimes much more than that—

to Hezbollah, most of which flowed through the above organs.

210. Hezbollah’s various subunits were closely interconnected, worked in tandem,

shared common sources of financing, and were run by the same people. There was never any

meaningful firewall between the intertwined components of Hezbollah. As Hezbollah spokesman

Ibrahim Mussawi publicly stated in 2013: “Hezbollah is a single large organization, we have no

wings that are separate from one another.”

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211. Hezbollah ordinarily acted as the IRGC’s interlocutor with its terrorist proxies,

including Hamas and PIJ in Israel and JAM in Iraq. Hezbollah provided expert training, technical

assistance, and in-country support, often through joint cells co-located with Hamas and PIJ (in

Gaza, Lebanon, and Syria, among other places) and with JAM (in Baghdad and Basra, among

other places).

212. Hezbollah pioneered several signature attacks, including kidnapping, roadside

bomb attacks using sophisticated devices known as explosively formed penetrators, and rocket

attacks using 107mm rockets. The IRGC relied upon Hezbollah’s experience and technical

expertise to train other proxies, including Hamas, PIJ, and JAM, with respect to how to

effectively conduct such attacks.

213. Hezbollah also jointly committed some attacks alongside other Axis of Resistance

members. For example, a joint Hezbollah-JAM cell committed attacks in Iraq in 2011.

214. Hezbollah played a vital planning role for IRGC proxies, including Hamas and

JAM. Hezbollah had vast experience that the other groups lacked, and it drew on such

experience to help such groups devise specific attack types, locations, and tactics. For example,

Hezbollah taught Hamas, PIJ, and JAM how to effectively kidnap targets.

215. Hezbollah has been an FTO since 1997.

II. The Iranian Regime’s Terrorist Sponsors Led A Global Terrorist Alliance Called
The “Axis Of Resistance,” Each Member Of Which Committed Terrorist Attacks
Targeting The United States

216. Since 1979, the IRGC has led an alliance of anti-American terrorist organizations,

united by their shared mission of conducting terrorist attacks targeting the United States—

directly, by targeting Americans, or indirectly, by targeting United States allies—to coerce U.S.

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government decisionmakers in Washington, D.C. and elsewhere to choose to withdraw from the

Middle East. Since 1990, that effort has been directly assisted by the SLO.

217. The IRGC’s and SLO’s global terrorist alliance functioned as a jihadist analogue

to NATO and similar western alliances. It included, among others: (1) Lebanese terrorist group

Hezbollah, a global terrorist organization that has been an FTO since 1997, which was founded

by the IRGC in 1982 and has been its most reliable and notorious proxy ever since;

(2) Palestinian terrorist groups Harakat al-Muqawama al-Islamiya (“Hamas”) and Palestinian

Islamic Jihad (“PIJ”), global terrorist organizations that have been FTOs since 1997; (3) Iraqi

terrorist group Jaysh al-Mahdi (or “JAM”), which was founded by Hezbollah, publicly identified

as Hezbollah’s “striking arm in Iraq,” operated in Baghdad through a joint Hezbollah-JAM cell,

and led by Muqtada al-Sadr, including notorious JAM cells known as Jaysh al-Mahdi Special

Groups (sometimes abbreviated “JAM-SG”), the most infamous of which were Jaysh al-Mahdi

Special Group Kataib Hezbollah (or “KH”), and Jaysh al-Mahdi Special Group Asa’ib Ahl al-

Haq (or “AAH”), FTOs since 2009 and 2020, respectively; and (4) the Reconnaissance General

Bureau of the Democratic People’s Republic of Korea.

218. Since 2003, this terrorist alliance has proudly called itself the “Axis of

Resistance.” According to the Defense Intelligence Agency (“DIA”):

Throughout its 40-year history, the Islamic Republic of Iran has remained
implacably opposed to the United States [and] our presence in the Middle East …
Tehran has committed itself to becoming the dominant power in the turbulent and
strategic Middle East. … It leads a cohesive if informal bloc of Shia and Alawi
state and nonstate actors—its ‘Axis of Resistance’ against the West.

219. Ayatollah Khamenei was a direct—and key—financial sponsor of each Axis of

Resistance member. As he publicly stated in 2015, “we will never stop supporting our friends in

the region and the people of Palestine, Yemen, Syria, Iraq, Bahrain, and Lebanon.” “Basically,”

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Congressman Duncan observed on May 12, 2016, Khamenei meant IRGC proxies like

“Hezbollah [and] Hamas.”

220. The Axis of Resistance was not merely a slogan: it had nearly every jihadist

function that would parallel a western alliance, including joint attacks—which the terrorists,

U.S., U.N., and E.U. all called “operations”—that were committed through the work of joint

cells in which two or more FTOs were co-located with one another for a common anti-American

purpose, supported by joint training, procurement, financial support, logistics, basing, and

intelligence. In Iran, for example, the regime maintained multiple complexes in which the IRGC,

Qods Force, Hezbollah, Hamas, PIJ, and JAM trained, studied, and plotted together as one

coordinated syndicate of terrorists who worked together to target the United States and sought to

coerce the U.S. government to withdraw from the Middle East.

221. Notably, the name “Axis of Resistance” itself targeted the United States because

its members “resist” the U.S. presence in the Middle East. Part of this “resistance” included

sponsoring waves of terrorist attacks against Israelis. But even that targeted the United States

because the terrorists believed Israel to be an agent of the United States and believed that the

United States was key to whether they could overthrow the Israeli government and replace it

with their shared goal of an Islamic caliphate that governed Jerusalem, which they called

“Qods.”

222. Each Plaintiff was injured in an attack that was funded by the IRGC, and

committed, planned, or authorized by Hezbollah, Hamas, PIJ, and/or JAM. Some attacks were

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committed jointly by Hezbollah and/or Hamas and/or PIJ (in Israel), or by Hezbollah and JAM

(in Iraq).

A. Hamas

223. Hamas established itself in or about 1989 as a violent, global, Sunni Islamist

group dedicated to destroying Israel and killing every Jewish person there.

224. In or about 1990, Khamenei and the IRGC cemented a deep bond with Hamas.

Ever since, Hamas has been the IRGC’s second most notorious proxy, behind only Hezbollah.

225. Hamas, like Hezbollah, viewed the United States and Israel as two inextricably

connected enemies. For example, Hamas leaders regularly blamed Israeli counterterrorism

operations targeting Hamas on the United States by pointing out that Israel buys most of its

advanced weapons from America.

226. Hamas needed money to conduct the attacks alleged herein. As a Hamas financial

appeal in 2019 admitted: “The reality of jihad is the expenditure of effort and energy, and money

is the backbone of war.”

227. The IRGC and the SLO provided most of Hamas’s budget, and directly financed

Hamas attacks through a range of vehicles, including salary and bonus payments to Hamas

leaders and attack cells, bounties for successful attacks, and martyr payments to the families of

dead Hamas terrorists.

228. The Iranian regime funded acts of terrorism committed by Hamas through an

array of channels, including the Qods Force, Hezbollah, the SLO, the Foundation for the

Oppressed, and Bank Saderat. From 2007 through 2020, the Iranian regime did so by collectively

routing between $50 million and $250 million per year to Hamas through the above organs.

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229. The Iranian regime’s financial support was vital to Hamas’s ability to conduct

terrorist attacks. In 2007, for example, former Treasury official Dr. Matthew Levitt observed that

“Hamas … is also a massive beneficiary of support from … Iran, [which] provide[s] direct state

funding” to “sponsor” “terrorism” committed by Hamas. He continued:

Iran is described by the CIA as “the foremost state sponsor of terrorism” and is
Hamas’ most important and explicit state sponsor. Israeli, British, Canadian, and
Palestinian intelligence all concur with the U.S. conclusion that Iran directly aids
Hamas with money, training camps, and logistical support. Estimates of Iran’s
financial assistance to Hamas vary, but there is unanimity on one score: the sum is
significant.

230. Senior U.S. officials confirmed that the Iranian regime, including the IRGC, were

vital to financing Hamas’s attacks—usually routing their aid through their most trusted proxy,

Hezbollah. On September 29, 2006, for example, Frank C. Urbancic, Principal Deputy

Coordinator at State, testified before Congress as follows:

Hizballah supports … Palestinian terrorist organizations … [through] the covert

provision of weapons, explosives, training, funding, and guidance, as well as
overt political support … since at least 2000 … Hizballah actively foments
terrorist activity that directly undermines [the peace process].

231. Notably, the IRGC and the SLO had a famous “pay for performance” approach

with Hamas, under which the Iranians would ramp up their financial support for such groups to

reward them for successful attacks and incentivize future attacks at the same time. As Dr. Levitt

explained in 2007, “the specific sum [] fluctuates given circumstances on the ground; Iran is

known to employ a performance-based approach to determining the level of funding it is willing

to provide terrorist groups. As a U.S. court noted in Weinstein v. Iran, the period of 1995-1996

‘was a peak period for Iranian economic support of Hamas because Iran typically paid for

results, and Hamas was providing results by committing numerous bus bombings.’”

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232. When the IRGC and SLO funded Hamas, they earmarked the money they

provided for use by Hamas’s attack cells. In this way, Iranian money was uniquely lethal. As Dr.

Levitt explained in 2007:

Unlike much of the [non-Iranian sources of Hamas] financing …, Iranian funding

of Hamas is generally … directed straight to operational units. According to a
December 2000 Palestinian intelligence report confiscated by Israeli authorities,
Iran had transferred $400,000 directly to Hamas’ Qassam Brigades to specifically
support “the Hamas military arm in Israel and encouraging suicide operations,”
and another $700,000 to other Islamic organizations opposed to the PA.
According to a former Jordanian prime minister, “grassroots fundraising is
really not enough for big Hamas operations. Most of the support [for such
operations] is from Iran. Iran’s money is more influential.” A senior Fatah official
and member of the Palestinian Legislative Council offered a similar assessment,
saying that while “some of Tehran’s money over the past three years [2001- 2004]
may go to supporting health and humanitarian services in Gaza,” the bottom line
is that the “money from Tehran that goes to Hamas is for the political leaders of
Hamas and for the bombings, not for the Palestinians.” (Emphasis added.)

233. The IRGC also provided vital training to Hamas, often using both Hezbollah and

the Qods Force to provide extensive, multi-month, multi-location training to Hamas operatives.

The IRGC’s and Hezbollah’s provision of training to Hamas made Hamas more lethal and had a

direct impact on Hamas’s ability to conduct attacks in Israel.

234. The IRGC was also Hamas’s most important source of weapons, for which the

IRGC usually used Hezbollah as its interlocutor with Hamas. For example, Hezbollah smuggled

IRGC-supplied weapons to Hamas and trained Hamas terrorists how to use them. The IRGC’s

and Hezbollah’s provision of weapons to Hamas made Hamas more lethal and had a direct

impact on Hamas’s ability to conduct attacks in Israel.

235. Hamas and Hezbollah have long cooperated on shared operations. Hamas jointly

planned some attacks with Hezbollah. For example, Hamas heavily leveraged Hezbollah’s

technical skills, experience, training, and in-country operatives to plan and execute its

kidnapping operations.

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236. Like its IRGC patron, Hamas regularly violated the laws of war when it

committed its barbaric attacks. As Hamas scholar Jonathan Schanzer observed in 2021: “Hamas

was a brutal enemy” that routinely engaged in “‘extra-judicial and willful killing,’ including

incidents in which Hamas fighters pushed [captured rivals] off tall buildings.”

237. Hamas has been an FTO since 1997.

B. Palestinian Islamic Jihad

238. Palestinian Islamic Jihad established itself in 1979 as a violent, global, Sunni

Islamist group dedicated to destroying Israel.

239. In or about 1990, Khamenei and the IRGC cemented a deep bond with PIJ. Ever

since, PIJ has been one of the IRGC’s most notorious proxies, and was regularly mentioned by

U.S. and Israeli officials alongside Hamas as a well-known IRGC proxy.

240. The Iranian regime’s relationship with PIJ was substantially like its relationship

with Hamas. In short, anything the Iranian regime did for Hamas, it likewise did for PIJ.

Accordingly, and as SCB knew, the United States regularly described Iranian support for Hamas

and PIJ in the same public warnings, and often collectively referred to both as “Palestinian

terrorist groups” or something similar.

241. The Iranian regime has spent decades promoting the close collaboration between

Hezbollah, Hamas, and PIJ. In 1998, for example, State reported to Congress:

Iran continued to provide support—in the form of training, money, and/or

weapons—to a variety of terrorist groups, such as Lebanese Hizballah, HAMAS,
and the PIJ. The Iranian Government continues to oppose recognition of Israel
and to encourage violent rejection of the Middle East Peace Process. In the fall of
1997, Tehran hosted numerous representatives of terrorist groups—including
HAMAS, Lebanese Hizballah, [and] the PIJ…—at a conference of “Liberation
Movements.” Participants reportedly discussed the jihad, establishing greater
coordination between certain groups, and an increase in support for some groups.

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In the decades since, the Iranian regime continued similar efforts. In 2010, for example, State

reported to Congress that the “Qods Force” was “the regime’s primary mechanism for cultivating

and supporting terrorists abroad” and “provided weapons, training, and funding to HAMAS and

other Palestinian terrorist groups, including Palestine Islamic Jihad (PIJ).”

242. PIJ, like Hezbollah and Hamas, viewed the United States and Israel as two

inextricably connected enemies.

243. PIJ needed money to conduct the attacks alleged herein.

244. The IRGC and the SLO provided most of PIJ’s budget, and directly financed PIJ

attacks through a range of vehicles, including salary and bonus payments to PIJ leaders and

attack cells, bounties for successful attacks, and martyr payments to the families of dead PIJ

terrorists.

245. The Iranian regime funded acts of terrorism committed by PIJ through an array of

channels, including the Qods Force, Hezbollah, the SLO, the Foundation for the Oppressed, and

Bank Saderat. From 2007 through 2020, the Iranian regime did so by collectively routing at least

tens of millions of dollars per year to PIJ through the above organs.12

246. The Iranian regime’s financial support was vital to PIJ’s ability to conduct

terrorist attacks.

247. Senior U.S. officials confirmed that the Iranian regime, including the IRGC, was

vital to financing PIJ’s attacks—usually routing its aid through its most trusted proxy, Hezbollah.

On September 29, 2006, for example, Frank C. Urbancic, Principal Deputy Coordinator at State,

12
True, the Iranian regime provided less aggregate money to PIJ than it did to FTOs like
Hezbollah and Hamas. As SCB knew, however, such distinction between PIJ funding levels, on
the one hand, and funding levels for Hezbollah and Hamas, on the other, was based simply on
the fact that PIJ was a substantially smaller organization than Hezbollah and Hamas.

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testified before Congress that “Hezbollah supports … Palestinian terrorist organizations”—

which, as SCB knew, referred to both Hamas and PIJ—“[through] the covert provision of

weapons, explosives, training, funding, and guidance, as well as overt political support . . . since

at least 2000 . . . Hizballah actively foments terrorist activity that directly undermines [the peace

process].”

248. Notably, the IRGC and the SLO had a famous “pay for performance” approach

with PIJ (substantially like the IRGC’s and SLO’s support for Hamas), under which the Iranians

would ramp up their financial support for such groups to reward them for successful attacks and

incentivize future attacks at the same time.

249. The IRGC also provided vital training to PIJ, often using both Hezbollah and the

Qods Force to provide extensive, multi-month, multi-location training to PIJ operatives. The

IRGC’s and Hezbollah’s provision of training to PIJ made PIJ more lethal and had a direct

impact on PIJ’s ability to conduct attacks in Israel.

250. The IRGC was also PIJ’s most important source of weapons, for which the IRGC

usually used Hezbollah as its interlocutor with PIJ. For example, Hezbollah smuggled IRGC-

supplied weapons to PIJ and trained PIJ terrorists how to use them. The IRGC’s and Hezbollah’s

provision of weapons to PIJ made PIJ more lethal and had a direct impact on PIJ’s ability to

conduct attacks in Israel.

251. PIJ and Hezbollah have long cooperated on shared operations.

252. Like its IRGC patron, PIJ regularly violated the laws of war when it committed its

barbaric attacks.

253. PIJ has been an FTO since 1997

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C. Jaysh Al-Mahdi

254. Hezbollah and Muqtada al-Sadr established JAM in 2003 to serve as Hezbollah’s

“striking arm in Iraq” (as Sadr put it) and provide an Iraqi face to Hezbollah-directed terrorist

attacks targeting Americans there.

255. The IRGC and SLO provided a substantial percentage of JAM’s budget, and

directly financed JAM attacks through a range of vehicles, including payment to JAM leaders

and attack cells, bounties for successful attacks, and martyr payments to the families of dead

JAM terrorists.

256. JAM served as Hezbollah’s notorious terrorist agent in Iraq. JAM terrorists also

publicly swore fealty to Hezbollah in two marches in Baghdad in 2006, during both of which

thousands of JAM fighters publicly marched under Hezbollah’s banners and photos of Hezbollah

General Secretary Nasrallah while loudly chanting “We are Hezbollah” and “Jaysh al-Mahdi and

Hezbollah are one.” Sadr’s decree that JAM was Hezbollah’s “striking arm” and the two JAM

marches described above were widely covered, in real-time, by the media.

257. JAM jointly committed some attacks alongside Hezbollah, like the one that killed

Dr. Everhart. It did so as part of joint Hezbollah-JAM cells in Iraq, which were directly funded

by Hezbollah and the Qods Force.

258. On July 2, 2009, the United States designated JAM Special Group Kata’ib

Hezbollah as an FTO, designated Abu Mahdi al-Muhandis as an SDGT, and published detailed

findings that Hezbollah and the Qods Force had played a vital role directing attacks committed

by JAM in Iraq. This U.S. designation was widely reported worldwide.

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259. On January 3, 2020, the United States designated JAM Special Group Asa’ib Ahl

al-Haq as an FTO, designated two of its leaders as SDGTs, and published detailed findings

confirming AAH’s close operational relationship with Hezbollah and the Qods Force

D. North Korean Reconnaissance General Bureau (RGB)

260. From 1980 through 2019, the RGB of the Democratic People’s Republic of Korea

(“DPRK” or “North Korea”) always comprised the North Korean regime’s primary external

terrorist operations arm. The RGB specialized in the full panoply of terrorist operations,

weaponry, tactics, techniques, and procedures associated with modern terrorist organizations,

including, but not limited to, hostage-taking, bombings, assassinations, rocket attacks, and tunnel

fortifications.

261. The RGB, and the North Korean security services for which it committed its

terrorist acts, enjoyed a close, high-level partnership with the Iranian Terrorist Sponsors for

decades—which was cemented by contacts by key Iranian and IRGC leaders. For example, as

scholars Dr. Victor Cha and Gabriel Scheinmann observed in 2014: “In 1989, just prior to

becoming Iran’s Supreme Leader, Ali Khamenei also visited Pyongyang. Even with the U.S.

Navy in hot pursuit after the first Gulf War, missile-laden ships from North Korea still made

their way to Iranian ports.”

262. The RGB was a founding member of the Axis of Resistance. The RGB’s Joint

Logistics Cells with the IRGC and Hezbollah, see infra, pre-date the Ayatollah Khamenei’s

public proclamation of the Axis’s existence, which occurred in 2003. The RGB had operated its

Joint Logistics Cells with the IRGC and Hezbollah since the 1980s, which expanded in the late

1990s to include Hamas and PIJ, and in 2003 to include JAM. Every one of these relationships

pre-dated the Axis. While North Korea’s terrorist apparatus was occasionally omitted from

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public discussions about Axis membership, an avalanche of contemporaneous reports confirmed

both North Korea’s membership in the Axis and vital role powering terrorist attacks targeting the

United States committed by Axis FTOs.

263. The RGB was strikingly similar to the IRGC, Hezbollah, Hamas, PIJ, and JAM

with respect to the profile of operations (types and threats), history of conducting high-profile

mass casualty attacks (e.g., shooting down a civilian airliner), training regimen, terrorist tactics,

techniques, and procedures, sanctions evasion techniques, use of barter trade, cash equivalents,

and black market trade to finance operations, and—most importantly of all—their shared status

as notorious anti-American terrorist organizations. Indeed, the IRGC, Hezbollah, and RGB have,

essentially, identical strategic doctrine regarding the United States: all see it as their foundational

enemy; all were specially built to target the United States; and all regularly publicly threatened to

inflict unspeakable violence against Americans throughout the world.

264. Despite not sharing a common religion with the Terrorist Sponsors, the RGB and

the Iranian Terrorist Sponsors overcame that difference to advance their shared goal of

sponsoring terrorist violence against the United States and its allies. For example, even though

the DPRK banned all religions, the RGB allowed the IRGC, Hezbollah, the Foundation for the

Oppressed, and the SLO to build and operate a Mosque in a multi-building joint logistics cell

compound in Pyongyang—the only mosque in North Korea. The Terrorist Sponsors, in turn,

regularly worked to facilitate travel by RGB agents throughout the Middle East, which was both

in the Terrorist Sponsors’ own self-interest (since the RGB was helping them prepare for attacks)

and a valuable service to the RGB.

265. Why? Because North Korean-based cover and concealment was much harder for

the RGB to obtain when it operated in the Middle East, which was its most important weapons

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export market from 2000 through at least 2019. So the Terrorist Sponsors worked with the RGB

to secure fake Chinese passports and then hired the RGB operatives on their own corporate

fronts’ payrolls with the doubly false cover and concealment provided by: (a) concealing their

terrorist identity through the cover of a false janitorial, housekeeper, or other similar fake work

persona designed to minimize suspicion (which was textbook IRGC-developed, Hezbollah-

enhanced tradecraft); and (b) concealing their North Korean nationality—which was an

unmistakable, if not almost conclusive indicator of RGB terrorist operative identity in the Middle

East from 2000 through at least 2019—through the use of a false Chinese persona.13

266. The RGB was always an internationally infamous terrorist organization—a

reputation it acquired through a series of catastrophic terrorist attacks.

267. On November 29, 1987, the RGB helped the North Korean regime target and

destroy Korean Air flight 858, which exploded midair killing all 115 passengers on board, most

of whom were South Korean civilian workers returning from assignments in the Middle East.

Thereafter, the United States continuously designated the DPRK as a State Sponsor of Terrorism

from 1988 until 2008.

13
From 2000 through at least 2019, North Korea did not permit its citizens to travel outside of
the country, other than for very limited purposes to parts of China. The only North Korean
citizens who were permitted to travel were, in effect: (1) RGB operatives; (2) Foreign Ministry
personnel; and (3) RGB-managed victims of human trafficking, whom the RGB effectively
leased for pennies on the dollar to certain friendly regimes. The first category reflected—by
far—the most economic activity, security activity, and intelligence activity for the regime, and
therefore, the highest concentration of personnel deployed outside of North Korea. The second
category was about the same size in most regions, but smaller than the first in the Middle East
owing to the outsized presence of RGB operatives scattered throughout the Joint Logistics Cells
located in Iran, Syria, Lebanon, and Egypt. And the third category necessarily involved the RGB.
Accordingly, from 2000 through at least 2019, an observer with any knowledge of North Korean
security and economic practices could conclude, based on nothing more than a person’s North
Korean identity, that if such person was in Lebanon, the Palestinian territories, Syria, Iran, Iraq,
or Egypt, such person was likely an RGB operative or reporting to one.

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268. In 2008, the United States rescinded the DPRK’s State Sponsor of Terrorism

designation for diplomatic reasons related to an attempted nuclear deal with the North Korean

regime. At no point, however, did the U.S. government ever clear the RGB, i.e., assert it did not

propagate terrorist attacks, nor did the U.S. government contradict the abundant evidence in the

public domain from 2008 through 2017 that RGB support for Hezbollah and Hamas had

dramatically intensified from 2009 through 2019 in comparison to previous eras. Indeed, a flood

of real-time reports and criticisms confirmed that the rescission decision did not in any way

reflect the nature, impact, or duration of RGB-supplied weapons, training, and tunnels to

Hezbollah, Hamas, PIJ, JAM, and the IRGC throughout the period from 2000 through 2019.

269. On May 8, 2008, for example, the Minority Staff of the House Foreign Affairs

Committee published a confidential analysis of the Iran-North Korean- Hezbollah relationship by

Larry Niksch, who worked for the Congressional Research Service at the time:

Terrorist Groups ... Hezbollah. French, Israeli, and South Korean sources have
reported an extensive program by North Korea to provide arms and training to
Hezbollah. The French publication, Paris Intelligence Online, published a report
on North Korean training of Hezbollah in September 2006. Paris Intelligence
Online reported that North Korean training of Hezbollah cadre reportedly began
in the late 1980s and early 1990s, including training in North Korea. Three
current top Hezbollah officials were said to have received training in North
Korea: Hassan Nasrallah, Hezbollah’s secretary-general and head of
Hezbollah’s military organization; Ibrahim Akil, the head of Hezbollah’s
security and intelligence service, and Mustapha Badreddine, Hezbollah’s
counter-espionage chief. According to Paris Intelligence Online, the North
Korean program reportedly expanded after 2000 when Israeli forces withdrew
from southern Lebanon and Hezbollah forces [2] occupied the area. North Korea
is said to have dispatched trainers to southern Lebanon where they instructed
Hezbollah cadre in the development of extensive underground military
installations (North Korea is believed to have constructed extensive military
facilities inside North Korea) One such North Korean-assisted facility in southern
Lebanon reportedly was a 25 kilometer underground tunnel that Hezbollah used
to move troops. Hezbollah’s underground facilities, according to reports,
significantly improved Hezbollah’s ability to fight the Israelis during the 2006
Israel-Lebanon war.

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In November 2007, Professor Moon Chung-in, a professor at South

Korea’s Yonsei University and adviser to the Roh Moo-hyun Administration,
reported assessments from the Israeli intelligence agency, Mossad, that “vital
missile components” of Hezbollah missiles fired into Israel during the 2006 war
came from North Korea. Dr. Moon stated that Mossad believes that the missiles
with North Korean components were assembled in Iran and were transported to
Hezbollah in Lebanon via Syria. According to Professor Moon, Mossad “partially
blames North Korea” for the effectiveness of Hezbollah’s missile strikes into
Israel. …
In 2008, it has been reported that Hezbollah has received new missiles
from Iran with longer ranges than the missiles that Hezbollah used in the 2006
war. The Israeli government reported that Hezbollah now has an arsenal that
includes 10,000 long-range missiles and 20,000 short-range rockets in southern
Lebanon. … If the Israeli estimate is correct and if the reported Mossad
assessment of North Korea’s role in providing components to missiles supplied to
Mossad prior to the 2006 war is correct, it would appear possible that North
Korea is continuing to supply parts to the missiles that Iran is supplying to
Hezbollah. (Emphasis added.)

270. On July 28, 2015, similarly, Mr. Niksch testified before Congress that:

Secretary of Defense Robert Gates stated in San Francisco on August 12, 2010,
that “North Korea continues to smuggle missiles and weapons to other countries
around the world Burma, Iran, Hezbollah, Hamas.” Hezbollah and Hamas are
designated by the U.S. Government as international terrorist organizations. In
2014, there were new reports that North Korea was negotiating with Hamas to
provide missiles and communications equipment to Hamas. …
[W]ith [respect to] the issue of Iran-North Korea collaboration[:]
Numerous reports describe the Iranian Revolutionary Guards as the main foreign
supporter of Hezbollah and Hamas and the facilitator of North Korean assistance
to these groups.

271. On November 20, 2017, after about nine years of continued North Korean support

for its Axis of Resistance partners—most of all the IRGC, Hezbollah, and Hamas—the United

States reinstated the DPRK’s designation as a State Sponsor of Terrorism. In 2017, State

reported to Congress in Country Reports on Terrorism 2019, that the “the Secretary of State” had

determined that the DPRK, inter alia: (1) “repeatedly provided support for acts of international

terrorism, as the DPRK was implicated in assassinations on foreign soil”; (2) “repeatedly

provided support for acts of international terrorism since its State Sponsor of Terrorism

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designation was rescinded in 2008”; and (3) “ failed to take action to address historical support

for acts of international terrorism,” including decades-long unresolved hostage-taking and

hijacking attacks.

272. From the early 1980s through at least 2019, the Foundation for the Oppressed

always helped coordinate the Iranian Terrorist Sponsors’ decades long partnership with RGB,

including through the efforts of Foundation leaders (and Khamenei Cell members) Mohsen

Rafiqdoost and Parviz Fattah, among others. Throughout, the Terrorist Sponsors and their RGB

allies engaged in a consistent custom and practice, and used the same general tactics, techniques,

and procedures: in sum and substance, the Terrorist Sponsors ordinarily traded (as barter) their

NIOC-supplied, NITC-transported, Foundation-financed, SLO-supervised, Hezbollah and Qods

Force-smuggled, petroleum products to the RGB and, in exchange, the RGB provided the

following to Hezbollah, Hamas, PIJ, and JAM:

a. weapons, including, but not limited to, rockets, missiles, mortars, explosives, small arms,
and communications equipment;

b. terrorist training and equipment maintenance services, including, but not limited to,
services provided in the country in which the terrorist group was based (e.g., Lebanon for
Hezbollah), in addition to related training and technical support services provided at the
Joint Logistics Cell locations in North Korea, Iran, and Syria; and

c. construction of state-of-the-art, military-grade, attack tunnels modeled after the

RGB’s tunnel network adjacent to the DPRK’s border with South Korea.14

14
On information and belief, the Iranian Terrorist Sponsors engaged in substantially similar
trades, for substantially similar weapon types, training, and technical support services, and attack
tunnel construction with the RGB on behalf of JAM in a similar manner as they did with respect
to Hezbollah, Hamas, PIJ, and JAM. In Iraq, JAM’s attack-related operations sites relied upon
JAM’s control of the Ministry of Health and attendant ability to benefit from the copious
German-engineered, military-grade, command-and-control bunkers that Saddam installed in the
basements of most major hospitals throughout Iraq from 1990 through 2003. Hezbollah’s
commitment to tunneling is so foundational and the utility of attack tunnels in Iraq so obvious,
that it is likely that the RGB provided substantial attack-tunnel related services to JAM in Iraq,

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This shared logistics partnership began in the early 1980s, endured ever since, and resulted in

anywhere from $100 million to several billion dollars per year in bartered oil-for-weapons,

services, and tunnels that the Terrorist Sponsors caused to flow through to Hezbollah, Hamas,

PIJ, and JAM to directly enable such groups’ attacks.

273. Since the 1980s, NIOC has been notoriously close to its North Korean customer

and strategic partner. On January 15, 1980, for example, the Associated Press reported that

“North Korea’s vice-premier Kong Chin-Tai” was “in Iran with an economic delegation,” where

he “met Iranian Oil Minister Ali Akbar Moinfar” and confirmed that “National Iranian Oil Co.”

was “ready to supply part of North Korea’s oil requirements.” On April 11, 1989, similarly,

Reuters reported that “National Iranian Oil Co [] has close relations with North Korea.”

274. Indeed, the U.S. government directly warned banks—including, on information

and belief, SCB—that Iran-facing sanctions violations foreseeably enabled IRGC-sponsored

arms purchases from North Korea. In 2005 and 2006, for example, media outlets in the United

States (e.g., the New York Times) and Asia (e.g., Xinhua News Agency), reported that U.S.

officials had met with foreign bankers to warn them about the related risks posed by the IRGC

and North Korea.

275. Those warnings were well founded: RGB-supplied weapons and services

comprised a substantial percentage of all weapons that Iranian Terrorist Sponsors delivered to

Hezbollah, Hamas, PIJ, and JAM throughout this period. Indeed, numerous high-profile weapons

seizures and intelligence reports since the early 2000s confirmed that Iranian Terrorist Sponsors

used their oil-for-barter deals with the RGB (sometimes directly, sometimes routed through

even if it did so on a smaller scale as compared to its services to Hezbollah in Lebanon and
Hamas and PIJ in the Palestinian territories.

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China) to pay for around half of all weapons and technical training they provided to Hezbollah,

Hamas, and PIJ, which services were ordinarily coordinated with the Qods Force and Hezbollah,

paid for by oil-based barter trading, and complementary to previous training supplied by the

IRGC. Indeed, much of IRGC field tactics and tradecraft, and therefore the tactics that govern

Hezbollah, Hamas, and PIJ doctrine, were ripped straight from the RGB’s playbook, which had

decades of relevant operational experience that it eagerly shared with the IRGC and Hezbollah as

such organizations grew.

276. From 2009 through 2019, the Iranian Terrorist Sponsors likely engaged in at least

more than $1 billion per year in oil-for-weapons, services, and tunnels trades on behalf of

Hezbollah, Hamas, PIJ, JAM, the IRGC, the Foundation for the Oppressed, NIOC, NITC, and

KAA; indeed, some estimates place the Hezbollah- and Hamas-related oil-for-weapons

expenditures at several billion per year (which was primarily conducted through the oil-for-guns

barter arrangement rather than cash).

277. Why did the Foundation for the Oppressed, NIOC, NITC, and KAA need to

purchase industrial-scale quantities of weapons, training, and tunnels supplied by the RGB and

paid for with NIOC oil barter trade as facilitated by the Foundation for the Oppressed and NITC?

Because their conduct makes plain, they knew two facts. First, the Terrorist Sponsors knew that

the Foundation for the Oppressed, NIOC, NITC, and KAA were terrorist fronts that maintained

vital stores of key operations-facing assets that keyed Hezbollah’s, the Qods Force’s, Hamas’s,

PIJ’s, and JAM’s ability to conduct terrorist attacks targeting the United States, including by

attacking U.S. ally Israel. Such vital attack power for Hezbollah and its proxies included the

Foundation’s, NIOC’s, NITC’s, and KAA’s substantial terrorist assets—in personnel (embedded

for cover), cash, financial accounts, petroleum, cash equivalents, ships, ports, storage facilities,

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and more—upon which Hezbollah and the Qods Force relied to conduct attacks targeting the

United States, and for which Hezbollah and the Qods Force played a direct day-to-day role in

their de facto role as the General Managers of the Terrorist Sponsors’ turnkey enterprise to

smuggle oil to China and North Korea as part of a packaged deal in which the RGB provides

direct arms, training, and tunnel construction assistance to Hezbollah, Hamas, and their allies.

Second, the Terrorist Sponsors also knew that the U.S. and Israeli Armed Forces also believed

that the Foundation for the Oppressed, NIOC, NITC, and KAA contained key assets that

powered attacks. Such fact was obvious given decades of on-the-record quotes from both

governments’ counterterrorism personnel, intelligence services, and law enforcement.

278. Armed with these two data points, the Foundation for the Oppressed, KAA,

NIOC, and NITC invested heavily in RGB-supplied weapons and services including, but not

limited to, surface-to-air missile batteries, anti-aircraft guns, small arms, military-grade

communications equipment, and other weapons designed to harden such sites against a potential

airstrike or special operations raid by the U.S. or Israeli militaries. Accordingly, the mere

presence of such weapons at facilities owned and/or operated by the Foundation for the

Oppressed, KAA, NIOC, and NITC was powerful evidence that each such Terrorist Sponsor (in

the case of the Foundation) or front (in the case of KAA, NIOC, and NITC) was an operational

front for both Hezbollah and the Qods Force (given their shared ground-level management of the

operations-related aspects of the Iranian Terrorists Sponsors’ overall network structure, including

its petroleum smuggling) and that such fact was sufficiently obvious that the Foundation, KAA,

NIOC, and NITC elected to spend the oil necessary to purchase such weapons, services, and

tunnels from the RGB.

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279. U.S. government findings have confirmed the RGB’s intimate partnership with

the IRGC—including the Qods Force and IRGC-IO. In 2021, for example, the Department of

Commerce tightened controls on U.S. technologies to prevent, inter alia, intelligence sharing

activities between the intelligence arms of terrorist groups “in terrorist-supporting countries” like

Iran and North Korea, highlighting “Iran’s Islamic Revolutionary Guard Corps Intelligence

Organization (IRGC-IO)” and “North Korea’s Reconnaissance General Bureau (RGB),” and

stated:

“We cannot allow the foreign military-intelligence organizations of our

adversaries in … Iran, and other terrorist-supporting nations to benefit from U.S.
technology or U.S. services to support their destabilizing activities,” said
Secretary of Commerce Wilbur Ross. “We must ensure our controls prevent U.S.
persons, wherever located, from supporting unauthorized WMD activities around
the globe … and [support export controls that] enhance our national security.”
(Emphasis added.)

280. Israeli government findings confirmed the nexus. On February 28, 2008, for

example, during a joint press conference with Japan’s Prime Minister, then-Israeli Prime

Minister Ehud Olmert directly warned about burgeoning cooperation between Iran, North Korea,

Syria, Hezbollah, and Hamas, and the direct threat raised by such efforts:

My judgment is that there is an axis of evil which combines both North Korea,
Iran, the Syrians, Hezbollah and the Hamas -- all these countries and
organizations which are joining forces together in order to upset the balance to
develop non-conventional weapons and to threaten the moderate countries …
Israel is naturally one of them. (Emphasis added.)

281. Decades of reports and statements published by the United States, Iranian regime,

Iranian opposition, mainstream media, terrorism scholars, and NGOs alerted SCB that its Iranian

oil- and gas-related transactions with, and value flow-through to, the Iranian regime’s oil

monopoly, i.e., NIOC, directly financed IRGC weapons purchased from North Korea’s RGB.

Such reports included, but were not limited to:

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a. New York Times, December 19, 1982: “North Korea has become the leading supplier of
arms to Iran in an arrangement that has helped Iran finance its continuing war with Iraq,
according to a high-ranking American defense official. The official, Francis J. West . . .
said Iran had been paying North Korea partly in cash and partly in oil. Military analysts,
who provided details at Mr. West’s request, said North Korea had provided about 40
percent of the approximately $2 billion worth of weapons, ammunition and equipment
Iran acquired abroad this year. . . . To pay for the arms imports, oil industry analysts said,
Iran has increased its oil production beyond the limits set by the Organization of
Petroleum Exporting Countries. They said it had also cut prices below those of OPEC
and established the guns-for-oil bartering arrangement with North Korea. …
Intelligence officials said earlier that arms obtained by Iran from North Korea [and
others] enabled Iran to continue the war with Iraq. Iran appears to have paid for the
weapons from a $4.2 billion special military budget . . . . [thanks to] a resurgence of
Iranian oil production.” (Emphasis added.)

b. Chicago Tribune, August 31, 1989: “The story … is an open secret among the local
foreign community. ... North Korea … sold [missiles] to Iran during the Gulf War.
Teheran paid with oil, thus liberating the North Korean bars of gold set aside to purchase
petroleum on the world market.” (Emphasis added.)

c. Chicago Tribune, April 1, 1990: “North Korea served as an intermediary in the shipment
of Chinese missiles to Iran. That caper earned North Korea a year’s supply of petroleum
from the grateful mullahs in Tehran.” (Emphasis added.)

d. Reuters, November 19, 1992: “Impoverished North Korea bartered Scud missiles for
Iranian oil last year, a South Korean government-funded trade organisation said …. The
Korea Trade Promotion Corp (KOTRA) said North Korea traded 100 remodelled Scuds
for $120 million of crude oil. Pyongyang also signed a treaty with Tehran pledging to
barter arms for $300 million worth of oil a year in the future but further details were
unavailable. Iran is now North Korea’s fourth largest trading partner after China, Japan
and the Commonwealth of Independent States (CIS), the KOTRA report said.”
(Emphasis added.)

e. Associated Press, April 8, 1993: “Mohaddessin is a member of the opposition coalition’s

largest group, the Peoples Mujahedeen, which has a widespread network of supporters
and sources in Iran and has given accurate information in the past on Iranian military
developments. … Mohaddessin said the Iranians are repaying North Korea for the
missiles and other arms purchases with oil shipments now running at a level of
100,000 barrels a day. … Iran and North Korea … [were in] a marriage of
convenience: Iran gets offensive weapons not available from advanced Western
nations and North Korea gets critical oil shipments which it lacks the dollars to buy.
North Korea gets 40 percent of its oil needs from Iran. Mohaddessin said the current
delegation is the fifth to visit North Korea in the past year, resulting in arms purchases
of more than $3 billion to be delivered over the next five years.” (Emphasis added.)

f. St. Paul Pioneer Press, April 9, 1993: “An Iranian military delegation is in North Korea
to complete the purchase of 150 missiles that have a 600-mile range. The Iranians are

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paying North Korea for the missiles and other arms purchases in a barter arrangement
with oil shipments now running at 100,000 barrels a day.” (Emphasis added.)

g. USA Today, August 18, 1993: “The next time a terrorist bomb explodes in New York,
Berlin or Cairo, expect to trace its origins to one or more of a half-dozen countries
scattered across three continents. Western intelligence agencies say a loose alliance of
outlaw nations is slowly coming together. … ‘It’s a threat that we’re not well prepared to
meet,’ says Vincent Cannistraro, former CIA chief of counterterrorism operations. ‘There
are more ties and more connections than actually have been made public so far.’ These
‘outlaw’ nations - such as Libya, Sudan, Iran … and North Korea - have trade links, some
dating to the 1960s. But because of their isolation from most of the world, they have
increased cooperation by exchanging data, weapons and technology. … The links are
numerous: … North Korea is dangling its latest version of the Scud missile before Iran
… in exchange for hard currency and oil.” (Emphasis added.)

h. Globe and Mail, September 13, 1993: “North Korea has resorted to bartering arms to Iran
in exchange for oil.”

i. Washington Post, December 25, 1993: “Now, North Korea gets as much as half of its oil
from Iran, probably in exchange for weapons, according to recent estimates, and that
traffic might well continue or even increase in defiance of a U.S.-led campaign to impose
U.N. sanctions. … ‘To have maximum impact, you would have to intercept the oil
shipments from Iran …,’ said Selig S. Harrison, a longtime Korea specialist at the
Carnegie Endowment for International Peace. …Iranian oil … [was a] key import for
North Korea.” (Emphasis added.)

j. Deutsche Presse-Agentur, November 26, 2005: “Iran is seeking to strengthen its ties with
North Korea by offering Pyongyang a comprehensive economic aid programme as part of
co-operation between the two countries on rocket development, the weekly Spiegel
reported Saturday. Teheran wants to work together with North Korea on the
development of … rockets, Spiegel reported citing western intelligence sources. An
Iranian envoy has already promised North Korea substantial supplies of free oil and
natural gas that could help the country through the winter. Teheran hopes to pursue two
interests with its trade offer to the North Koreans, Spiegel said. Firstly, to ensure that it
would have technical advantages, because the Iranian medium-range missile Schahab-3-
Rakete [rocket] is based on North Korean technology.” (Emphasis added.)

k. Deutsche Welle, December 8, 2015: “Thanks to historical ties between Tehran and
Pyongyang, both countries are likely to be in favor of resuming the trade in oil,
possibly in a barter arrangement for weapons, according to some analysts. ‘Iran and
North Korea have generally been allies, in part because both have been considered by
the United States and its allies as ‘outcasts’ or ‘pariah states,’ subjected to wide-
ranging international sanctions,’ Middle East analyst Kenneth Katzman wrote in the
CRS report on Iranian foreign policy. … With limited hard currency of its own,
Pyongyang may be willing to trade knowledge for desperately needed oil. … Rah Jong-
yil, a former head of South Korean intelligence and an expert on the regime in
Pyongyang, told DW …[:] ‘The North has limited resources and other ways to pay for

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oil, so the opening up of Iran again gives Pyongyang an opportunity to barter weapons
for oil,’ … This has been the case in the past, analysts say, with a North Korean
aircraft seized in Thailand in December 2009 carrying an undeclared cargo of 35 tons
of North Korean made rocket-propelled grenades, missile and rocket launchers, missile
tubes, surface-to-air missile launchers and spare parts. The manifest claimed the cargo
was oil-drilling equipment and it subsequently emerged that it was bound for Iran.
‘There has been a lot of cooperation in hardware, software and nuclear technology in the
past, but I would assume the Iranians will be extremely cautious this time about trying to
bring in nuclear technology,’ Rah added.” (Emphasis added.)

282. The specific IRGC-North-Korea-IRGC proxy nexus was equally infamous.

Decades of reports and statements published by the United States, Iranian regime, Iranian

opposition, mainstream media, terrorism scholars, and NGOs alerted SCB that its Iranian oil- and

gas-related transactions with, and value flow-through to, the Iranian regimes oil monopoly, i.e.,

NIOC, fueled IRGC-sponsored terrorist attacks committed by Hezbollah, Hamas, and PIJ that

leveraged IRGC-purchased North Korean weapons and services for delivery (by the IRGC, or

directly by the RGB) to IRGC proxies Hezbollah, Hamas, and PIJ. Such reports included, but

were not limited to:

a. Guardian (UK), December 13, 2009: “A lethal cargo of rocket launchers, grenades and
other weapons seized in Thailand at the weekend may be just a glimpse of what US and
UN investigators say is a global North Korean illegal arms smuggling network …
[S]uspicion immediately fell on Iran, the destination of a previous illegal weapons
shipment impounded in the United Arab Emirates in July. …The cargo, declared in the
plane’s manifest as oil-drilling equipment, was said to include rocket-propelled grenades,
missile and rocket launchers, missile tubes, surface-to-air missile launchers, spare parts
and other heavy weapons. … The Bangkok arms seizure followed several similar recent
incidents. In July, the French-owned, Bahamian-flagged ANL Australia bound for Iran
was intercepted in the UAE after a US tip-off. The ship was found to be carrying
containers of small arms made in North Korea, military hardware and sufficient
explosive powder to arm thousands of short-range rockets. Also uncovered was a cache
of 2,030 detonators for 122mm rockets and other rocket components. The manifest also
detailed the cargo as oil drilling supplies. …US officials said the ANL Australia was
one of five vessels caught this year carrying large consignments of weapons apparently
intended for Iran’s militia clients such as Hezbollah and Hamas.” (Emphasis added.)

b. Dr. Christina Y. Lin (Former Director, China Affairs, Policy Planning, DoD), March
2010: “[N]umerous public reports have appeared since 1993 describing elements of
DPRK-Iranian collaboration …. Cooperation reportedly began at the same time DPRK

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negotiated with Iran’s Islamic Revolutionary Guard Corps (IRGC) for cooperation in
developing and manufacturing Nodong missiles in Iran. …The next stage of cooperation,
from 2003 onwards, appears to have been influenced by the joint advancement of the
Nodong (Shahab) [rocket] program in Iran … [for which Iran] offered oil and gas
shipments as payment.”

c. U.N. Security Council, November 5, 2010: “In August 2009, the United Arab Emirates
reported to the Committee that it had seized on 22 July 2009 military shipment aboard
ANL Australia. … The shipper of the cargo was the Pyongyang representative office of
OTIM SPA, an Italian shipping company. The cargo was falsely described on the
shipping documents as oil boring machine (spare parts). The cargo was custom sealed
and loaded on a Democratic People’s Republic of Korea ship in the port of Nampo,
Democratic People’s Republic of Korea, and trans-shipped multiple times on its way to
the declared destination, Bandar Abbass, Islamic Republic of Iran.”

283. Summing it all up, former Congressional Research Service Korea specialist Larry

Niksch testified before Congress on July 28, 2015 that “Iranian Money” was the “Lubricant for

the Wheels of Iran-North Korean Collaboration”:

Iran has paid North Korea huge sums of money for cooperative projects related to
missiles … and Pyongyang’s assistance to Hezbollah and Hamas. … It seems to
me that North Korea may receive from Iran upwards of $2 to $3 billion annually
from Iran for the various forms of collaboration between them. … There should
be no doubt that North Korea drives a hard financial bargain with Iran for the
benefits it provides to Iran. As the collaboration has deepened and North Korea
has expanded its programs, North Korea’s asking price no doubt has risen. …
Iranian money appears to be the lubricant for North Korea[] … Iran’s greed for
benefits from North Korea’s … terrorist-supporting assistance also appears to be
growing, so the match likely will continue despite the Iran nuclear agreement.

III. Iran’s Terrorist Sponsors and Proxies Used Multiple Coordination Mechanisms To
Orchestrate Their Attacks Targeting The United States

A. Joint Cells

284. From 2000 through 2024, Hezbollah, the IRGC, and the proxies they trained,

including Jamas, PIJ, and JAM, relied heavily on a “joint cell” model of terrorist attacks, under

which two or more terrorist groups combine one or more of their cells in a certain location, or for

a certain competency, to optimize the lethality of their shared attacks.

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285. U.N. Security Council reports confirmed the Iranian Terror Sponsor’s emphasis

on using joint cells to manage terrorist operations. On July 12, 2016, for example, the Council’s

Panel of Experts reported that “an Iranian news agency reproduced photographs showing the

Commander of the Quds Force . . . Qasem Soleimani in a joint cell’s “‘Fallujah operations room’

in Iraq” in which triple-hatted IRGC, Hezbollah, and JAM (Kataib Hezbollah) terrorist operative

“Abu Mahdi al-Muhandis . . . appeared in the same photograph”:

286. Hezbollah and IRGC terrorists have regularly confirmed their joint cell approach.

For example, as State informed Congress in Country Reports on Terrorism 2014: “In late

November” 2014, IRGC “General Amir Ali Hajizadeh … admitted that ‘The IRGC and

Hizballah are a single apparatus jointed together.’” On November 9, 2017, similarly, an IRGC-

and SLO-controlled media outlet published an interview with Hezbollah Deputy Secretary

General Sheikh Naim Qassem in which Qassem boasted about the combined attack power of

Hezbollah’s Iranian-backed joint cells, which he credited for terrorizing the United States.

287. U.S. government reports to Congress, publications, and studies also confirmed

Hezbollah’s, the IRGC’s, and their proxies’ programmatic reliance on the joint cell model of

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terrorism. As a U.S. Army officer warned in an analysis published by the Joint Special

Operations University in 2019:

Too often, the USG pigeonholes terrorists as members of one group or another, as
if operatives carry membership cards around in their wallets. Today’s terrorists
are better defined as belonging to a network of networks, which is both informal
and unstructured. For instance, not every Al Qaeda operative has pledged an oath
of allegiance (bayat) to Osama bin Laden, and many terrorists maintain
affiliations with members of other terrorist groups and facilitate one another’s
activities. Even though terrorist organizations tend to maintain the cellular
structure at the tactical level for security purposes, one of their critical
vulnerabilities at the operational and strategic level lies in the area of terrorist
financing and logistical support due to the overlap and cooperation between
terrorist groups and facilitators within their network of networks.

288. Nowhere was this warning more appropriate than with respect to Hezbollah. In

January 2019, for example, Colonel Joel D. Rayburn (U.S. Army, ret.) and Colonel Frank K.

Sobchak (U.S. Army, ret.), published the official DoD history of the U.S. Army’s experiences in

Iraq, which observed: “The Qods Force used members of Lebanese Hizballah, the Badr Corps,

and, later, Jaysh al-Mahdi to establish Iranian surrogate military cells throughout Iraq that could

increase or reduce violent attacks against the coalition on order.” On May 9, 2019, for example,

an analysis released by U.S. government-published Radio Farda observed that the “Quds Force,

led by Qassem Soleimani” served as a “‘command’ and headquarters for [IRGC] and Shia forces

operating throughout the [Middle East] region” and was “[r]esponsible for dozens of terror

attacks in the region and beyond.” On September 16, 2019, similarly, Marine Corps University

published Dr. Mark D. Silinsky’s observation that the “Qods Force maintains a joint command-

and-control structure with Hezbollah, in which Hezbollah assists the Qods Force in its program

to advise, support, and train other Shia militia groups.” In 2023, likewise, State reported to

Congress that: “Hizballah is closely allied with Iran, and the two often work together on shared

initiatives.”

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289. Terrorism scholars also confirmed Hezbollah’s, the IRGC’s, and their proxies’

widespread reliance on a joint cell approach and combined command-and-control. On July 9,

2013, for example Bipartisan Policy Center scholar Blaise Misztal testified to Congress that the

“Quds Force … is heavily linked to Hezbollah, engaging in joint activities all over the world. In

2018, likewise, Iran scholar Nader Uskowi testified to Congress:

The Quds Force maintains a joint command-and-control structure with

Hezbollah. The Quds Force commander, General Qasem Soleimani, frequently
meets with the Hezbollah’s leader, Hassan Nasrallah, and his senior aides. The
Quds Force senior officers also participate in Hezbollah’s decision-making
process at its highest levels regarding all … terrorist operations carried out by the
organization, almost certainly as part of Quds Force’s larger campaigns. This
practice began in the first days of the founding of Hezbollah. (Emphasis added.)

290. In 2021, similarly, scholar and former Treasury official Dr. Matthew Levitt

observed that Hezbollah’s and the Qods Force’s share tradecraft, and custom and practice,

emphasized that the use of joint cells involving, at least, Hezbollah and one other Qods Force

proxy, e.g., Hamas or JAM, was vital to such groups’ ability to maximize the lethality, and

operational tempo, of their attacks targeting the United States. Among other things, Dr. Levitt

noted:

a. “Iranian ‘auxiliaries’ were even embedded in Hezbollah units in the Bekaa Valley, with
the IRGC sharing Hezbollah’s communications and support network.”

b. “Deploying key commanders to priority conflict zones facilitated [Hezbollah]’s ability to

commit significant added value to its and Iran’s allies in these conflicts. Hezbollah’s
contributions vary from large and small military deployments, training local militias,
capacity building efforts focused on weapons or technology transfers, propaganda and
disinformation, cyber training and campaigns, illicit financial activities, intelligence
collection efforts, and even terrorist plots and preoperational surveillance in the region.”

c. “Soleimani became the one leading Hezbollah deployments and activities across the
region. Indeed, it was because of his dual-hatted role as head of the IRGC-QF and
director of Iran’s sub-state proxies that U.S. government lawyers concluded Soleimani
was a legitimate target for a targeted assassination in January 2020. The extent of his
personal leadership of these proxies became clear as U.S. analysts tracked his movements
and mapped out his ‘pattern of life.’”

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291. The widespread prevalence of dual-hatted Hezbollah/Qods Force terrorists further

reinforced the centrality of joint cells. In 2005, for example, Dr. Daniel Byman, of Georgetown

University, explained:

Iran’s ties are particularly strong to Hizballah’s terrorist wing … [C]ertain

Lebanese clans that are prominent in Hizballah’s terrorist operations, such as the
Musawis and the Hamiyehs, work directly with the Iranians as well as affiliating
with Hizballah. Similarly, … Imad Mugniyah, Hizballah’s terrorist mastermind,
reports directly to the Iranians. Such individuals are thus both members of
Hizballah and terrorists who report directly to the Iranians. Unlike many senior
Hizballah members, some of Iran’s favored Hizballah terrorists hold Iranian
diplomatic passports.

1. The Khamenei Cell: A Joint IRGC-Hezbollah Leadership Cell in

Iran, Iraq, and Lebanon

292. From 2000 through 2020, Ayatollah Khamenei directly funded, logistically

supported, and organized the Joint IRGC/Hezbollah Khamenei Cell that coordinated the

deployment of operatives, weapons, logistics, pre-attack intelligence, and associated finances and

fronts to keep everything off-books as was the Ayatollah Khamenei’s, the SLO’s, Qods Force’s,

and Hezbollah’s common tradecraft with respect to their role in attacks intended to intimidate the

United States and potentially kill or maim Americans (the “Khamenei Cell”). That attack

qualifier mattered because any such contemplated attack posed unique and potentially life- and

group-ending consequences that few (if any) other attacks raised. Accordingly, such attacks were

the most carefully coordinated, vetted, and planned by Khamenei, the SLO, the Qods Force, and

Hezbollah. To that end, the Khamenei Cell operated a shared Hezbollah/IRGC/SLO Leadership

Cell with respect to Iranian regime-sponsored terrorist attacks targeting the United States,

including U.S. ally Israel, that were committed, planned, or authorized by Hezbollah in the

Palestinian territories and Iraq.

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293. The Khamenei Cell included around 20-25 Hezbollah and/or IRGC operatives

based in Iran, Iraq, and Lebanon, and was remarkably stable, with every member being a senior

terrorist who had sworn allegiance to the Supreme Leader, was a long-standing ally of Khamenei

and part of his “inner circle” or a key lieutenant of such person, and who had directly sponsored

successful attacks targeting the United States in the past.15 During this period, the IRGC’s

Leadership Cell included, but was not limited to:

a. Ali Khamenei, Supreme Leader of the IRGC and Hezbollah from 1989 through 2020;

b. Mojtaba Khamenei, de facto leader of SLO and IRGC-IO from 2004 through 2020;

c. Qasem Soleimani, IRGC-QF Commander from 1998 through 2020;

d. Hassan Nasrallah, Hezbollah Secretary General and Khamenei’s Top Hezbollah Ally
from 1993 through 2020;

e. Imad Mugniyeh, dual-hatted member of the IRGC-QF and Hezbollah, who served as
Khamenei’s, Hezbollah’s, and the IRGC’s lead terrorist attack planner from the 1980s
through his death in 2008, and was responsible for establishing the joint Hezbollah-local
proxy cells in Iraq (i.e., joint Hezbollah-JAM cells) and Gaza (i.e., joint Hezbollah-
Hamas and Hezbollah-PIJ cells);

f. Esmail Ghaani, IRGC-QF Deputy Commander from 1998 through 2020;

g. Rostum Qasemi, Deputy Commander of IRGF-QF, Director of IRGC front KAA from
2007 through 2011, Minister of Oil and/or de facto leader of Qods Force and Hezbollah
petroleum smuggling from 2011 through 2020;

h. Parviz Fattah, Deputy Commander of IRGF-QF, Director or Board Member the

Foundation for the Oppressed from at least 2010 through at least 2020, and other fronts
operated for the benefit of the IRGC and/or SLO;16

i. Mohammad Ali Jafari, IRGC Commander from September 2017 through April 2019;

15
Some Khamenei Cell members were dual-hatted terrorists, meaning they were members of two
allied groups, e.g., Abu Mahdi al-Muhandis.
16
Some Hezbollah fronts alleged herein were entities for which both the IRGC and SLO
extracted substantial value for their shared sponsorship of attacks by Hezbollah, Hamas, PIJ, and
JAM, e.g., the Foundation the Oppressed, NIOC, and Petro Nahad.

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j. Abu Mahdi al-Muhandis, dual-hatted member of IRGC-QF (since the 1980s) and JAM
(since 2003), and Khamenei’s and Qasem Soleimani’s longest serving Iraqi asset;

k. Mohsen Rafiqdoost, former personal bodyguard and driver of Khomeini, largest bazaar
network in Iran, founder of IRGC, co-founder of Hezbollah, decades-long de-facto leader
of the Foundation for the Oppressed, key IRGC/Supreme Leader liaison for arms
purchases from DPRK RGB;

l. Mohsen Rezai, IRGC Commander (1981 through 1999), co-founder Hezbollah, founder
IRGC Intelligence Bureau (predecessor to IRGC-IO), Senior “Security” Advisor to Ali
Khamenei;

m. Hossein Taeb, IRGC Basij Commander (2007 through 2009) and IRGC-IO Commander
(2009 through 2022).

294. The Khamenei Cell played a direct role in every attack against Plaintiffs, which

typically featured multiple separate touchpoints with the Khamenei Cell.

295. When Ayatollah Khamenei flowed financial support to members of the Khamenei

Cell, he relied upon, inter alia, the Foundation for the Oppressed, the IRGC, and the SLO.

2. The Joint Axis of Resistance Logistics Cells (IRGC-LH-Hamas-PIJ-

JAM-RGB) in Iran, Lebanon, Syria, the Palestinian Territories, and
North Korea

296. From 2000 through at least 2020, the IRGC, Hezbollah, Hamas, PIJ, JAM, and

North Korea’s RGB maintained a Joint Logistics Cell that coordinated the development,

distribution, testing, and training of the common terrorist weapons, tactics, and objective that

united the Axis of Resistance, including, but not limited to: (1) rocket and missile research,

development, and deployment; (2) specialized training by the RGB to the other Axis members

concerning kidnapping, rocket attacks, and tunnel attacks – three of the RGB’s signature attack

types; (3) shared ratlines, safehouses, and sites for meetings and operational planning; and (4)

collaboration to promote weapons-related interoperability between all the members of the Axis

of Resistance (“Joint Logistics Cell”). Each of these features benefit all members of the Joint

Logistics Cell.

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297. The IRGC, Hezbollah, Hamas, PIJ, JAM, and North Korea’s RGB Joint Logistics

Cell had cell locations in at least the following locations:

a. Iran. The Joint Logistics Cell operates in Tehran out of a massive, multi-building
complex that Iranian regime built out to promote cross-pollination amongst allies and
logistics cooperation at a vast scale. Indeed, the RGB deployed up to 1,000 people at a
time to the Joint Logistics Cell in Tehran – so many North Korean terrorists were on site
that the Iranian regime at one point elected to procure an entire resort on the Caspian
Sea to accommodate them all.

b. North Korea. The Joint Logistics Cell’s oldest site in Pyongyang, which has hosted
trilateral logistics and training efforts with the Hezbollah, the IRGC, and the RGB for
decades. Prior to 2024, Hezbollah’s top leadership trained there, including Hassan
Nasrallah.

c. Syria. The Joint Logistics Cell’s newest location is in Syria, near the Syrian/Iraqi border.
While the other two locations primarily emphasize logistics cooperation and training, the
Joint Logistics Cell’s Syria location also served as a key transit node for Axis terrorists
seeking to travel to, or from, Lebanon, Gaza, and Iraq, because the Syrian site was ideally
located for all such uses. Moreover, Axis terrorists sometimes launched rocket attacks
directly from the Joint Logistics Cell location, as the IRGC-QF did in 2018, when they
fired rockets at Israel from Syria.

d. Egypt. The Joint Logistics Cell leveraged the RGB’s long-standing presence in Egypt,
which allowed Hezbollah to flow funds and weapons to Hezbollah and Hamas operations
cells in Gaza.

298. The Joint Logistics Cell reflected a simple truth: terrorists cannot kill people

without a robust logistics network behind them. In 2005, for example, Dr. Daniel Byman, or

Georgetown University, explained how logistics drive lethality:

299.

A successful terrorist act is often the culmination of months, at times even years,
of planning and preparation. For understandable reasons, the world focuses on the
man who seizes a hostage or the woman who plants a bomb. These people,
however, are often only part of a larger organization. Such operatives are often
supported by a vast apparatus of people who are false documents, run safe houses,
offer training on explosives and procure surveillance, and take care of the
terrorist’s family should they die or go to prison. Indeed, the actual attacker may
be far more replaceable than the other specialized cogs in the terrorist group’s
machine. As Colonel Yves Godard … contended, “the man who places the bomb
is but an arm that tomorrow will be replaced by another arm.” Shattering this

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logistics organization is often vital to successful counterterrorism. … Bruce

Hoffman and Kim Cragin, in their summary of successful counterterrorism
practices, emphasized the importance of stopping logistics. French officials found
that only by going after logistics networks were they able to … [achieve] the
successful prevention of attacks in the long term. Simply put, it is far harder for
the terrorist group to replace logisticians than operatives.

300. In 2019, for likewise, an analysis authored by a U.S. Army officer and published

by DOD’s Joint Special Operations University observed:

The 9/11 attacks could never have been executed without the logistical assistance
of a sophisticated and well-entrenched support network. … Accordingly, an
individual, group, or state that provides funds, travel documents, training, or other
support for terrorist activity is no less important to a terrorist network than the
operative who executes the attack. A key lesson learned from 9/11 is that
counterterrorism efforts must target financial and logistical cells with the same
vigor as operational cells.

301. Indeed, logistics are also an area where state sponsorship has an outsized impact

on the lethality of terrorist attacks. As Dr. Byman explained in 2005: “States can also help a

group conduct operations indirectly through logistical assistance” by “fund[ing] front companies

or non-government organizations that offer jobs and legitimate documentation for terrorists

masquerading as employees.”

302. The Joint Logistics Cell was a decades-long construct for which there were media

reports as early as the 1990s. In 1993, for example, the Washington Post reported: “Across from

the Foreign Ministry in north Tehran is an old government building housing protocol offices for

foreign diplomats and branch offices for two radical Islamic movements -- Hezbollah, from

Lebanon, and Hamas, from the Israeli-occupied West Bank and Gaza Strip.”

303. Such practices endured throughout the relevant period. In 2008, for example,

Treasury reported as to the substantial activities at the Joint Logistics Cell’s site in Tehran: “Iran

remains the most active of the listed state sponsors of terrorism, routinely providing substantial

resources and guidance to multiple terrorist organizations. For example, Hamas, Hizballah, and

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the Palestinian Islamic Jihad (PIJ) maintain representative offices in Tehran to help coordinate

Iranian financing and training of these groups.”

304. On information and belief, the Joint Logistics Cell played a direct role in every

attack against Plaintiffs, each of which featured one or both of (a) weapons that were likely

supplied by the RGB to Hamas and/or PIJ (e.g.,, rockets); and/or (b) an attack that was directly

or indirectly enabled by RGB-construction terror tunnels for Hamas and PIJ in Gaza and

Hezbollah in South Lebanon.

3. Joint Hezbollah-Hamas Operations Cells in Iran, Lebanon, Syria, and

the Palestinian Territories

305. From 2000 through 2020, Hezbollah and Hamas often collaborated on attacks

targeting the United States (including through attacking its ally, Israel) through a Joint

Hezbollah/Hamas Operations Cell with sites located in Lebanon, Syria, and the Palestinian

territories (collectively, the “Joint Hezbollah/Hamas Operations Cell”).

306. Throughout, Hezbollah’s role in the Joint Hezbollah/Hamas Operations Cell was

substantially like Hezbollah’s role in similar joint cells with JAM in Iraq. In both areas,

Hezbollah terrorists embedded with the local Iranian proxy, served as a liaison between the

proxy and, inter alia, Ayatollah Khamenei, the IRGC, and the SLO, and helped direct proxy

attacks to align such activities with Khamenei’s objectives.

307. Hamas and Hezbollah have long cooperated on shared operations. Hamas jointly

planned some attacks with Hezbollah. For example, Hamas heavily leveraged Hezbollah’s

technical skills, experience, training, and in-country operatives to plan and execute its

kidnapping operations.

308. Terrorism scholars concurred. As Dr. Matthew Levitt summed-up in 2007,

“Hamas has long cooperated with Hezbollah operationally.”

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309. The Iranian regime has spent decades promoting the close collaboration between

Hezbollah, Hamas, and PIJ. In 1993, for example, State reported to Congress: “Iran was the

principal sponsor of extremist Islamic and Palestinian groups. Besides providing funding,

training, and weapons to groups that conduct terrorist acts, Iran also hosted a series of high-

profile meetings with Hizballah and HAMAS that had the stated goal of coordinating efforts

against Israel and bringing the Arab-Israeli peace process to a halt.” In 1998, likewise, State

reported to Congress:

Iran continued to provide support—in the form of training, money, and/or

weapons—to a variety of terrorist groups, such as Lebanese Hizballah, HAMAS,
and the PIJ. The Iranian Government continues to oppose recognition of Israel
and to encourage violent rejection of the Middle East Peace Process. In the fall of
1997, Tehran hosted numerous representatives of terrorist groups—including
HAMAS, Lebanese Hizballah, [and] the PIJ…—at a conference of “Liberation
Movements.” Participants reportedly discussed the jihad, establishing greater
coordination between certain groups, and an increase in support for some groups.

310. In 2001, similarly, State reported to Congress: “Iran has long provided Lebanese

Hizballah and the Palestinian rejectionist groups--notably HAMAS [and] the Palestine Islamic

Jihad, … Iran continued to encourage Hizballah and the Palestinian groups to coordinate their

planning and to escalate their activities against Israel.”

311. Moreover, on September 19, 2006, Under Secretary of State R. Nicholas Burns

testified to Congress: “We have no illusions about the nature and objectives of the Iranian

regime. … In their foreign policy, they are pursuing a course of aggressive behavior from their

arming of Hizballah with long-range rockets to strike Israel to their work to create a nexus of

terrorism encompassing Hizballah, Hamas, Palestinian Islamic Jihad, the Popular Front for the

Liberation of Palestine General Command, and Syria.”

312. The Joint Hezbollah/Hamas Operations Cell played a direct role in every Hamas-

committed hostage-taking and rocket attack that killed and injured Plaintiffs. That is because

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kidnapping and rocket attacks were Hezbollah’s specialty, for which Hezbollah provided in-

country direction to Hamas, as well as coordination for things like resupply.

4. Joint Hezbollah-PIJ Operations Cells in Iran, Lebanon, Syria, and the

Palestinian Territories

313. From 2000 through 2020, Hezbollah and PIJ often collaborated on attacks

targeting the United States (including through attacking its ally, Israel) through a Joint

Hezbollah/PIJ Operations Cell with sites located in Lebanon, Syria, and the Palestinian

territories (collectively, the “Joint Hezbollah/PIJ Operations Cell”).

314. Throughout, Hezbollah’s role in the Joint Hezbollah/PIJ Operations Cell was

substantially like Hezbollah’s role in similar joint cells with Hamas in Gaza and JAM in Iraq. In

all areas, Hezbollah terrorists embedded with the local Iranian proxy, served as a liaison between

the proxy and, inter alia, Ayatollah Khamenei, the IRGC, and the SLO, and helped direct proxy

attacks to align such activities with Khamenei’s objectives.

315. PIJ and Hezbollah have long cooperated on shared operations. Indeed, State

regularly reported to Congress—including, but not limited to, in 2015, 2017, 2018, and 2020—

that “PIJ has partnered with Iranian- and Syrian-sponsored Hizballah to carry out joint

operations.”

316. Indeed, per a UANI analysis published on December 8, 2020: “In 2019, … Iran’s

supreme leader reportedly proposed PIJ form a joint operations room in Gaza with Hezbollah

and Iraqi militias,” which was among recent “signs of increased coordination within Iran’s

broader Axis of Resistance in furtherance” of IRGC-sponsored terrorist attacks in Israel.17

17
Jordan Steckler (Research Analyst, United Against a Nuclear (UANI)), How Iran Exports Its
Ideology, at 45 (UANI Dec. 8, 2020), https://tinyurl.com/4yrd8xcf.

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317. The Joint Hezbollah/PIJ Operations Cell played a direct role in every PIJ-

committed rocket attack that killed and injured Plaintiffs. That is because rocket attacks were a

Hezbollah specialty, for which Hezbollah provided in-country direction to PIJ, as well as

coordination for things like resupply.

B. Terrorist Fronts

1. Khatam al-Anbiya Construction Headquarters (aka GHORB)

318. Khatam al-Anbiya (or “KAA”), Persian for “Seal of the Prophet,” was a front for

the IRGC, including the Qods Force.

319. Khatam al-Anbiya was a front for Hezbollah.

320. Ostensibly a construction company, Ayatollah Khamenei created Khatam al-

Anbiya in 1990 to serve as a vehicle for the IRGC, Hezbollah and their proxies to be financially

self-sustaining and in direct response to concerns that the Iranian state could not, on its own,

afford to rebuild after the Iran-Iraq war while simultaneously funding terrorist proxies outside

Iran. Per its charter, KAA’s purpose was to “efficiently utilize the available construction and

economic resources, capacities and talents of the IRGC to continue the Islamic Revolution”—

i.e., IRGC-sponsored acts of terrorism targeting the United States. KAA’s primary purpose was

always to maximize the amount of money spent on terrorism committed by the Qods Force,

Hezbollah, and their shared proxies. KAA did so through its wide array of companies, personnel,

agents, deals, and facilities inside and outside of Iran. KAA operations inside Iran were

controlled by the IRGC, while operations outside Iran were controlled by the Qods Force and

Hezbollah. These factors, and others, distinguished KAA from nearly all other Iranian firms,

aside from fronts controlled by the IRGC or the SLO.

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321. KAA notoriously owned a wide array of companies in the Iranian oil, gas,

construction, and logistics spaces—all of which were part of the IRGC’s terrorist machine. Such

notorious fronts included, but were not limited to: (1) Oil Industries Engineering & Construction

(Sherkat-e Sakhteman-e Sanaye’ Naft); (2) Iranian Offshore Engineering & Construction

Company (Sherkat-e Mohandesi Va Sakht-e Ta’sisat-e Daryayi) (“IOEC”); (3) Persian Gulf

Petrochemical Industries Company (“PGPIC”); and (4) Bandar Imam Petrochemical Company.

(KAA jointly owned IOEC alongside fellow IRGC front NIOC.)

322. The IRGC, Qods Force, and Hezbollah, and their proxies, including Hamas and

PIJ, leveraged KAA resources, including KAA profits, to serve as a source of funds, logistical

aid, cover, and safe houses in Iraq, Lebanon, Syria, and Gaza, among other places. KAA was the

ideal cover because it had extensive offices, projects, and facilities inside and outside of Iran,

including in Lebanon, Syria, Iraq, and Gaza. Among other uses, the Qods Force, Hezbollah,

Hamas, PIJ, and JAM used KAA to stockpile and pre-position weapons earmarked for attacks,

including EFPs, rockets, and communications technologies. KAA also worked closely with other

IRGC fronts, including the SLO, Foundation for the Oppressed, NIOC, and NITC.

323. From at least 2000 through present, the Qods Force and Hezbollah used KAA to

finance terrorist attacks in Israel that were committed by Hezbollah, Hamas, and PIJ, and funded

and supplied by the Qods Force. From 2003 through present, the Qods Force and Hezbollah used

KAA to finance terrorist attacks in Iraq that were committed by Hezbollah and JAM and were

funded and supplied by Hezbollah and the Qods Force. At all relevant times, KAA was

controlled by the Qods Force and Hezbollah, and used by the Qods Force and Hezbollah to flow

funds, logistics, and weapons; provide safe houses for forward-deployed operatives; and conceal

terrorist funds, weapons, and supplies moved through transnational construction-related

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shipments. KAA support flowed from Iran to recipients in Iraq, Lebanon, Syria, and Gaza,

among other places, including to Hamas and PIJ (through Hezbollah) and JAM (through

Hezbollah) attack cells, to finance terrorist attacks in Israel and Iraq committed by such groups.

324. Indeed, KAA profits provided a key funding source for the IRGC’s tunnel-related

support to IRGC proxies throughout the world, including Hezbollah in Lebanon and Hamas and

PIJ in Israel and Gaza. Moreover, KAA activities also provided valuable intelligence benefits to

the IRGC and SLO in every geography in which KAA operated, including Iran, Iraq,

Afghanistan, Lebanon, and Yemen, among others.

325. On October 25, 2007, the United States sanctioned KAA under U.S. weapons-

related sanctions targeting the IRGC and concerning, inter alia, missiles and drones; listed KAA

as an “IRGC-owned or -controlled compan[y]”; and warned banks contemplating doing business

with Iranian counterparties—including SCB—that the IRGC had seized a monopolistic share of

Iran’s oil sector, the IRGC used KAA to operationalize such tactics, and the IRGC used some of

the resulting profits to finance IRGC-sponsored weapons programs that threatened the United

States. (The latter finding was needed to impose U.S. weapons sanctions against the IRGC.)

326. On June 24, 2008, the E.U. sanctioned “Khatem-ol Anbiya Construction

Organisation” (i.e., KAA) for direct facilitation of illicit IRGC weapons acquisition and

proliferation efforts, which focused on IRGC acquisition, development, and export of weapons

like missiles, rockets, and UAVs (drones), and in recognition of KAA’s role as a vital supporter

of the IRGC’s ballistic missile operations.

327. On July 27, 2010, the E.U. announced sanctions that targeted, inter alia, IRGC

ballistic missiles, proxy terrorism, and fundraising through KAA:

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a. “Islamic Revolutionary Guard Corps (IRGC) … Reasons: Has operational control for
Iran’s ballistic missile programme” and “[h]as undertaken procurement attempts for to
support Iran’s ballistic missiles”;

b. “Parviz FATAH … Reasons: Deputy Commander of Khatam al Anbiya”;

c. “Rostam QASEMI (a.k.a. Rostam GHASEMI) … Reasons: Commander of Khatam al-

Anbiya”; [and]

d. “IRGC Qods Force … Reasons: Iran’s Islamic Revolutionary Guard Corps (IRGC) Qods
Force is responsible for operations outside Iran and is Tehran’s principal foreign policy
tool for special operations and support to terrorists and Islamic militants abroad.
Hizballah used Qods Force-supplied rockets, anti-ship cruise missiles (ASCMs), man-
portable air defense systems (MANPADS), and unmanned aerial vehicles (UAVs) in the
2006 conflict with Israel and benefited from Qods Force training on these systems,
according to press reporting. According to a variety of reporting, the Qods Force
continues to re-supply and train Hizballah on advanced weaponry, anti-aircraft missiles,
and long-range rockets. The Qods Force continues to provide limited lethal support,
training, and funding to Taliban fighters in southern and western Afghanistan including
small arms, ammunition, mortars, and short-range battlefield rockets. Commander [i.e.,
Qasem Soleimani] has been sanctioned under UNSCR[.]”

328. On March 28, 2012, Treasury imposed additional sanctions against KAA and

reiterated that KAA’s profits funded IRGC-sponsored terrorism:

Today’s actions further expose IRGC … continued involvement in illicit activities

and deceptive behavior.
Pursuant to Executive Order (E.O.) 13382 – an authority aimed at freezing
the assets of proliferators of weapons of mass destruction (WMD) and their
supporters and thereby isolating them from the U.S. financial and commercial
systems – Treasury today designated the following entities and individuals.
Iran Maritime Industrial Company SADRA (SADRA), an entity owned by
the IRGC’s Khatam al-Anbiya …
“By designating the individuals and entities today, Treasury is sending a
clear signal to the international community that Iran’s attempts to evade
international sanctions will not go unnoticed. We will continue to target the
Iranian regime and specifically the IRGC as it attempts to continue its nefarious
infiltration of the Iranian economy,” said Adam Szubin, Director of [OFAC].
The IRGC continues to be a primary focus of U.S. and international
sanctions against Iran because of the central role the IRGC plays in … [inter alia]
Iran’s … support for terrorism …. The IRGC has continued to expand its control
over the Iranian economy – in particular in the defense production, construction,
and oil and gas industries – subsuming increasing numbers of Iranian businesses
and pressing them into service in support of the IRGC’s illicit conduct.

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329. On May 31, 2013, Treasury sanctioned KAA affiliate Bandar Imam

Petrochemical Company as part of a package that, per Treasury, comprised “Actions [that]

Target the Iranian Petrochemical Industry as well as the Iranian Regime’s Attempts to Evade

Sanctions and Support Terrorism.”

330. On November 17, 2017, the United States designated KAA (inclusive of KAA’s

alter egos) as an SDGT when it also designated the entire IRGC as an SDGT.

331. On June 7, 2019, the United States imposed IRGC counterterrorism-related

sanctions that targeted, inter alia, KAA, KAA affiliate PGPIC (also an IRGC front), and the

IRGC’s monopoly on Iran’s oil and gas sector:

OFAC … act[ed] … against Iran’s largest and most profitable petrochemical

holding group, Persian Gulf Petrochemical Industries Company (PGPIC), for
providing financial support to Khatam al-Anbiya …, the engineering
conglomerate of the [IRGC]. In addition to PGPIC, OFAC is designating
PGPIC’s vast network of 39 subsidiary petrochemical companies and foreign-
based sales agents. PGPIC and its group of subsidiary petrochemical companies
hold 40 percent of Iran’s total petrochemical production capacity and are
responsible for 50 percent of Iran’s total petrochemical exports.
“By targeting this network we intend to deny funding to key elements of
Iran’s petrochemical sector that provide support to the IRGC,” said Treasury
Secretary Steven T. Mnuchin. “This action is a warning that we will continue to
target holding groups and companies in the petrochemical sector and elsewhere
that provide financial lifelines to the IRGC.”
“The IRGC systemically infiltrates critical sectors of the Iranian economy
to enrich their coffers, while engaging in a host of other malign activities,” said
Under Secretary for Terrorism and Financial Intelligence Sigal Mandelker.
The IRGC and its major holdings, such as … Khatam al-Anbiya, have a
dominant presence in Iran’s commercial and financial sectors, controlling multi-
billion dollar businesses and maintaining extensive economic interests in the
defense, construction, aviation, oil, banking, metal, automobile and mining
industries, controlling multi-billion dollar businesses. The profits from these
activities support the IRGC’s full range of nefarious activities, including …
support for terrorism ….
In 2018, Iran’s Ministry of Petroleum awarded the IRGC’s Khatam al-
Anbiya ten projects in oil and petrochemical industries worth the equivalent of 22
billion dollars, a value four times the official budget of the IRGC.

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332. On July 6, 2022, the United States imposed additional counterterrorism sanctions

targeting the IRGC through KAA, PGPIC, and their affiliates under Executive Order 13,846.

333. On September 15, 2023, Treasury imposed counterterrorism sanctions “pursuant

to E.O. 13224” upon “Abdolreza Abedzadeh” who was “the newly appointed Commander” of

KAA, and confirmed that KAA continued to enable IRGC attacks through at least 2022 when it

observed that “the U.S.-designated Khatam ol Anbia Gharargah Sazandegi Nooh (Khatam al-

Anbiya Construction Headquarters) [is] an IRGC-controlled construction conglomerate that

undertakes multi-billion-dollar projects in the oil, petrochemical, and various infrastructure

sectors, generating revenue for the IRGC and expanding its control across multiple industries.”

334. From 2009 through 2024, senior Qods Force leader Rostam Qasemi led, or helped

lead, KAA. On November 17, 2017, the United States designated Qasemi as an SDGT when it

also designated the entire IRGC as an SDGT.

335. The U.S. government and U.N. statements confirming KAA’s direct connection to

IRGC sponsored, proxy-committed, acts of terrorism targeting the United States described a

consistent pattern of conduct that existed at all relevant times throughout SCB’s scheme with the

IRGC and Hezbollah. These sources show that KAA was closely intertwined with terrorist

violence because the Qods Force and Hezbollah used KAA’s profits to finance terrorist attacks.

336. KAA was a front for the Qods Force, Hezbollah, and such FTOs’ proxies. Thus,

funds, weapons (including weapons components), intelligence, cover and concealment, and

logistical support obtained by KAA through its (or its controlled companies’ and/or

investments’) commercial transactions, resources, and profits with, or generated by, KAA

inevitably flowed through KAA to reach the Qods Force and Hezbollah and, through them, to

Hamas and JAM, to provide the funding, weapons, intelligence, and logistics that enabled IRGC-

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sponsored attacks in Israel (committed by Hezbollah and/or Hamas) and Iraq (committed by

Hezbollah and JAM).

337. SCB always knew the above facts. Among other reasons, Treasury sanctions

designations alerted financial institutions, like SCB, that its transactions with, and value flow-

through to, KAA fueled IRGC-sponsored acts of terrorism.

338. KAA was never a normal company: it was fully captured by the IRGC, led by,

and comprised of, avowed supporters and financiers of the Qods Force, Hezbollah, Hamas, PIJ,

and JAM, and operated for the benefit of their shared mission to sponsor terrorist attacks

targeting the United States to coerce U.S. government decisionmakers in the United States to exit

the Middle East and abandon its allies there, including Israel and Iraq

2. National Iranian Oil Company (NIOC)

339. NIOC was the entity responsible for exploring and exporting Iran’s oil. It was a

government-owned business overseen by the Iranian Ministry of Petroleum, and it exercised a

monopoly over the petroleum trade in Iran and with respect to exports of Iranian petroleum-

based products (e.g., oil and natural gas). NIOC had affiliates, including the Naftiran Intertrade

Company Ltd. (“NICO”), to handle much of its overseas trade.

340. By no later than 2007, the IRGC seized NIOC and converted it to an IRGC front.

Since the IRGC seized NIOC, NIOC’s express purpose has always been the same: to source

funds and weapons (including weapons components) for Hezbollah, the Qods Force, and their

proxies to use to commit acts of international terrorism targeting the United States. From 2009

onward, NIOC was a notorious front for Hezbollah and the Qods Force, which relied upon NIOC

to help finance acts of terrorism committed by Hezbollah, Hamas, PIJ, and other IRGC proxies.

Accordingly, NIOC was not a normal oil company: it was fully captured by the IRGC and

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operated for the benefit of the IRGC’s mission—i.e., sponsoring acts of terrorism targeting the

United States.

341. At all relevant times, NIOC provided key financial and logistical aid to acts of

terrorism committed by Hezbollah and the Qods Force and, through Hezbollah, to IRGC proxies

including Hamas, PIJ, and JAM. NIOC did so by directing funds to the IRGC through a web of

contracting arrangements with other IRGC businesses. NIOC’s revenues thus flowed through to

the IRGC, the Qods Force, and Hezbollah—and, at those organizations’ direction, to the IRGC’s

terrorist proxies elsewhere, including to JAM in Iraq and to Hamas and PIJ in Israel.

342. The nexus between NIOC and IRGC-sponsored attacks committed by Hezbollah,

Hamas, and PIJ was especially tight because NIOC’s shipments, oil, gas, and profits comprised

one of the IRGC’s primary means of paying their North Korean allies in the RGB so that the

IRGC could trade such NIOC goods and services to the RGB and, in return, receive North

Korean weapons, training, and technical support for delivery to, and on behalf of, IRGC proxies

Hezbollah, Hamas, and PIJ.

343. NIOC notoriously owned a wide array of companies in the Iranian oil, gas,

construction, and logistics spaces—all of which were part of the IRGC’s terrorist machine. Such

notorious IRGC fronts, through NIOC, included, but were not limited to: (1) NICO; (2) Petropars

Ltd. (“Petropars”); and (3) IOEC, which was a joint venture between NIOC and Idro, a

subsidiary of the Iranian Ministry of Heavy Industry, in which KAA also had a stake. As such,

the IRGC fully controlled IOEC like it did NIOC.

344. NIOC’s investment in South Pars was a notorious front for Iran-backed proxy

attacks committed by Hezbollah, Hamas, and PIJ. On November 3, 1997, for example, Senator

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Sam Brownback, who chaired the Senator Foreign Relations Subcommittee relating to Iran at the

time, publicly warned:

In the foreign policy arena, there are few hard and fast rules. One of them is this:
American investors should not fund Iranian ballistic … missile development. And
yet, that is essentially the deal that the Russian company Gazprom will be offering
to unsuspecting American investors when it launches a new convertible bond …
to invest $2 billion in Iran's South Pars gas field.
The South Pars deal poses two big problems. First, by providing a steady
stream of new revenues, it will help finance Tehran’s … terrorist activities. Iran is
a terrorist nation. It is committed to undermining the Middle East peace process
[between Israel and Palestinians], wreaking death and destruction in Lebanon and
on the South Lebanese border, and acquiring a nuclear capability. By exploiting
Iran's South Pars field and helping Tehran foot the bill for terrorist activities,
Gazprom will be squarely on the side of the terrorists.
Second, the deal runs afoul of the Iran-Libya Sanctions Act (ILSA). ILSA
limits investment in the Iranian energy sector to $40 million a year and provides
sanctions for companies that exceed the limit. ILSA's underlying premise is
simple: Assisting Iran's energy sector means financing a campaign against
Mideast peace and stability. …
If there is money to be made on such a venture, it is blood money.
Gazprom is short on the cash it needs for investments such as South Pars. The
company is planning to get U.S. investors to pony up by selling convertible bonds
on Wall Street. …
We should not stand by and watch U.S. … dollars bankroll an enterprise
that subsidizes barbarism in the Middle East and is a threat to world peace.
Trading peace for profit is a lousy investment.

345. High-profile investigations confirmed in real-time that the Qods Force used

NIOC-related transactions to provide cover for IRGC weapons purchases, and alerted SCB to the

same. In 2004 and 2005, for example, the Ukrainian government brought high-profile charges

that targeted IRGC weapons purchases routed through Ukrainian middlemen in which the IRGC

used NIOC, which prompted a wave of reports by the global press alerting SCB to the risk. On

March 26, 2005, for example, the BBC reported that prominent Ukrainian member of parliament

Hryhoriy Omelchenko publicly “point[ed] out … that ‘a bogus contract between the Iranian

company SATAK Co. Ltd of NIOC [i.e., National Iranian Oil Company] and Hyder Sarfraz's

S.H. Heritage Holding Limited for the supply of gas turbine equipment for oil refineries was

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used to cover the accounts for the missiles smuggled into Iran’.” In 2009, similarly, authorities in

Thailand interdicted an aircraft transporting a shipment containing 35 tons of explosives and

weapons, including RPGs, which the IRGC – through NIOC oil – had purchased from the RGB,

and which the IRGC was subsequently smuggling – through an aircraft cloaked with the cover of

a NIOC-related purported end user from Iran that was ostensibly purchasing oil drilling

equipment, which was ultimately destined for delivery to Hezbollah, Hamas, and PIJ. The

foregoing was major international news from 2009 through 2011, and prompted waves of

reporting both years concerning the above facts.

346. United States designations and reports repeatedly confirmed that NIOC-related

transactions powered IRGC-sponsored violence. On November 26, 2008, Treasury “identified

the National Iranian Oil Company (a.k.a. NIOC), Naftiran Intertrade Company Ltd. (a.k.a.

NICO), and Naftiran Intertrade Co. Sarl as entities owned or controlled by the Government of

Iran,” and warned (emphases added):

The inclusion of the National Iranian Oil Company, Naftiran Intertrade Company
Ltd., and Naftiran Intertrade Co. Sarl marks the first non-financial institutions to
be added to the appendix. Moving forward, OFAC will continue to list both
financial institutions and other entities that are determined to be owned or
controlled by the Government of Iran.
While the ITR do not impose an asset freeze, they do prohibit most
commercial and financial transactions with entities owned or controlled by the
Government of Iran, regardless of where such entities are located or incorporated.
Most transactions with any branches or subsidiaries of these entities are also
prohibited, regardless of where such branches or subsidiaries are located and
incorporated.
This appendix serves as a tool to assist U.S. persons in complying with
the ITR. The identified entities are considered to be owned or controlled by the
Government of Iran when they operate not only from the locations listed in the
appendix, but also from any other location. The ITR prohibitions apply to all
entities owned or controlled by the Government of Iran, regardless of where they
are located or incorporated, even if they are not listed in the appendix. The
prohibitions in the ITR also apply to transactions with entities located in Iran that
are not owned or controlled by the Government of Iran.

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Naftiran Intertrade Company Ltd. is a subsidiary of the National Iranian

Oil Company that is registered in the United Kingdom and located in Jersey,
Channel Islands, United Kingdom. NICO, in turn, has a subsidiary, called
Naftiran Intertrade Co. (NICO) Sarl, which is incorporated and located in
Switzerland. The ITR prohibit most transactions with NIOC, NICO and NICO
Sarl, in any locations worldwide, because these companies are entities owned or
controlled by the Government of Iran.

347. On June 16, 2010, Treasury sanctioned NIOC’s subsidiaries, and their associated

investments, including Petropars, again warning that the IRGC seized Iran’s energy sector.

348. On November 15, 2011—the same day SCB helped the IRGC evade imminent

U.S. sanctions targeting its oil sector—terrorism experts testified to Congress that “NIOC

operates as the ultimate front company obscuring the role of the IRGC in the oil trade,” and

warned of deepening ties between NIOC and the IRGC. Expert organization United Against

Nuclear Iran (“UANI”) wrote that “working with NIOC and the IRGC” would “directly

contribut[e] to Iran’s capabilities to sponsor terrorism, kill and maim NATO servicemen and

develop its weapons of mass destruction programs”—for example, by bankrolling “groups in

Iraq … that execute attacks against American and NATO servicemen” while “being actively

supported by Iran.” The United States responded by increasing sanctions pressure on the IRGC

to prevent the IRGC from using oil revenues to support terrorism.

349. On December 31, 2011, Congress in the 2012 National Defense Authorization

Act blacklisted CBI/Markazi. Congress also, with limited exceptions, subjected to sanctions

foreign financial institutions doing any significant financial transactions with CBI/Markazi, as

well as several other IRGC-affiliated financial institutions. These sanctions were imposed

because CBI/Markazi—which was a principal repository of Iranian oil revenue—was

participating actively in the IRGC’s illicit transactions, including transferring funds used to

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support IRGC-backed terrorism. Through this legislation, Congress reaffirmed the connection

between Iranian oil revenue and IRGC terrorism.

350. In August 2012, Congress enacted the Iran Threat Reduction and Syria Human

Rights Act of 2012 (“ITRSHRA”), Section 312 of which directed Treasury to determine whether

NIOC was acting as an agent or affiliate of the IRGC. A month later, Treasury publicly

announced that the answer was “yes.”

351. The finding that NIOC was effectively a front for the IRGC triggered additional

sanctions on NIOC. Specifically, under the ITRSHRA, NIOC was sanctioned for providing

support to the IRGC. And under CISADA and the Iranian Financial Sanctions Regulations,

foreign financial institutions determined to knowingly facilitate significant transactions or

provide significant financial services for NIOC were subject to sanctions, including the

prohibition or imposition of strict conditions on the opening or maintaining of correspondent or

payable-through accounts in the United States.

352. NIOC was also listed on the Specially Designated Nationals (“SDN”) list (a list of

sanctioned entities), specifically with an “IRGC” identifier after its name. As the Foundation for

Defense of Democracies explained on September 23, 2012 after Treasury’s determination, “U.S.

law now makes it explicitly clear that NIOC’s business partners are doing direct business with

the world’s most dangerous terrorist organization and nuclear proliferator.”

353. By threatening to cut foreign financial institutions off from the U.S. financial

system if they continued to deal in any significant way with CBI/Markazi and NIOC, these

sanctions essentially forced foreign financial institutions to choose between dealing with IRGC

fronts, or maintaining access to U.S. dollar trading—and prompted most financial institutions to

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curtail their services for IRGC companies. This made it extremely difficult for the IRGC to

access revenue from its oil sales, and also to access the international financial system.

354. On September 24, 2012, Treasury sanctioned NIOC as an “agent or affiliate” of

the IRGC.

355. On May 31, 2013, Treasury sanctioned NIOC subsidiaries as part of a package

that “Target[ed] the Iranian Petrochemical Industry as well as the Iranian Regime’s Attempts to

Evade Sanctions and Support Terrorism,” and warned:

As part of its ongoing efforts to intensify sanctions pressure on Iran, … Treasury

took a series of related actions to disrupt efforts to evade sanctions on the Iranian
regime … [and] sanctioned a company that has aided Iran’s efforts to evade
sanctions by attempting to conceal oil transactions with the Government of Iran
… These actions, which were taken under a number of different authorities, apply
sanctions to companies operating in several countries that are aiding Iran’s
support for terrorism ….
Treasury…, acting in concert with … State, … act[ed] … to target Iran’s
petrochemical industry. As Iran’s oil revenues continue to fall due to international
sanctions, the Iranian government has increasingly turned to other industries to
make up for lost profits. One of these sectors is the petrochemical industry, which
is now the second largest source of revenue for the Iranian Government. The
Administration is taking action today to target this revenue stream by both
designating companies involved in transactions with the sector and identifying
several petrochemical companies as subject to sanctions because they are
controlled by the Iranian government.
“We are committed to intensifying the pressure against Iran, not only by
adopting new sanctions, but also by actively enforcing our sanctions and
preventing sanctions evasion. Today’s actions take aim at revenues from Iran’s
petrochemical sector, as well as deceptive schemes Iran has employed in an effort
to evade sanctions on its oil sales and its airlines,” said Treasury Under Secretary
for Terrorism … David S. Cohen. …
Treasury … is also identifying eight Iranian petrochemical companies that
are owned or controlled by the Government of Iran, including Bandar Imam
Petrochemical Company, Bou Ali Sina Petrochemical Company, Mobin
Petrochemical Company, Nouri Petrochemical Company, Pars Petrochemical
Company, Shahid Tondgooyan Petrochemical Company, Shazand Petrochemical
Company, and Tabriz Petrochemical Company. These identifications made
pursuant to E.O. 13599, which targets the government of Iran.

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356. The United States has confirmed that the Iranian regime used profits from NIOC

and its affiliates, including NICO, to fund terrorist attacks by IRGC proxies. For example, in

2018, Executive Order 13,846 included the finding that “financial, material, or technological

support for, or goods or services in support of, the National Iranian Oil Company” and “Naftiran

Intertrade Company” directly enabled “threats posed by Iran, including Iran’s … network and

campaign of regional aggression, its support for terrorist groups, and the malign activities of the

Islamic Revolutionary Guard Corps and its surrogates.”

357. In 2020, Treasury reiterated its 2012 finding that NIOC was an IRGC agent, and

commercial transactions with NIOC foreseeably enabled IRGC-sponsored terrorist attacks

committed by its proxies. On January 23, 2020, for example, OFAC described NIOC as

“instrumental in Iran’s petroleum and petrochemical industries, which helps to finance Iran’s

Islamic Revolutionary Guard Corps – Qods Force (IRGC-QF) and its terrorist proxies,”

necessarily including Hezbollah, Hamas, PIJ, and JAM. In that same release, the Treasury

Secretary commented that “Iran’s petrochemical and petroleum sectors are primary sources of

funding for the Iranian regime’s global terrorist activities,” i.e., IRGC-sponsored acts of

terrorism targeting the United States and committed by one or more IRGC proxy.

358. On October 26, 2020, OFAC designated NIOC’s related Ministry, the Iranian

Ministry of Petroleum, and NIOC’s subsidiary, NICO, among others, under E.O. 13,324

(counterterrorism) “for their financial support to Iran’s Islamic Revolutionary Guard Corps-Qods

Force (IRGC-QF),” noted that “[t]he cooperation and coordination between the IRGC-QF and

these entities extends well beyond the simple sale of oil,” and the Treasury Secretary observed

that “[t]he regime in Iran uses the petroleum sector to fund the destabilizing activities of the

IRGC-QF,” i.e., acts of terrorism targeting the United States, which was a required finding for

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the legal designation announced. Treasury justified the counterterrorism sanctions against NIOC

under E.O. 13,324 by observing that NIOC services were inextricably connected to Hezbollah-

sponsored acts of terrorism targeting the United States, finding, inter alia, that: (1) “Senior

NIOC … personnel have worked closely with Rostam Ghasemi, a senior IRGC-QF official and

former Minister of Petroleum who was designated in 2019, and who has assumed a portion of

former IRGC-QF Commander Qasem Soleimani’s role in facilitating shipments of oil and

petroleum products for the financial benefit of the IRGC-QF” through, inter alia, IRGC-

controlled “front companies”; and (2) “NIOC” facilitated “oil deals used to generate revenue for

the IRGC-QF and Hizballah” through its “coordination” with such terrorists by working with the

IRGC-QF, Hezbollah, and NITC to route IRGC-QF oil to Hezbollah through trades in other

Middle Eastern countries to raise funds for Hezbollah and the Qods Force to distribute to IRGC

proxies to sponsor acts of terrorism targeting the United States.

359. The U.S. government statements confirming NIOC’s direct connection to IRGC

sponsored, proxy-committed acts of terrorism targeting the United States described a consistent

pattern of conduct that existed at all relevant times throughout SCB’s scheme with the IRGC and

Hezbollah. These sources confirm that NIOC was closely intertwined with terrorist violence

because the IRGC used revenues from NIOC oil sales to finance terrorist attacks.

360. Given NIOC’s status as a front for the Qods Force, Hezbollah, and such FTOs’

proxies, funds obtained by NIOC through its or its controlled companies’ and/or investments’

(including Petropars’) commercial transactions, resources, and profits with, or generated by,

NIOC inevitably flowed through NIOC to reach the Qods Force and Hezbollah and, through

them, to Hamas, PIJ, and JAM, to finance Hezbollah and the Qods Force’s provision of fighters,

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funds, and weapons that enabled IRGC-sponsored attacks in Israel (committed by Hezbollah

and/or Hamas and/or PIJ) and Iraq (committed by Hezbollah and JAM).

361. NIOC ceased to be a normal oil company by 2007, when the IRGC completed its

capture of NIOC and thereafter operated NIOC for the benefit of the IRGC’s mission to sponsor

terrorist attacks targeting the United States to coerce U.S. government decisionmakers in the

United States to exit the Middle East and abandon its allies there, including Israel and Iraq.

3. National Iranian Tanker Company (NITC)

362. NITC was responsible for transporting NIOC’s oil. It was a government-owned

business overseen by the Iranian Ministry of Petroleum, and it exercised a monopoly over the

transportation aspects of petroleum trade in Iran and with respect to exports of Iranian

petroleum-based products (e.g., oil and natural gas).

363. By 2007, the IRGC took control of NITC by seizing its sole customer, NIOC, and

the IRGC has controlled NITC as an IRGC front ever since. Since the IRGC seized NITC in

2007, NITC’s purpose—like NIOC’s—has been to source funds and weapons (including

weapons components) for Hezbollah, the Qods Force, and their proxies to use to commit acts of

terrorism targeting the United States. From 2009 onward, NITC has been a notorious front for

Hezbollah and the Qods Force, which relied upon NITC to help finance acts of terrorism

committed by Hezbollah, Hamas, PIJ, and other IRGC proxies. Accordingly, NITC was not a

normal oil tanker company: it was fully captured by the IRGC, and operated for the benefit of,

the IRGC’s mission, i.e., sponsoring acts of terrorism targeting the United States.

364. At all relevant times, NITC provided key financial and logistical aid to acts of

terrorism committed by Hezbollah and the Qods Force and, through Hezbollah, to IRGC proxies

including Hamas, PIJ, and JAM. NITC did so by coordinating oil shipments with NIOC, the

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Qods Force, and Hezbollah to flow funds to the Qods Force, Hezbollah, and their proxies

through NIOC’s web of contracting arrangements with other IRGC businesses, all of which

depended upon NIOC’s ability to reliably export IRGC-QF owned oil, in contravention of U.S.

counterterrorism sanctions, to customers outside of Iran. NITC’s conduct was thus intended to,

and did, flow tens of millions in revenues through NIOC to the IRGC, the IRGC-QF, and

Hezbollah—and, at those organizations’ direction, to the IRGC’s terrorist proxies elsewhere,

including Iraq (to its Shiite terrorist proxy groups) and Israel (to Hamas and PIJ).

365. On May 31, 2013, Treasury imposed sanctions on NITC to “Target the Iranian

Petrochemical Industry as well as the Iranian Regime’s Attempts to Evade Sanctions and

Support Terrorism,” and warned:

Treasury imposed sanctions on [a European firm] because it has facilitated

deceptive transactions for or on behalf of the [NITC], which was identified by
Treasury as a Government of Iran entity in July 2012. This Treasury action is the
first use of sanctions pursuant to Executive Order (E.O.) 13608, which targets
Foreign Sanctions Evaders, including those that facilitate deceptive transactions
for or on behalf of persons sanctioned in connection with Iran …
In March 2013, Ferland and NITC cooperated in a scheme to sell Iranian
crude oil deceptively in order to help Iran evade international sanctions …. The
scheme involved ship-to-ship transfers of oil between three oil tankers … working
on behalf of Iran in March 2013. …

366. The United States has confirmed that the Iranian regime used profits generated by

NITC to fund terrorist attacks by Hezbollah, Hamas, PIJ, and JAM. On August 6, 2018, for

example, Executive Order 13,846 included findings that “financial, material, or technological

support for, or goods or services in support of, the National Iranian Oil Company (NIOC)”

including services provided by any “person” who was “a part of the energy, shipping, or

shipbuilding sectors of Iran”—all of which described NITC—directly enabled “threats posed by

Iran, including Iran’s … network and campaign of regional aggression, its support for terrorist

groups, and the malign activities of the Islamic Revolutionary Guard Corps and its surrogates.”

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367. In 2020, Treasury confirmed that NITC, like NIOC, was an IRGC agent, and

commercial transactions with NITC foreseeably enabled IRGC-sponsored terrorist attacks

committed by IRGC proxies. On October 26, 2020, for example, OFAC designated NITC “for

[its] financial support to Iran’s Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF),”

noted that “[t]he cooperation and coordination between the IRGC-QF and [NITC] extends well

beyond the simple sale of oil,” and the Treasury Secretary himself observed that “[t]he regime in

Iran uses the petroleum sector to fund the destabilizing activities of the IRGC-QF”—i.e., acts of

terrorism targeting the United States, which was a required finding for the legal designation

announced. Treasury justified the counterterrorism sanctions against NITC by observing that

NITC services were inextricably connected to Hezbollah-sponsored acts of terrorism targeting

the United States by finding, inter alia, that: (1) “Senior … NITC personnel have worked closely

with Rostam Ghasemi, a senior IRGC-QF official and former Minister of Petroleum who was

designated in 2019, and who has assumed a portion of former IRGC-QF Commander Qasem

Soleimani’s role in facilitating shipments of oil and petroleum products for the financial benefit

of the IRGC-QF” through, inter alia, IRGC-controlled “front companies”; and (2) “NITC has

also played a significant role in oil deals used to generate revenue for the IRGC-QF and

Hizballah. NITC personnel coordinated with the IRGC-QF on the loading of oil provided by

NIOC, and NITC Managing Director Nasrollah Sardashti (Sardashti) worked with Hizballah on

logistics and pricing for oil shipments to Syria. Sardashti also worked with Qatirji Group

representative Viyan Zanganeh (Zanganeh) and a senior IRGC-QF official to facilitate the

shipment of millions of dollars of oil by NITC.”

368. Treasury’s decision to not characterize NITC as an IRGC “agent or affiliate” 2012

was based on its narrow definition of “agent or affiliate,” for which only direct agency mattered.

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Treasury thus deemed NIOC an IRGC agent, but it did not deem NITC an IRGC agent. In

practice, however, transacting with NITC was no different than transacting with NIOC directly:

NITC was always a known NIOC agent, and NIOC was always NITC’s only customer.

Accordingly, when Treasury declined to formally confirm that NITC was an IRGC “agent or

affiliate” for purposes of complying with an edict from Congress, SCB knew that such decision

did not authorize its NITC-related transactions because SCB understood that NITC was an agent

for NIOC and NIOC was an agent for the Qods Force and Hezbollah.

369. The U.S. government statements confirming NITC’s direct connection to IRGC

sponsored, proxy-committed, acts of terrorism targeting the United States described a consistent

pattern of conduct that existed at all relevant times throughout SCB’s scheme with the IRGC and

Hezbollah. These sources show that NITC was closely intertwined with terrorist violence

because the IRGC used revenues from NITC shipments, including but not limited to the profits

NITC itself realized as well as the income NITC helped other IRGC fronts, including NIOC,

earn, to finance terrorist attacks.

370. Given NITC’s status as a front for the Qods Force, Hezbollah, and such FTOs’

proxies, including Hamas and PIJ, funds obtained by NITC through its or its controlled

companies’ and/or investments’ commercial transactions, resources, and profits inevitably

flowed through NITC to reach the Qods Force and Hezbollah and, through them, to Hamas, PIJ,

and JAM, to finance Hezbollah and the Qods Force’s provision of fighters, funds, and weapons

that enabled IRGC-sponsored attacks in Israel (committed by Hezbollah and/or Hamas and/or

PIJ) and Iraq (committed by Hezbollah and JAM).

371. NITC was no longer a normal company by 2007, when the IRGC had completed

its capture of NITC’s only customer, NIOC, and the IRGC thereafter operated NIOC, and by

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extension NITC, to sponsor terrorist attacks targeting the United States to coerce U.S.

government decisionmakers in the United States to exit the Middle East and abandon its allies

there, including Israel and Iraq.

4. Caspian Petrochemical

372. Caspian Petrochemical FZE, inclusive of its predecessor entity, the Iranian

Petrochemical Company (collectively, “Caspian Petrochemical”) helped ship petroleum

products, including oil and gas, that IRGC energy fronts extracted from IRGC-controlled areas,

including the IRGC’s South Pars field and the IRGC’s energy claims in the Caspian Sea. (Unless

otherwise indicated, all references to Caspian Petrochemical in this Complaint are inclusive of its

predecessor entity, and inclusive of such entity’s conduct from at least 2007 through 2011, when

the IRGC rebranded it as “Caspian Petrochemical.”)

373. Caspian Petrochemical was subordinate to the Supreme Leader’s Office, via SLO

entity Petro Nahad, and handled much of the Iranian regime’s overseas oil and gas shipments.

374. By no later than 2007, the SLO and IRGC seized Caspian Petrochemical’s

predecessor when they seized their monopoly in the Iranian energy sector. The SLO and IRGC

have controlled Caspian Petrochemical as an IRGC front ever since. Since being seized by the

SLO and IRGC, Caspian Petrochemical’s express purpose has always been to source funds and

weapons (including weapons components) for Hezbollah, the Qods Force, and their proxies to

use to commit acts of international terrorism targeting the United States. From 2007 onwards,

Caspian Petrochemical was a known front for Hezbollah and the Qods Force (given Caspian

Petrochemical’s responsibility for shipping the IRGC’s most lucrative financial asset). Hezbollah

and the Qods Force relied upon Caspian Petrochemical to help finance acts of terrorism

committed by Hezbollah, Hamas, and other IRGC proxies. Caspian Petrochemical was not a

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normal energy or shipping company: it was fully captured by the IRGC, and it supported the

IRGC’s mission—i.e., sponsoring acts of terrorism targeting the United States to export the

Islamic Revolution.

375. At all relevant times, Caspian Petrochemical provided key financial and logistical

aid to acts of terrorism committed by Hezbollah and the Qods Force and, through Hezbollah, to

IRGC proxies including Hamas, PIJ, and JAM. Caspian Petrochemical did so by directing funds

to the IRGC through a web of contracting arrangements with other IRGC businesses. Caspian

Petrochemical’s revenues thus flowed through to the IRGC, the Qods Force, and Hezbollah—

and, at those organizations’ direction, to the IRGC’s terrorist proxies elsewhere, including Iraq

(to its Shiite terrorist proxy groups) and Israel (to Hamas and PIJ).

376. Caspian Petrochemical was never a normal company: it was fully captured by the

IRGC, led by, and comprised of, avowed supporters and financiers of the Qods Force,

Hezbollah, Hamas, and JAM, and operated for the benefit of their shared mission to sponsor

terrorist attacks targeting the United States to coerce U.S. government decisionmakers in the

United States to exit the Middle East and abandon its allies there, including Israel and Iraq.

5. Euro African Group Ltd. (EAGL) and the Bazzi Network

377. The Bazzi network, and its primary holding company, Euro African Group Ltd.

(EAGL) is a group of individuals and companies led by Muhammad Bazzi that leveraged

Hezbollah’s West African presence, which dates back to the group’s inception. Bazzi developed

a partnership with the then-President of Gambia, Yahya Jammeh. By the time Bazzi arrived in

Gambia in the early 2000’s, Jammeh was a notoriously corrupt and brutal dictator. All told, they

extracted nearly $1 billion from Gambia, one of the poorest countries in the world.

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378. While telling the public they were free-market entrepreneurs, Bazzi network

entities would provide bribes and side-payments to Jammeh, who would force Gambian agencies

to give contracts and privatization deals to Bazzi’s firms. These sham privatizations also allowed

Hezbollah to convert illicit cash into licit, state-sanctioned corporate holdings. Within just a few

months of their incorporation, Bazzi’s previously unheard-of companies had secured monopolies

on essential imports like oil, fuel, and electrical generator equipment.

379. Even with public disclosure of these dealings, clear evidence of massive

corruption, and Bazzi’s role in Hezbollah, Jammeh and Bazzi became more brazen—and banks,

including Standard Chartered—continued to enable their schemes. Bazzi introduced other

members of his network to Jammeh and brokered similar deals. This enabled Bazzi and other

Hezbollah financiers to take over the country’s public utilities, as well as its telecommunications

sector. Hundreds of millions of dollars in taxes, utility payments, and cash from pension funds

vanished into the Bazzi network’s companies.

380. Despite readily available public information documenting Bazzi’s role in

organized crime, corruption, and terrorist finance, SCB provided banking services to Bazzi

network entities until at least 2012, and made rent payments to Bazzi’s Gambian business

partner, a Jammeh henchman, until at least 2017. OFAC designated Bazzi’s associate Ali

Youssef Charara and his telecoms companies as SDGTs on January 7, 2016. Bazzi, EAGL, and

its subsidiaries were designated SDGTs on May 17, 2018, confirming both his corrupt dealings

with Jammeh, and his longstanding ties to Hezbollah’s narcotics and money laundering

operations. On September 20, 2024, in the Eastern District of New York, Bazzi pleaded guilty to

conspiracy to conduct and to cause United States persons to conduct unlawful transactions with

an SDGT.

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6. Tajco, Ltd. and the Tajideens

381. According to Treasury’s designation of Tajco on December 9, 2010, Tajco is a

“multipurpose, multinational business venture involved in international trade as well as real

estate and presided over by Ali, Husayn and Kassim Tajideen. As of February 2007, Kassim

Tajideen owned Tajco and used proceeds from this business to provide millions of dollars in

financial support to Hizballah. Husayn Tajideen, co-owner of Tajco Ltd in The Gambia, serves

as the company’s managing director. Ali Tajideen and Kassim Tajideen were business partners

and co-owners of Tajco Sarl, operating as Tajco Company LLC in Tyre, Lebanon, with Ali

Tajideen serving as the managing partner.”

382. On May 27, 2009, one of the co-owners, Kassim Tajideen, was designated by

Treasury for supporting Hezbollah. The press release explained that “Kassim Tajideen and his

brothers run cover companies for Hizballah in Africa.” Another one of Tajco’s co-owners, Ali

Tajideen, was a “major player” in Jihad al-Bina, a Lebanon-based Hezbollah-run construction

company designated by Treasury on February 20, 2007. The Tajideen family was also linked to

diamond smuggling to launder money for Hezbollah, as well as land purchases in Lebanon for

Hezbollah.

383. SCB Gambia and SCB Dubai helped Hezbollah front Tajco Ltd. access the

international financial system from at least 2008-2010 to finance terrorist attacks, knowing it was

co-owned by the Tajideen brothers, who had multiple businesses acting as fronts to provide

funding and resources to Hezbollah.

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IV. Since 1982, Iran’s Terrorist Sponsors Have Partnered With Their Lebanese,
Palestinian, And Iraqi Proxies To Target The United States

384. When the Iranian Terror Sponsors established Hezbollah in 1982, they

inaugurated the IRGC’s modern history of anti-American terrorism, for which Hezbollah was

always the most important variable. The subsequent history since 1982 was replete with

examples of the same terrorists involved in the attacks decades ago also facilitated attacks

against Plaintiffs. Indeed, as the United States found in 2018, since “the early days of the

revolution …, the one constant is that the Iranian regime will do whatever it takes to … spread

its revolutionary ideology … primar[ily] … [through] the Islamic Revolutionary Guard Corps

(IRGC).” In 2018, State found that, “[s]ince 1979, Iran’s Islamic Republic has made it a policy

of state to actively direct, facilitate, and carry out terrorist activity globally.” Thus, as State found

in 2018, “[f]or 40 years, the … Revolutionary Guard Corps has actively engaged in terrorism and

created, supported, and directed other terrorist groups.” As U.S. official Brian Hook explained on

April 8, 2019: “When you study their 40-year history, it’s impossible to allow the IRGC to

continue to operate under this fiction that it’s a benign part of the Iranian Government …, and it

has been that way for decades.” Equally unmistakable: that such terrorism increased alongside

the IRGC’s control of Iran’s economy; as the DIA reported in 2019, “[t]he past 40 years have

seen a growth in … increased IRGC political influence and control of key economic sectors.”

385. In 2015, Suzanne Maloney of the Brookings Institution observed: “It is tempting

to view the Islamic Republic in isolation from its antecedents. … However, … [t]he salience of

Iranian history requires that” even a “primary focus on the postrevolutionary era” in Iran should

“begin as any serious analysis of contemporary Iran must, with an examination … of the long

history of the Iranian state and the evolution of the economic and political conditions.” To that

end, Plaintiffs briefly identify key events in Iranian history that, among other things, confirm the

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plausibility of Plaintiffs’ allegations and demonstrate a longstanding IRGC pattern and practice

relevant to Plaintiffs’ claims. Beyond that, these key events alerted SCB as to the nature of their

counterparties and/or the ultimate beneficial owners of the transactions SCB facilitated.

386. On October 23, 1983, Hezbollah detonated a massive bomb provided by the

IRGC, which killed 241 U.S. military personnel in a terrorist attack against the Marine Corps

barracks in Beirut, Lebanon. On July 21, 1987, while discussing this attack in Iranian media,

Rafiqdoost famously boasted that he and the IRGC directly enabled this attack: “The U.S. felt

our power and knows the explosives mixed with that ideology that sent 400 officers and soldiers

to Hell. Both the TNT and the ideology came from Iran. This is very much obvious for the U.S.”

387. On December 12, 1983, Hezbollah and the IRGC jointly committed another

audacious attack targeting the United States, this time by bombing America’s embassy in

Kuwait. For this attack, Hezbollah and the IRGC worked closely with Abu Mahdi al-Muhandis,

a dual Iranian-Iraqi national and Hezbollah/IRGC asset, who would later play a key leadership

role in Jaysh al-Mahdi.

388. On August 20, 1988, the Iran-Iraq War ended. On June 3, 1989, Khomeini died,

leaving the Islamic Republic without a Supreme Leader and the IRGC without an overall

commander. These two rapid-fire events produced a power contest in Iran, in which there was no

clear successor. In this mix, IRGC Brigadier General Ali Khamenei emerged as the IRGC’s and

hardline clerics’ preferred candidate to succeed Khomeini. There was only one hitch: Khamenei

did not have Khomeini’s religious credentials, while the competition did. Khamenei had a simple

solution: he threw his lot in with the IRGC, leaned heavily on them, and effectively promised a

partnership with the IRGC if they backed his play. The IRGC did, and Khamenei succeeded

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Khomeini as Supreme Leader and overall commander of the IRGC and Hezbollah, a role that

Khamenei has held ever since.

389. During this period in 1989, Khamenei wooed the IRGC by promising several

structural changes in how the Iranian regime would sponsor terrorism when he was Supreme

Leader. First, Khamenei would direct a massive expansion of the IRGC’s role in Iran’s

economy, as a vehicle for allowing the IRGC to self-finance its operations. (As part of this effort,

Khamenei later approved the creation of IRGC megafirm Khatam al-Anbiya in or about late

1989 or early 1990.) Second, Khamenei would greatly expand the share of Iranian regime

resources devoted to IRGC sponsorship of terrorism abroad, including through the IRGC’s

newly created (in 1989) Qods Force. Third, Khamenei would greatly expand the Iranian regime’s

alliance with Palestinian terrorists, including the newly created group Hamas. Khamenei

delivered on each of these promises and has enjoyed an ironclad, inseparable bond with the

IRGC ever since.

390. In 1990, Khamenei determined that the IRGC was not spending enough of the

money its fronts and charities raised on the IRGC’s mission, i.e., sponsoring terrorist attacks to

drive the United States out of the Middle East. To remedy this, and to optimize the amount of

cash the Iranian regime could supply to its proxies, including Hezbollah, Hamas, and PIJ,

Khamenei created a new organization: the Supreme Leader’s Office.

391. Throughout the 1990s, the IRGC and the SLO gradually expanded their role in

Iran’s economy while, in parallel, the IRGC intensified its attacks targeting the United States

worldwide, including in Europe, the Middle East, and Africa, among other places.

392. In 1999, Khamenei tripled down on his support for Palestinian terrorists,

including Hamas and PIJ, by greatly expanding the already sizeable aid the SLO and IRGC sent

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them; by some estimates, the Iranian regime was supplying Hamas with $50 million annually by

2000. By 2001, Hamas and PIJ leadership regularly visited Iran, had their own offices provided

by the IRGC, and coordinated Hamas and PIJ operations in Israel from Iran by collaborating

with representatives of the SLO, IRGC, and Hezbollah who were based there.

393. In June 2002, Khamenei met with Palestinian terrorists on the sidelines of an

Iranian-sponsored conference in Tehran explicitly designed to support Palestinian terrorist

attacks against Israelis that were known as the intifada. As Dr. Matthew Levitt reported in his

2007 book on Hamas:

Khamene’i pledged to … increase … funding by 70 percent “to cover the expense

of recruiting young Palestinians for suicide operations.” U.S. officials note that in
the period following the onset of violence in September 2000, Tehran instituted
an incentive system in which millions of dollars in cash bonuses … were
conferred … for successful attacks. Tehran often demands of its terrorist
beneficiaries videotapes or other evidence of successful attacks.

394. By the fall of 2002, Khamenei and the IRGC correctly anticipated a U.S. military

intervention in Iraq the following year. Accordingly, on September 9, 2002, Khamenei convened

Iran’s Supreme National Security Council in Tehran, which concluded, “It is necessary to adopt

an active policy in order to prevent long-term and short-term dangers to Iran” from the imminent

American occupation of Iraq next door. Thereafter, the IRGC, including its Qods Force, and the

SLO worked closely with Hezbollah to stand up a Shiite terrorist organization in Iraq that was

modeled after Hezbollah, trained by Hezbollah, and functioned as Hezbollah’s notorious Iraqi

branch, in effect.

395. By late April 2003, the United States had invaded Iraq and deposed Saddam’s

regime. By then, Hezbollah had already worked with Muqtada al-Sadr to create JAM, which

always tightly collaborated with Hezbollah thereafter.

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396. To finance this escalated campaign of terrorism, on June 8, 2003, the Iranian

regime published an official directive ordering the IRGC to dedicate the profits it earned from its

commercial fronts to its core mission, i.e., protecting and exporting the Islamic Revolution

through acts of terrorism (“Logistics Policy Directive”). The Logistics Policy Directive provided

that with respect to the profits derived from whenever “any unit” of “the Islamic Revolutionary

Guard Corps … and related organizations … sign[ed] contract agreements for civil projects,”

“[t]he monies received from any [such IRGC-related] contract … shall be deposited to the

Chancery, and its equivalent shall be placed at authority of the [IRGC] from the credit

determined in the annual budget, so that it would be used for the costs related to the [IRGC-

related] contract, also the strengthening of the [IRGC], and replacing [IRGC] equipment and

machinery parts” needed for its operations, i.e., terrorism. Moreover, under the Directive, the

IRGC “can, proportionally to [the IRGC’s] needs, exchange or sell excess material, and

equipment and machinery” to finance IRGC operations.

397. At bottom, the Logistics Policy Directive established—and was known by SCB to

establish—an ironclad rule: the IRGC was authorized and encouraged to act as contractors in

development schemes, subject to the requirement that any profit would be used to help the IRGC

“purchase and upgrade equipment for the Revolutionary Guards and fund its other activities,”

i.e., the IRGC’s central anti-American terrorist mission under Iran’s constitution. As a result,

IRGC profits were required under Iranian law to be reinvested in the IRGC’s specific lanes of

activity that supported terrorism. The Logistics Policy Directive, in effect, mandated that IRGC

profits derived from IRGC fronts be used primarily to enable IRGC-sponsored terrorism by

providing off-the-books funding sources for key IRGC weapons programs—the entire point of

the Logistics Policy Directive in the first place.

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398. From June 2003 through the present, the Logistics Policy Directive was always in

force, always applied to profits generated for IRGC front companies by SCB, and always

required that such IRGC profits be dedicated to sponsoring acts of terrorism.

399. SCB knew about the Logistics Policy Directive because, among other reasons,

SCB’s Iranian personnel knew about it, SCB’s in-house compliance and intelligence personnel

knew about it, SCB was familiar with basic Iranian government pronouncements as part of its

country-related diligence, and because media reports from at least 2007 onward alerted SCB to

such fact because such reports regularly described the Directive as a potential IRGC-related

compliance challenge for companies contemplating partnerships with IRGC-controlled entities.

400. In October 2007, for example, Iran scholar Ali Alfoneh reported the sum and

substance of Logistics Policy Directive and explained that the Directive was intended to help the

IRGC “purchase and upgrade equipment for the Revolutionary Guards and fund its other

activities,” i.e., IRGC-sponsored acts of terrorism.

401. On May 25, 2010, likewise, Iranian expatriate media outlet Peyk-e Iran reported

(as translated from Farsi) that “the IRGC … gradually expanded its power and influence since

1979” through fronts like “Khatam ol-Anbiya[’s] … projects extended across weapons

manufacturing, petrochemical plant, dams and bee-keeping, reflecting Iranian economy’s

dominance by a military-mafia institution,” for which “the Logistics Directive” served “as a

component of this expansion” because the Directive was an “‘order that all IRGC units … must

participate in civil projects as contractors,’” upon which the IRGC relied to assert the ”IRGC’s

dominance in security … institutions, and IRGC companies’ influence” through “IRGC-

controlled companies” that controlled Iran’s energy and communication sectors.

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402. Returning to the timeline, in 2005, while Khamenei and the IRGC were

sponsoring the murder of Americans in Iraq, they also seized an opportunity in Israel.

Specifically, by September 22, 2005, the Israeli government had fully withdrawn Israeli forces

from their positions inside Gaza, ceding administration of the area to Palestinians. Khamenei, the

IRGC, and SLO wasted no time: working through Hezbollah, they sponsored a massive surge of

resources to Hamas to ensure that it could seize control of Gaza and turn it into an Iranian

striking base directly under what the regime perceived to be Israel’s soft underbelly. Within a

year, the pace of Hamas attacks against Israeli civilians escalated dramatically, as a direct result

of the Iranian regime’s sponsorship.

403. On June 7, 2007, Hamas launched a terrorist campaign to seize control of the

Gaza Strip. Seven days later, Hamas’s killings had done their job, and Hamas assumed clear

control of all of Gaza. Immediately, it was apparent to the U.S. government—and SCB—that the

Iranian regime was behind Hamas’s attacks. In 2021, for example, Hamas scholar Jonathan

Schanzer observed, in looking back on this era, that:

Iran was widely suspected of being behind the orchestrated assault in Gaza.
Iranian assistance had likely helped Hamas build tunnels and train fighters.
Authors Beverly Milton-Edwards and Stephen Farrell were able to establish that
Iranian support increased “exponentially” after the 2006 elections. Senior Hamas
leader Mahmoud al-Zahar later admitted that Iran had given him $22 million in
cash in 2006. Months before the Gaza takeover, Yuval Diskin, the head of Israel’s
Shin Bet, noted, “We know that Hamas has started to dispatch people to Iran, tens
with the promise of hundreds, for months and maybe years of training.” … Hamas
leaders also later admitted that the group’s fighters received training in Iran.
During this time, the US government strove to prevent the flow of cash
from Iran to Hamas. In July 2007, the US Treasury Department issued sanctions
against Iran’s Martyr’s Foundation for funneling money from Iran to Hamas,
among other groups. Later that year, Treasury targeted Iran’s Quds Force and
Bank Saderat for funding Hamas, along with Hezbollah and PIJ. Through these
designations, Treasury’s message was clear: Iran was providing Hamas with
significant financial support.

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404. Meanwhile, in Iraq in 2007, the IRGC and SLO worked closely with Hezbollah—

which served as their face, agent, and primary interlocutor with JAM—to intensify terrorist

attacks targeting the United States there. Among other things, they intensified JAM’s

deployment—under Hezbollah’s in-country supervision—of explosively formed penetrators, a

bomb type that the U.K. government concluded in 2005 was associated “exclusively” with

Hezbollah, meaning that Hezbollah played a direct role in every attack in Iraq that involved an

EFP, which was based on Hezbollah designs and had been field-tested at scale by Hezbollah for

the first time during its 2006 hostilities with Israel. On January 20, 2007, a joint cell comprised

of Hezbollah and JAM that was funded and logistically aided by the IRGC, including the Qods

Force, attacked the Karbala Provincial Joint Coordination Center in Iraq, which resulted in the

kidnapping and murder of five U.S. soldiers, and was quickly confirmed by the U.S. and media

outlets to have been an example of IRGC-sponsored, Hezbollah/JAM-committed attacks in Iraq.

More broadly, the U.S. government conducted a “surge” in Iraq in 2007, which was focused

most of all on preventing Hezbollah and JAM attacks in Baghdad, during which Hezbollah and

JAM escalated their use of EFP attacks against the United States in Iraq.

405. In October 2007, the United States responded to the IRGC’s and Hezbollah’s

twinned escalation of IRGC-sponsored terrorism by Hezbollah, Hamas, and PIJ in Israel and by

Hezbollah and JAM in Iraq by formally recognizing the Qods Force for its direct, lethal support

to acts of terrorism committed by IRGC proxies, including Hezbollah, Hamas, and JAM.

406. On November 6, 2008, Treasury published a fact sheet intended to alert banks,

including SCB, to the extreme risk that illicit Iran-related transactions processed through the U.S.

banking system funded IRGC-sponsored acts of terrorism committed by IRGC proxies, including

Hezbollah, Hamas, PIJ, and Iraqi Shiite terrorists:

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Iran Misuses the International Financial System to Support Terrorism

Iran is the world’s most active state sponsor of terror. The support provided by the
regime to terrorist groups includes financing that is routed through the
international financial system, especially through Iranian state-owned banks.

• Iran’s Support to Terror. The Department of State designated Iran as a state

sponsor of international terrorism in 1984, and Iran remains the most active of the
listed state sponsors of terrorism, routinely providing substantial resources and
guidance to multiple terrorist organizations. For example, Hamas, Hizballah, and
the Palestinian Islamic Jihad (PIJ) maintain representative offices in Tehran to
help coordinate Iranian financing and training of these groups.

• Iran’s IRGC and IRGC-Qods Force Support Terrorist Groups. Elements of

[the] … IRGC … have been directly involved in the planning and support of
terrorist acts throughout the world, including in the Middle East …. The IRGC-
Qods Force, which has been designated under Executive Order 13224 for
providing material support to … terrorist groups, is the Iranian regime’s primary
mechanism for cultivating and supporting terrorist and militant groups abroad.
Qods Force-supported groups include: … Hizballah; Palestinian terrorists; [and]
certain Iraqi Shi’a militant groups …. The Qods Force is especially active in the
Levant, providing … Hizballah with funding, weapons and training. It has a long
history of supporting Hizballah’s military, paramilitary and terrorist activities, and
provides Hizballah with more than $100 to $200 million in funding each year. …

• Iran Uses its Banks to Finance Terrorism. … Iran has used its state-owned
banks to channel funds to terrorist organizations. Between 2001 and 2006, Bank
Saderat transferred $50 million from the Central Bank of Iran through Bank
Saderat’s subsidiary in London to its branch in Beirut for the benefit of Hizballah
fronts that support acts of violence. Hizballah also used Bank Saderat to send
funds to other terrorist organizations, including Hamas, which itself had
substantial assets deposited in Bank Saderat . … Treasury … designated Bank
Saderat under E.O. 13224 for providing financial services to Hizballah, Hamas
and PIJ . . . . Iran’s Bank Melli, which has been designated by the United States
under E.O. 13382 for proliferation-related activities, was used to transfer at least
$100 million to the IRGC-Qods Force between 2002 and 2006.

• Iran Lacks a Counter-Terrorist Financing Legal Regime. In addition to its

regime-directed support to terrorist organizations, Iran continues to lack a legal
framework to counter the risk of terrorist financing and has not indicated a
willingness to address this deficiency. The FATF’s October statement on Iran
notes that, while Iran has taken some steps towards implementing an anti-money
laundering regime, there is a lack of even such a minimal corresponding effort by
Iran in the area of counter-terrorist financing.

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407. On February 10, 2010, Treasury imposed substantial additional sanctions on the

IRGC and its economic fronts, including new sanctions targeting KAA, and stated, inter alia:

a. “Treasury today took further action to implement existing U.S. sanctions against [the]
IRGC … by designating an individual and four companies affiliated with the IRGC
pursuant to Executive Order (E.O.) 13382, which freezes the assets of designated
proliferators of weapons of mass destruction (WMD) and their supporters.”

b. “Khatam al-Anbiya …, the engineering arm of the IRGC that serves to help the IRGC
generate income and fund its operations. … Treasury also today designated [] companies
that are owned or controlled by, or that act on behalf of, [KAA].”

c. “‘As the IRGC consolidates control over broad swaths of the Iranian economy, displacing
ordinary Iranian businessmen in favor of a select group of insiders, it is hiding behind
companies like Khatam al-Anbiya and its affiliates to maintain vital ties to the outside
world,’ said Under Secretary for Terrorism and Financial Intelligence Stuart Levey.
‘Today’s action … will help firms worldwide avoid business that ultimately benefits the
IRGC and its dangerous activities.’”

d. “The IRGC has a growing presence in Iran’s financial and commercial sectors and
extensive economic interests in [inter alia] the … construction, and oil industries,
controlling billions of dollars of business. The profits from these activities … support the
full range of the IRGC’s illicit activities, including … support for terrorism.”

e. “Elements of the IRGC have also been designated for UN sanctions pursuant to UN
Security Council Resolutions (UNSCRs) 1737 and 1747. … The European Union has
also designated IRGC-affiliated companies, including [KAA]….”

Treasury’s February 10, 2010 IRGC sanctions rollout received widespread media coverage.

408. On June 9, 2010, the U.N. Security Council adopted Resolution 1929, which the

Council enacted only after formally: “[n]oting with serious concern the role of elements of the …

IRGC … in Iran’s proliferation sensitive … activities” and “noting the potential connection

between Iran’s revenues derived from its energy sector and the funding of Iran’s proliferation-

sensitive … activities.” As SCB knew, Resolution 1929, like every other U.N. Security Council-

related sanction targeting Iran, was primarily about halting the IRGC’s ability to use its

commercial fronts, including KAA, to finance and logistically support IRGC operations.

Resolution 1929 imposed sweeping sanctions that specifically targeted the IRGC and its use of

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KAA, the IRGC’s monopoly over Iran’s oil and gas sector, and IRGC-controlled Iranian banks,

to finance IRGC-sponsored international operations conducted by the Qods Force, including the

Qods Force’s acquisition and distribution of weapons of mass destruction, including missiles and

nuclear weapons. Resolution 1929 created a comprehensive sanctions regime, which was directly

based upon, referred to, and targeted, among others, Iran and the IRGC.

409. Paragraph 8 of Resolution 1929 prohibited a wide array of IRGC weapons exports

relating to missiles: “[A]ll States shall prevent the direct or indirect supply, sale or transfer to

Iran, from or through their territories or by their nationals or individuals subject to their

jurisdiction, or using their flag vessels or aircraft, and whether or not originating in their

territories, of any battle tanks, armoured combat vehicles, large calibre artillery systems, combat

aircraft, attack helicopters, warships, missiles or missile systems as defined for the purpose of the

United Nations Register of Conventional Arms, or related materiel, including spare parts, or

items as determined by the Security Council or the Committee established pursuant to resolution

1737 (2006) (‘the Committee’), decides further that all States shall prevent the provision to Iran

by their nationals or from or through their territories of technical training, financial resources or

services, advice, other services or assistance related to the supply, sale, transfer, provision,

manufacture, maintenance or use of such arms and related materiel, and, in this context, calls

upon all States to exercise vigilance and restraint over the supply, sale, transfer, provision,

manufacture and use of all other arms and related materiel.”

410. Resolution 1929’s sanctions primarily targeted the IRGC and the IRGC’s use of

Iran’s oil sector and banks to finance weapons purchases and exports. As the U.K. House of

Commons observed on October 13, 2010, for example, Resolution 1929 was understood to focus

“especially on the Islamic Revolutionary Guard Corps (IRGC).” Paragraph 12 of Resolution

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1929, for example, provided: “The Security Council … Decides that the measures specified in

paragraphs 12, 13, 14 and 15 of resolution 1737 (2006) shall apply also to the Islamic

Revolutionary Guard Corps (IRGC, also known as ‘Army of the Guardians of the Islamic

Revolution”) individuals and entities specified in Annex II, and to any individuals or entities

acting on their behalf or at their direction, and to entities owned or controlled by them, including

through illicit means, and calls upon all States to exercise vigilance over those transactions

involving the IRGC that could contribute to Iran’s proliferation-sensitive … activities ….”

411. Annex II of Resolution 1929, in turn, alerted SCB that “Entities owned,

controlled, or acting on behalf of the Islamic Revolutionary Guard Corps” included KAA and a

broad array of IRGC oil fronts that SCB knew were participants in the same transactions it

financed by servicing IRGC fronts like Caspian Petrochemical, such as Oriental Oil Kish.

412. Paragraph 22 of Resolution 1929 provided: “The Security Council … Decides

that all States shall require their nationals, persons subject to their jurisdiction and firms

incorporated in their territory or subject to their jurisdiction to exercise vigilance when doing

business with entities incorporated in Iran or subject to Iran’s jurisdiction, including those of the

IRGC …, and any individuals or entities acting on their behalf or at their direction, and entities

owned or controlled by them, including through illicit means ….”

413. Resolution 1929 also targeted the IRGC’s use of Iranian banks to finance IRGC

operations. Paragraph 21, for example, provided: “The Security Council … Calls upon all States,

in addition to implementing their obligations pursuant to resolutions 1737 (2006), 1747 (2007),

1803 (2008) and this resolution, to prevent the provision of financial services, including

insurance or re-insurance, or the transfer to, through, or from their territory, or to or by their

nationals or entities organized under their laws (including branches abroad), or persons or

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financial institutions in their territory, of any financial or other assets or resources ….” Paragraph

23, similarly, provided: “The Security Council … Calls upon States to take appropriate measures

that prohibit in their territories the opening of new branches, subsidiaries, or representative

offices of Iranian banks, and also that prohibit Iranian banks from establishing new joint

ventures, taking an ownership interest in or establishing or maintaining correspondent

relationships with banks in their jurisdiction to prevent the provision of financial services …”.

Paragraph 24, likewise, provided: “The Security Council …Calls upon States to take appropriate

measures that prohibit financial institutions within their territories or under their jurisdiction

from opening representative offices or subsidiaries or banking accounts in Iran ….”

414. Resolution 1929 also created continuing reporting structures, such as paragraph

36, which mandated reports from the International Atomic Energy Agency.

415. On June 16, 2010, Treasury sanctioned a wide swath of IRGC-controlled oil and

gas firms—which Treasury described as its “First Set of Actions in Response to President

Obama’s Call for Vigorous Enforcement of … Resolution 1929” and inter alia, sought to inhibit

the IRGC’s acquisition, redistribution, and use of some of the world’s most dangerous

weapons”—and warned:

Treasury announced … designations [comprising] … the first set of measures

from the United States implementing UNSCR 1929 and building upon the actions
mandated by the Security Council. … [and] highlight[ed] for the international
community Iran’s use of its financial sector, shipping industry and [IRGC] to
carry out and mask its … activities, and respond to the Council’s call for all states
to … prevent their own financial systems from being abused by Iran. …

Islamic Revolutionary Guard Corps (IRGC)

Treasury today is targeting … [two] [o]il and [g]as … subsidiaries of
Khatam al-Anbiya …, the engineering arm of the IRGC that serves to help the
IRGC generate income and fund its operations. KAA [is] owned or controlled by
the IRGC and is involved in the construction … [sector]. KAA was designated by
Treasury under E.O. 13382 in October 2007 and most recently under UNSCR

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1929. [The KAA oil and gas companies] were also sanctioned on June 9, 2010 by
the United Nations with the adoption of UNSCR 1929.
The IRGC maintains significant political and economic power in Iran. It
has ties to companies controlling billions of dollars in business and construction
projects and it is a growing presence in Iran’s financial and commercial sectors.
The IRGC has numerous economic interests related to … construction[] and the
oil industry … [including] … PETROPARS LTD …[,] [which] is an entity that is
wholly-owned by NICO. On November 26, 2008, NICO, a subsidiary of NIOC,
was identified by OFAC as an entity that is owned or controlled by the
Government of Iran.

416. A wide array of subsequent U.S. and U.N. reports and statements confirmed the

tight nexus between violations of Resolution 1929 and IRGC-sponsored acts of terrorism. True,

the U.S., U.N., and E.U. promulgated sanctions targeting the IRGC under several separate

authorities, including based upon the IRGC’s state sponsorship of terrorism through IRGC

proxies, proliferation of lethal weapons like rockets and drones to IRGC proxies, and hostage-

taking, kidnapping, and other similar abuses. At all times, however, SCB knew that all such U.S.,

U.N., and E.U. sanctions against the IRGC were intended to, and did in fact, reduce the risk of

IRGC-committed acts of terrorism, and that SCB’s violations of the applicable U.S., U.N., and

E.U. sanctions targeting IRGC weapons and human rights violations also enabled IRGC-

sponsored acts of terrorism. At all relevant times, SCB knew that its illicit financial services that

helped Iranian persons evade U.N. sanctions under Resolution 1929 directly enabled IRGC

sponsored terrorist attacks in the Middle East.

417. On June 22, 2010, for example, Treasury Under Secretary for Terrorism and

Financial Intelligence Levey testified before Congress that any bank’s violations of Resolution

1929 directly supported IRGC-sponsored terrorism (emphases added):

a. “With the adoption of [Resolution] 1929 …, the international community made clear that
Iran’s continued failure to meet its international obligations will have increasingly serious
consequences. … [With respect to] the so-called pressure track of [United States] strategy
[to deter IRGC-backed violence] … is intended to hold Iran accountable for its continued
refusal to address the international community’s concerns regarding its nuclear program,

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as well as its support for terrorism …. The adoption of Resolution 1929 marks an
inflection point in this strategy, as it broadens and deepens existing sanctions programs
on Iran and creates an opportunity for us to further sharpen Iran’s choices.”

b. “Resolution 1929 … broadens the existing UN sanctions framework, and it is important

to remember that each resolution builds upon earlier resolutions. Resolution 1929
enhances the international community’s obligation to impose measures on Iran’s financial
sector, businesses owned or controlled by the … IRGC … Implementation of the
financial provisions of the Resolution and its predecessors will be consequential,
provided that countries implement them robustly and faithfully. The implementation of
these provisions will also assist financial institutions around the world to avoid the risks
associated with business that supports the Iranian government’s proliferation activity and
support for terrorism.”

c. “[P]aragraph 22 of the Resolution [1929] obliges all states [to] require their nationals,
persons subject to their jurisdiction and firms incorporated in their territory…to exercise
vigilance when doing business with entities incorporated in Iran or subject to Iran’s
jurisdiction, including those of the IRGC …. Treasury … today published a public
advisory that explains the financial provisions of UNSCR 1929 and provides guidance on
steps that can be taken to mitigate the tremendous risks underscored by the Security
Council. Implementation of the financial provisions of the Resolution and its
predecessors will be consequential, provided that countries implement them robustly and
faithfully. The implementation of these provisions will also assist financial institutions
around the world to avoid the risks associated with business that supports the Iranian
government’s proliferation activity and support for terrorism.”

d. “Resolution 1929 highlights. . . . the risks associated with providing financial services to
Iran, makes it nearly impossible for financial institutions and governments to assure
themselves that transactions with Iran could not contribute to [illegal IRGC] activities.”

e. “[P]aragraph 23 of the Resolution calls upon states to prohibit in their territories the
opening of new branches, subsidiaries, or representative offices of Iranian banks, and also
[to] prohibit Iranian banks from establishing new joint ventures, taking an ownership
interest in or establishing or maintaining correspondent relationships with banks in their
jurisdiction [and] to prevent the provision of financial services if they have information
that provides reasonable grounds to believe that these activities could contribute to Iran’s
proliferation-sensitive nuclear activities. Consistent with this, governments are to take
steps to be certain that correspondent relationships with Iran cannot be used for illicit
conduct. Given the information described above regarding Iranian banks’ involvement in
Iran’s proliferation-sensitive activities, coupled with well-known information about
Iranian banks’ use of a range of deceptive conduct – such as concealing their identity by
stripping their names from transactions – it is nearly impossible for governments to
ensure that correspondent relationships with Iran are not abused for illicit purposes.”

Terrorism scholars also publicly warned the world, including SCB, in real-time.

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418. Moreover, on June 22, 2010, FinCEN published an advisory—titled “Update On

The Continuing Illicit Finance Threat Emanating From Iran”—that further alerted SCB (on

pages 1-2) that its transactions designed to help Iranian customers evade Resolution 1929 also

supported IRGC-sponsored terrorism:

a. “FinCEN[] is issuing this advisory to supplement information previously provided on the

serious threat of money laundering, terrorism finance, and proliferation finance
emanating from the Islamic Republic of Iran, and to provide guidance to financial
institutions regarding [Resolution] 1929, adopted on June 9, 2010.”

b. “UNSCR 1929 contains a number of new provisions which build upon and expand the
financial sanctions imposed in previous resolutions (UNSCRs 1737, 1747, and 1803) and
which are designed to prevent Iran from abusing the international financial system to
facilitate its illicit conduct … [and it] … requires States to ensure their nationals exercise
vigilance when doing business with any Iranian firm, including the … IRGC ….”

c. “These Security Council actions, in addition to [FATF] statements regarding the risks
posed by Iran and calling for countries to impose countermeasures, illustrate the
increasing risk to the integrity of the international financial system posed by:
• the Iranian financial sector, including the Central Bank of Iran;
• commercial enterprises that are owned or controlled by the IRGC, which was
designated by the State Department under Executive Order 13382 in 2007; and
• other Iranian entities supporting proliferation-related activities ….”

d. “Iran’s record of illicit and deceptive activity, coupled with its extensive integration into
the global financial system, increases the risk that responsible financial institutions will
… become involved in Iran’s illicit activities. Many of the world’s major financial
institutions have either cut off or dramatically reduced their relationships with Iranian
banks, leaving Iran’s financial institutions increasingly isolated. Despite the degradation
in Iran’s access to correspondent and other financial relationships with major
international financial institutions, Iran continues to maintain a visible presence in the
international financial system and is constantly seeking to expand its banking presence
internationally.”

e. “Public sources indicate that Iranian banks operate globally, including seven state-owned
commercial banks, four specialized government banks, and six privately owned Iranian
financial institutions with more than four dozen overseas branches and subsidiaries in
Asia, Europe, South America, and the Middle East. Many of these banks report
significant relationships in key global financial centers. … Treasury is also concerned
that Iranian banks (both designated and non-designated) are seeking to expand their
international presence in order to circumvent the impact of sanctions on Iran’s state-
owned banks, presenting a risk that Iran’s illicit conduct will shift to those banks that are
able to maintain ties to the international financial sector.”

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419. The U.N.’s real-time public reports pursuant to Resolution 1929 also alerted SCB

that SCB’s transactions with Iranian customers designed to evade Resolution 1929 directly

enabled Qods Force and Hezbollah-sponsored proxy attacks. On June 4, 2012, for example, the

Security Council reported that, with respect to the IRGC’s oil- and gas-related entities subject to

sanctions under Resolution 1929:

Some Member States have informed the Panel that the [Islamic Revolutionary
Guard] Corps also controls informal economic channels. In particular, some
Iranian charitable organizations (foundations) controlled by the Corps are
believed to support the Corps’ economic activities, including provision of
informal channels for business transactions. Such foundations include the Islamic
Revolutionary Guards Corps Cooperative Foundation (Bonyad-e Taavon-e Sepah)
and the Foundation of the Oppressed (Bonyad-e Mostazafan), both of which
include incumbent and/or former officers of the Corps as board members.

As SCB always knew, the Foundation for the Oppressed and the IRGC Cooperative Foundation

were both notorious IRGC fronts; the former was a notorious, and direct, front for Hezbollah and

Qods Force operations, infra, while the latter was a well-known, notorious front for the IRGC’s

other elements that also served to finance Hezbollah, the Qods Force, and their proxies. On June

1, 2015, similarly, the Security Council reported pursuant to Resolution 1929 that, with respect

to the sanctioned persons targeted by Resolution 1929, “media reports point[ed] to continuing

[Iranian, including Qods Force] military support and alleged arms transfers to the Syrian Arab

Republic, Lebanon, Iraq, … and to Hizbullah and Hamas” and “further note[d] that Iranian

officials … [did] not deny[]” providing such “military support” to any of the above-identified

IRGC terrorist proxies.

420. Contemporaneous warnings from terrorism scholars and Members of Congress

also alerted SCB that violations of sanctions under U.S. and U.N. counterproliferation

authorities, including Resolution 1929, that targeted the IRGC foreseeably enabled IRGC-

sponsored acts of terrorism committed by IRGC proxies, including Hezbollah, Hamas, and PIJ.

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While sanctions announcements distinguished between terrorism and proliferation, SCB knew,

as did any other sophisticated participant in the Iranian, financial services, and U.S. markets, that

when the IRGC and Hezbollah fronts engaged in transactions to fund terrorism, both groups used

all firms designated under the proliferation sanctions to enable terrorist attacks. On February 16,

2007, for example, former Treasury official Dr. Matthew Levitt warned:

Last week, … Ayatollah Khamenei threatened to hit back at U.S. interests

“worldwide” if attacked … [through the] IRGC ….
The question of the day is how to … confront[] [Iran] over its … support
for terrorist groups and its involvement in improvised explosive device (IED)
networks in Iraq. U.S. officials are pressing their European counterparts to
discourage investment and financial transactions with Iran … and to work with
the private sector to deny Iran access to outside financial services. …
And therein lies the answer. The most robust and effective non-military
tool available to the international community is to apply Resolution 1737 in full.
While many pundits blasted UNSCR 1737 as toothless and ineffective, its full
implementation would employ travel bans and targeted financial sanctions against
the very tool of Iranian foreign policy responsible for the regime’s unacceptable
conduct: the IRGC.
The annex to the resolution listing entities involved in Iranian proliferation
activity does not include the IRGC. But two key leaders, IRGC commander Major
Gen. Yahya Rahim Safavi and IRGC air force chief General Hosein Salimi, are
listed …. Under the resolution, … by virtue of listing the overall head of the
IRGC …, the U.N. empowered a strict reading suggests it requires member states
to freeze IRGC funds and financial assets.
The IRGC … provid[es] funds, weapons, improvised-explosive-device
technology and training to terrorist groups like Hezbollah and Hamas and
insurgents attacking coalition and Iraqi forces in Iraq. …
Moreover, the IRGC controls vast financial assets and economic
resources. While most of the actual funds and assets are in Iran and beyond
seizure, the IRGC’s business and industrial activities especially those connected
to the oil and gas industries are heavily dependent on the international financial
system. Consider, for example, the $2.09 billion contract to develop parts of the
South Pars natural-gas field, or the $1.3 billion contract to build parts of a
pipeline, both meted out to the IRGC’s engineering arm, the Khatam-ol-Anbia. …
A simple reading of Resolution 1737 requires member states to apply
financial measures against the financial assets and economic resources controlled
by the head of the IRGC. Moreover, targeted financial measures against the IRGC
… pulls at the purse strings of the specific element of the Iranian bureaucracy
responsible for the regime’s most egregious behavior.

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421. A colloquy between Dr. Levitt and Representative Ted Deutsch during the

former’s testimony before Congress on March 4, 2014 was instructive of SCB’s knowledge

throughout the era from 2007 through 2017 (emphases added):

REP. DEUTCH: “[I]n the area of banking sanctions, … can you contrast
sanctions that exist with respect to the nuclear area and sanctions that exist for
terror funding? … [D]o the sanctions that are in place with respect to Hezbollah
and terror funding go as far as in the … nuclear area [e.g., U.S.
counterproliferation sanctions and UNSCR 1929]? And if not, why not?”

DR. LEVITT: “… [I]n a nutshell, the vast majority … of the banking sanctions
are technically proliferation sanctions.
is the … only one I can think of right now, that’s actually a terrorism basis. But
it’s not like Hezbollah uses this bank for terrorism and this bank for
proliferation. And whatever the reason, it has the impact across the board. …
I’m less concerned with which executive order is used -- terrorism or
proliferation or others -- to effect the change. …”

REP. DEUTCH: “… You said most of the banking sanctions that exist now are
focused on proliferation. … [W]hy would we draw that distinction between
proliferation and terror financing, … Dr. [Levitt]?”

DR. LEVITT: “More often than not, it just has to do with what information is
most readily available, without declassifying really sensitive stuff, that can
underscore the designation. So if there’s a bad bank, one of the things that will be
looked at is, what’s the world of information that’s available and what can be
most easily made public and available?”

422. On July 1, 2010, President Obama signed the Comprehensive Iran Sanctions,

Accountability, and Divestment Act of 2010 (“CISADA”), Pub. L. No. 111-195, 22 U.S.C.

§ 8501, et seq., which provided, inter alia:

a. 22 U.S.C. § 8501(1): “Congress makes the following findings: (1) The … Government of
Iran[’s] … support for international terrorism[] represent a threat to the security of the
United States.”

b. 22 U.S.C. § 8513(a): “Congress makes the following findings: (1) [FATF] is an

intergovernmental body whose purpose is to develop and promote national and
international policies to combat money laundering and terrorist financing. … (4) The
[FATF] has repeatedly called on members—(A) to advise financial institutions in their
jurisdictions to give special attention to business relationships and transactions with Iran,
including Iranian companies and financial institutions; (B) to apply effective

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countermeasures to protect their financial sectors from risks relating to money laundering
and financing of terrorism that emanate from Iran; (C) to protect against correspondent
relationships being used by Iran and Iranian companies and financial institutions to
bypass or evade countermeasures and risk-mitigation practices; and (D) to take into
account risks relating to … financing of terrorism when considering requests by Iranian
financial institutions to open branches and subsidiaries in their jurisdictions. (5) At a
February 2010 meeting of [FATF], [FATF] called on members to apply countermeasures
‘to protect the international financial system from the ongoing and substantial … terrorist
financing … risks’ emanating from Iran.”

c. 22 U.S.C. § 8519: “SENSE OF CONGRESS REGARDING IRAN’S

REVOLUTIONARY GUARD CORPS AND ITS AFFILIATES. It is the sense of
Congress that the United States should—(1) persistently target Iran’s Revolutionary
Guard Corps and its affiliates with economic sanctions for its support for terrorism …;
(2) identify, as soon as possible—(A) any foreign individual or entity that is an agent,
alias, front, instrumentality, official, or affiliate of Iran’s Revolutionary Guard Corps; (B)
any individual or entity that—(i) has provided material support to any individual or entity
described in subparagraph (A); or (ii) has conducted any financial or commercial
transaction with any such individual or entity; and (C) any foreign government that—(i)
provides material support to any such individual or entity; or (ii) conducts any
commercial transaction or financial transaction with any such individual or entity; and (3)
immediately impose sanctions, including travel restrictions, sanctions authorized pursuant
to this Act or the Iran Sanctions Act of 1996, as amended by section 102 of this Act, and
the full range of sanctions available to the President under the International Emergency
Economic Powers Act (50 U.S.C. 1701 et seq.), on the individuals, entities, and
governments described in paragraph (2).”

423. The sum and substance of this avalanche of sanctions between late 2007 and the

end of 2010 was simple: the entire landscape of U.S. policy towards Iran was transformed

through a series of new findings concerning the inextricable connection between a bank that

transacts with IRGC fronts and the IRGC’s ability to sponsor attacks.

V. Iran’s Terrorist Sponsors Seized Sector-Wide Monopolies In Key Iranian Markets

To Fund Terrorist Attacks

424. From 2007 through 2020, Iran’s Terrorist Sponsors notoriously controlled well

over half of the entire Iranian economy; some estimates ranged as high as 85%. Indeed, the U.S.

government has concluded similarly. In 2021, for example, Treasury observed that the Supreme

Leader’s and IRGC’s collaborative post-2007 economic takeover alerted banks, like SCB, that

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Iran’s Terrorist Sponsors were collectively “said to control more than half of the Iranian

economy.” This provided the context for the Supreme Leader’s and IRGC’s shared strategy to

support violence by funneling profits from monopolies to IRGC proxies.

425. Between 2005 and 2009, using fronts they controlled, the IRGC and SLO

orchestrated a monopolistic takeover of key components of Iran’s economy. Contemporaneous

reports confirmed as much. For example, per a DoD analysis published on October 12, 2011:

The IRGC’s expansion beyond the roles and tasks traditionally associated with
military or security services is most pronounced in its dominant role in Iran’s
economy. Speaking at the change of command at the Khatam ol-Anbia Base
Complex, IRGC commander [Mohammad Ali] Jafari bluntly summarized his
position, “The IRGC must play a leading role in the nation’s economic fronts.”
Referencing the IRGC’s role in the Iran-Iraq war, Jafari further rationalized the
IRGC’s economic responsibilities, “The IRGC actually goes into areas of activity
the other sectors cannot do, as in [Iran-Iraq] war where … the IRGC had the duty
to go on the battlefield with all its being. We are doing the same thing today in
economic areas.” …
Through [the IRGC’s] complex network of foundations and their
subsidiary banks, assisted by generous subsidies, the IRGC has diligently
expanded its business holdings at a deep discount. The true private sector only
gained 19% of the “privatized” public assets, while the cooperatives consumed
68% of the resources. The IRGC has systematically militarized rather than
privatized the Iranian economy.

426. After the U.S. inaugurated the new era of sanctions targeting Iran’s Terrorist

Sponsors with its designations of the IRGC, Bank Saderat, Bank Melli, and associated persons in

October 2007, the SLO and the IRGC responded to the new sanctions era by leaning heavily into

Iran’s longstanding tolerance of monopolies, by seizing entire economic sectors and awarding

them to the IRGC. Ayatollah Khamenei’s strategy was simple: keep the IRGC loyal through

industrial sector-scale bribes in the form of the Ayatollah’s provision of monopolies to the IRGC

in key Iranian industrial sectors that overlapped with the IRGC’s terrorist mission. As the

Christian Science Monitor reported in 2009, “[Ayatollah] Khamenei … had to pay dearly for

such [IRGC] backup, however, says [Ali] Alfoneh [of the American Enterprise Institute]. ‘The

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IRGC’s support for [Ayatollah] Khamenei does not come cheap, and he has had to bribe the

IRGC with economic monopolies,’ [said Alfoneh]. … The result has been a ‘very deep and

symbiotic relationship with the supreme leader, and [the IRGC] have used the Ahmadinejad

administration to not just solidify their hold on power, but to enrich themselves at the same

time,’ says [Alireza] Nader of RAND.” Others reported similar findings. Ayatollah Khamenei’s

strategy leveraged a pre-existing feature of Iran’s economy: the heavy tendency towards

monopolies dating back to the Shah, which trend continued at all relevant periods. As the

Economist alerted SCB in 2011, “Iran’s economy” was “[a]lmost entirely reliant on oil receipts,

unproductive and monopolistic” at the same time “the Revolutionary Guard’s commercial

divisions [took] over ever larger bits of the economy.”

427. From 2007 through 2009, the SLO and the IRGC rapidly seized monopolistic

shares of key sectors of Iran’s economy, which seizures were all complete by the end of 2009.

428. U.S. government-published statements alerted SCB to such risks in real time. On

July 26, 2006, for example, Dr. Kenneth Katzman, a Middle East Specialist at the Congressional

Research Service, testified before Congress that “key [Iranian] leaders and factions have gained a

substantial measure of control over major segments of the Iranian economy, avoiding virtually

any official transparency or accountability,” which allowed “Iran’s leaders … to steer the

proceeds of parts of the economy to provide patronage.” In 2009, similarly, seven (U.S.

government-funded) RAND Corporation Iran scholars publicly observed “the IRGC’s …

monopolization of key business sectors” in Iran. Likewise, in 2009, a State report about Iran

warned that its “hard-line clerical establishment … grew wealthy through its control of bonyads

… that monopolize[d] many sectors of [Iran’s] economy ….”

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429. Such real-time warnings also directly warned SCB that the IRGC’s ability to

leverage its control of entire sectors of Iran’s economy directly funded IRGC-sponsored terrorist

attacks committed by Hezbollah, Hamas, and other IRGC proxies. On October 6, 2009, for

example, Treasury Under Secretary Levey testified before Congress that:

In the name of privatization, the IRGC has taken over broad swaths of the Iranian
economy. Former IRGC members in Iranian ministries have directed millions of
dollars in government contracts to the IRGC for myriad projects, including
developing the South Pars gas field …. Furthermore, the IRGC seeks to
monopolize black-market trade of popular items, funneling the proceeds from
these transactions through a patronage system and using them to help subsidize
the government’s support for terrorist groups.

On June 22, 2010, Treasury Under Secretary Levey testified before Congress that “the

Revolutionary Guards … has provided material support to … Lebanese Hizballah, Hamas,

Palestinian Islamic Jihad, and others,” the needed funding for which compelled the IRGC to

“assume[] control over broad areas of the Iranian economy.”

430. Terrorism scholars also concluded that the IRGC seized monopolies during this

period to support its proxies’ acts of terrorism.

431. The Supreme Leader and IRGC strategy for monopolization focused on key

sectors: they did not seek to control the entire economy, just those sectors that were inextricably

connected to the IRGC’s ability to sponsor terrorism. Consequently, from 2007 through 2020,

the IRGC notoriously exercised a monopoly over certain IRGC “exclusive sectors” of Iran’s

economy, including Iran’s oil, gas, construction, import/export, and communications sectors. As

Dr. Michael Rubin testified on April 19, 2016:

[T]he IRGC … maintains a stranglehold over trade and the economy and so has
become the chief if not sole beneficiary from the hard currency now flowing into
Iran. Here the problem is … Khatam al-Anbiya, the IRGC’s economic wing. To
understand what Khatam al-Anbiya is, picture the U.S. Army Corps of Engineers
combined with Bechtel, Halliburton, KBR, Shell, Exxon, Boeing, and Northrop-
Grumman, all rolled up into one. Today, Khatam al-Anbiya monopolizes heavy

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industry, shipping, electronics, manufacturing as well as import-export. All

together, it controls perhaps 40 percent of the Iranian economy. …
Under former President Mahmoud Ahmadinejad, IRGC-linked companies
received upwards of $50 billion in no-bid contracts in the oil industry alone. In
short, even if President Hassan Rouhani were to take the IRGC’s official budget
to zero, it would be facing less of a budget cutback proportionately than the U.S.
military has through sequestration. …
Iran today has at its disposal a hard currency windfall which will enable it
to support proxies to pursue its ideological goals with an ease that it has not
enjoyed in decades.
Against this backdrop of Iranian empowerment, it is important that the
United States recognize that responding to Iranian bluster and complaints with
incentive and greater access to the U.S. and European investment and financial
markets is counterproductive to regional security. It is also essential to recognize
the depth of IRGC involvement in almost every sector to which U.S. and
European firms might consider investing. To bolster both U.S. security and that of
Israel and other American regional allies requires draining rather than augmenting
IRGC coffers. This will ultimately mean ... greater vigilance absent diplomatic
subjectivity to IRGC commercial involvement and terror finance.

432. On October 22, 2017, the New York Times likewise reported that “Khatam Al

Anbiya … is the most important economic arm of Iran’s elite Islamic Revolutionary Guards

Corps.” It is, the New York Times reported, “a giant construction company [that] direct[ed] its

operations across Iran, building mosques, airports, oil and gas installations, hospitals and

skyscrapers,” “led by a military commander” (i.e., IRGC Commander Mohammad Ali Jafari),

and was part of the IRGC’s “monopoly on large sectors of the economy.”

433. Despite the substantial nature of the IRGC’s and SLO’s involvement throughout

Iran’s economy from 2007 through present, Plaintiffs do not allege that the IRGC monopolized

every—or even most—segments of Iran’s economy. While the IRGC and SLO had substantial

interests in every Iranian economic sector, they only exercised a monopoly in certain sectors,

including the six sectors alleged herein. Among other Iranian market sectors, the IRGC exercised

influence but did not have a monopoly in, inter alia: (1) Accounting; (2) Agriculture; (3)

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Domestic Retail; (4) Foodstuffs and Groceries; (5) Legal Services; (6) Music; (7) Publishing; (8)

Real Estate; (9) Restaurants and Hookah Bars; (10) Textiles; and (11) Utilities.

434. Below, plaintiffs identify six relevant IRGC market segment monopolies that

provided the context for SCB’s transactions alleged herein: (1) Energy; (2) Construction; (3)

Sanctions Evasion; (4) Finance; (5) Import/Export; and (6) Communications.

A. The Energy Sector: Oil, Gas, and Petroleum-Based Products

435. The Supreme Leader’s provision of monopolies to the IRGC began in the energy

sector, and for good reason: as a U.S. government-published analysis of the IRGC later warned,

“[b]y far, the IRGC’s greatest economic instrument is its influence over the energy sector, which

accounts for over 80% of the regime’s revenue.”

436. In June 2006, the Supreme Leader and the IRGC effectively announced their

intention to monopolize Iran’s energy sector when they caused the awarding of the largest energy

project in Iranian history—its South Pars field, which connected to Caspian routes via pipeline—

to notorious IRGC firm Khatam al-Anbiya.

437. Indeed, an IRGC general signed for the cameras on behalf of Khatam al-Anbiya,

which photo was then circulated throughout global media by the IRGC’s Mehr News Agency:

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438. Public testimony by U.S. officials confirmed that the IRGC seized South Pars as

part of its plan to monopolize Iran’s oil sector. On July 26, 2006, for example, Dr. Katzman, a

Middle East Specialist at the Congressional Research Service, testified before Congress that “the

Revolutionary Guard[’s] … motivations for expanding its economic role are apparently to

provide rewards for senior officers, and to generate revenue to supplement the budget allocated

to the Guard by the government. The Guard has formed contracting firms to bid on government

projects, using its strong political influence to win business. In one recent example, one of the

firms owned by the Guard, called ‘Ghorb,’ [i.e., Khatam al-Anbiya] is being awarded a $2.3

billion deal to develop two phases of Iran’s large South Pars gas field. Most of the other phases

have been awarded to well-known multi-national energy firms, and the work given to Ghorb

[KAA] had originally been awarded to Norway’s Aker Kvaerner, but was re-tendered. This

suggests that the Guard exerted political influence to win the [South Pars] contract and take it

away from what most industry experts would consider a more capable firm.”

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439. In June 2008, the SLO and IRGC further cemented their monopoly over all

Iranian petroleum-related assets when Ayatollah Khamenei decreed that the Foundation for the

Oppressed—which was a front shared by the SLO and IRGC—would be responsible for

negotiating, collecting, and redistributing all funds associated with Iranian petroleum exports.

440. When SCB deliberately helped Iranian entities evade sanctions targeting their

sponsorship of terrorism, SCB knew that the Supreme Leader and IRGC had seized a monopoly

in Iran’s energy sector, operationalized through, inter alia, the SLO, the Foundation for the

Oppressed, and Khatam al-Anbiya (including their respective agents and affiliates). Having

seized their energy monopoly in 2006, the SLO and the IRGC aggressively sought to expand

their respective reach into their newfound monopoly from 2007 through 2011 by vertically

integrating the SLO’s and IRGC’s fronts, operatives, and agents throughout all energy firms and

projects in Iran or subject to Iranian investment outside of Iran.

441. By spring of 2011, the SLO’s and IRGC’s shared monopoly over Iran’s entire oil

and gas industry—including associated construction, financing, shipping, and logistics—was

officially enshrined in a new joint SLO/IRGC entity that had full control, supervision, and

ownership of all Iranian companies operating in Iran’s oil and gas sector.

442. On March 10, 2011, Ayatollah Khamenei decreed that all oil and gas contracts

would be awarded by Petro Nahad, a newly created front established by the SLO and operated

jointly by, and for the benefit of, the SLO and the IRGC, including IRGC leaders like

Commander of the Qods Force Qasem Soleimani (who received a direct cut of SLO/IRGC oil

profits) and Soleimani’s counterpart, Commander of the IRGC Mohammad Ali Jafari (who was a

direct, and publicly identified, beneficiary of SLO/IRGC oil profits derived from trades routed

through the UAE, necessarily including all of SCB’s UAE-related oil and gas-related

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transactions alleged herein). They did so by creating Petro Nahad, which was a supervisory

entity under the SLO’s auspices that was assigned complete authority over all energy projects,

deals, companies, and decisions in Iran. Simply put, on March 10, 2011, Ayatollah Khamenei

made official the SLO’s and IRGC’s previously understood effective monopoly on the Iranian

oil and gas sector, which the IRGC and SLO had fully accomplished by 2006.18

443. Real-time reports by the United States, terrorism scholars, human rights groups,

and Iranian media outlets alerted SCB that the SLO and IRGC created Petro Nahad and used it to

exercise a full monopoly over Iran’s energy sector, and directly financed the activities of overall

IRGC commander—and notorious Hezbollah, Hamas, and JAM supporter—Mohammad Ali

Jafari. On May 3, 2011, for example, Iran Press News reported:

On March 10, 2011, Khamenei decreed that all oil field projects, contracts and oil
purchase agreements must be made exclusively by Petro Nahad. All existing
companies and organizations responsible for such deals – Petro Sina Arya, Petro
Pars, National Iranian Drilling Company (a subsidiary of the National Iranian Oil
Company), and the Industrial Development and Renovation Organization (IDRO)
– would henceforth operate under Petro Nahad’s direct control.
All contracts relating to gas and oil would now be awarded solely by Petro
Nahad. All revenues would be deposited exclusively into an account belonging to
Petro Nahad.
Khamenei further directed that all of Petro Nahad’s financial and
administrative affairs be assigned to a three-man board of directors, two of whom
are members of his family. Those members are: Mojtaba Khamenei, the Supreme
Leader’s son; Gholamali Haddad Adel, a member of the regime’s Expediency
Council who happens to be Mojtaba Khamenei’s father-in-law; and Majid
Hedayatzadeh.
Fazel Larijani, a member of the famous family allied with the Supreme
Leader and former diplomat in Ottawa, and Hojatollah Ghanimi Fard, a deputy oil
minister since 1997 in charge of marketing for crude oil and NIOC’s overseas
divisions, were appointed as international affairs directors for Petro Nahad. …
Any Petro Nahad contract is considered confidential, with strict
prohibitions against their disclosure. Even though Petro Nahad is a government
entity, the contracts are not available to parliament’s budget committee.

18
To be clear: The IRGC seized control of the energy sector by 2006, and the SLO joined in
control by 2008 when the Foundation for the Oppressed—jointly controlled by the IRGC and the
SLO—assumed a leadership role in all Iranian oil sales.

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Revolutionary Guards commander gets some of the spoils

Fazel Larijani recently brought Revolutionary Guards (IRGC)
Commander Mohammad Ali Jafari in on Petro Nahad deal with the United Arab
Emirates. The deal reportedly would sell the UAE oil products below market
price in exchange for $89 billion in cash and $89 billion in imported consumer
goods from Dubai over a 23-year period.

Opportunity for the opposition

The upside to this opaque, corrupt, nepotistic control of Iran’s oil wealth is
that the scheme makes it easier for Western democracies to impose sanctions on
the regime’s oil sector. All they have to do is embargo Petro Nahad and its
subsidiaries.

444. On May 24, 2012, State publicly warned that “The oil sector was embroiled in

financial scandal throughout the year.” In so doing, State effectively vouched for the Iran Press

News May 3, 2011 report above:

In May [2011,] [Iranian] opposition Web sites reported that on March 10, [2011,]
[Ayatollah] Khamenei decreed that all oil and gas contracts would be awarded by
Petro Nahad, a new entity established within his office and not subject to
parliamentary or regulatory oversight. All revenues would be deposited into an
account belonging to that organization. Further, according to these reports, all
administrative and financial decisions of Petro Nahad were to be controlled by a
three-person board of directors, whose members included Khamenei’s son,
Mojtaba Khamenei, and Gholamali Haddad Adel, a member of the Expediency
Council and Mojtaba’s father-in-law.

445. Terrorism scholars also publicly reported, in real-time, that the SLO and IRGC

used Petro Nahad to deepen and optimize their extraction of cash from their energy monopoly in

order to finance acts of terrorism. On June 4, 2013, for example, IRGC scholars Emanuele

Ottolenghi and Saeed Ghasseminejad warned that the Supreme Leader had appointed “Gholam

Ali Haddad Adel, … the father-in-law of the Supreme Leader’s son, Mojtaba Khamenei …[,]to

the board of directors of Petro Nahad alongside his son Mojtaba” when “Khamenei himself

recently established Petro Nahad to control all energy-sector contracts, thereby evading any

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parliamentary oversight or public scrutiny” throughout “[t]he country’s energy sector” in

response to “the weight of [United States counterterrorism] sanctions.”

446. The United States publicly confirmed the SLO’s and IRGC’s seizure of a

monopoly over the Iranian energy sector as a tool for financing terrorism. On October 13, 2011,

for example, Treasury Under Secretary David S. Cohen testified before Congress that:

Sanctions have also led to the IRGC taking over key aspects of Iran’s economy,
exacerbating the cronyism and corruption that pervades the Iranian regime. We
have seen this in a number of areas. Khatam al-Anbiya, the U.S.-, EU-, and [U.N.
Security Council]-designated engineering arm of the IRGC, has been recruited to
develop key energy resources. The IRGC, through its sanctioned affiliates Bonyad
Tavon Sepah and Mehr Bank, took over Tidewater, a port operator that until a few
years ago had been privately owned. And President Ahmadinejad recently
appointed Rostam Ghasemi, a U.S. and EU-designated IRGC commander and
former leader of Khatam al-Anbiya, as Minister of Oil. This appointment was
applauded by the IRGC, which characterized Ghasemi’s new role as a
“meaningful and critical response to the attacks against the [IRGC] from the
west[]. . . . ” . . . Furthermore, the inclusion of the IRGC throughout the Iranian
[energy] economy has opened up Iran to greater pressure through sanctions.

447. Looking back on this era in 2019, Iran scholar Khosrow Semnani observed that

Khamenei’s sponsored “power and money grab by the … IRGC” was completed by “2009”:

Under the guise of evading sanctions, an oil mafia with ties to the IRGC, and
acting with the blessing of Iran’s supreme leader, consolidated its grip over the
Iranian state. Billions in no-bid contracts were awarded to the IRGC by the
Petroleum Council … established in the Oil Ministry in 2006. Yet, despite the
significance, scale and volume of these contracts, Iran’s oil and gas sector
operated as a closed and incestuous system rigged in favor of insiders. Under the
guise of ‘destroying Israel’ …, IRGC cronies positioned themselves to benefit
from sanctions. All they had to do was to sell Iran’s oil, in unknown quantities, at
a discount and pocket the difference by importing goods at a premium. For these
thieves of state, … the shadow of sanctions … served as both the excuse and
opportunity for pillaging Iran’s oil sector.

448. The United States has formally confirmed that the Iranian regime exercised a

monopoly over Iran’s petroleum sector and used such monopoly to fund terrorist attacks by

IRGC proxies. On August 6, 2018, for example, President Trump signed Executive Order

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13,846, which imposed sector-wide sanctions targeting the energy sector in Iran based on a

formal finding that all revenue generated by Iran’s petroleum industry funded Iranian regime-

sponsored terrorist attacks committed by IRGC proxies in the Middle East:

a. “[T]o advance the goal of applying financial pressure on the Iranian regime in pursuit of
a comprehensive and lasting solution to the full range of the threats posed by Iran,
including Iran’s … network and campaign of regional aggression, its support for terrorist
groups, and the malign activities of the Islamic Revolutionary Guard Corps and its
surrogates, [I] hereby order as follows: …”

b. “Sec. 2. Correspondent and Payable-Through Account Sanctions Relating to Iran’s

Automotive Sector; Certain Iranian Persons; and Trade in Iranian Petroleum, Petroleum
Products, and Petrochemical Products. (a) The Secretary of the Treasury, in consultation
with the Secretary of State, is hereby authorized to impose on a foreign financial
institution the sanctions described in subsection (b) of this section upon determining that
the foreign financial institution has knowingly conducted or facilitated any significant
financial transaction: (i) on or after August 7, 2018, for the sale, supply, or transfer to
Iran of significant goods or services used in connection with the automotive sector of
Iran; (ii) on or after November 5, 2018, on behalf of any Iranian person included on the
SDN List (other than an Iranian depository institution whose property and interests in
property are blocked solely pursuant to Executive Order 13599) or any other person
included on the SDN List whose property and interests in property are blocked pursuant
to subsection 1(a) of this order or Executive Order 13599 (other than an Iranian
depository institution whose property and interests in property are blocked solely
pursuant to Executive Order 13599); (iii) on or after November 5, 2018, with NIOC or
NICO, except for a sale or provision to NIOC or NICO of the products described in
section 5(a)(3)(A)(i) of ISA provided that the fair market value of such products is lower
than the applicable dollar threshold specified in that provision; (iv) on or after November
5, 2018, for the purchase, acquisition, sale, transport, or marketing of petroleum or
petroleum products from Iran; or (v) on or after November 5, 2018, for the purchase,
acquisition, sale, transport, or marketing of petrochemical products from Iran.”

449. Since 2006, reports and statements published by the United States, Iranian regime,

Iranian opposition, media, terrorism scholars, and NGOs alerted SCB that its energy sector-

related transactions concerning an Iranian deal, project, and/or counterparty (including oil, gas,

and associated financing, construction, shipping, and logistics) that participated in the IRGC’s

monopoly over the oil and gas sector, including South Pars, supported IRGC-sponsored terrorist

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violence committed by IRGC proxies given the IRGC’s monopoly on the sector. Such warnings

included, but were not limited to (emphases added):

a. Sharq (Iranian Newspaper), June 30, 2006: “Some members of [Iran’s parliament] …
sent a written note to [President Ahmadinejad] with regard to the reason for the award of
a 2 billion dollars contract for the expansion of phases 15 and 16 of [South] Pars… to the
[IRGC]. This note was read out at yesterday’s open session of [parliament]. Recently, a 2
billion dollars contract for the expansion of phases 15 and 16 of [South] Pars …, was
signed between the Petroleum Ministry and the IRGC, without inviting any tenders. The
[Iranian parliamentarians] … called for an inquiry into the manner of the award of the
above contract, and its financial sources. ... In conclusion, the members of [parliament]
… have elaborated: Will not the delegation of economic projects, be construed as a
monopoly of oil-sector projects in the hands of the IRGC, and the awarding of political
privileges by the government?”

b. Inter Press Service, December 29, 2009: “News that [the] … Revolutionary Guard Corps
is withdrawing a billion dollars from the country’s Foreign Reserve Fund in order to
complete Phases 15 and 16 of the gigantic South Pars gas project has generated concern
among Iranian analysts, who believe the move reveals the [IRGC]’s excessive power
over Iran’s economy. In view of looming sanctions from the United States and the United
Nations Security Council … , the IRGC’s control over the country’s sensitive oil, and gas
and nuclear industries could provoke a serious crisis, they warn. … In 2006, … [Khatam
al-Anbiya] took on the National Gas Company’s 90-kilometre Asalouyeh-Iranshahr
pipeline project in Iran’s Sistan and Baluchistan provinces, a contract worth 1.3 billion
dollars. Another large project the Oil Ministry awarded to IRGC is the South Pars Gas
Field Development Project’s Phases 15 and 16. At 2.97 billion dollars, the contracts were
awarded to [KAA] two years ago, bypassing the tender process. However, the IRGC firm
was unable to finish the project in time. Jamshid Asadi, an economics professor at the
American University in Paris, said that the latest action by IRGC culminates its
aggressive efforts to monopolise key state projects over the last six years. … [KAA] … is
currently under sanctions by the European Union and the United States. ‘The economic
dominance of the IRGC over gigantic gas and oil projects has made Iran’s economy
extremely vulnerable towards [a] new round of sanctions on the country’s financial
institutions and oil industry,’ the source said.”

c. Economist Intelligence Unit, April 30, 2010: “Under President Ahmadinejad, the …
IRGC … has enjoyed a substantial increase of its economic power. On several occasions,
the IRGC won lucrative contracts in fields ranging from oil and gas to
telecommunications. For example, … in 2005, [Ahmadinejad] granted a no-bid
development contract for Phases 15 and 16 of South Pars …, the world’s largest gasfield.
The contract amounted to over US$7bn, to [KAA], the construction arm of the IRGC.
The contract was in violation of government norms that require a competitive process. …
[Iran’s] Foreign Investment Promotion and Protection Act (FIPPA) specifically prohibits
foreign investors from having a monopoly over any specific sector or market … [but

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grants] state monopolies in such industries as oil, defence, … and [the] state-sanctioned
monopolies of bonyads ….”

d. APS Diplomat News Service, January 9, 2012: “[T]he IRGC runs its own economy which
is totally independent and booming. … IRGC’s Khatem ul-Anbia’ …, a huge engineering
and construction company, now has a quasi monopoly on key sector[s] such as that of
petroleum. … Petroleum Minister Gen Rustam Qassemi is a former IRGC chief and until
he took up the oil portfolio he was the head of [KAA].”

e. Ali Alfoneh (American Enterprise Institute), April 1, 2013: “The IRGC … has become a
moneymaking machine … [in part through] Iran’s oil and gas sector, which has hitherto
been the monopoly of the National Iranian Oil Company, [and] has become the ultimate
prize of the IRGC.”

f. Australian, March 25, 2014: “[The IRGC’s energy monopoly extends] beyond petroleum
production to [encompass] all aspects of the Iranian energy sector, which is fully
controlled by the congressionally blacklisted Islamic Revolutionary Guards Corps.”

g. Iran Briefing, September 22, 2014: “Oil and Gas Sectors: The IRGC has a major stake in
the petrochemical industry, including oil refineries, drilling companies, the National
Iranian Oil Company (a/k/a ‘NIOC’), Arvandan Oil & Gas Company, and the National
Iranian Tanker Company. It has almost full control over the oil ministry and oil trading,
and most aspects of the wider oil industry. Khamenei’s immediate family members own a
major portion of this sector.”

h. APS Review Downstream Trends, December 22, 2014: “[Iranian President Hassan]
Rowhani added: ‘Continuation of corruption and the spread of corruption [in Iran] would
mean the system and fundamentals of the revolution are in danger’. Iran … [was] a
country where state institutions such as the IRGC exert control in businesses [transacting]
… oil sales. Rowhani went on to say: ‘Monopoly is the cause of corruption and we must
fight against monopolies. Anything which does not have rivalry or whose management is
monopolised is flawed’.”

i. Barak Seener (Jerusalem Center for Public Affairs), December 2018: “The IRGC stands
to benefit [from transactions with Western companies and banks] … due to its monopoly
of [] Iranian econom[ic] …… sectors including oil and gas [and] petrochemicals ….”

450. Additional public reports subsequently confirmed what had already been clear,

i.e., that the IRGC had a complete monopoly over Iran’s energy sector, including oil and gas.

451. From 2007 through 2020, the SLO and IRGC continuously, and notoriously,

exercised their monopoly over all Iran-related energy transactions, including every such

transaction processed by SCB alleged herein. When SCB facilitated transactions that SCB knew

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were on behalf of Iran-related persons, and concerned energy, SCB knew, or was willfully blind,

that it was directly or indirectly supplying the IRGC with funds and financing that the IRGC

could, and did, use to sponsor acts of terrorism that targeted the United States and were

committed by Hezbollah, Hamas, PIJ, and JAM.

B. The Construction Sector

452. By late 2007, the Supreme Leader and IRGC had seized a monopoly in Iran’s

construction sector, operationalized through Iran’s Terrorist Sponsors. Having seized their linked

monopolies in these sectors by 2007, the SLO and the IRGC aggressively sought to expand their

respective reach into these monopolies from 2007 through 2011 by vertically integrating Iran’s

Terrorist Sponsors throughout every significant construction firm and project in Iran or subject to

Iranian investment outside of Iran.

453. The United States has formally confirmed that the Iranian regime exercised a

monopoly over Iran’s construction sector and used such monopoly to fund terrorist attacks by

IRGC proxies. On January 10, 2020, for example, President Trump signed Executive Order

13,902, imposing sector-wide sanctions targeting Iran’s construction sector based on a formal

finding that all revenue generated by the “construction … sector[] of the Iranian economy”

funded Iranian regime-sponsored attacks by IRGC proxies in the Middle East.

454. Beginning around 2007, the SLO and IRGC continuously, and notoriously,

exercised their monopoly over all Iran-related construction transactions, including every such

transaction processed by SCB alleged herein. When SCB facilitated transactions that SCB knew

were on behalf of Iran-related persons, and concerned construction, SCB knew, or was willfully

blind, that it was directly or indirectly supplying the IRGC with funds and financing that the

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IRGC could, and did, use to sponsor acts of terrorism that targeted the United States and were

committed by Hezbollah, Hamas, PIJ, and JAM.

C. The Sanctions Evasion Sector: Black Market, Smuggling, and Shipping

455. In Iran, sanctions evasion was an industrial sector with dedicated practitioners,

firms, strategies and the like and primarily comprised three sub-sectors: (1) the black market; (2)

smuggling and port operations; and (3) transnational shipping and logistics. The SLO and IRGC

always exercised a monopoly over the sanctions evasion sector of Iran’s economy, as Plaintiffs

define it herein, which they operationalized through Iran’s Terrorist Sponsors.

456. The United States has formally confirmed that the Iranian regime exercised a

monopoly over Iran’s inextricably linked sanctions evasion, smuggling, and black market

sectors, and used such monopoly to fund terrorist attacks by IRGC proxies. On April 8, 2011, for

example, State reported to Congress that “[t]he IRGC is [] widely considered to control the vast

majority of [Iran’s] underground and black market economy” and “[u]p to 80 percent of illegal

goods enter [Iran] through unregistered ports and jetties controlled by the IRGC.”

457. Reports and statements published by the United States, Iranian regime, Iranian

opposition, media, terrorism scholars, and NGOs alerted SCB that its Iranian black market- and

smuggling-related transactions supported IRGC-sponsored terrorist violence committed by IRGC

proxies given the IRGC’s monopoly on the Iranian black market and smuggling. As RAND

scholars reported in 2009, “the IRGC” exercised “control of Iran’s shadow economy” including

“the illicit smuggling networks.” Other such warnings included, but were not limited to:

a. CNBC, December 8, 2010: “One third of all imported goods in Iran are delivered through
the IRGC controlled illegal black market according to [a] member of [Iran’s parliament].
The IRGC cuts out all competition in this field, jailing and intimidating Iranians dealing
in black market goods so the Guard itself has a virtual monopoly.”

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b. Dr. Michael Rubin, April 19, 2016: “[T]he IRGC … maintains a stranglehold over trade
… and so has become the chief if not sole beneficiary from the hard currency now
flowing into Iran. … Today, Khatam al-Anbiya monopolizes … shipping.”

c. DT News, August 14, 2018: “[D]espite the accumulation of international sanctions after
2005, Iran’s paramilitary spending similarly mushroomed; partly because the Islamic
Revolutionary Guard Corps filled its coffers through monopolizing sanctions-evading
networks in oil, heavy arms, narcotics and basic goods.”

458. From 2007 through 2020, the SLO and IRGC continuously, and notoriously,

exercised their monopoly over all Iran-related black market, smuggling, and shipping

transactions, including every such transaction processed by SCB alleged herein. When SCB

facilitated transactions that SCB knew were on behalf of Iran-related persons, and concerned

black market, smuggling, or shipping, SCB knew, or was willfully blind, that it was directly or

indirectly supplying the IRGC with funds and financing that the IRGC could, and did, use to

sponsor acts of terrorism that targeted the United States and were committed by Hezbollah,

Hamas, and JAM.

D. The Financial Sector: Banks, Currency Exchanges, and Hawalas

459. Even before 2007, Iran’s major financial institutions—including SCB’s customers

CBI/Markazi, Bank Saderat, and Bank Melli—played essential roles in facilitating the IRGC’s

support to terrorist organizations including but not limited to Hezbollah, Hamas, and JAM.

Indeed, that is why these institutions were sanctioned by the United States in 2007. Over time,

the IRGC’s influence over Iran’s financial sector only grew.

460. By late 2007, the Supreme Leader and IRGC had seized a monopoly in Iran’s

financial sector, which comprised Iranian banks, currency exchanges, and hawalas,

operationalized through, Iran’s Terrorist Sponsors. These entities, collectively, owned and/or

exercised direct or indirect control over all banks, currency exchanges, and hawalas in Iran.

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461. The United States has formally confirmed that the Iranian regime exercised a

monopoly over Iran’s banks and used such monopoly to fund terrorist attacks by IRGC proxies.

On August 6, 2018, for example, President Trump signed Executive Order 13,846 based upon

the Executive branch’s finding that U.S. dollar-denominated transactions with any person

supervised by “the Central Bank of Iran”—Iran’s financial regulator, which always controlled all

Iranian banks—directly enabled “threats posed by Iran, including Iran’s … network and

campaign of regional aggression, its support for terrorist groups, and the malign activities of the

Islamic Revolutionary Guard Corps and its surrogates.”

462. On September 20, 2019, similarly, Treasury sanctioned the Central Bank of Iran,

and confirmed its findings that the Qods Force and Hezbollah controlled CBI and used it to

finance their attacks as well as those of their proxies, including Hamas and PIJ:

[OFAC] … act[ed] against the Central Bank of Iran (CBI) … under its
counterterrorism authority, Executive Order (E.O.) 13224. Iran’s Central Bank
has provided billions of dollars to the Islamic Revolutionary Guards Corps
(IRGC), its Qods Force (IRGC-QF) and its terrorist proxy, Hizballah. …
“Treasury’s action targets a crucial funding mechanism that the Iranian
regime uses to support its terrorist network, including the Qods Force, Hizballah,
and other militants that spread terror and destabilize the region. … Iran’s
repressive regime … attempts to achieve its revolutionary agenda through
regional aggression while squandering the country’s oil proceeds,” said Treasury
Secretary Steven T. Mnuchin. “Iran’s Central Bank … [was] ostensibly intended
to safeguard the welfare of the Iranian people, but have been used instead by this
corrupt regime to move Iran’s foreign currency reserves for terrorist proxies.” …

CENTRAL BANK OF IRAN FUNDS THE IRGC, ITS QODS FORCE AND
HIZBALLAH
Today’s action targets the CBI for its financial support to the IRGC-QF
and Hizballah. In May 2018, OFAC designated the CBI’s then-Governor
Valiollah Seif, and the Assistant Director of the International Department Ali
Tarzali, for facilitating financial transfers for the IRGC-QF and Hizballah. Also,
in November 2018 and as part of Treasury’s disruption of an international oil-for-
terror network, OFAC designated the CBI’s International Department Director
Rasul Sajjad, and the CBI’s International Department Director, Hossein
Yaghoobi, for conducting financial transactions for the IRGC-QF.

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Since at least 2016, the IRGC-QF has received the vast majority of its
foreign currency from the CBI and senior CBI officials have worked directly with
the IRGC-QF to facilitate CBI’s financial support to the IRGC-QF. In 2017, the
IRGC-QF oversaw the transfer of tens of millions of euros to Iraq from the CBI.
Then-Governor of the CBI Valiollah Seif directed the transfer. …
CBI has [] coordinated with the IRGC-QF to transfer funds to Hizballah.
OFAC is designating the CBI today for having materially assisted,
sponsored, or provided financial, material, or technological support for, or goods
or services to, the IRGC-QF and Hizballah.
The IRGC-QF, … is … responsible for [the IRGC’s] external operations
and has provided material support to numerous terrorist groups, including …
Hizballah, HAMAS, and the Palestinian Islamic Jihad ….

463. On February 14, 2024, similarly, Treasury imposed additional counterterrorism

sanctions against the Central Bank of Iran pursuant to E.O. 13,324, and confirmed, inter alia:

OFAC … sanctioned a procurement network responsible for facilitating the illegal

export of goods and technology from over two dozen U.S. companies to end-users
in Iran, including the Central Bank of Iran (CBI), which is designated for its role
in providing financial support to the … [Qods Force] and Hizballah. …
“The Central Bank of Iran has played a critical role in providing financial
support to the IRGC-QF and Hizballah, two key actors intent on further
destabilizing the Middle East,” said Under Secretary of the Treasury for
Terrorism … Brian E. Nelson. “The United States will continue to use all
available means to disrupt the Iranian regime’s illicit attempts to procure sensitive
U.S. technology and critical inputs.”

464. From 2009 through 2020, reports and statements published by the United States,

Iranian regime, Iranian opposition, media, terrorism scholars, and NGOs alerted SCB that

transactions with Iranian banks supported IRGC-sponsored terrorist violence committed by

IRGC proxies given the IRGC’s assumption of total control over all Iranian banks after 2007. In

2009, for example, seven RAND scholars warned, in a U.S. government funded research paper,

of “the IRGC’s … monopolization of key financial sectors.” Other such warnings to SCB

included, but were not limited to:

a. Al Arabiya, August 19, 2010: “Iran’s Supreme National Security Council has granted the
… Revolutionary Guards more powers to expand and maintain its control of the
economy, Al Arabiya TV reported, stating informed sources. …[,] [and] issued a
resolution stipulating the appointment of a representative of the [IRGC] … in the Board

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of Directors of Iran’s Central Bank, [per] reliable government sources … According to

the resolution, no decisions can be taken at the bank without the approval of the [IRGC]
representative. … The decisions also coincide with harsh criticism by leading reformist
and presidential candidate Mehdi Karroubi against Khatam al-Anbiya, the construction
unit of the [IRGC], and its monopoly over the most substantial of business transactions in
the industry and economy sectors. … ‘The private sector is no longer able to compete as
the economy is monopolized by the Revolutionary Guard,’ he said.”

b. Dr. Majid Rafizadeh (Harvard International Review), August 12, 2016: “[T]he IRGC and
the office of the Supreme Leader, Ayatollah Khamenei [i.e., the SLO], maintains [a]
monopoly over [Iran’s] wealth and financial system.”

c. Perviz S. Khazai (National Council of Resistance of Iran), April 22, 2019: “[IRGC]
members … loot[] … [Iran]’s wealth to support their policy of exporting the ‘Islamic
revolution’ and destabilization in the Middle East. … The IRGC … has monopolized the
lion’s share of the Iranian economy since 2005 [including] … finance, speculation, [and]
banking … This entity … is the financier and gunsmith of Hezbollah in Lebanon [and]
barbaric militias in Iraq ….”

d. National Council of Resistance of Iran, April 2022: “The consequent economic

configuration is defined by at least 14 major economic powerhouses [including the
Foundation for the Oppressed and Khatam al-Anbiya] either directly or indirectly
controlled by Khamenei, the IRGC, or a combination of their affiliates. When it comes to
banks, financial and credit institutions, insurance, the stock market, domestic and foreign
commerce, real estate, and the financial instruments market, Khamenei’s office [i.e., the
SLO] (along with the IRGC) has taken control of virtually everything that matters. …
[T]he astronomical profits … end[] up funding … IRGC mercenaries and [IRGC] terror
operations in … Iraq … and … around the world. Foreign investors cannot in practical
terms avoid entanglement by affiliation in the Iranian regime’s support for terrorism ….
In reality, the back-breaking control of the Supreme Leader and the IRGC, over the
economic system … [means that even though] Western companies engaged in economic
and financial deals with Iran would like to portray their activities as transactions with the
‘private sector[]’ …, behind the official banks and companies lies a web of institutions
controlled by the theocracy, and specifically the IRGC. Western companies … cannot
avoid the reality that today the gatekeepers to Iran’s economy are those who … export
the very terrorism … that threaten[s] the West.”

465. From 2007 through 2020, the SLO and IRGC continuously, and notoriously,

exercised their monopoly over all Iran-related bank, currency exchange, and hawala transactions,

including every such transaction processed by SCB alleged herein. When SCB facilitated

transactions that SCB knew were on behalf of Iran-related persons, and concerned banks,

currency exchanges, or hawalas, SCB knew, or was willfully blind, that it was directly or

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indirectly supplying the IRGC with funds and financing that the IRGC could, and did, use to

sponsor acts of terrorism that targeted the United States and were committed by Hezbollah,

Hamas, PIJ, and JAM.

E. The Import/Export Sector

466. By late 2007, the Supreme Leader and IRGC had seized a monopoly in Iran’s

import/export sector, which was comprised of Iranian importers and exporters who typically had

affiliated entities outside of Iran, operationalized through Iran’s Terrorist Sponsors.

467. Reports and statements published by the United States, Iranian regime, Iranian

opposition, media, terrorism scholars, and NGOs alerted SCB that its import- and export-related

transactions concerning Iranian counterparties, deals, or projects supported IRGC-sponsored

terrorist violence committed by IRGC proxies given the IRGC’s and SLO’s assumption of a

monopoly over Iran’s import/export sector. Such warnings included, but were not limited to:

a. Economist, February 2, 2013: “[T]he Revolutionary Guard … enjoys … a virtual

monopoly over imports.”

b. Dr. Michael Rubin, April 19, 2016: “IRGC … maintains a stranglehold over trade and the
economy and so has become the chief if not sole beneficiary from the hard currency now
flowing into Iran. … Today, Khatam al-Anbiya monopolizes … import-export.”

c. Perviz S. Khazai (National Council of Resistance of Iran), April 22, 2019: “[IRGC]
members … loot[] … [Iran]’s wealth to support their policy of exporting the ‘Islamic
revolution’ … in the Middle East. … The IRGC … has monopolized the lion’s share of
the Iranian economy since 2005 … [including] … import and export … [and] … is the
financier and gunsmith of Hezbollah … [and] barbaric militias in Iraq ….”

d. Eurasia Review, August 15, 2020: “The drop in foreign currency revenue [shows] … the
plundering [of Iranian wealth] by corrupt bands affiliated to the … IRGC … and
Khamenei himself. … This mafia band [comprised of] … the IRGC and The Executive
Headquarters of Imam [i.e., the SLO], which belongs to Khamenei, is clinging on to
Iran’s import and export trade like an octopus, with exclusive control over it, causing
immense corruption. … The wealth of bodies and institutions under the control of Iran’s
Supreme Leader, Ali Khamenei, is estimated at hundreds of billions of dollars. Today the
majority of banks, industries, mines, communication enterprises, and financial
institutions are under the exclusive ownership of Khamenei and the [IRGC]. Each year
tens of billions of dollars are drained out of the country through the mullahs’ and IRGC’s

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corruption and looting, being spent on the regime’s terrorism and its proxies in Iraq,
Syria, … and Lebanon. This has gone so far that the United States has issued an
ultimatum that it will close its embassy in Baghdad unless the regime’s proxies are
brought to account for their consecutive attacks on [U.S.] embassies and convoys.”

e. National Council of Resistance of Iran, April 2022: “When it comes to … domestic and
foreign commerce … Khamenei’s office (along with the IRGC) has taken control of
virtually everything that matters. … [T]he astronomical profits … end[] up funding …
IRGC … terror operations in … Iraq … and … around the world.”

468. From 2007 through 2020, the SLO and IRGC continuously, and notoriously,

exercised their monopoly over all Iran-related import/export companies, including every such

transaction processed by SCB alleged herein. When SCB facilitated transactions that SCB knew

were on behalf of Iran-related persons, and concerned imports to Iran and/or exports from Iran,

SCB knew, or was willfully blind, that it was directly or indirectly supplying the IRGC with

funds and financing that the IRGC could, and did, use to sponsor acts of terrorism that targeted

the United States and were committed by Hezbollah, Hamas, PIJ, and JAM.

F. The Communications Sector: Telecoms, Internet, and Related Technology

469. The SLO and IRGC began their seizure of the communications sector when it

seized control of Irancell—Iran’s most important internet and telecoms company—in 2005. The

SLO and IRGC completed their seizure of the communications sector in 2009, when they

collaborated to help the IRGC purchase the Telecommunications Company of Iran. By 2009, the

Supreme Leader and IRGC had seized a monopoly in Iran’s communications sector, which was

comprised of Iranian telecoms, internet, social media, and computing, and communications

technologies firms, operationalized through Iran’s Terrorist Sponsors. These entities,

collectively, owned and/or exercised direct or indirect control over all communications

companies in Iran.

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470. From 2009 through 2020, reports and statements published by the United States,

Iranian regime, Iranian opposition, media, terrorism scholars, and NGOs alerted SCB that its

communications-related transactions (including landline and mobile telecoms, internet,

computing, social media, and associated technologies) concerning Iranian counterparties, deals,

or projects supported IRGC-sponsored terrorist violence committed by IRGC proxies given the

IRGC’s assumption of a monopoly over the Iranian communications sector. Such warnings to

SCB included, but were not limited to:

a. Ali Alfoneh (American Enterprise Institute), October 22, 2007: “The IRGC rooted its
rhetoric on [seizing telecoms companies] in national security. … the IRGC expects to
maintain its dominant position not only on the battlefield, but in civilian sectors as well.
… Because some of the Iranian economy’s most advanced technological undertakings
occur under the aegis of the IRGC and within the framework of the Iranian arms industry,
the IRGC can monopolize the transfer and adaptation of high technology to civilian
applications … … The homepage of [IEI] … display[s] many consumer goods produced
by the arms industry for sale in the Iranian market. The list includes personal computers,
scanners, telephone sets and intercoms, mobile phones, and telephone sim cards. These
purchases support … IRGC operations ….”

b. APS Diplomat News Service, November 23, 2009: “[T]he IRGC now monopolises Iran’s
huge communications sector.”

c. UPI, November 24, 2009: “[A] company tied to the Revolutionary Guards acquired a
majority share in the nation’s telecommunications monopoly, essentially giving the
[IRGC] control of Iran’s land lines, Internet providers and cellphone companies.”

d. Guardian, November 25, 2009: “[U]nofficial spokesman for the opposition Green
Movement … Mohsen Makhmalbaf … called for ‘smart’ sanctions targeting the Islamic
Revolutionary Guard Corps and their extensive business interests – including a
communications monopoly – that are often described as constituting a parallel economy.
‘The Revolutionary Guards are terrorists. They are in Iraq … and Lebanon.’”

e. Dr. Monika Gill, October 2020: “[W]hilst the Guard relied on the communications
economy to propagate their ideology, they also acquired and monopolised
communications infrastructure as a source of capital gain. The Guard’s involvement with
the communications economy moved beyond the projection of revolutionary ideology,
becoming equally a matter of realpolitik and of accruing military capital.”

471. From 2007 through 2020, the SLO and IRGC continuously, and notoriously,

exercised their monopoly over all Iran-related telecoms, internet, social media, computing, and

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communications technology-related transactions, including every such transaction processed by

SCB alleged herein. When SCB facilitated transactions that SCB knew were on behalf of Iran-

related persons, and concerned Iran’s communications sector, SCB knew, or was willfully blind,

that it was directly or indirectly supplying the IRGC with funds and financing that the IRGC

could, and did, use to sponsor acts of terrorism that targeted the United States and were

committed by Hezbollah, Hamas, PIJ, and JAM.

VI. For More Than A Decade, SCB Engaged In An Illegal Scheme To Help Iran’s
Terrorist Sponsors And Their Fronts Access The U.S. Financial System

472. SCB has long considered itself a “frontier bank” that was unafraid—indeed,

eager—to pursue business opportunities in emerging markets that other large financial

institutions avoided due to reputational, regulatory, and geopolitical risks.19 Consistent with

SCB’s pursuit of such high-risk, high-reward opportunities, SCB for decades aggressively

pursued business in Iran and with Iranian companies and individuals doing business in nearby

countries, particularly the United Arab Emirates.

473. The cornerstone of SCB’s business strategy to grow its presence in the Middle

East was its willingness to offer customers U.S. dollar clearing services. U.S. dollar clearing is

the process by which U.S. dollar-denominated transactions are satisfied between counterparties

through a U.S. bank; payments are converted from a foreign currency into U.S. dollars.

Participation in global commerce depends on access to U.S. dollars and dollar clearing services.

474. U.S. dollar clearing was particularly important to the Iranian government, Iranian

state-owned banks, Iran’s Terrorist Sponsors, their front companies, and other Iranian businesses

for several reasons. First, the persistent weakness of Iran’s currency, the Rial, led to a desire for

19
Decl. of Robert G. Marcellus ¶ 39 (“Marcellus Decl.”), U.S. ex rel. Brutus Trading, LLC v.
Standard Chartered Bank, No. 18-cv-1111 (S.D.N.Y. Jan. 10, 2020), ECF 48-1.

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access to a more stable, globally accepted currency. Second, Iran’s economy has long depended

on exporting oil and gas—a commodities market denominated primarily in U.S. dollars. Third,

Iran’s Terrorist Sponsors and their terrorist proxies have long depended on access to U.S. dollars

to fund anti-American violence.

475. After September 11th, the United States and most other Western nations markedly

expanded their anti-money laundering and anti-terror financing sanctions, while bolstering

related enforcement activities. As a result, Iran—and in particular its IRGC, which was the

principal target of many sanctions directed at Iran—became increasingly isolated from the

international financial community, and its access to U.S. dollars became constricted.

476. SCB saw this as a money-making opportunity. SCB knew that Iran—including its

Terrorist Sponsors—needed access to U.S. dollars, and SCB was willing to facilitate that access.

SCB was aware of the heightened regulatory scrutiny and risks associated with banking with

Iranian entities. But SCB was not deterred. To the contrary: SCB thought the heightened

regulatory risks would discourage SCB’s competition and allow SCB to monopolize the

market—while extracting a higher premium for its U.S. dollar clearing services.

477. From at least 2001 through at least late 2014 or early 2015, SCB engaged in a

deceptive and illegal scheme to provide its Iranian customers with covert and largely unfettered

back-door access to the U.S. financial system. In doing so, SCB violated U.S. sanctions and

other laws and regulations designed to prevent the U.S. financial system from being used to

finance terrorism—despite knowing, or at least being aware of a high probability, that several of

its Iranian customers were agents and fronts for Iran’s Terrorist Sponsors. SCB’s scheme caused

hundreds of millions—if not billions—to flow to these prohibited Iranian customers.

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478. That staggering sum is a conservative estimate. One former SCB employee-

turned-whistleblower estimated, based on a forensic analysis of internal SCB data, that SCB’s

illicit U.S. dollar transactions with sanctioned Iranian customers totaled tens of billions.20

479. SCB knew, or was at least deliberately ignorant of the fact, that its illegal

assistance to Iranian customers would directly and indirectly benefit Iran’s Terrorist Sponsors

and help finance anti-American terrorist attacks committed by the IRGC, including its Hezbollah

branch, and its terrorist proxies, including Hamas. Those anti-American terrorist attacks included

the ones that killed and injured Plaintiffs and their loved ones.

480. SCB’s knowledge can be traced to multiple sources. First, as a major financial

institution, SCB had and has access to state-of-the-art tools for customer diligence and economic

intelligence, which allow it to understand the nature of the markets in which it operates and the

customers it serves. SCB also had abundant incentives to employ these tools to their fullest

effect—including regulatory requirements and best-practices guidance requiring it to do so, as

well as business imperatives to know its customers’ business so that it could provide them with

financial services that they would appreciate and pay for. These tools alerted SCB to public

reports discussing its customers and the sectors in which they operated, as well as non-public

information that SCB gathered about its customers while trying to earn and maintain their

business.

481. Second, SCB was in contact with other banks and with regulators, which

communicated private information to SCB about its customers and the environment in which

20
See Decl. of Julian M. Knight ¶¶ 2, 12, U.S. ex rel. Brutus Trading, LLC v. Standard
Chartered Bank, et al., No. 18-cv-11117 (S.D.N.Y. May 31, 2024), Dkt. 105; see also Decl. of
Julian M. Knight ¶¶ 40, 44, 67, U.S. ex rel. Brutus Trading, LLC v. Standard Chartered Bank,
No. 18-cv-11117 (S.D.N.Y. Jan. 10, 2020), ECF 48-2.

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they operated. For example, NYDFS’s 2012 resolution with SCB found its misconduct

“especially egregious” because, at the time it occurred, “SCB’s New York branch was subject to

a formal supervisory action” for other money-laundering and sanctions-related violations,

meaning SCB was in direct contact with regulators throughout the relevant time period.21 News

reports also revealed that in the years after September 11, 2001, U.S. Treasury officials

conducted road shows to major financial institutions where they explained the risks of taking on

customers from jurisdictions like Iran, including explaining that it was highly likely that

businesses in sectors that had been taken over by Iran’s Terrorist Sponsors were contributing to

their terrorist-support mechanisms. SCB was the beneficiary of such briefings. Additionally,

when other banks were asked to process transactions for an SCB customer, they would analyze

the transaction and, if it raised issues, explain those issues to SCB, providing SCB with further

intelligence about its customers and the nature of their transactions.

482. Third, the customers SCB served through its evasion schemes were not

individuals with small, simple checking accounts; they were large entities moving millions upon

millions of dollars each and every year, and paying hefty commissions to SCB in the process.

For business reasons, banks like SCB get to know such customers—including learning the

identities of their beneficial owners and understanding the true nature of their businesses. Thus,

banks, including SCB, assign relationship managers to learn about the customers and assess how

the bank can best serve them. They gather and monitor data about their customers, and find

opportunities to expand the banking relationship. They strive to understand, at a deep and

fundamental level, what the customer wants from the relationship. When, as here, the customer

wants to obscure its identity and covertly move money for Iran’s Terrorist Sponsors, SCB would

21
2012 NYDFS Consent Order ¶ 6.

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learn that fact through its relationship with the customer. Indeed, SCB chose to satisfy those

illicit needs.

483. Fourth, SCB had a physical presence in Iran through its office in Tehran, which

remained open until May 2012, just before U.S. authorities’ first enforcement actions against

SCB became public. Through this office, as well as its branch in nearby Dubai, SCB employees

and agents observed firsthand major developments in the Iranian economy, including, as

discussed in greater detail infra, the IRGC’s overt and public takeover of key sectors that SCB

wanted to serve, which began as early as 2005. The pervasive role that Iran’s Terrorist Sponsors

and their fronts played in the Iranian economy was a matter of common knowledge within Iran

and Dubai, and therefore a matter of knowledge to SCB, which was present there. The bank’s

presence in Iran and Dubai also created many opportunities for IRGC officers and fronts to

interface directly with the bank, free from the prying eyes of Western regulators.

484. SCB’s culpable assistance to Iran’s Terrorist Sponsors lasted until at least late

2014 or early 2015, from which Iran’s Terrorist Sponsors and their proxies Hezbollah, Hamas,

JAM, and PIJ continued to finance their terrorist attacks through at least 2019.

485. SCB’s conduct resulted in multiple criminal and civil proceedings that SCB

settled by paying massive penalties to regulators, including the DOJ, OFAC, Federal Reserve,

NYDFS, and the U.K. FCA. Between 2012 and 2019, SCB paid nearly $2 billion in forfeitures

and penalties to U.S., New York, and United Kingdom authorities for the illegal conduct

described herein. In evaluating SCB’s conduct, those agencies described the bank’s conduct as

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“intentional,”22 its violations “egregious,”23 and the bank itself as a “rogue institution”24 whose

persistent misconduct left the United States “vulnerable to terrorists.”25

486. SCB went to great lengths to disguise the magnitude of its sanctions-evasion

efforts. Throughout the life of the scheme, SCB actively concealed its illegal conduct from

governmental authorities in the United States and United Kingdom to keep its profits flowing—

regardless of the cost in American lives.

VII. SCB’s Scheme Involved Willful, Systemic, Company-Wide Efforts To Provide

Banking Services To Iran’s Terrorist Sponsors And Their Associated Fronts While
Helping Them Evade Counterterrorism Controls

487. For more than a decade, SCB conspired with clients owned and/or controlled by

Iran’s Terrorist Sponsors—Ayatollah Khamenei, the SLO, the Friday Prayer Organization, the

IRGC, Hezbollah, and/or the Foundation for the Oppressed—to perform massive volumes of

financial transactions for those clients in violation of U.S. sanctions, while simultaneously

helping them evade counterterrorism controls. SCB’s assistance to its terrorist-sponsor clients

included systematically concealing and/or misrepresenting critical Iran-related information from

its wire transactions (i.e., wire stripping), which SCB knew would inhibit reporting and

surveillance systems that the U.S. and other governments relied upon to combat terrorism. SCB

also conspired with front companies to cover their tracks by closing accounts, changing names,

and/or submitting transactions in a manner designed to evade scrutiny. SCB’s efforts further

included lying to government regulators, falsifying internal documents, employing deliberately

22
N.Y. State Dep’t of Financial Services (“NYDFS”), In re Standard Chartered Bank, Consent
Order Under New York Banking Law §§ 39, 44 ¶ 1 (Apr. 9, 2019) (“2019 NYDFS Consent
Order”).
23
Office of Foreign Assets Control (“OFAC”), Settlement Agreement with Standard Chartered
Bank ¶¶ 3,4 (Apr. 9, 2012) (“2019 OFAC Settlement”).
24
See 2019 Amended DPA ¶ 29 & SOF ¶ 2.
25
2012 NYDFS Consent Order at 1.

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ineffective compliance programs, and retaliating against whistleblowers who tried to expose or

otherwise stop the scheme. SCB helped its clients evade counterterrorism controls not only to

hide its own sanctions violations from U.S. and U.K. regulators, but also to protect its terrorist-

sponsor clients from unwanted scrutiny that might jeopardize their operations and the bank’s

lucrative business as the U.S. and other governments were ratcheting up their concern over

terrorism financing by Iran, the IRGC, and Iran’s other terrorist sponsors. Plaintiffs learned of

the specific instances of misconduct below without access to SCB’s files; discovery is likely to

reveal additional examples of SCB’s knowing provision of extraordinary assistance to fronts for

Iran’s Terrorist Sponsors, similar to the ones alleged herein.

A. The U.S. Government’s Counterterrorism Controls

488. The U.S. government’s counterterrorism controls in the banking system included

three key elements: (1) economic sanctions that prohibited certain transactions at high risk for

terrorism financing; (2) review and reporting of suspicious transactions by financial institutions;

and (3) direct monitoring of transactions by the government. Before discussing SCB’s scheme,

Plaintiffs first provide relevant background on these counterterrorism controls.

1. OFAC’s Iran Sanctions

489. Financial transactions with Iran have been subject to U.S. economic sanctions

since 1979. The U.S. government’s sanctions regime aims to identify and block those who

attempt to use the U.S. financial system in contravention of U.S. foreign policy, as well as

foreign countries, entities, and individuals who may present a threat to national security. In

particular, the sanctions are intended to prevent U.S. dollars from being used to finance terrorist

organizations, proliferators of weapons of mass destruction, drug traffickers, and other hostile

enterprises. With respect to Iran, these measures were strengthened in 1995 when President

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Clinton found that “the actions and policies of the Government of Iran constitute an unusual and

extraordinary threat to the national security, foreign policy, and economy of the United States,”

and declared “a national emergency to deal with that threat.” Through the issuance of Executive

Order 12957 in March 1995 and Executive Order 12959 in May 1995, President Clinton imposed

comprehensive trade and financial sanctions on Iran.

490. A key purpose of these sanctions was to prevent Iran from using its petroleum

resources to fund terrorism. As President William J. Clinton explained in a message to Congress

on September 18, 1995, “I issued Executive Order 12957. . . to prohibit the financing,

management, or supervision by United States persons of the development of Iranian petroleum

resources. This action was in response to actions and policies of the Government of Iran,

including support for international terrorism, efforts to undermine the Middle East peace process,

and the acquisition of weapons of mass destruction and the means to deliver them.” However,

“[f]ollowing the imposition of these restrictions with regard to the development of Iranian

petroleum resources, Iran continued to engage in activities that represent a threat to the peace and

security of all nations, including Iran’s continuing support for international terrorism.” To

“further respond to the Iranian threat,” President Clinton explained that he issued Executive

Order 12959, which imposed comprehensive sanctions prohibiting exportation from the United

States to Iran or to the Government of Iran of goods, technology, or services, as well as

prohibiting transactions by United States persons in goods and services of Iranian origin or

owned or controlled by the Government of Iran. These comprehensive sanctions were intended

in part to limit the flow of funds to terrorism, and thus in the President’s words, “advance[d]

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important objectives in promoting the nonproliferation and antiterrorism policies of the United

States.”

491. In a subsequent message to Congress on August 19, 1997, President Clinton

explained that he was issuing another Executive Order (E.O. 13059) to “confirm[] that United

States persons are prohibited from engaging in any trade- or investment-related activities with

Iran.” He added, “I want to make clear that this means all direct or indirect involvement in such

activities wherever those activities occur.”

492. The sanctions regime is primarily administered by OFAC, which implemented the

President’s Executive Orders through its Iran Transaction Regulations (ITRs) and related

guidance. Until November 2008, OFAC rules permitted U.S. financial institutions, under limited

circumstances and with close regulatory supervision, to process certain transactions for Iranian

banks, individuals, and other entities. These were called “U-Turn” transactions because such

transactions originated and terminated with foreign banks, passing through U.S. banks or

branches as part of the clearing process. U-Turn clearing transactions, although not categorically

prohibited by OFAC’s regulations, posed an exceedingly high risk that required stringent

scrutiny under applicable regulatory standards. For example, OFAC regulations required that

“[b]efore a United States depository institution initiates a payment on behalf of any customer, or

credits a transfer to the account on its books of the ultimate beneficiary, the United States

depository institution must determine that the underlying transaction is not prohibited by this

part.” And beyond OFAC, other regulations required heightened due diligence and reporting of

suspicious transactions as part of a bank’s Anti-Money Laundering/Countering the Financing of

Terrorism (AML/CFT) program. The obligation to determine that a U-Turn complied with U.S.

law, and to review and report suspicious U-Turn transactions to the government, thus fell

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squarely on U.S. clearing banks and U.S.-based compliance personnel. In satisfying this

obligation, U.S. clearing banks and U.S.-based compliance personnel relied heavily on the

accuracy and completeness of wire transfer messages they received from correspondent banks

and overseas branches.

493. Recognizing that the U-Turn exception was being abused by an Iranian regime

whose support to terrorist groups was pervasive, OFAC revoked the U-turn exception for Bank

Saderat on September 7, 2006, effectively prohibiting all transactions, directly or indirectly,

involving the bank. In announcing this action, Treasury Under Secretary for Terrorism and

Financial Intelligence Stuart Levey explained, “The bank is used by the Government of Iran to

transfer money to terrorist organizations, including Hizballah, Hamas, the Popular Front for the

Liberation of Palestine-General Command and Palestinian Islamic Jihad. A notable example of

this is a Hizballah-controlled organization that has received $50 million directly from Iran

through Bank Saderat since 2001.” Although Treasury acknowledged that Bank Saderat was one

of the largest Iranian-owned banks, the bank had been so permeated by terrorist financing and

illicit activity that all transactions with the bank were prohibited. As Levey explained, “Bank

Saderat facilitates Iran’s transfer of hundreds of millions of dollars to Hizballah and other

terrorist organizations each year. We will no longer allow a bank like Saderat to do business in

the American financial system, even indirectly.”

494. The action against Bank Saderat followed a long campaign by the U.S.

government and international partners to shine a spotlight on the terrorism risks of doing

business with Iran’s banks. As former Treasury Assistant Secretary for Terrorist Financing and

Financial Crimes Juan C. Zarate explained in his 2013 memoir, Treasury’s War, Treasury had

begun a “Bad Bank Initiative” in early 2003 to target banks that were serving as nodes of illicit

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financing and to send “a clear message to others in the banking world.” “In 2003,” Zarate

explains, “we identified Bank Saderat as a principal target in our Bad Bank Initiative.” At that

time, there was “direct and convincing evidence that Bank Saderat was being used as the bank of

choice for transactions taking place between Iran and Hezbollah, with the branch in Beirut

serving as the central conduit for support to Hezbollah’s activities in Lebanon.” Those activities

were well-known outside of Treasury.26 And as part of its Bad Bank Initiative, Treasury sounded

the alarm to other financial institutions, including on information and belief, SCB. As Zarate

explains, “[a]n argument would be made directly to banks and companies around the world that

it was too risky to do business with Iran, since no one really knew who was lurking behind

corporate veils, pulling the strings, and accessing bank accounts and funding in Tehran.”

495. Treasury’s Bad Bank Initiative also included Banks Melli, Mellat, and Sepah, as

well as CBI/Markazi, which “would begin to look like a commercial bank for Iranian interests,

and it, too, was willing to serve as a banking hub for Iranian illicit activity.”

496. What remained of the U-Turn exception did not permit U-Turn transactions

involving entities or individuals that had been designated by OFAC. As relevant here, OFAC

designated numerous Iranian entities on October 25, 2007, for supporting terrorism and

proliferation: the IRGC; the IRGC’s Qods Force; the MODAFL; nine IRGC-affiliated companies

involving the IRGC in a diverse array of activities, including in the petroleum and construction

sectors; five IRGC leaders; and three Iranian banks—Bank Saderat, Bank Mellat, and Bank

Melli.

26
Zarate explains, “We were not the only ones to focus on Bank Saderat—this was a bank that
Israel would consider bombing during its war with Hezbollah in 2006, considering its central
importance to Hezbollah’s financing.”

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497. A fact sheet accompanying Treasury’s October 25, 2007, designations contained

detailed information about Iran’s use of IRGC-affiliated entities and banks to finance terrorism

and other illicit activity. According to the fact sheet, “FATF called on its members to advise

institutions dealing with Iran to seriously weigh the risks resulting from Iran’s failure to comply

with international standards.” Bank Melli, Bank Saderat, along with various IRGC-affiliated

entities and individuals were designated under E.O. 13382. Bank Melli was cited as using

deceptive banking practices to provide banking services for the IRGC, IRGC-QF, as well as

entities owned or controlled by them. Bank Saderat was identified as being used by Hezbollah

“to send money to other terrorist organizations,” as well as being used by the Iranian government

to “channel funds to terrorist organizations.” The IRGC “has significant political and economic

power in Iran, with ties to companies controlling billions of dollars in business and construction

and a growing presence in Iran’s financial and commercial sectors. Through its companies, the

IRGC is involved in a diverse array of activities, including petroleum production and major

construction projects across the country.” Although OFAC did not formally designate

CBI/Markazi until September 20, 2019, Treasury warned in the 2007 fact sheet (and would

continue to warn) that CBI/Markazi was facilitating terrorist financing: “For example, from 2001

to 2006, Bank Saderat transferred $50 million from the Central Bank of Iran through its

subsidiary in London to its branch in Beirut for the benefit of Hizballah fronts in Lebanon that

support acts of violence.”

498. On November 6, 2008, Treasury revoked authorization for U-Turn transactions in

their entirety. In a fact sheet accompanying this action, Treasury explained that it was “revoking

the U-turn general license today to protect U.S. financial institutions individually, and the U.S.

financial system as a whole, from the significant terrorist financing and proliferation risks posed

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by Iran. This regulatory action will close the last general entry point for Iran to the U.S. financial

system.”

499. Treasury’s November 6, 2008, fact sheet provided a detailed explanation and

warning about how Iran and the IRGC were using the international financial system to evade

counterterrorism controls and finance acts of terrorism by their proxies in the Middle East:

Iran’s access to the international financial system enables the Iranian regime to facilitate
its support for terrorism and proliferation. The Iranian regime disguises its involvement
in these illicit activities through the use of a wide array of deceptive techniques,
specifically designed to avoid suspicion and evade detection by responsible financial
institutions and companies. Iran also is finding ways to adapt to existing sanctions,
including by turning to non-designated Iranian banks to handle illicit transactions. . . .

Iran Misuses the International Financial System to Support Terrorism

Iran is the world’s most active state sponsor of terror. The support provided by the regime
to terrorist groups includes financing that is routed through the international financial
system, especially through Iranian state-owned banks.

• Iran’s Support to Terror. The Department of State designated Iran as a state sponsor
of international terrorism in 1984, and Iran remains the most active of the listed state
sponsors of terrorism, routinely providing substantial resources and guidance to multiple
terrorist organizations. For example, Hamas, Hizballah, and the Palestinian Islamic Jihad
(PIJ) maintain representative offices in Tehran to help coordinate Iranian financing and
training of these groups.

• Iran’s IRGC and IRGC-Qods Force Support Terrorist Groups. Elements of Iran’s
Islamic Revolutionary Guard Corps (IRGC) have been directly involved in the planning
and support of terrorist acts throughout the world, including in the Middle East, Europe
and Central Asia, and Latin America. The IRGC-Qods Force, which has been designated
under Executive Order 13224 for providing material support to the Taliban and other
terrorist groups, is the Iranian regime’s primary mechanism for cultivating and supporting
terrorist and militant groups abroad. Qods Force-supported groups include: Lebanese
Hizballah; Palestinian terrorists; certain Iraqi Shi’a militant groups; and Islamic militants
in Afghanistan and elsewhere. The Qods Force is especially active in the Levant,
providing Lebanese Hizballah with funding, weapons and training. It has a long history
of supporting Hizballah’s military, paramilitary and terrorist activities, and provides
Hizballah with more than $100 to $200 million in funding each year. The Qods Force
continues to provide the Taliban in Afghanistan with limited weapons, funding, logistics
and training in support of anti-U.S. and anti-coalition activities.

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• Iran Uses its Banks to Finance Terrorism. In a number of cases, Iran has used its
state-owned banks to channel funds to terrorist organizations. Between 2001 and 2006,
Bank Saderat transferred $50 million from the Central Bank of Iran through Bank
Saderat’s subsidiary in London to its branch in Beirut for the benefit of Hizballah fronts
that support acts of violence. Hizballah also used Bank Saderat to send funds to other
terrorist organizations, including Hamas, which itself had substantial assets deposited in
Bank Saderat as of early 2005. The Treasury Department designated Bank Saderat under
E.O. 13224 for providing financial services to Hizballah, Hamas and PIJ. Australia has
also designated Bank Saderat. Iran’s Bank Melli, which has been designated by the
United States under E.O. 13382 for proliferation-related activities, was used to transfer at
least $100 million to the IRGC-Qods Force between 2002 and 2006.

500. Treasury’s November 6, 2008, fact sheet also provided an additional explanation

and warning about how Iran was seeking to evade counterterrorism controls:

Iran Uses Deceptive Financial Practices to Evade Sanctions

• Iranian Commercial Banks. It has been a standard practice for Iranian financial
institutions to conceal their identity to evade detection when conducting transactions. For
example, Bank Sepah has requested that its name be removed from transactions in order
to make it more difficult for intermediary financial institutions to determine the true
parties to a transaction. Following the designation of Bank Sepah under UNSCR 1747,
Bank Melli took precautions not to identify Bank Sepah in transactions. Bank Melli also
has employed similar deceptive practices to obscure its involvement from the
international banking system when handling financial transactions on behalf of the IRGC.
In addition, when Iranian assets were targeted in Europe, branches of Iranian state-owned
banks in Europe took steps to disguise ownership of assets on their books in order to
protect assets from future actions.

• Central Bank of Iran. The Central Bank of Iran (CBI), the sole Iranian entity that
regulates all Iranian banks, has not only engaged in deceptive practices itself – such as
asking for its name to be removed from transactions – but has also encouraged such
practices among Iran’s state-owned banks. For example, prior to EU and UN sanctions,
the CBI attempted to help Banks Sepah and Melli protect their assets from being frozen.
Later, the CBI instructed non-sanctioned Iranian state-owned banks to issue payment
instructions on behalf of Sepah in order to circumvent sanctions. In the case of Bank
Melli, the CBI provided substantive assistance to minimize the impact of sanctions. In
fact, between January and March 2008, the CBI handled tens of millions of dollars in
transactions to and from the accounts of U.S.- and UN-designated banks held at the CBI.

• Use of Front Companies and Misuse of Bank Accounts. Iran hides behind front
companies and intermediaries to engage in ostensibly legitimate financial and
commercial transactions that are actually related to its nuclear or missile programs.
Iranian entities form front companies outside of Iran for the sole purpose of exporting
dual-use items to Iran that can be used in these programs. These front companies enable

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the regime to obtain materials that the country of origin would typically prohibit from
being exported to Iran. Iran also has a history of using accounts set up for one purpose to
facilitate activities with designated entities.

501. In remarks accompanying the revocation of the U-Turn exception, Treasury

Under Secretary for Terrorism and Financial Intelligence Stuart Levey explained that the action

was the culmination of a campaign that had been launched in November 2006 “to warn the world

about how Iran’s threat to our security also posed a threat to the integrity of the international

financial system.” Since that time, he explained, “we have shared information with foreign

governments and financial institutions about how Iran is using its banks to finance its nuclear

and missile programs and terrorist groups. We have provided reliable information to back up our

words, demonstrating that even seemingly benign business with Iran should be cause for

concern.” Levey went on to explain that most financial institutions had heeded the warnings:

At the same time, many private financial institutions and companies worldwide have
voluntarily shunned business with Iran. Banks see Iran’s behavior as posing an
unacceptable risk to their reputations, and they would rather forgo the business and
preserve their integrity[.] Back in September 2006, I could count on one hand the major
banks that had cut off or dramatically reduced their business with Iran. Now, there are
only a few that have not done so.

There is now a global consensus that Iran poses an unacceptable threat to the
international financial system. The Financial Action Task Force (FATF), which has
members representing 32 jurisdictions and is the world’s premier standard-setting body
on combating money laundering and terrorist financing, issued its fourth warning on Iran
last month, calling for countries worldwide to strengthen measures to protect their
financial sectors from this threat.

...

As members of the FATF, we are fulfilling our obligation to strengthen measures to

protect our financial sector from those risks. Therefore, today we are revoking the U-turn
license for Iran, thus terminating the last general entry point for Iranian banks – both
state-owned and private – to the U.S. financial system. U-turn transactions allowed U.S.
banks to indirectly process payments involving Iran if they began and ended with a non-
Iranian foreign bank. Given Iran’s conduct, it is necessary to close even this indirect
access.

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In recent months, many U.S. institutions have refused to host these U-turn transactions
for Iran. Still, the exemption was used by Iran as a hook to solicit foreign banks to
process transactions through the United States on its behalf, sometimes with requests to
substitute another bank or code word for the Iranian institution. With today’s action,
Iran’s potential to manipulate U.S. financial institutions has been significantly curtailed.

502. The sum and substance of this avalanche of sanctions was simple: the entire

landscape of U.S. policy towards Iran was transformed through a series of actions that sought to

isolate Iran and its terrorist financing from the U.S. and international financial system.

2. Transaction Review and Reporting

503. Separate and apart from sanctions, U.S. banks and foreign banks with U.S.

branches are subject to an additional set of regulations under the Bank Secrecy Act (BSA) and

state and federal banking laws to prevent money laundering and the financing of terrorism. These

Anti-Money Laundering/Countering the Financing of Terrorism (AML/CFT) regulations are

administered by Treasury’s Financial Crimes Enforcement Network (FinCEN), along with the

banking regulators. At the heart of these regulations is an obligation by financial institutions to

carefully review the transactions they process, and to promptly report suspicious activity—

including terrorist financing—to FinCEN, which disseminates these reports to law enforcement

agencies and the intelligence community.

504. The critical importance of BSA reporting as a counterterrorism control was

explained in findings Congress made when it bolstered BSA requirements in the International

Money Laundering Abatement and Financial Anti-Terrorism Act of 2001, part of the USA

PATRIOT Act. In the Act, Congress found that “money laundering, and the defects in financial

transparency on which money launderers rely, are critical to the financing of global terrorism and

the provision of funds for terrorist attacks.” Such money launderers “subvert legitimate financial

mechanisms and banking relationships by using them as protective covering for the movement of

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criminal proceeds and the financing of crime and terrorism, and, by so doing, can threaten the

safety of United States citizens and undermine the integrity of United States financial institutions

and of the global financial and trading systems upon which prosperity and growth depend.” And

in particular, “correspondent banking facilities are one of the banking mechanisms susceptible in

some circumstances to manipulation by foreign banks to permit the laundering of funds by

hiding the identity of real parties in interest to financial transactions.”

505. Among other things, the Act amended the BSA’s declaration of purpose (31

U.S.C. 5311) to emphasize counterterrorism: “It is the purpose of this subchapter (except section

5315) to require certain reports or records where they have a high degree of usefulness in

criminal, tax, or regulatory investigations or proceedings, or in the conduct of intelligence or

counterintelligence activities, including analysis, to protect against international terrorism.”

(emphasis added). Congress also added language in another section (31 U.S.C. 5319) making

clear that BSA reports shall be made available to any “United States intelligence agency.”

506. To underscore the importance of BSA reporting in countering terrorist attacks,

President George W. Bush visited FinCEN on November 7, 2001, and gave a speech to “put the

world’s financial institutions on notice.” He explained that the War on Terrorism was “not a war

just of soldiers and aircraft. It’s a war fought with diplomacy, by the investigations of law

enforcement, by gathering intelligence and by cutting off the terrorists’ money.” He explained

how certain terrorist financiers “present[ed] themselves as legitimate businesses. But they skim

money from every transaction, for the benefit of terrorist organizations. They enable the

proceeds of crime in one country to be transferred to pay for terrorist acts in another.” President

Bush did not mince words in delivering his “clear message to global financial institutions”: “you

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are with us or you are with the terrorists. And if you’re with the terrorists, you will face the

consequences.”

507. FinCEN explains on its website that BSA reports have “proven to be of

considerable value in money laundering, terrorist financing and other financial crimes

investigations by law enforcement.”

508. BSA requirements and regulatory expectations are summarized in the Federal

Financial Institutions Examination Council (FFIEC) Bank Secrecy Act (BSA) /Anti-Money

Laundering (AML) Examination Manual (FFIEC Manual), which was developed by federal and

state banking agencies, FinCEN, and OFAC to provide guidance to banks and their examiners,

and to ensure consistency in the application of BSA/AML requirements. The FFIEC Manual was

first released in 2005, but it summarized requirements and expectations in effect since before

2001. The FFIEC Manual was commonly regarded by U.S. bank personnel as an authoritative

source of guidance on BSA compliance.

509. BSA compliance required two principal components. First, banks had to establish

and maintain an effective AML/CFT program that assessed the banks’ AML/CFT risk and

monitored transactions for suspicious activity. Second, banks had to investigate transactions for

potential illicit activity and report suspicious transactions to FinCEN.

510. As part of a bank’s risk assessment, according to the FFIEC Manual, a bank had

to “first, identify the specific risk categories (i.e., products, services, customers, entities, and

geographic locations) unique to the bank; and second, conduct a more detailed analysis of the

data identified to better assess the risk within these categories.” The FFIEC Manual explained

that high-risk products and services included the following:

 funds transfers

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 electronic banking

 foreign correspondent accounts

 trade finance

High-risk customers and entities included the following:

 foreign financial institutions

 foreign individuals

 foreign corporations

High-risk geographic locations included the following:

 countries subject to OFAC sanctions, including state sponsors of terrorism

 countries identified as supporting international terrorism under section 6(j) of the

Export Administration Act of 1979

 jurisdictions determined to be “of primary money laundering concern” by the

Secretary of the Treasury, and jurisdictions subject to special measures imposed by

the Secretary of the Treasury, through FinCEN, pursuant to section 311 of the Patriot

Act.

 jurisdictions or countries identified as non-cooperative by the Financial Action Task

Force on Money Laundering (FATF)

511. The second step of the risk assessment required considering more specific data

regarding the purpose of an account, actual or anticipated activity in the account, the nature of

the customer’s business, the customer’s location, and the types of products and services used by

the customer, with the bank’s Customer Due Diligence (CDD) information having an important

role in the process.

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512. The FFIEC Manual further explained that the risk assessment process needed to

be “an ongoing process, not a one-time exercise.” Banks were expected to update their risk

assessments to identify changes in the bank’s risk profile, and this required banks to continually

monitor information from a variety of sources. The FFIEC Manual included a list of sources,

including U.S. Government threat assessments, FinCEN guidance, and FATF publications.

513. A bank’s risk assessment was expected to inform its reporting obligations: “For

example, the bank’s monitoring systems to identify, research, and report suspicious activity

should be risk-based, with particular emphasis on high-risk products, services, customers, and

geographic locations as identified by the bank’s BSA/AML risk assessment.”

514. The next step was to establish a set of internal controls reasonably designed to

ensure ongoing compliance with BSA requirements. The FFIEC Manual explained that a bank’s

“board of directors, acting through senior management, is ultimately responsible for ensuring

that the bank maintains an effective BSA/AML internal control structure, including suspicious

activity monitoring and reporting,” and the “board of directors and management should create a

culture of compliance to ensure staff adherence to the bank’s BSA/AML policies, procedures,

and processes.”

515. The FFIEC Manual explained that the “cornerstone of a strong BSA/AML

compliance program is the adoption and implementation of comprehensive CDD policies,

procedures, and processes for all customers, particularly those that present a high risk for money

laundering and terrorist financing.” The FFIEC Manual explained that CDD policies, procedures

and processes “provide the critical framework that enables the bank to comply with regulatory

requirements and to report suspicious activity,” as well as aiding the bank in “[a]voiding criminal

exposure from persons who use or attempt to use the bank’s products and services for illicit

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purposes.” Where customers pose high risk, the FFIEC Manual contemplates an intensive review

of relevant customer information, including:

 Purpose of the account.

 Source of funds and wealth.

 Beneficial owners of the accounts, if applicable.

 Customer’s (or beneficial owner’s) occupation or type of business.

 Financial statements.

 Banking references.

 Domicile (where the business is organized).

 Proximity of the customer’s residence, place of employment, or place of business to

the bank.

 Description of the customer’s primary trade area and whether international

transactions are expected to be routine.

 Description of the business operations, the anticipated volume of currency and total

sales, and a list of major customers and suppliers.

 Explanations for changes in account activity

516. The final element of BSA compliance, and the culmination of a bank’s AML/CFT

controls, was suspicious activity reporting, which the FFIEC Manual explained was “critical to

the United States’ ability to utilize financial information to combat terrorism, terrorist financing,

money laundering, and other financial crimes.” Under BSA regulations, banks were required to

file a Suspicious Activity Report (SAR) for any transaction conducted or attempted by, at, or

through the bank (or an affiliate) and aggregating $5,000 or more, if the bank or affiliate knows,

suspects, or has reason to suspect that the transaction involves money laundering or illegal

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activity. The FFIEC Manual specified that this included any suspected “terrorism financing.”

Indeed, although SARs were normally required to be filed no more than 60 days after the date of

initial detection, the FFIEC Manual instructed banks to act immediately upon any suspected link

between a customer and terrorist activity:

If a bank knows, suspects, or has reason to suspect that a customer may be linked to
terrorist activity against the United States, the bank should immediately call FinCEN’s
Financial Institutions Terrorist Hotline at the toll-free number: 866-556-3974. . . . [T]he
bank must also file a SAR.

517. Under BSA regulations, SARs are highly confidential. No bank, and no director,

officer, employee, or agent of a bank, that reports a suspicious transaction may notify any person

involved in the transaction that the transaction has been reported.

518. More generally with respect to terrorist financing, the FFIEC Manual contained

an appendix entitled “Money Laundering and Terrorist Financing ‘Red Flags,’” wherein

examples of potentially suspicious activity that may indicate terrorist financing were listed. The

examples included:

 Funds are generated by a business owned by persons of the same origin or by a

business that involves persons of the same origin from high-risk countries (e.g.,
countries designated by national authorities and FATF as non-cooperative countries
and territories).

 Funds transfers do not include information on the originator, or the person on whose
behalf the transaction is conducted, when the inclusion of such information would be
expected.

 Banks from high-risk locations open accounts.

 Funds are sent or received via international transfers from or to high-risk locations.

In explaining these red flags, the FFIEC Manual referenced Guidance for Financial Institutions

in Detecting Terrorist Financing that had previously been issued in 2002 by the Financial Action

Task Force (FATF) and listed similar red flags.

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519. The FFIEC Manual also explained that terrorist financing can happen through

legitimate business activity, even where the transactional activity itself contains no red flags:

“Other legitimate sources have also been found to provide terrorist organizations with funding;

these legitimate funding sources are a key difference between terrorist financiers and traditional

criminal organizations. In addition to charitable donations, legitimate sources include foreign

government sponsors, business ownership, and personal employment.”

520. FATF issued a report on Terrorist Financing in February 2008 specifically

explaining that “[d]etecting terrorist involvement in otherwise legitimate financial activity

requires financial institutions to implement the FATF standards through strong application of the

‘know your customer’ principle and of customer due diligence (CDD) policies and procedures.”

This report also clearly stated that “financial information” including “suspicious transaction

reporting . . . has a central role in identifying terrorist financing and the movement of terrorist

funds through the financial system.”

3. The Terrorist Finance Tracking Program

521. A third key counterterrorism control was the U.S. government’s ongoing

monitoring of payment messages sent through the Society for Worldwide Interbank Financial

Telecommunication (SWIFT) system. The SWIFT system was the primary means by which

payments were processed through the international banking system. At all relevant times

beginning in 2001, the Treasury Department monitored SWIFT payment messages through the

Terrorist Finance Tracking Program (TFTP).

522. Treasury explains the history and importance of this program on its website:

“After the terrorist attacks on September 11, 2001, the United States Department of the Treasury

(Treasury) initiated the Terrorist Finance Tracking Program (TFTP) to identify, track, and pursue

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terrorists — such as Al-Qaida, Hizballah, HAMAS and their networks. This was an important

part of Treasury’s larger effort to track terrorist money flows and assist in broader U.S.

government efforts to uncover terrorist cells and map terrorist networks here at home and around

the world.”

523. Since the start of the program in 2001, Treasury’s website reports that “the TFTP

has provided hundreds of thousands of valuable leads to U.S. government agencies and other

governments that have aided in the prevention or investigation of many of the most visible and

violent terrorist attacks and attempted attacks of the past decade. . . . SWIFT information greatly

enhances our ability to map out terrorist networks, often filling in missing links in an

investigative chain. . . . By following the money, the TFTP has allowed the United States and our

allies to identify and locate operatives and their financiers, chart terrorist networks, and help

keep money out of their hands.”

524. Although the TFTP began as a covert program, it was revealed and widely

publicized by the press in June 2006, including in a New York Times article by Eric Lichtblau

and James Risen. The following month, Treasury Under Secretary for Terrorism and Financial

Intelligence Levey confirmed and explained the importance of the program in testimony before

the House Financial Services Subcommittee on Oversight and Investigations:

As this Committee knows well, tracking and combating terrorist financing are critical
facets of our overall efforts to protect our citizens and other innocents around the world
from terrorist attacks. This is true for two main reasons. First, when we block the assets
of a terrorist front company, arrest a donor, or shut down a corrupt charity, we deter other
donors, restrict the flow of funds to terrorist groups and shift their focus from planning
attacks to worrying about their own needs. While any single terrorist attack may be
relatively inexpensive to carry out, terrorist groups continue to need real money. They
depend on a regular cash flow to pay operatives and their families, arrange for travel,
train new members, forge documents, pay bribes, acquire weapons, and stage attacks.
Disrupting money flows stresses terrorist networks and undermines their operations. In
recent months, we have seen at least one instance of what we look for most - a terrorist

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organization indicating that it cannot pursue sophisticated attacks because it lacks

adequate funding.

Second, “following the money” is one of the most valuable sources of information that
we have to identify and locate the networks of terrorists and their supporters. If a terrorist
associate whom we are watching sends or receives money from another person, we know
that there’s a link between the two individuals. And, while terrorist supporters may use
code names on the phone, when they send or receive money through the banking system,
they often provide information that yields the kind of concrete leads that can advance an
investigation. For these reasons, counter-terrorism officials place a heavy premium on
financial intelligence. . . .

The Terrorist Finance Tracking Program has been a key part of these overall efforts. . . . I
have on my staff a group of intelligence analysts who spend their days in a secure room
poring over information to unmask the key funders and facilitators of terrorist groups. If
you spoke with them, they would point to this program as one of the most important and
powerful tools they have to follow the money.

B. Between 2001 and 2007, SCB Made a Series of Business Decisions to Serve
Customers with Close Connections to Iran’s Terrorist Sponsors by Helping
Them Subvert Counterterrorism Controls

525. Beginning no later than 2001 and continuing through at least 2007, SCB moved at

least $250 billion through the NY Branch on behalf of client Iranian financial institutions

(“Iranian Banks”) with close ties to Iran’s Terrorist Sponsors. The Iranian Banks included at

least CBI/Markazi, as well as Bank Saderat and Bank Melli, both of which were (and still are)

Iranian State-owned institutions.27 All three of these banks have been sanctioned by the United

States for their connections with the IRGC’s anti-American terrorism.

526. Only a few weeks after President Clinton sounded the alarm about Iran’s funding

of terrorism and imposed comprehensive sanctions in May 1995, SCB began to view those

warnings as a business opportunity. In a June 1, 1995, email, SCB’s General Counsel strategized

with SCB’s compliance staff about how to evade the new sanctions, advising, “if SCB London

were to ignore OFACs regulations AND SCB NY were not involved in any way & (2) had no

27
2012 NYDFS Consent Order ¶ 1.

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knowledge of SCB Londons [sic] activities & (3) could not be said to be in a position to control

SCB London, then IF OFAC discovered SCBLondons [sic] breach, there is nothing they could

do against SCB London, or more importantly against SCBNY.” Recognizing the illicit nature of

this scheme, he instructed that a memorandum containing this plan was “highly confidential &

MUST NOT be sent to the US.”28

527. Despite the U.S. singling out Iran’s petroleum sector for particular concern in

1995, SCB viewed it as a source of lucrative business to provide Iranian petroleum companies

with access to U.S. dollars. In 2001, CBI/Markazi asked SCB to act as its correspondent bank

with respect to international U.S.-dollar payments, including relating to oil sales by NIOC. At

that time, the CEO of SCB’s Iran representative office wrote a memo in support of expanding the

CBI account, noting that “[t]o be the bank handling Iran’s oil receipts would be very prestigious

for SCB. In essence, SCB would be acting as Treasurer to the CBI/the country.”29 SCB decided

to accept this business in 2001.

528. SCB determined that OFAC’s U-turn exception would generally enable SCB to

clear CBI/Markazi’s U.S.-dollar transactions through its NY Branch without violating OFAC

sanctions, but SCB knew that the U.S. government’s counterterrorism controls posed a greater

obstacle. Not only did U-turn transactions need to be reviewed to ensure that they complied with

the U-turn exception, but the NY Branch also had an obligation under the BSA to review and

report suspicious transactions. SCB knew that acting as a correspondent bank for an Iranian bank

was an activity that would be viewed by U.S. regulators as entailing an extraordinarily high risk

of terrorist financing, which would necessitate intensive review by BSA compliance personnel in

28
2012 NYDFS Consent Order ¶ 20.
29
2012 DPA Factual Statement ¶ 22.

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the NY Branch. SCB and its Iranian clients also knew that SCB’s NY Branch would be required

to report suspicious terrorist financing activity to FinCEN for dissemination to law enforcement

and the intelligence community.

529. Those counterterrorism controls had at least two distinct problems from the

perspective of SCB and CBI/Markazi.

530. The first problem was the potential for delay. A “critical component” of the deal

between SCB and CBI/Markazi was the timing of $500 million in daily U.S. dollar payments. A

senior manager of SCB’s Iranian business noted that “the most important aspect to CBI/Markazi

of this relationship with SCB” was SCB’s “willingness to pay away funds in advance of receipts

(intraday of up to USD 200m).” He stressed that providing rapid U.S. dollar payments for

CBI/Markazi “could lead to increased business activity with [other Iranian] banks.”30

531. But the second problem was the very fact that CBI/Markazi’s suspicious activity

could be reported. The CEO of SCB’s Iran representative office, Mohammed Sarrafzadeh,

explained in an interview with federal and state law enforcement authorities that he believed the

Iranians’ real concern was that the U.S. government would gain information about the

Iranians’ business dealings if the payments were transparent to the NY Branch.31 In other

words, the U.S. government would gain information about how the IRGC’s oil business and

other activities were funding terrorist attacks. And CBI/Markazi left no doubt that this was of

paramount importance to the bank, making clear to SCB that payment processing that showed

CBI/Markazi’s involvement in the transaction was not an option if SCB was to receive the

30
2012 NYDFS Consent Order ¶ 23.
31
2012 DPA Factual Statement ¶ 23.

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business.32 As one SCB employee wrote about the CBI/Markazi account, “this account must

remain completely secret to the U.S.”33

532. SCB decided to oblige. It conspired with CBI/Markazi to route U.S. dollar

payments through the NY Branch after first stripping data from SWIFT wire transfer messages

used to identify sanctioned countries, individuals and entities—a practice known as “wire

stripping.”34

533. SCB ensured the anonymity of its U.S. dollar clearing activities for Iran’s

Terrorist Sponsors through the NY Branch by falsifying SWIFT wire payment directions. SCB

would have employees at SCB London review transactions involving Iranian counterparties,

stripping the message of unwanted identifying data and replacing it with false entries or returning

the payment message to the Iranian Bank for wire stripping and resubmission—a process that

SCB, conscious of its illegality, euphemistically called “repairing” the wire.

534. SCB utilized such schemes to keep SCB NY in the dark about the true nature of

the U.S. dollar clearing transactions, so that SCB NY would not scrutinize or report these

transactions as suspicious activity.

535. In March 2001, SCB’s Group Legal Advisor counseled several of SCB’s officers

that “our payment instructions [for Iranian Banks] should not identify the client or the purpose of

the payment.”35

32
2012 DPA Factual Statement ¶ 23.
33
2012 DPA Factual Statement ¶ 23 (emphasis added).
34
2012 NYDFS Consent Order ¶ 3. According to SCB’s independent consultant, this figure
represents about 30,000 messages that were sent to the NY Branch by SCB’s London office,
mainly on behalf of state-owned Iranian banks, and approximately 30,000 messages from SCB
Dubai to the NY Branch on behalf of Iranian-owned banks, corporations and other unknown
entities. Id. n.2.
35
2012 NYDFS Consent Order ¶ 24.

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536. SCB went to great lengths to manipulate the SWIFT system to deceive payment

message recipients in New York. SCB instructed CBI/Markazi to “send in their MT

202’s”—a standardized SWIFT payment message for transfers between banks—“with a [SCB

London’s business identifier code] as this is what we required them to do in the initial set up of

the account. Therefore, the payments going to NY do not appear to NY to have come from an

Iranian Bank.” SCB also accomplished this subterfuge by: (a) inserting special characters (such

as “.”) in electronic message fields used to identify transacting parties; (b) inserting phrases such

as “NO NAME GIVEN” or “NOT STATED” in lieu of requested information that would

identify the Iranian Banks; and (c) employing a system known as SCB’s “repair procedure,”

whereby SCB overseas employees screened payment messages—before they were

communicated to its NY branch—to ascertain whether any messages contained information that

identified the Iranian Banks, and if so, remove it.36

537. SCB understood that simply omitting Iranian client information on SWIFT MT

202 payment messages going to New York was insufficient because the electronic payment

system would automatically fill in blank data fields, identifying the Iranian Bank. Consequently,

to disguise the transactions effectively and thereby avoid regulatory scrutiny, SCB deliberately

made false and misleading entries in SWIFT “field 52,” a data field that would otherwise identify

the Iranian party.37

538. SCB documents show that its attorney in charge of Bank Secrecy Act (“BSA”)

and anti-money laundering (“AML”) compliance knew that “the process for effecting Bank

Markazi’s “payment instructions” was deceptive wire-stripping. He was specifically told that

36
2012 NYDFS Consent Order ¶ 27.
37
2012 NYDFS Consent Order ¶ 28.

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“field 52 (ordering institution) is quoted by Bank Markazi in their MT202 as [SCB London]” or

SCB would manually “repair” or “over-type field 52 as [SCB London].” He knew that these

actions would leave “no reference to Bank Markazi,” and would thus “send[] incorrect

information.”38

539. Senior SCB management memorialized many of these procedures in formal

operating manuals. One such manual entitled, “Quality Operating Procedure Iranian Bank

Processing,” directed SCB’s London-based employees to “repair payment[s] by making

appropriate changes” to transacting party codes. It provided step-by-step wire stripping

instructions for any payment messages containing information that would identify the Iranian

Banks. An example directive read: “[e]nsure that if the field 52 of the payment is blank or

displayes [sic] any SWIFT code that it is overtyped at the repair stage to a ‘.’ This will change

the outgoing field 52 on the MT103 to a field 52D of ‘.’ Or, in the case of a ‘normal MT202

instruction change the field 52 on the outgoing MT202 to [SCB’s New York branch] to a ‘.’

(Note: if this is not done then the Iranian Bank SWIFT code may appear – depending on routing

– on the payment message being sent to [the New York branch]).”39

540. The chief lawyer in charge of Legal & Compliance for SCB’s Wholesale Bank

division commented to other senior legal and compliance staff that the document, “read in

isolation, is clearly . . . designed to hide, deliberately, the Iranian connection of payments.”40

541. These masking procedures evolved to meet SCB’s growing volume demands.

When SCB anticipated that its business with the Iranian Banks would grow too large for SCB

employees to “repair” manually the instructions for New York bound wire transfers, SCB

38
2012 NYDFS Consent Order ¶ 29.
39
2012 NYDFS Consent Order ¶ 30 (brackets in original).
40
2012 NYDFS Consent Order ¶ 31.

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automated the process by building an electronic repair system with “specific repair queues” for

each Iranian client.41

542. As SCB vigorously cultivated U.S. dollar clearing business from the Iranian

Banks, SCB’s outside counsel continuously admonished SCB to not evade regulatory

requirements. In 2003, one of SCB’s outside legal counsel in the U.S. warned that the bank’s

system for executing U-Turns anonymously through the NY Branch did “not comport with the

law or the spirit of OFAC rules, which lay out explicit details on how such transactions are to be

conducted.” She further instructed that “OFAC insists on full disclosure of all parties in

transactions to ensure that transactions meet the terms of the rule.”42

543. SCB also acutely understood how its wire stripping practices made it impossible

for the bank to carry out its AML/CFT obligations to report suspicious activity. In fact, in

November 2003, SCB’s New York banking regulators conducted an examination of this very

matter, in which they concluded that SCB NY’s “monitoring of funds transfer activity was found

to be ineffective against safeguarding against legal, reputational and compliance risks associated

with suspicious and unusual activity in U.S. dollar funds transfer.” The regulators warned that

the “identification and control of risk exposures is lacking, and considered far below the level

expected for a high-risk profile institution such as SCNY.”43 They concluded, “A prompt and

satisfactory resolution of the deficiencies is of utmost importance, and we expect both the head

office and branch management to assign this situation the highest priority and provide full

support to the plan.”44

41
2012 NYDFS Consent Order ¶ 32.
42
2012 NYDFS Consent Order ¶ 33.
43
2012 DPA Factual Statement ¶ 74.
44
2012 DPA Factual Statement ¶ 74.

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544. SCB’s external counsel provided a similar warning: “I should point out that

permissible U-Turn transactions should be done on a fully disclosed basis, that is, SCB (London)

. . . should disclose all details of the transaction. Not to do so could place SCB (New York)

seriously in harm’s way under the law and should be a condition for moving forward with any

transaction.”45

545. SCB promised its New York regulators in a written agreement that it would

correct its AML/CFT compliance failures by “enhanc[ing] due diligence policies and procedures

relating to the New York Branch’s funds transfer clearing operations and correspondent accounts

for non-U.S. banks” and “implementing industry sound practices designed to identify and

effectively manage risks.”46 SCB’s CEO and the CEO of SCB Americas signed this written

agreement. But the promise was false. As an internal SCB memorandum about its Iran business

noted, the agreement to correct AML/CFT compliance failures created negative “implications for

[SCB’s] growth ambition and strategic freedom that [went] way beyond just the U.S.”47 It stood

as a significant obstacle to SCB’s growth and evolving business strategies.

546. Beginning in 2003, other banks with significant Iran portfolios began exiting the

U-Turn business. For instance, SCB’s business managers learned that Lloyds TSB London was

“withdrawing their services” with one of its Iranian client banks “primarily for reputational risk

reasons.”28 Rather than follow suit, and despite concerns regarding the terrorist financing risk,

SCB positioned itself to take the abandoned market share.48 It sought to pick up this business and

45
2012 DPA Factual Statement ¶ 31.
46
2012 DPA Factual Statement ¶ 75.
47
2012 NYDFS Consent Order ¶ 42.
48
2012 NYDFS Consent Order ¶ 35.

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add U.S.-dollar accounts for five Iranian banks at SCB London: Bank Melli, Bank Sepah, Persia

International Bank, Bank Saderat, and Bank Mellat.49

547. As described in a December 2005 internal memorandum written by the CEO of

SCB’s United Arab Emirates region and the Group Head of Compliance and Regulatory Risk,

SCB’s “short to medium term strategy [was] to grow the wholesale business by growing our

wallet share from existing relationships with Financial Institutions and Iranian companies and

establishing new relationships with Iranian companies and [intermediaries] in oil and gas related

businesses.”50 That memorandum, entitled Project Gazelle, Report on Iranian Business, was

circulated among SCB’s key legal, compliance, and Iranian client business managers.

548. As with CBI/Markazi, the other Iranian banks objected to transparency in

payment messages sent to the United States.51 The CEO of SCB Americas expressed concern,

explaining, “it is my understanding that we must cease and desist all these current transactions

with Iranian customers that don’t fully disclose the remitter and beneficiary since it’s not a

question of interpretation but rather is clearly the law as regards these types of transactions.”52

But SCB’s business personnel pushed back, and Mohammed Sarrafzadeh, CEO of SCB’s Iran

representative office, explained that full transparency “will be a deal breaker” to the Iranian

banks.53

549. To avoid such deal-breakers, SCB instituted a system of so-called “offshore

OFAC due diligence.” The entire enterprise was a sham. Although SCB’s offshore operation

could do minimal OFAC compliance, it could not substitute for the most critical counterterrorism

49
2012 DPA Factual Statement ¶ 30.
50
2012 NYDFS Consent Order ¶ 36.
51
2012 DPA Factual Statement ¶ 30.
52
2012 DPA Factual Statement ¶ 32.
53
2012 DPA Factual Statement ¶ 33.

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controls, which were the AML/CFT compliance and suspicious activity reporting that the BSA

required SCB’s New York Branch to perform. Thus, the true objective and effect of SCB’s

offshore scheme was not to relocate meaningful terrorism risk compliance, but to disable it.

Consistent with the wishes of SCB’s Iranian clients, SCB’s offshore scheme continued its

practice of depriving U.S. personnel responsible for suspicious activity reporting of key

information they needed.

550. SCB’s overseas due diligence staff members were responsible for both SCB’s U-

Turn “repair procedures” and OFAC “compliance”—a paradoxical task to say the least. SCB

personnel did not know the elements of a lawful U-Turn transaction other than that the payment

“had to be offshore to offshore,” and they were not trained to determine whether the

underlying transactions were valid according to the Iranian Trade Regulations. In fact, as late as

August 2006, SCB’s operations staff still “resolve[d] ‘hits’ on sanctioned names directly with the

customer”—a method designed to facilitate, not prevent, client misconduct.54

551. Senior SCB management knowingly embraced the bank’s fraudulent U-Turn

procedures with full awareness that (as one internal report put it) “the current process under

which some SWIFT messages are manually ‘repaired’ to remove reference to Iran could . . . be

perceived by OFAC as a measure to conceal the Iranian connections from [the NY Branch], and

therefore evade their controls for filtering Iranian related payments. Unless transactions are

repaired they face delays caused by investigations in the U.S. banking system, subjecting SCB to

interest claims.”55 An SCB executive described SCB’s repair procedures as a “process to check

that a payment is, prima facie, an acceptable U-turn transaction (i.e. offshore to offshore),” and

54
2012 NYDFS Consent Order ¶ 39 (emphasis added).
55
2012 NYDFS Consent Order ¶ 21.

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fully acknowledged that “they do not provide assurance that it does not relate to a prohibited

transaction, and therefore SCB NY is exposed to the risk of a breach of sanctions.”56

552. One of the most pointed internal concerns came from SCB’s CEO for the

Americas in October 2006. As reported by NYDFS, that executive “sent a panicked message to

the Group Executive Director in London” urging the bank to reconsider the Iranian business in

light of “the potential to cause very serious or even catastrophic reputational damage to the

Group,” and to subject “management in US and London (e.g. you and I) and elsewhere to

personal reputational damages and/or serious criminal liability.”57 The Group Executive Director

responded by belittling the concern and displaying “obvious contempt for U.S. banking

regulations,” saying in a meeting: “You fucking Americans. Who are you to tell us, the rest of

the world, that we’re not going to deal with Iranians.”58

553. These candid statements are exceptional because people working in banks and in-

house legal departments are trained not to leave paper trails admitting wrongdoing. Thus, when

executives and attorneys speak in anodyne terms about potential “risk,” it is a fair inference that

they privately know to a high degree of certainty that their conduct is unlawful. When they spell

out, in such stark terms, that they face catastrophic risk and serious criminal liability, the

inference is inescapable. Accordingly, SCB’s senior executives were aware, as of October 2006

(and likely earlier), that the bank was playing a role in very serious unlawful activities.

554. The American executive’s concern proved true. Multiple regulatory and law

enforcement agencies concluded that SCB’s conduct posed serious sanctions risks, interfered

with its ability to perform effective safety and soundness examinations, and prevented it from

56
2012 NYDFS Consent Order ¶ 21 (emphasis removed).
57
2012 NYDFS Consent Order ¶ 7 (emphasis in the original).
58
2012 NYDFS Consent Order ¶ 8.

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identifying suspicious activity that could assist them in effectively supervising other licensed

institutions and from assisting other law enforcement authorities.

555. SCB’s systemic misconduct was the basis for the violations of law set forth in

SCB’s 2012 DPA with DOJ and the 2012 NYDFS Consent Order—in connection with which

SCB paid more than $550 million in penalties and forfeitures.

556. SCB was found by regulatory and law enforcement agencies to have processed

$23 million in transactions for Iranian customers from 2001 through 2007 that violated OFAC’s

U-turn rules. No less troubling, however, was the larger bulk of transactions SCB processed

through New York for Iranian banks and other Iranian customers with fraudulent and misleading

SWIFT messages. Between 2001 and 2007, these transactions included more than $32 billion

and at least 2,684 SWIFT messages for CBI/Markazi; more than $79 billion and at least 5,189

SWIFT messages for the five other Iranian banks; and more than $3.9 billion for other Iranian

clients of SCB’s Dubai Branch.

557. SCB’s deliberately fraudulent and misleading SWIFT messages impeded critical

counterterrorism controls by depriving the U.S. government of important information about the

transactions, just as SCB’s Iranian clients wanted. SCB’s scheme made it impossible for SCB’s

AML/CFT compliance staff to effectively flag and investigate suspicious activity in these

transactions, and then to report terrorist financing concerns to the government. SCB’s scheme

also impeded the effectiveness of the U.S. government’s own monitoring of the SWIFT system

to track terrorist financing through the TFTP program.

558. A “lookback review” performed by a consultant at the behest of SCB’s New York

regulators confirmed the impact of SCB’s scheme. The consultant reviewed the dollar clearing

activity of SCB’s NY Branch between 2002 and 2004 to determine if there was any suspicious

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activity which required reporting under state and federal banking regulations. Using a risk-based

AML/CFT assessment methodology, the consultant screened SCB’s New York wire payment

data against criteria indicative of high risk for terrorism finance and other illicit activity. Wire

transfers involving “high-risk jurisdictions” like Iran received the highest rating and generated an

automatic alert requiring further review. But because SCB’s New York data had been stripped of

Iranian references by SCB before it was received in New York, no alerts were generated for

customer transactions involving Iran and no bank-to-bank transactions involving Iran were

listed as potentially suspicious—despite SCB processing approximately $88 billion in Iranian

U.S. dollar transactions during the lookback period.59 Because the Iranian payments were non-

transparent, many were risk-ranked as zero, since they appeared to be coming from SCB London

or SCB Dubai.60 SCB submitted its final report to regulators in October 2005, without disclosing

that the data upon which it was based was false.61

559. As NYDFS concluded: “SCB acted for at least ten years without any regard for

the legal, reputational, and national security consequences of its flagrantly deceptive actions.

Led by its most senior management, SCB designed and implemented an elaborate scheme by

which to use its New York branch as a front for prohibited dealings with Iran – dealings that

indisputably helped sustain a global threat to peace and stability.”62 In particular, “[b]ecause

SCB regularly concealed the names of [its] high risk clients, it could not accurately track and

evaluate their risk levels. Nor could SCB effectively screen for suspicious activity and financial

transactions—monitoring that is essential to any institution’s BSA/AML program. Perhaps worst

59
2012 DPA Factual Statement ¶¶ 82, 87-88.
60
2012 DPA Factual Statement ¶ 89.
61
2012 DPA Factual Statement ¶¶ 92-93.
62
2012 NYDFS Consent Order at 22 (“Conclusion”).

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of all, SCB’s actions prevented regulators from doing their job in detecting potential threats to

the U.S. financial system and other national security breaches.”63 SCB’s actions “left the U.S.

financial system vulnerable to terrorists, weapons dealers, drug kingpins and corrupt regimes,

and deprived law enforcement investigators of crucial information used to track all manner of

criminal activity.”64

C. SCB Lied to Regulators about Winding-Down Its Iran Business and

Continued to Process Transactions Through 2015 for Iran’s Terrorist
Sponsors and Their Fronts While Helping Them Evade Counterterrorism
Controls

560. In the settlement agreements that resolved investigations into SCB’s rampant

wire-stripping and evasions of Iran sanctions, SCB represented that it had exited its Iran business

as of 2007. In its 2012 DPA with DOJ, for example, SCB professed that, given the potential for

“very serious or even catastrophic reputational damage” “and/or serious criminal liability,” SCB

“made the decision to exit the Iranian business” in October 2006.65 SCB claimed to have

“ended” its “U.S.-dollar clearing activity for all the Iranian banks” by March 2007.66 And SCB

claimed that “[f]rom August 2007, SCB suspended all new Iranian business in any currency.”67

561. Not only that, but SCB also claimed that as part of its efforts to remediate its

decade-long sanctions evasion, SCB had also “taken voluntary steps to enhance and optimize its

sanctions compliance programs”—including by “[t]erminating relationships with sanctioned

banks and entities and closing its Iranian representative office and branch,” “[s]ubstantially

increasing personnel and resources devoted to sanctions compliance,” and “[e]nhancing its

63
2012 NYDFS Consent Order ¶ 51.
64
2012 NYDFS Consent Order at 1.
65
Deferred Prosecution Agreement ¶¶ 101-102, U.S. v. Standard Chartered Bank, No. 12-cr-262
(D.D.C. Dec. 10, 2012), ECF 2 (emphasis added) (hereinafter, “2012 DPA”).
66
2012 DPA ¶ 103.
67
2012 DPA ¶ 104 (emphasis added).

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global sanctions compliance policies and procedures, including a general prohibition on new

transactions on behalf of U.S. designated terrorists … or WMD proliferators in all currencies.”68

562. Criminal and regulatory investigations—by DOJ, OFAC, NYDFS, and the U.K.

FCA—revealed that SCB’s stated commitment to winding-down its Iran business in 2007 was a

lie. As a whistleblower who had worked in SCB’s Dubai branch explained in an interview with

federal and state law enforcement authorities, SCB’s internal document system contained

information about a secret project staffed out of Dubai and overseen by Meddings in London that

had been given the codename “Project Green.” Multiple SCB Dubai employees explained to the

whistleblower in 2009 and 2010 that the purpose of “Project Green” was to “[route] around” or

“navigate clients around” sanctions, and that it involved visits by SCB Dubai employees to Iran

and to Iranian financial institutions based in Dubai. The whistleblower was told that SCB Dubai

employees were “very actively opening Iranian accounts in 2009” for which Mohammed

Sarrafzadeh, the CEO of SCB’s Iran representative office, would have been listed as the account

representative. The whistleblower also shared SCB files, including spreadsheets containing a

December 2008 list of “hot” “targets” for SCB’s sales team to solicit. The list included Bank

Saderat, Bank Mellat, Bank Melli, Bank Sepah, and Bank Tejarat. Similar lists dated December

2007 and February 2008 also included Bank Saderat and Bank Melli as “prospective clients.”69

68
2012 DPA ¶ 107 (emphasis added).
69
FBI Report of Interview with Julian Knight, U.S. ex rel. Brutus Trading, LLC v. Standard
Chartered Bank, et al., No. 18-cv-11117 (S.D.N.Y. March 8, 2021), ECF 87-1. Allegations from
other whistleblowers further undercut SCB’s representations that it had exited its Iran business in
2007. See Marcellus Decl. ¶ 21; see id. ¶ 17 (describing post-2007 invitations from SCB Dubai
employees to “meet[] some of SCB’s Iranian customers . . . in Iran”); id. ¶¶ 25-26 (identifying an
“enormous volume of transactions by SCB with Iranian persons after 2007” on SCB transaction
spreadsheets). SCB’s own presentation to regulators also acknowledged that, even after SCB
stopped processing U.S. dollar transactions for certain Iranian clients through its NY Branch, it
did not stop serving those clients and profiting from the relationships it had developed over the

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563. From 2008 through at least 2014 or early 2015, SCB continued to actively move

money for individuals and entities connected to Iran—including agents and fronts for the

IRGC—while continuing to engage in wire-stripping and other tactics to help its Iranian clients

evade counterterrorism controls. SCB’s culpable assistance to the IRGC lasted until at least late

2014 or early 2015, from which the Qods Force, Hezbollah, and their shared proxies Hamas and

JAM continued to finance their attacks through at least 2019.

564. In direct contradiction of its claim to have exited the Iran business, SCB Dubai

maintained “at least nine Eurodollar bank accounts for CBI” and processed “at least two trade

finance transactions for [C]BI worth a total SCB profit value of $50,679.00 U.S. dollars between

December 1, 2009 and December 31, 2009.”70 SCB thus continued to serve CBI/Bank Markazi,

even as longstanding terrorist financing concerns about the bank reached a fevered pitch—with

the Secretary of the Treasury warning that “the Central Bank of Iran was sending money through

Bank Saderat to Hizballah” (CQ-RollCall Political Transcriptions, June 14, 2007), more than 25

members of Congress calling for the bank’s designation as a “terrorist entity” (U.S.

Congressional News, March 5, 2008), and others in Congress calling it the “central bank of

terrorism” (Reuters News, April 17, 2008) that was “heavily involved in the funding of

terrorism” (Congressional News, October 22, 2008).

years. SCB did not cease business conducted in other currencies for Iranian clients, and in fact
invited clients to open accounts in alternative currencies, conducting foreign exchange
transactions to convert their U.S. dollar balances to those alternative currencies.
70
Decl. of David J. Scantling ¶¶ 115-16 (“Scantling Decl.”), U.S. ex rel. Brutus Trading, LLC v.
Standard Chartered Bank, et al., No. 18-cv-11117 (S.D.N.Y. May 31, 2024), ECF 104. Plaintiffs
expect discovery to shed more light on these and other SCB transactions identified in the Brutus
Trading litigation about which complete information is not currently available to Plaintiffs. The
Times Media Limited filed a motion in that case for the court to unseal the SCB spreadsheets
filed as exhibits by the Relators; SCB opposed that motion, which is currently pending before the
court as of the date of this filing (Dkt. No. 146).

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565. SCB also continued to serve Bank Saderat—a notorious IRGC Quds Force front

and direct conduit of funding for anti-American terrorism throughout the Middle East—which

enjoyed full “always execute” access to SCB’s online currency trading platform at least through

2008 and beginning again in April 2013.71

566. Indeed, as one whistleblower put it, SCB’s “representations denying Iranian

business to the US authorities in 2012 were likely completely false.”72

1. SCB’s Dubai Branch

567. Despite SCB’s purported commitment to winding down business with Iran-linked

customers, SCB continued to knowingly help numerous IRGC fronts evade counterterrorism

controls—particularly through its branch in Dubai, which became the hub for its continuing Iran

business.

568. SCB knew that Dubai was a hotbed of IRGC sanctions evasion and terrorist

financing. It was well known in the financial industry that Dubai front companies were a primary

means for Iran to access the international financial system, and the fronts were often readily

apparent to locals on the ground. In the words of the Chairman of the American Business

Council of the Gulf Countries, as reported by Forbes Global on April 19, 2004, “[w]hen you

blow off the dust, the Dubai region sometimes means Iran and Libya.”

569. The New York Post on February 21, 2006 noted a “white-hot spotlight on the

UAE, a country long considered the arms-smuggling and money-laundering capital of the

Middle East,” with “[t]ens of billions of dollars . . . laundered every year through [its] banks”

and a “shady” record in the war on terrorism, according to U.S. officials. As the Wall Street

71
Decl. of Julian Knight ¶ 71, U.S. ex rel. Brutus Trading, LLC v. Standard Chartered Bank, No.
18-cv-11117 (S.D.N.Y. Jan. 10, 2020), ECF 48-2.
72
Marcellus Decl. ¶ 21.

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Journal reported on February 23, 2006, Dubai was “the most free-wheeling of the Emirates,” and

“Iran uses Dubai to evade U.S. economic sanctions.”

570. On March 7, 2007, Treasury Under Secretary for Terrorism and Financial

Intelligence Stuart Levey visited Dubai to deliver a sharp warning to the business community

about how “Iran’s nuclear program and support for terrorism poses a great threat to our safety

and security.” Noting that the world is well aware of Iran’s “sponsorship of terrorist

organizations that maim and murder innocent civilians,” Levey warned that “Iran disguises its

activities through an array of deceptive techniques specifically designed to evade the controls of

responsible financial institutions and avoid suspicion,” including requesting that “financial

institutions take their names off of transactions when processing them in the international

financial system.” Levey’s message then focused directly on the IRGC:

In addition, I want to tell you about another area of concern about how Iran does
business. Iran’s Revolutionary Guard Corps, or IRGC, is used by the regime to provide a
`train and equip program’ for terrorist organizations like Hizballah, as well as to pursue
other military objectives of the regime. The IRGC’s control and influence in the Iranian
economy is growing exponentially under the regime of Ahmadinejad. More and more
IRGC-associated companies are being awarded important government contracts. An
IRGC company, for example, took over management of the airport and runways in
Tehran, while another company won the contract to build the Tehran metro. When
corporations do business with IRGC companies, they are doing business with
organizations that are providing direct support to terrorism.

Levey explained that many banks had “conclude[ed] that they did not wish to be the banker for a

regime that deliberately conceals the nature of its business”—where it is “too often the business

of funding terrorism.” He ended with another warning:

As you make your business decisions, I urge you to consider whether it is wise for your
company to focus its efforts on doing business with Iran. I recognize that it may be
tempting to step into the void that is being created by other companies pulling back their
business in Iran, but they are pulling back for a reason. The world’s top financial
institutions and corporations are re-evaluating their business with Iran because they are
worried about the risk and their reputations. You should worry too and be especially
cautious when it comes to doing business with Iran.

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571. SCB’s leadership recognized those risks, and it knew that they were rife in its

Dubai branch. A note to file describing a 2005 meeting attended by SCB’s General Counsel,

Head of Legal and Compliance, and outside UK counsel, recounted that SCB considered whether

the new CEO for the Americas—who was the former CEO for the United Arab Emirates—was

obligated to report to U.S. regulators any suspicions he may have had about SCB’s Iran business

conducted in Dubai and “whether his physical presence in the USA heightens the prospect of

[him] becoming a more available witness of fact for SCB’s Iran Business.”73

572. Although SCB often told U.S. regulators what they wanted to hear, SCB’s

London leadership internally viewed the sharp warnings about the immense terrorism risks in

Dubai as an “annoyance,” according to a July 20, 2007, article from The Guardian, and just a

few months after Levey’s warning in Dubai, SCB said it “wanted to develop its Dubai office into

a regional hub,” according to a June 1, 2007, article from Dow Jones International News.

573. SCB Dubai’s rank-and-file understood that the bank’s revenue took precedence

over counterterrorism concerns. Accordingly, as explained below, several SCB Dubai employees

worked closely with Iran’s Terrorist Sponsors and fronts to help them evade U.S.

counterterrorism controls. SCB Dubai employees coached their customers on how to avoid

suspicion, lied to compliance officials and other banks about the fronts’ Iran connections, and

even helped open new accounts to help fronts for the Qods Force, Hezbollah, and their proxies

escape detection.

574. Beyond that, SCB Dubai permitted sanctioned IRGC-affiliated parties to transact

in U.S. dollars by offering virtually unregulated access to fax-based and internet-based banking

73
2012 NYDFS Consent Order ¶ 40 (emphasis added).

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services. When it became clear that these fax and internet services were being used by high-risk

Iranian customers to evade sanctions, SCB Dubai refused to implement simple technical fixes

that would have cut off Iranian customers’ access.

575. SCB Dubai’s actions caused at least hundreds of millions of U.S. dollars to flow

through the U.S. financial system to Iran’s Terrorist Sponsors and fronts between 2008 and 2015.

2. SCB Dubai Helped an Iranian Petrochemical Company Operating as

a Front for Iran’s Terrorist Sponsors to Covertly Access the U.S.
Financial System

576. Throughout the relevant period, SCB Dubai employees consciously and culpably

helped Iran’s Terrorist Sponsors and fronts evade U.S. sanctions and counterterrorism controls.74

577. As one example, SCB “process[ed] a significant volume of [U.S. dollar]

payments” for “a front company for a prohibited Iranian entity”—an “Iranian petrochemical

company in the business of shipping liquefied petroleum gas.”75 That “Iranian petrochemical

company” was a front for Iran’s Terrorist Sponsors, for which SCB served as a key banker from

at least 2005 through at least June 2012 (hereinafter, the “Iranian Petrochemical Company” a/k/a

“Caspian Petrochemical FZE”).

578. NYDFS discovered that, between November 2008 and June 2012, SCB

“processed more than $150 million in incoming and outgoing [U.S. dollar] transactions” for the

Iranian Petrochemical Company. The “majority” of those transactions “were transmitted through

the [NY] Branch.”76 OFAC’s investigation confirmed those findings.77

74
See 2019 Amended DPA ¶¶ 18-32.
75
2019 NYDFS Consent Order ¶ 30.
76
2019 NYDFS Consent Order ¶ 31.
77
2019 OFAC Settlement ¶7 (“SCB Dubai maintained an account for the petrochemical
company, a company owned by an Iranian national ordinarily resident in Iran, which engaged in
the sale of petroleum products to, from, or through Iran. Following OFAC’s revocation of the U-

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579. SCB Dubai willfully helped the Iranian Petrochemical Company conduct

“prohibited business” through both active assistance and “glaring compliance deficiencies.”78

580. SCB Dubai opened a U.S. dollar denominated account for the Iranian

Petrochemical Company in May 2005.79 By at least October 2007, SCB knew that the Iranian

Petrochemical Company was a front company owned by the Government of Iran. Although

documents provided to SCB Dubai purported to show that it was located and operated in the

Dubai Airport Free Zone, SCB Dubai’s customer due diligence documents for the Iranian

Petrochemical Company at that time, upon which SCB Dubai relied heavily, were marked

“YES” in answer to the following questions:

 Is the client a sanctioned country government (anywhere in the world)?

 Is the client a sanctioned country government-owned bank or other enterprise

(anywhere in the world), including subsidiaries, branches and offices thereof?

SCB’s customer due diligence documents also identified a single individual as the company’s

“sole owner”—i.e., the sole nominal owner of an enterprise beneficially owned by the

Government of Iran.80

581. As of October 2007, SCB Dubai’s customer due diligence documents for the

Iranian Petrochemical Company’s nominal owner identified this individual as “resident in a

[high risk jurisdiction]—Iran.”81 SCB’s records listed both Iranian and Dubai contact

Tum authorization on November 10, 2008, SCB, beginning no later than June 27, 2009, and,
continuing through June 24, 2012, processed 190 transactions totaling $151,269,725 to or
through the United States that were for or on behalf of the petrochemical company—the benefit
of which services were received in Iran—in apparent violation of § 560.204 of the [Iranian
Transactions and Sanctions Regulations].”).
78
2019 NYDFS Consent Order ¶¶ 32-33, 37.
79
2019 OFAC Settlement ¶ 10.
80
2019 OFAC Settlement ¶ 13 (emphasis added).
81
2019 OFAC Settlement ¶ 13.

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information for the individual, including Iranian fax and phone numbers. SCB’s records also

contained an Iranian passport purportedly for the individual.

582. Shortly after OFAC revoked its U-Turn exception in November 2008 and warned

in urgent detail about the IRGC’s funding of terrorism and its frequent use of front companies,

SCB Dubai orchestrated a scheme to help the Iranian Petrochemical Company evade

counterterrorism controls, while continuing to clear its U.S. dollar transactions through SCB’s

New York Branch. To this end, SCB provided a variety of illicit and atypical banking services to

the Iranian Petrochemical Company between 2009 and 2011.

583. First, in 2009, SCB Dubai altered the company’s customer due diligence file to

hide its Iranian beneficial ownership and connections to Iran. Where SCB’s records had

previously answered “YES” to questions about whether the Iranian Petrochemical Company was

owned by the Government of Iran, as well as other questions about its presence in Iran, SCB

Dubai changed the “YES” to “NO.”82

584. Second, SCB Dubai continued the wire-stripping tactic SCB had pioneered since

2001 to help its Iranian customers evade due diligence and suspicious activity reporting. The

payment messages for the Iranian Petrochemical Company omitted all references to Iran, the

company’s Iranian ownership, or any affiliated Iranian entities. As a result of SCB Dubai’s

transmission of stripped or misleading payment messages, “[m]ost of the transactions originated

by SCB Dubai on behalf of the petrochemical company were processed successfully and reached

their intended beneficiary.”83

82
2019 OFAC Settlement ¶ 16.
83
2019 OFAC Settlement ¶ 16.

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585. Third, in April 2010, when a U.S. bank rejected a large U.S. dollar payment

originated by SCB for the Iranian Petrochemical Company, SCB lied to OFAC to hide the source

of the funds. The U.S. bank told SCB’s New York compliance staff that it found the front

company to be an Iranian entity and warned that it had “contacted OFAC, and was advised by

OFAC to reject [USD] payments” for it.84 These warnings were transmitted to SCB’s Senior

U.K. Sanctions Officer immediately, who did nothing.85 SCB’s compliance staff in Dubai and

New York then found numerous obvious reasons to believe the Iranian Petrochemical Company

was an Iranian front, including: (i) a simple Google search showed that a company with the same

name and email address on file with SCB was “Iranian”; (ii) the identified owner was an Iranian

national; (iii) his UAE visa had expired two years earlier; and (iv) a document in the company’s

account file from 2008 revealed its representative office was located in Tehran.86 These obvious

Iran links caused SCB Dubai’s operational risk manager to warn SCB Dubai’s senior AML

officer that he “strongly believe[d] that the subject customer is an Iranian.”87 The senior AML

officer, in turn, escalated the findings to the senior U.K. sanctions officer, who “rejected this

warning” and “allow[ed] the payment to be made by relying on an undocumented” denial of any

link between the company and Iran, purportedly obtained from the customer by SCB Dubai’s

Relationship Manager.88 The U.K. officer also ignored a fax communication located in the

Iranian Petrochemical Company’s account file that contained correspondence from Iran. The fax,

sent to the Bank in September 2011, bore Iran’s country prefix (+98).89

84
2019 NYDFS Settlement ¶ 32 (brackets in original); see 2019 OFAC Settlement ¶ 18.
85
2019 NYDFS Settlement ¶ 32.
86
2019 NYDFS Settlement ¶ 32; 2019 OFAC Settlement ¶¶ 20, 23.
87
2019 NYDFS Settlement ¶ 32.
88
2019 NYDFS Settlement ¶ 32.
89
2019 NYDFS Settlement ¶ 32.

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586. Despite the mountain of evidence to the contrary, SCB proceeded to explain to

OFAC that the account was used for petroleum purchases from Turkmenistan and sales to

Armenia, Pakistan, and Iraq, and to falsely and confidently represent to OFAC that the Iranian

Petrochemical Company had “no direct or indirect involvement with Iran.”90 SCB’s Relationship

Manager knew the representation about no involvement with Iran was false; he would later admit

in his own criminal prosecution that he knew the Iranian Petrochemical Company “either

operated from Iran, or transacted USD business with Iranian entities.”91 And SCB’s senior

management in the U.K. was all too willing to rely on the Relationship Manager’s dubious and

unverified representations in the face of much contrary evidence. SCB’s senior U.K. sanctions

officer thus “inexplicably” gave the Iranian Petrochemical Company the “benefit of the doubt”

and “allowed it to continue conducting business through the Bank – including transactions

processed through the New York Branch.”92

587. Thus, despite the numerous payments rejected by other U.S. financial institutions

involving the Iranian Petrochemical Company, as well as the concerns raised internally within

SCB regarding its Iranian ownership and connections—“both SCB Dubai and SCB NY

continued to process [U.S. dollar] payments on the company’s behalf.”93 In total, following

SCB’s lie to OFAC, “SCB Dubai and SCB NY processed 133 funds transfers totaling

$140,310,539 that were for or on behalf of the petrochemical company to or through the United

States in apparent violation of the [Iranian Transactions and Sanctions Regulations].”94

90
2019 OFAC Settlement ¶ 24.
91
Statement of Offense ¶ 11, U.S. v. Mobeen Ahmed, No. 17-cr-190 (D.D.C. Oct. 26, 2017),
ECF 12 (hereinafter, “Ahmed Statement of Offense”).
92
2019 NYDFS Settlement ¶ 32.
93
2019 OFAC Settlement ¶ 25.
94
2019 OFAC Settlement ¶ 25.

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588. Fourth, after the Iranian Petrochemical Company had proven too easy to identify

as Iranian through a Google search, another relationship manager advised it to evade detection

by changing its name: “if you change the company name then we can reopen another account

with Standard Chartered.”95

589. On information and belief, the IRGC took SCB’s advice and reincorporated the

Iranian Petrochemical Company on November 15, 2011, as a new company named Caspian

Petrochemical FZE, which it registered in Dubai, UAE, and London, U.K. that same day by

using cut-outs who incorporated Caspian Petrochemical.96 The company’s corporate filings,

publicly identified the “Objects of the company” as “Trade of gas, oil and petrochemicals” and

listed its officers as Phati Sebua and Seyedasadoollah Emamjomeh (a/k/a Seyed Asadollah

Ememjome), who was identified as its Chairman.

590. The surname “Emamjome” is a religious title in Iran referring to an imam

appointed by the Supreme Leader to lead Tehran’s Friday prayers, which regularly included

slogans condemning the United States, Israel, and other enemies of the Ayatollah’s regime.

“Seyed” and “Asadollah” are also common religious honorific titles in Iran translating to

“Descendant of Prophet Mohammed – Lion of God.”

591. SCB’s advice to its IRGC customer to change its name, which it did in November

2011, and SCB’s continuing maintenance of accounts for the Iranian Petrochemical Company,

95
2019 NYDFS Consent Order ¶ 37.
96
Plaintiffs expect discovery to shed further light on the name used by the Iranian Petrochemical
Company and its ownership structure, the precise nature of the entity’s relationship with the
successor entity incorporated as Caspian Petrochemical FZE, and any subsequent transactions
SCB may have processed for that entity after November 15, 2011. Although it has not disclosed
the name of the Iranian petrochemical company that was the subject of its enforcement actions
against SCB, the government has acknowledged that the name of the company or a corporate
affiliate is “somewhat similar” to “Caspian Chemical.”

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Caspian Petrochemical FZE, and/or their affiliates through at least June 2012 was particularly

notable in light of the dramatic developments between November 2011 and March 2012, in

which the U.S. government intensified its sanctions on Iran and the IRGC. As explained above,

starting around November 8, 2011, when the International Atomic Energy Agency published a

bombshell report exposing the Iranian regime’s comprehensive nuclear weapons program, the

international community, including the United States, Israel, and European allies, signaled that

they would impose harsh new sanctions on Iran. Iran and Hezbollah contemporaneously

threatened retaliation. Against the backdrop of high-profile statements emphasizing the

importance of sanctions, countered by threats of war, SCB assisted the Iranian Petrochemical

Company in rebranding itself to Caspian Petrochemical FZE so that it could continue evading

sanctions and supplying funds to the IRGC. SCB thus intentionally aided the IRGC in evading

counter-terrorism sanctions at the very moment the global community was emphasizing the

grave terrorism and national security threats posed by sanctions evasion.

592. SCB’s transactions for the Iranian Petrochemical Company directly and indirectly

flowed at least tens of millions of dollars each year to the Qods Force, Hezbollah, Hamas, PIJ,

and JAM.

593. SCB’s decision to continue to process payments for the Iranian Petrochemical

Company was a “significant compliance failure” by SCB that directly assisted the IRGC and its

proxies; as NYDFS found, however, “this series of events was not isolated.”97

97
2019 NYDFS Settlement ¶ 33.

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3. SCB Dubai Helped IRGC Agent Mahmoud Reza Elyassi Access the
U.S. Financial System to Fund Iran’s Terrorist Sponsors

594. Another example of SCB’s knowing provision of banking services to Iran’s

Terrorist Sponsors involved an Iranian national—and, as explained infra, likely IRGC agent—

named Mahmoud Reza Elyassi. He was indicted by the DOJ in 2019 for evading sanctions on

Iran, aided by SCB Dubai employees.98 Since Elyassi’s indictment, he has escaped prosecution.

595. From late 2006 through at least September 2011, Elyassi controlled multiple

companies that held accounts with SCB Dubai. The Amended DPA and Elyassi’s indictment

highlight two such companies, identified by the United States as Company C-1 and Company

C-2.99 The Complaint adopts the Government’s terminology.

596. Company C-1 and Company C-2 were “general trading companies” that were

used as “fronts” for a “money exchange business located in Mashhad, Iran,” in order to “provide

services to Iranian individuals and companies seeking to conduct U.S. dollar transactions through

the United States in violation of U.S. economic sanctions.”100

597. Between November 2007 and August 2011, SCB “willfully” and illegally

processed approximately 9,500 dollar-denominated transactions through the United States,

including through the NY Branch, for Company C-1 and Company C-2.101 Those transactions

totaled approximately $240 million.102

98
See generally Indictment, U.S. v. Elyassi, No. 19-cr-117 (D.D.C. Apr. 5, 2019), available at:
https://www.justice.gov/d9/press-releases/attachments/
2019/04/11/elyassi_indictment_filed_0.pdf (“Elyassi Indictment”).
99
SOF ¶ 10; Elyassi Indictment ¶ 1. These companies are referred to as Company A and
Company B, respectively, in the 2019 OFAC Settlement. See 2019 OFAC Settlement ¶ 31.
100
Elyassi Indictment ¶ 12.
101
SOF ¶ 31.
102
SOF ¶ 31.

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598. SCB employees helped Elyassi consummate these illegal transactions. At all

relevant times, at least two SCB Dubai employees—a Relationship Manager (Person A) and a

Treasury Sales Manager (Person B)—worked closely with Elyassi to provide him access to the

U.S. financial system and U.S. dollars.103 At all relevant times, these employees were acting

within the scope of their employment for SCB, i.e., performing the role they were hired to

perform, for the type of customer SCB Dubai was happy to have.104

599. SCB knew that Elyassi and his companies were linked to Iran and operated in

industries dominated by Iran’s Terrorist Sponsors. See infra. SCB’s records were replete with

evidence that confirmed the connection: (a) SCB’s banking system listed Elyassi as an Iranian

person and contained both UAE and Iranian contact information for him—including telephone

and fax numbers that began with Iran’s country code prefix (+98); (b) SCB’s records contained a

copy of Elyassi’s Iranian passport; (c) SCB’s records contained a Know Your Customer

(“KYC”) form for Company C-1 from 2007 stating that the company had a facility in Iran and

exported materials from Iran to various countries; (d) contact information for Company C-1 in

SCB’s records included at least two Iranian phone numbers (as evidenced by +98 country code

prefix); and (e) SCB Dubai personnel recorded phone calls in 2008 between Elyassi and his

Treasury Sales Manager at SCB (Person B), during which Elyassi admitted that he was based in

Iran and invited the Treasury Sales Manager to visit him there.105

600. Knowledge of Elyassi’s Iran connections was not cabined to these two employees.

Several SCB employees knew that Elyassi’s businesses were operated from Iran and conducted

103
Amended DPA ¶¶ 8-9 (referring to Relationship Manager as “Person A” and Treasury Sales
Manager as “Person B”); see also Elyassi Indictment ¶¶ 3-4.
104
SOF ¶ 30.
105
SOF ¶ 24; see 2019 OFAC Settlement ¶¶ 34-35.

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U.S. dollar transactions through the United States for the benefit of Iranian entities. Moreover,

SCB employees knew that several outgoing payments made from Company C-1 in 2008, 2010,

and 2011 (which SCB did not block) were rejected by beneficiary and correspondent banks due

to Company C-1’s Iranian connections.106

601. SCB did not respond to this information by severing its relationship with Elyassi

and his companies. Instead, SCB employees also actively facilitated Elyassi’s malfeasance by

showing him how to navigate the bank’s processes to avoid further detection. Thus, the SCB

Dubai employees executed illicit U.S. dollar transactions for Elyassi’s companies by providing

“false and misleading information” to “disguise [Elyassi’s] Iranian connections.”107

602. In August 2008, for example, in response to an internal compliance inquiry, the

Relationship Manager (Person A) falsely stated that Company C-1 operated exclusively in the

UAE—even though that was materially false, and even though SCB’s KYC form confirmed that

Company C-1 operated out of Iran.108 And when “other financial institutions rejected payment

requests from SCB on behalf of Company C-1 and Company C-2,” the Relationship Manager

(Person A) and the Treasury Sales Manager (Person B) helped “conceal the transactions’ Iranian

connections through lies and omissions.”109

603. In December 2010, after “numerous payment requests” involving Company C-1

were “stopped” due to “Iranian sanctions concerns,” SCB decided to exit its banking relationship

with Company C-1.110

106
SOF ¶ 25; 2019 OFAC Settlement ¶ 33 (“Several U.S. banks rejected or returned payments
initiated from Company A’s account with SCB Dubai as early as July 2008.”).
107
SOF ¶ 26.
108
SOF ¶ 26.
109
SOF ¶ 26.
110
SOF ¶ 27.

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604. But before Company C-1’s accounts were closed, the Relationship Manager

(Person A) and the Treasury Sales Manager (Person B) “helped [Elyassi] open a new business

account under a new name, Company C-2, so that [Elyassi] could continue conducting U.S.

dollar transactions through the United States without suffering similar rejections.”111

605. SCB Dubai employees thus “knew” that Elyassi controlled Company C-2 in all

meaningful respects, even though “a non-Iranian co-conspirator of [Elyassi] was the nominal

owner.”112 Indeed, SCB’s account records for Company C-2 identified Elyassi “as an authorized

signatory/dealer on Company C-2’s account,” and “[d]ocuments contained in SCB’s records also

show[ed] that much of the contact information (telephone number, mobile phone number, fax

number, and mailing address) for Company C-2 was the same as Company C-1.”113

606. SCB thus ensured that Elyassi had unfettered access to SCB-facilitated U.S. dollar

transactions: Company C-2’s account with SCB Dubai was opened “on or about February 14,

2011, and Company C-1’s account with SCB Dubai was closed on or about February 13,

2011.”114

607. After opening Company C-2’s account, SCB Dubai employees coached Elyassi

“on how to structure financial transactions that would not raise suspicion of an Iranian

connection or other illegality.”115

111
SOF ¶ 27.
112
SOF ¶ 27.
113
SOF ¶ 27.
114
SOF ¶ 27.
115
SOF ¶ 27; see 2019 OFAC Settlement ¶ 41 (“In or around this time, the [Relationship
Manager] held several phone calls with [Elyassi] regarding these transactions. The [Relationship
Manager] appears to have referenced prior discussions in which he had coached [Elyassi] how to
process certain types of transactions.”).

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608. On or about March 9, 2011, for example, in a telephone call recorded by SCB

Dubai, the Relationship Manager (Person A) told Elyassi “not to send payments to Iranian

individuals directly from Company C-2’s account, but rather, to have a co-conspirator transfer

the funds from Company C-2’s account to his personal account at SCB Dubai and then send the

payments to the Iranian individuals in order to avoid having Company C-2’s account closed.”116

The Amended DPA reflects the following transcribed conversation between Elyassi (Person C)

and the Relationship Manager (Person A):

Person A: “I am telling you once these go there will be no next time then you’ll
come back and they will say we will need to close the account [be]cause now even
one payment is going [to an individual who] is Iranian.”

Person C: “Mm”

Person A: “[The payment] will be stuck. And once it is stuck . . . then you will
come to me when no no don’t close the account then nothing left and I am telling
you.”

Person C: “Mm”

Person A: “[The second individual payee] is Iranian, I know [the third individual
payee] is Iranian, [and the first individual payee] is Iranian.”

Person C: “Mmm how we can do this?”

Person A: “I am telling you, ask ask [co-conspirator] to transfer funds from

[Company C-2’s account at SCB-Dubai] to his personal account [at SCB-Dubai].
From [his] personal account he can make these five payments.”117

609. It was not until September 2011 that SCB Dubai closed Company C-2’s account

“due to sanctions concerns.”118 Before closing the account, however, SCB Dubai “processed 210

116
SOF ¶ 28.
117
SOF ¶ 28.
118
SOF ¶ 28.

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[U.S. dollar]-denominated funds transfers to or through the United States based on payment

instructions it received from Iran.”119

610. At all times, the Relationship Manager (Person A) and the Treasury Sales

Manager (Person B) “willfully engaged in this misconduct knowing that it was in violation of

U.S. law”—all to “generate revenue for SCB.”120 At all times, these SCB employees acted within

the scope of their employment as they served Elyassi and his companies.

4. SCB Dubai Helped Numerous Other Agents and Fronts for Iran’s
Terrorist Sponsors Access the U.S. Financial System to Finance Their
Operations in Several Other Ways

611. SCB Dubai’s misconduct extended beyond the specific examples discussed

above. Documents that resolved investigations into SCB either state directly or permit the

reasonable inference that SCB Dubai employees helped Iran Terrorist Sponsors and fronts to

evade U.S. sanctions in other ways.

i. SCB Dubai Helped Numerous Other Iranian Fronts Evade

Counterterrorism Controls

612. It is clear SCB’s bad behavior extended beyond assisting the petrochemical front

company and Elyassi to evade sanctions, and that its tactics extended beyond wire-stripping,

name-changes, and false customer due diligence documents. As NYDFS found, for example,

SCB Dubai employees warned “another Iranian front company’s owner” to close its account

before SCB reported it as suspicious: “before [the Bank] report[s] to [the local bank

regulator] ... please can you send me a closure notice before [the Bank] raise question on you?”121

Indeed, NYDFS concluded that “during the period November 2008 through July 2014, the Bank

119
2019 OFAC Settlement ¶ 42.
120
SOF ¶ 30.
121
2019 NYDFS Consent Order ¶ 36 (emphasis modified).

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processed nearly 15,000 illegal payments for the benefit of sanctioned Iranian parties, totaling

more than $600 million,” a “majority” of which “flowed through the New York Branch.”122

613. Throughout the relevant period, SCB had—as the U.K. FCA put it—a “culture”

problem, where SCB Dubai employees were “colluding to evade controls and knowledge by

other [SCB] employees of accounts operated for financial sanctions evasion.”123 SCB Dubai’s

“compliance infrastructure” was “woefully inadequate” and “no match for even unsophisticated

evasion efforts.”124

614. SCB admitted as part of the 2019 Amended DPA that multiple SCB Dubai

employees “willfully conspired with several people and entities to help Iran-connected

customers of SCB Dubai conduct U.S. dollar transactions and cause U.S. financial services to be

exported to Iran through SCB.”125 That included assisting “Iranian nationals located in Dubai”

who were opening “commercial bank accounts” for “commercial entities” that “were fronts for

Iranian businesses.”126

615. OFAC, similarly, explained that, in “several instances two employees within

SCB Dubai—including a Relationship Manager associated with several general trading

company accounts—actively worked with the account holders to obfuscate the sanctions nexus

associated with the parties and/or their transactions . . . .”127 Those SCB Dubai employees

“conspired with other Iran-connected individuals and business organizations during their

122
2019 NYDFS Consent Order ¶ 38.
123
2019 U.K. FCA Decision Notice § 5.16.
124
2019 NYDFS Consent Order ¶ 43.
125
SOF ¶ 22.
126
SOF ¶ 22 (emphasis added).
127
2019 OFAC Settlement ¶ 31.

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employment with SCB Dubai during much of the same period and using many of the same

tactics as they used with [Elyassi].”128

616. The U.K. FCA echoed that conclusion: “Two employees in SCB’s UAE branches

had, in fact, colluded with customers in order to evade financial sanctions against Iran,”129 and

other “SCB employees in the UAE were aware that accounts were opened for financial sanctions

evasion purposes.”130

617. SCB Dubai’s flagrant Iran-related misconduct permeated SCB’s provision of

financial services in Dubai from at least the early 2000s through at least late 2014 or early 2015.

SCB Dubai helped one or more of Iran’s Terrorist Sponsors launder at least several million

dollars on behalf of IRGC and SLO money through at least late 2014 or early 2015, including in

connection with oil trades.

618. Thus, throughout the relevant period, there was a pattern of malfeasance at SCB

Dubai. And SCB Dubai employees knew at the time of their misconduct that they were violating

U.S. and U.N. sanctions, and other laws, that were specifically designed to thwart violent IRGC-

sponsored terrorist attacks—all while acting within the scope of their employment for SCB.131

128
SOF ¶ 29 (emphasis added).
129
2019 U.K. FCA Decision Notice § 4.84.
130
2019 U.K. FCA Decision Notice § 4.84.
131
SOF ¶ 30.

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ii. SCB Enabled Agents and Fronts of Iran’s Terrorist Sponsors

to Access the U.S. Financial System Through SCB Dubai’s
“Right Fax” System

619. SCB enabled Iran’s Terrorist Sponsors and fronts to transact in U.S. dollars by

allowing Iran-based customers to fax payment instructions to SCB Dubai using the latter’s

“Right Fax” system—with virtually no oversight.

620. In late 2009, a Senior SCB Dubai AML Officer discovered that the Right Fax

system could facilitate U.S. dollar payments initiated by Iran-based entities.132 SCB knew this

risk: Faxed payment instructions frequently bore a digital header containing the originating

fax machine’s telephone number, which—in Iran’s case—would include the “+98” Iranian

country code.133 In other words, the face of the fax made clear it was sent from Iran. Upon

making this discovery, SCB Dubai’s Senior AML Officer alerted nearly all sanctions and

compliance managers responsible for the UAE region—including SCB’s senior U.K. sanctions

officer—to advise: “[w]e can receive [payment] instructions via [R]ight [F]ax ... a check will

have to be done here [to discover] whether these fax numbers begin with the Iran [country]

code +98.”134

621. Even though this entire issue could have been addressed simply by checking the

country codes on originating fax numbers, SCB Dubai chose instead to look the other way. Thus,

when a senior SCB Dubai AML officer proposed a policy that would screen for faxed requests

sent from Iran, SCB business staff refused to implement it.135 As a result, use of the Right Fax

system by Iran’s Terrorist Sponsors continued to go unmonitored and unabated.136 Other

132
2019 NYDFS Consent Order ¶ 36.
133
2019 NYDFS Consent Order ¶ 36.
134
2019 NYDFS Consent Order ¶ 24.
135
See 2019 NYDFS Consent Order ¶ 25.
136
See 2019 NYDFS Consent Order ¶¶ 26-28.

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attempts to prevent sanctioned Iranian entities from using Right Fax were similarly shot down,137

despite the “high risk” involved in customers “sending payment instructions from Iran.”138

622. The Right Fax system remained available for effectuating illegal payments from

Iran until as late as May 2014.139 This resulted in the bank processing tens of millions of U.S.

dollar transactions for hundreds of Iranian entities. OFAC’s investigation “identified 11,809

faxed payment instructions from 176 distinct SCB Dubai customers, all of which were corporate

or commercial entities.”140 At its “peak” in August 2010, “the number of faxed payment

instructions received by SCB’s UAE branches in a single month from Iran[] reached 635.”141

623. While SCB has not revealed the full roster of sanctioned Iranian entities that used

its Right Fax system, U.S. regulators found that Elyassi’s front companies (Company C-1 and

Company C-2), standing alone, used Right Fax to “request more than $104 million in U.S. dollar

transactions from SCB Dubai,”142 and his companies “generated the majority of the transaction

volume” resulting from faxed-payment requests from Iran.143

iii. SCB Enabled Agents and Fronts of Iran’s Terrorist Sponsors

to Access the U.S. Financial System Through Its Online
Banking Platforms

624. Through its “iBanking” and “Straight-to-Bank” (or “S2B”) online banking

platforms, SCB permitted customers in Iran to originate U.S. dollar-denominated transactions—

“despite multiple supervisory and management personnel [at SCB] in various business lines

137
See 2019 NYDFS Consent Order ¶¶ 26-28.
138
2019 U.K. FCA Decision Notice § 4.119.
139
See 2019 NYDFS Consent Order ¶ 28. SCB’s inexplicable delay was not due to any technical
complexity; once SCB began the process to block such fax transmissions in May 2014, it took
less than a week to fully implement. See 2019 NYDFS Consent Order ¶ 29.
140
2019 OFAC Settlement ¶ 29.
141
2019 U.K. FCA Decision Notice § 4.77.
142
SOF ¶ 33.
143
2019 OFAC Settlement ¶ 31.

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having actual knowledge of, and having discussions pertaining to, the sanctions risks associated

with these specific products and services.”144

625. As early as May 2010, SCB compliance officials knew that Iranian entities were

using SCB’s online platforms to evade sanctions.145 As a senior SCB AML officer in Dubai

wrote to colleagues: “the added risk that we have to live with that if the transactions were

originated through iBanking [where] there is no way of us knowing whether the issuer of such

transactions was in Iran when he [e]ffected [the payment].”146

626. This was not an isolated warning. Over the next two years, SCB compliance

officers repeatedly alerted senior SCB personnel—including a senior financial crime risk officer

for the UAE, a senior sanctions officer in the United States, and a senior member of SCB’s

executive management team who reported directly to the CEO—that SCB was at risk of

“infiltration by Iranian parties through its online banking platform.”147 Despite those known

risks, SCB allowed Iranian customers to continue to use these online banking systems.

627. SCB’s decision to allow continued online banking from Iran was deliberate.

SCB’s information technology personnel discovered a technical fix that could block IP addresses

from Iran.148 But “business” personnel at SCB scuttled that initiative.149 SCB determined to not

implement such a block—instead, it “proceeded ‘in a business-as-usual’ fashion, undertaking a

sluggish effort to persuade business managers to implement blocking of access to the S2B

144
2019 OFAC Settlement ¶ 44.
145
SOF ¶ 35.
146
2019 NYDFS Consent Order ¶ 16 (emphasis modified)
147
2019 NYDFS Consent Order ¶ 18 (emphasis added).
148
2019 NYDFS Consent Order ¶ 20.
149
2019 NYDFS Consent Order ¶ 21.

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platform from IP addresses located in Iran.”150 Yet again, SCB prioritized profits—and the

customer experience of Iran’s Terrorist Sponsors and fronts—over compliance with U.S. laws.

628. Moreover, SCB personnel made no attempt to identify which Iran-based

customers had accessed its online banking platforms, as any reasonable, responsible financial

institution would have.151 Nor did SCB promptly report the multitude of illegal transactions to

financial regulators.152

629. SCB instead waited two years—until it was under active investigation by NYDFS

and other agencies—to review the illegal transactions. And it was not until July 2014 that SCB

comprehensively disabled access to internet-based U.S. dollar banking channels from Iran.153

630. As a result of SCB’s online banking services—and deliberate delay in blocking

Iran-based customers’ access to those services—from November 2008 to 2012, SCB permitted

“more than 100 customers” to use SCB’s online platforms to conduct thousands of U.S. dollar

transactions from Iran and other sanctioned countries.154

631. Estimates of the transaction volume vary, but all financial regulators agree that

SCB processed at least tens of millions of U.S. dollars for Iran-based customers through its

online banking platforms:

a. NYDFS: “[B]etween June 2009 and mid-2014, the Bank processed more than $275
million in online banking transactions from Iran, Myanmar, Sudan, Syria and Cuba, in
direct violation of OFAC regulations.”155

150
2019 NYDFS Consent Order ¶ 22.
151
2019 NYDFS Consent Order ¶ 21.
152
2019 NYDFS Consent Order ¶¶ 21-22.
153
2019 NYDFS Consent Order ¶ 23.
154
2019 NYDFS Consent Order ¶ 19.
155
2019 NYDFS Consent Order ¶ 19.

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b. OFAC: “Between June 2009 and May 2014, SCB processed . . . 705 [U.S. dollar]-
denominated online payments to or through the United States with a total value of
$46,911,754” in violation of Iranian sanctions.156

c. U.K. FCA: The “aggregate value” of “payments from SCB’s UAE customers that appear
to have originated in Iran through online banking systems” and “processed by SCB” was
“tens of millions of US dollars.”157

632. SCB’s decision benefitted Iran’s Terrorist Sponsors and fronts, in particular.

IRGC agent Elyassi’s front companies directed more than $15 million in U.S. dollar transactions

during that time by using SCB’s online platforms from Iran-assigned IP addresses.158

D. SCB Employed Other Methods to Disguise Its Misconduct and Thwart

Counterterrorism Controls

1. SCB Used a “Sundry Account” to Hide Transactions with Agents and

Fronts for Iran’s Terrorist Sponsors

633. Similar to SCB’s “wire stripping” tactic, SCB also used temporary holding or

error accounts—referred to as “sundry accounts”—to book revenues for illegal transactions

involving Iranian individuals and entities instead of SCB’s account in the Iranian client’s name.

In SCB’s regular course of business, sundry accounts would typically be used to book

transactions for which the true counterparty had not been identified. But for SCB’s illegal Iran-

linked U.S. dollar-denominated transactions, SCB had identified the correct counterparty but

instead intentionally dropped a word or changed a letter from that party’s name to prevent the

transactions from being booked to the correct client account where it could be detected by SCB’s

NY Branch or by U.S. law enforcement personnel. Instead, the transaction would go to the

sundry account where it could no longer be discovered by a computer search performed by

regulators and correspondents involved in the dollar clearing process. One experienced banker

156
2019 OFAC Settlement ¶ 55.
157
2019 U.K. FCA Decision Notice § 4.105.
158
SOF ¶ 33.

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described this practice as “highly irregular” and noted that it appeared to him that this flaw was

“purposefully designed and intended to facilitate evasion by SCB of U.S. sanctions on

transactions with certain Iran-related persons.”159 This practice also made it nearly impossible to

determine whether SCB was transacting with individuals or entities designed by OFAC.

634. On information and belief, SCB continued to employ its strategy of using sundry

accounts to mask its ongoing business transactions with Iranian parties well after 2007 and to the

tune of at least several billion dollars in illegal Iran-linked transactions that were concealed from

law enforcement and regulatory agencies.

635. One SCB whistleblower against whom the bank retaliated for his attempts to

assist the United States’s investigation by providing details about SCB’s use of sundry accounts

to engage in and conceal illegal Iran-linked transactions concluded that “the revenues derived

from SCB’s scheme to evade U.S. sanctions contributed to funds made available to Iran-related

parties and ultimately used to support terrorist activities that killed and wounded soldiers serving

in the U.S.-led coalition and many innocent civilians.”160

159
Marcellus Decl. ¶ 22.
160
Decl. of Anshuman Chandra ¶ 8, U.S. ex rel. Brutus Trading, LLC v. Standard Chartered
Bank, No. 18-cv-1111 (S.D.N.Y. Jan. 10, 2020), ECF 48-3.

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2. SCB Maintained a Deliberately Ineffective Anti-Money

Laundering/Combating the Financing of Terrorism Program

636. SCB both enabled and concealed its ongoing sanctions evasion by maintaining a

deliberately ineffective compliance regime. This was not merely a function of SCB “failing to do

more” to stop Iranian entities, including terrorist fronts and financiers, from accessing and

misusing its financial services. SCB, particularly SCB Dubai, wanted to have its cake—i.e.,

lucrative banking relationships with Iranian customers, including sanctioned persons and

entities—and eat it too—i.e., by avoiding any resulting regulatory or law enforcement

consequences.

637. SCB established a built-to-fail system that ensured it remained willfully blind

about its highest-risk customers, in one of its highest-risk geographies for terrorist finance. Put

another way, SCB’s management unlawfully enabled its employees to pursue lucrative-but-

illegal business with terrorist customers that no responsible bank would have served.

638. SCB’s actions contravened its extensive obligations under U.S., U.K., and New

York laws and regulations regarding customer due diligence, transaction monitoring, anti-money

laundering, countering the financing of terrorism, and sanctions compliance.

639. Even after the 2012 Consent Order that resolved the investigation into its wire-

stripping misconduct, the NYDFS monitor identified multiple “serious flaws” in the NY

Branch’s “transaction monitoring system which had a direct and negative impact on the efficacy

of the New York Branch’s compliance function.” SCB’s systems completely failed to detect,

much less prevent, “a significant number of potentially high-risk transactions that should have

been subjected to further review” internally.161 Those high-risk transactions included illegal Iran-

161
2019 NYDFS Consent Order ¶ 13.

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linked transactions between 2008 and 2014—totaling at least several hundreds of millions U.S.

dollars—most of which were routed through the NY Branch.162

640. NYDFS also found that SCB Dubai’s compliance function was even worse. It

lacked the resources needed to implement and enforce its stated policies.163 The handful of

compliance staff were poorly trained, and SCB Dubai personnel writ large neither understood

nor cared about U.S. sanctions on Iran. Many SCB Dubai customer due diligence files were

“wholly inadequate, missing for example, critical information and key documents such as a valid

UAE residency visa.” SCB Dubai’s compliance regime was “no match for even unsophisticated

evasion efforts.”164

641. The U.K. FCA reached similar conclusions. SCB Dubai did not collect sufficient

information from customers to allow them to understand the nature and purpose of their

accounts, businesses, and sources of funds. This “impeded SCB’s ability to manage its money

laundering and terrorist financing risks effectively, and establish a basis for monitoring customer

activity and transactions.”165

642. In the rare circumstances where SCB determined that a customer required

enhanced monitoring, SCB Dubai either did not conduct such monitoring adequately or at all—

even after certain preset “trigger events” calling into question the verity or adequacy of

documents previously obtained for diligence, material changes to the nature of a business or its

beneficial ownership, the rejection of a customer’s transactions by counterparty banks due to

sanctions risks, or even the filing/reporting of a suspicious activity report (“SAR”) due to

162
2019 NYDFS Consent Order ¶¶ 5-6.
163
2019 U.K. FCA Decision Notice §§ 4.36-4.39.
164
2019 NYDFS Consent Order ¶ 43.
165
2019 U.K. FCA Decision Notice §§ 4.23-4.31.

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suspicious activity on that customer’s account.166 SCB Dubai repeatedly and willfully

disregarded and/or ignored its own red flags.

643. For example, in May 2011, a senior compliance officer at the NY Branch

recommended that SCB Dubai undertake a limited review of 19 specific small-to-medium

enterprises (“SMEs”) due to an identified sanctions risk based on the SMEs all being general

trading companies. A senior manager of SME Banking for the Middle East confirmed this risk,

stating in early 2012 in an e-mail to a very senior SME banker, “[M]any of our [Dubai branch]

customers are (a) Iranian nationals (owners of SMEs), (b) Selling to Iran ... (c) Supplying to

local buyers who have customers in Iran.... 814 SME customers have Iranian owners. They

may or may not have any direct/indirect exposure to Iran.”167

644. However, the Senior Financial Crime Risk Officer for SCB’s UAE operations

dismissed the request, stating, “All accounts where there is an Iranian national involvement

conform with our policy that if they are resident in the UAE then we are able to deal with

them . . . .” SCB Dubai ultimately reviewed only five SMEs. Of the 14 unreviewed companies,

two were responsible for approximately $100 million in illegal Iranian transactions that SCB

conducted between November 2008 and 2012.168

645. SCB’s deliberately “inadequate sanctions compliance program” was, in the words

of NYDFS, “a root cause” of its years-long, multi-million dollar sanctions evasion.169 SCB’s

failings were “particularly serious because they occurred against a background of heightened

awareness within SCB of issues with its global financial crime controls arising from action

166
2019 U.K. FCA Decision Notice §§ 4.65-4.77.
167
2019 NYDFS Consent Order ¶ 44.
168
2019 NYDFS Consent Order ¶ 45.
169
2019 NYDFS Consent Order ¶ 45.

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taking by US regulators and prosecutors, direct feedback from the [U.K. FCA], and through its

own internal assessments,”170 including its acknowledgment that SCB Dubai was a particularly

“high financial crime risk environment” given its “geographic proximity to . . . Iran.”171

646. As set forth supra, SCB was intentionally seeking to expand its business with

Iranian financial institutions and companies during the relevant time period. SCB knew,

however, that each of the most significant clients it could obtain were fronts for the IRGC, which

was rapidly expanding its hold over major sectors of the Iranian economy including energy,

finance, sanctions evasion, and import-export. In that context, SCB’s deliberately anemic

compliance system was a feature designed to attract IRGC business because IRGC decision-

makers would seek out banks that would take the necessary unlawful steps to willfully facilitate

illegal transactions.

E. SCB Facilitated Hezbollah Financing in Gambia

647. SCB Dubai and SCB Gambia knowingly moved millions of dollars for Hezbollah

financiers operating in and through Gambia until at least 2012.172 These funds flowed to

Hezbollah in the Middle East, where it used them to finance attacks on Americans.

648. Gambia is a small country in Western Africa with a population of approximately

1.7 million. Gambia has a well-established Lebanese diaspora community. Hezbollah has

notoriously leveraged this community to obtain resources necessary to facilitate its attacks on

Americans. This fact was confirmed by U.S. government officials and NGO experts, and was

widely reported in news media, including local media reports in Gambia.

170
2019 U.K. FCA Decision Notice § 2.7.
171
2019 U.K. FCA Decision Notice § 4.5.
172
Decl. of David J. Scantling ¶ 40 (“Scantling Decl.”), U.S. ex rel. Brutus Trading, LLC v.
Standard Chartered Bank, et al., No. 18-cv-11117 (S.D.N.Y. May 31, 2024), ECF 104.

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649. In a 2003 paper, Dr. Matthew Levitt described a “consensus among intelligence

professionals” that Hezbollah had “global reach” and conducted “extensive fundraising

operations in Africa” through “illicit diamonds” and “the local Shi’a expatriate community.”

650. On April 9, 2004, the U.S. State Department publicly summarized congressional

testimony from investigative journalist Douglas Farah citing voluminous evidence that

“Hezbollah has operated in West Africa since its inception in the early 1980s” due to “the

hundreds of thousands of Lebanese living in the region, ‘the vast majority being Shiite

Muslims.’” Farah explained that Hezbollah “‘collects donations from businesses, runs

shakedown operations, operates front companies and is also deeply involved in the ‘blood

diamond’ trade.” All of these activities were prevalent in Gambia at the time.

651. On September 28, 2006, Frank C. Urbancic, the State Department’s Principal

Deputy Coordinator for Counterterrorism, similarly testified before Congress that Hezbollah

“receives a significant amount of financing from the Shiite Muslim diaspora of West and Central

Africa,” and Lebanese traders there “have significant control over basic imported commodities”

and are “very active in diamond exports.”

652. A September evaluation by the Financial Action Task Force (FATF) identified

structural risks in the Gambian economy, including lack of risk assessments, absence of an AML

strategy, and inability to report suspicious transactions. It noted that “[t]he Gambian financial

system remains vulnerable to the activities of organized criminal groups and terrorists.” Gambia

also ranked 158 out of the 180 countries covered in the 2007 and 2008 Transparency

International corruption indices.

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653. SCB maintained a longstanding and deep presence in Gambia. It operated in

Gambia for decades, even playing “the Central Bank role at one point.”173 SCB Gambia’s

management was therefore knowledgeable about the local culture, dialect, market conditions,

and politics, and knew the extent to which Hezbollah had penetrated the Gambian economy.

Armed with this knowledge, SCB willfully facilitated Hezbollah’s terrorist financing activities in

Gambia.

1. SCB Gambia Helped Hezbollah’s Bazzi Network Access the U.S.

Financial System to Finance Terrorist Attacks

654. After helping overthrow the sitting government of Gambia in 1994, Yahya A.J.J.

Jammeh became President in November 1996, remaining in that post until January 2017. For

over twenty years, Jammeh’s corruption and willingness to steal state resources facilitated the

diversion of millions of dollars from the Gambian economy to Hezbollah. Indeed, as early as

December 8, 2005, African news outlets described Jammeh’s regime as an organized crime

enterprise, referring to Jammeh and his close associates as a “mafia.”

655. One of Jammeh’s closest business partners—who banked with SCB—was

Hezbollah financier Mohammad Bazzi. In 2018, the U.S. Treasury Department designated Bazzi

and his business enterprises as SDGTs, describing Bazzi as “a key Hizballah financier who has

provided Hizballah financial assistance for many years and has provided millions of dollars to

Hizballah generated from his business activities,” including in “West Africa.” Treasury Secretary

Mnuchin stated that “Hizballah uses financiers like Bazzi who are tied to drug dealers, and who

launder money to fund terrorism.” He further described Bazzi as “one of Hizballah’s most

prominent financiers,” engaged in “savage and depraved acts.”

173
https://www.sc.com/gm/about-us/.

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656. A 2019 report from the Organized Crime and Corruption Reporting Project

(“OCCRP”), described Bazzi as Jammeh’s “consigliere” as Jammeh ran Gambia “like an

organised crime syndicate.” Bazzi was “by far the most influential businessman” in Jammeh’s

inner circle.

657. As high-profile public figures, both Bazzi and Jammeh were known to SCB.

Additionally, by the mid-2000s, both Bazzi and Jammeh were notorious, as they were reportedly

involved in illegal enterprises that directly supported Hezbollah including drug trafficking, arms

sales, and blood diamonds. In addition to direct financial support for Hezbollah, Bazzi also

reportedly assisted Jammeh in trading girls from refugee camps for funds to assist Hezbollah.

658. Bazzi and Jammeh’s ties to Hezbollah were well-known. In December 2006,

Gambia (headed by President Jammeh) and Iran publicly issued a joint statement on mutual

cooperation, including support for Hezbollah. On December 19, 2007, the globally syndicated

Gambian newspaper Freedom reported that Gambia was “no longer in the hands of the Gambians

but Lebanese,” that the state’s telecom company and energy firms had been “hijacked” by Bazzi,

that Hezbollah money was used to purchase the companies from the state, and that profits from

these firms were “wired through the Standard Chartered Bank Banjul Branch [in Gambia] to

Arab countries.” Additional reports in December 2006 and 2007 named Bazzi as a Hezbollah

financier, and noted that Jammeh’s personal security force was covertly receiving weapons and

training from the IRGC. Another Freedom newspaper report on January 21, 2008 noted that

Jammeh’s Government “has been linked to welcoming Hezbollah terrorists into the country.”

659. On March 25, 2011, The Gatestone Institute, citing earlier local media reports,

stated that Gambia was procuring weapons from Iran and selling them to Hezbollah, as well as

selling drugs through Hezbollah: “President Jammeh is colluding with Lebanese businessman

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Mohammad Bazzi, Gambia’s Consul General to Lebanon, to buy weapons from Iran to sell to

Hezbollah.” These and other reports alerted SCB that Bazzi was arming terrorists. According to

numerous news reports and U.S. government statements, in 2010, Qods Force Deputy

Commander Esmail Ghani used Qods Force agents in West Africa to transfer over 240 tons of

weapons, including small arms, large-caliber artillery shells, and Katyusha rockets to Hezbollah

and Hamas. The weapons were intercepted in Nigeria awaiting shipment to Gambia.

660. Against the backdrop of these reports, Jammeh and his associates—including

Bazzi and his network—robbed the state of at least hundreds of millions of dollars. OCCRP

reported that they used the Gambian Central Bank as their “personal slush fund,” looting $363.9

million from the state telecommunications company, $60 million from its pension fund, and

$55.2 million from the state-run oil company.

661. A substantial portion of the looted funds flowed through to Hezbollah. Jammeh,

working with Bazzi and others, turned Gambia and its banking system into a Hezbollah

laundromat in exchange for multi-million dollar bribes. Specifically, through the companies in

his Euro African Group Ltd. (“EAGL”), Bazzi paid bribes to Jammeh in exchange for sham

privatizations and government contracts being routed to companies that Bazzi and other known

Hezbollah financiers and commanders controlled.

662. Through these corrupt deals, Bazzi’s network monopolized entire sectors of the

Gambian economy, such as fuel, telecommunications, and construction between 2002 and 2017

(these dates being approximate and inclusive). For example, between 2010 and 2014, Jammeh

diverted $18 million from a state-owned enterprise to Gam-Petroleum Gambia, Co., which was

connected to Bazzi. EAGL also received $60 million from Gambia’s state oil company in just

two years (2015-2017). Bazzi’s fuel monopoly continued until at least 2017.

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663. Bazzi also paid a multi-million dollar bribe to induce Jammeh to ‘privatize’ the

Gambia’s telecommunications companies, and ‘sell’ them to Ali Charara, another Hezbollah

financier, for roughly 22% of their fair-market value. This transaction likely laundered illicit

Hezbollah revenues from other ventures. It also routed $150 million to Charara’s companies

(which were often joint ventures with Bazzi) between 2006 and 2014.

664. EAGL’s transactions with Jammeh and his henchmen provided Hezbollah with

tremendous political influence in Gambia, making it a safe haven for Hezbollah’s terrorist

operations. This enabled Hezbollah to profit from other illicit activities in Gambia, without

interference from the country’s (corrupted) legal and intelligence officials. For example, in 2004,

Bazzi and other Hezbollah financiers bribed the country’s Director of National Intelligence, who,

like Bazzi, banked with SCB. Another Bazzi counterparty was regime official Baba Jobe, who

trafficked arms and diamonds in collaboration with another notorious SCB client, Victor Bout.

The illicit trade in diamonds was primarily conducted by Lebanese traders, who paid ‘taxes’ and

provided raw gems to Hezbollah in such great quantities that the 2006 war with Israel caused the

global price of diamonds to collapse. Hezbollah also extorted legitimate Lebanese diaspora

businesses. U.S. government, U.N., and expert reports published well before 2008 indicate that

Gambia served as a critical node in Hezbollah’s diamond and drug smuggling operations, which

were used to fund its terrorist attacks on Americans.

665. SCB played an important role in Jammeh and Bazzi’s schemes. OCCRP found

that SCB “approved transactions for what would turn out to be Jammeh’s seizure of state funds.”

And whistleblower accounts state that SCB Gambia, between 2008 and 2012, “maintained USD

and GMD denominated bank accounts for Euro African Group LTD, identified by SCB group ID

number “*****7340”, and processed funds transfers worth millions of U.S. dollars through

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SWIFT’s data center in Virginia, CHIPS in New York, and SCB New York [for Euro African

Group LTD]. Further, between January 2009 and June 2010, SCB Dubai processed 73 foreign

exchange transactions worth a total of $16,659,286.07 U.S. dollars for the benefit of Euro

African Group’s transactional account, number “*****7701.”174 Because SCB provided services

to both the Bazzi network and state agencies it was pillaging, it had a unique, comprehensive

view of the totality of the Jammeh-Hezbollah organized crime enterprise. Jammeh and Bazzi’s

corrupt schemes were exclusively located in Standard Chartered branch buildings. Co-locating

with SCB gave the network the same benefits that using the bank’s services did: it afforded

legitimacy, efficiency, and revenue generation opportunities which would have been unavailable

otherwise.

666. EAGL and SCB Gambia had a close relationship. As early as 2004, EAGL gave

its address as the second floor of the Standard Chartered Bank building in Banjul, Gambia.

EAGL also listed SCB Gambia as its principal banker. EAGL gave the same address at Standard

Chartered for Petroleum Storage Facility, an affiliated company of EAGL. In 2018, OFAC

designated Bazzi and EAGL, listing its Gambian address as “Standard Chartered House,” and its

energy-focused subsidiary, Global Trading Group (GTG)’s location as the second floor of the

“Standard Chartered Bank Building.” Bazzi and his son conspired to evade those sanctions, and,

in 2019, OFAC designated multiple GTG successor entities at the same “Standard Chartered

Bank Building” address.

667. Jammeh and Bazzi’s corrupt schemes were literally being carried out under

SCB’s nose. According to the Gambian commission that investigated Jammeh and Bazzi’s

174
Decl. of David J. Scantling ¶ 40 (“Scantling Decl.”), U.S. ex rel. Brutus Trading, LLC v.
Standard Chartered Bank, et al., No. 18-cv-11117 (S.D.N.Y. May 31, 2024), ECF 104.

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corrupt enterprises, Jammeh’s umbrella holding company and many of his enterprises were co-

located with Bazzi’s in Standard Chartered House. These companies were entirely dependent on

the circular flow of bribes, stolen public assets, and illegal contracts and therefore shared both

space and leadership: the managing director of EAGL, Ahmad Hodroj, was simultaneously a

signatory on Jammeh’s companies’ bank accounts. Bazzi and high-ranking regime officials used

Standard Chartered House to hold meetings in furtherance of their conspiracy to convert

Gambian public property into private wealth and Hezbollah assets.

668. Similarly, Bazzi took over the state water and electricity company (NAWEC) by

inducing Jammeh to contract with a Bazzi-controlled company to oversee it. Bazzi then purged

NAWEC’s top leadership. He then called a management meeting at Standard Chartered House to

intimidate its remaining leaders. Thereafter, Bazzi forced NAWEC’s nominal managers to

shuttle between his office at Standard Chartered House and their headquarters—about 3

kilometers away—multiple times each day. Bazzi and his co-conspirators thus ensured an

uninterrupted flow of NAWEC’s funds into the coffers of EAGL’s monopolies on fuel and

electricity generators.

669. Indeed, Standard Chartered House as such owes its very existence to SCB’s

knowing collusion with the Jammeh-Bazzi criminal network. SCB does not own the building,

and thus, on information and belief, SCB made regular rent and naming-rights payments. In

exchange, SCB received the use of a sparkling, modern location situated on a 27,000 square-foot

lot of prime real estate on Gambia’s highest-value commercial thoroughfare. SCB, of course,

sought the highest possible return on this investment in visibility. Consequently, the OFAC-

designated headquarters of one of the 21st century’s most destructive state-sponsored crime and

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terrorist finance syndicates bears a huge sign: “STANDARD CHARTERED HOUSE.” The

slogan on banner reads “You believe – we achieve.”175

670. In the ordinary course of business, a sophisticated multinational bank with

knowledgeable local managers would not open a branch without performing thorough diligence

on the location and its owners. But this was an extraordinary lease: SCB negotiated to create a

location on the Gambian equivalent of Wall Street that would literally and figuratively bear its

175
https://maps.app.goo.gl/aoiJFBqzSnpnGyUB9 (June
2007).https://maps.app.goo.gl/aoiJFBqzSnpnGyUB9 (June 2007)

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name, and to share said building with its owners—landlords who were, not coincidentally, the

most powerful and dangerous actors in Gambia—and, simultaneously, high-value SCB clients.

671. Standard Chartered House is a monument to the synergy of organized crime,

torture, and terrorist finance. It does not have a typical numbered street address because it was

built on Jammeh illegally converted public parkland. According to the Gambian commission,

Jammeh forced the property’s prior owner to “sell” the property to Jammeh—and then leased the

property to EAGL’s co-owner, Jammeh regime official Amadou Samba. Samba, in turn,

developed the property. It is therefore unsurprising that EAGL and the president’s own

companies were headquartered there, and inconceivable that SCB was unaware of the constant

stream of corrupt officials and their victims meeting with their landlord and client, Bazzi.

672. True to its signage, SCB did, indeed, help the Bazzi network “achieve.” Fully half

of its Gambian branch locations housed Bazzi network offices. SCB Gambia, for use as EAGL’s

headquarters. But the building was named “STANDARD CHARTERED HOUSE,” and

contained an SCB Gambia branch office, indicating a very close relationship between SCB and

EAGL—as well as likely substantial rent payments flowing from SCB to EAGL despite

evidence of EAGL’s complicity in terrorist finance.

673. Bazzi was also one of the owners and founders of Prime Bank in Gambia.

Treasury’s February 10, 2011 press release identifying Lebanese Canadian Bank SAL (“LCB”)

as a financial institution of primary money laundering concern stated that: “LCB’s other links to

Hizballah include LCB’s subsidiary, Gambia-based Prime Bank, which is partially owned by a

Lebanese individual known to be a supporter of Hizballah.” Local and international media

contemporaneously confirmed that this partial owner was Bazzi. The corporate records used in

these reports were accessible to SCB at least as early as 2009. LCB was also identified as “the

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sole correspondent bank for Prime Bank,” and SCB served as a U.S. correspondent bank for

LCB.

674. SCB not only ignored the lack of oversight and counterterrorism controls imposed

by the government in Gambia; it actively assisted Bazzi and his business interests by conducting

financial transactions worth millions of dollars through the United States so that Bazzi could

provide funds to Hezbollah for terrorist attacks. SCB provided accounts and transactional

support for Bazzi and his companies so that they could continue to funnel money to Hezbollah,

even though Bazzi’s Hezbollah connections were known at the time.

675. Plaintiffs’ allegations about Bazzi’s activities were confirmed by the U.S.

Government when it designated and prosecuted Bazzi and his network. In addition to the 2018

designation of Bazzi, which identified him as “a key Hizballah financier who has provided

Hizballah financial assistance for many years and has provided millions of dollars to Hizballah

generated from his business activities,” Treasury also designated Bazzi’s co-conspirator in

Gambia, Charara, and his telecommunications enterprise as SDGTs on January 7, 2016. That

designation said that Charara “has received millions of dollars from Hizballah to invest in

commercial projects that financially support the group,” including “extensive business interests

in the telecommunications industry in West Africa.” Adam J. Szubin, acting Under Secretary for

Terrorism and Financial Intelligence described how “Hizballah relies upon accomplices in the

business community to place, manage, and launder its terrorist funds,” explaining that by

“exposing and disrupting these networks,” the Government sought “to pressure Hizballah’s

finances and degrade its ability to foment violence in Lebanon, Syria, and across the region.”

676. Bazzi, EAGL, and other companies connected to Bazzi were designated SDGTs

on May 17, 2018 (and OFAC listed their Standard Chartered building addresses). OFAC said

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that the designation showed the “convergence of Iran’s support for terrorism with many facets of

illicit criminal activity, including narcotics trafficking. In addition to providing millions of

dollars to Hizballah, Mohammad Bazzi is a close associate of Yahya Jammeh, the corrupt former

leader of The Gambia who, in addition to ordering targeted assassinations, plundered The

Gambia’s state coffers for his personal gain.” The designation added that Bazzi had “business

ties to the Ayman Joumaa Drug Trafficking and Money Laundering Organization,” and that

Abdallah Safi-al-Din, Hezbollah’s highest-ranking representative to Iran, personally “worked

with Bazzi to reestablish a political relationship between The Gambia and Iran.” “Bazzi and Safi-

Al-Din previously worked with the Central Bank of Iran” to “expand banking access between

Iran and Lebanon.”

677. The upshot is that, for years, SCB, through its Gambia branch, knowingly assisted

Bazzi and his confederates as they corruptly extracted millions of dollars from the Gambian state

to raise and transfer money for Hezbollah’s violent activities.

2. SCB Dubai Helped Hezbollah Front Tajco Ltd. Access the U.S.
Financial System to Finance Terrorist Attacks

678. SCB Gambia and SCB Dubai helped Hezbollah front Tajco Ltd. access the

international financial system to finance terrorist attacks. Treasury identified Tajco Ltd. as a

“multipurpose, multinational business venture involved in international trade as well as real

estate and presided over by Ali, Husayn and Kassim Tajideen. As of February 2007, Kassim

Tajideen owned Tajco and used proceeds from this business to provide millions of dollars in

financial support to Hizballah.”

679. SCB Gambia and SCB Dubai maintained relationships with Tajco Ltd. knowing it

was co-owned by the Tajideen brothers, who had multiple businesses acting as fronts to provide

funding and resources to Hezbollah. Despite overwhelming evidence that Tajideen’s African

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enterprises were providing enduring infrastructure for Hezbollah’s terrorist operations, until at

least 2010, “SCB Gambia maintained U.S. dollar (‘USD’) and Gambian dalasi (‘GMD’)

denominated bank accounts for Tajco LTD, identified by SCB group ID number ‘*****7865’,

and processed funds transfers worth millions of U.S. dollars [for Tajco LTD] through SWIFT’s

Viriginia data center, CHIPS in New York, and SCB New York. Further, in August 2010, SCB

Dubai processed a foreign exchange transaction worth a total of $290,803.56 U.S. dollars for the

benefit of Tajco’s transactional account, number ‘*****9201.’”176

680. Evidence of Tajco’s high-profile connections to Hezbollah was strong and known

to SCB. In May 2009, the Treasury Department designated Kassim Tajideen Executive Order

13224 for supporting Hezbollah, explaining that “Kassim Tajideen is an important financial

contributor to Hizballah who operates a network of businesses in Lebanon and Africa. He has

contributed tens of millions of dollars to Hizballah through his brother, a Hizballah commander

in Lebanon. In addition, Kassim Tajideen and his brothers run cover companies for Hizballah in

Africa.”

681. According to Treasury in 2010, Ali Tajideen, one of Tajco’s co-owners, provided

cash “in tranches as large as $1 million” to Hezbollah and was a “major player” in Jihad al-Bina,

a Lebanon-based Hezbollah-run construction company designated by Treasury in February 2007.

682. Evidence of the Tajideen family’s connections to terrorism was public well before

these designations. On February 26, 2007, The Times (London), reported that Ali Tajideen’s

“connections to Hezbollah are well known in south Lebanon.” The Times stated that Ali was

purchasing land in Lebanon for Hezbollah, and further highlighted that a member of his family

176
Decl. of David J. Scantling ¶ 40 (“Scantling Decl.”), U.S. ex rel. Brutus Trading, LLC v.
Standard Chartered Bank, et al., No. 18-cv-11117 (S.D.N.Y. May 31, 2024), ECF 104.

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was charged with using West African diamonds to launder money for Hezbollah. In its

designation of the Tajideen family network, OFAC confirmed that their companies were trading

diamonds.

683. SCB knew that the Tajideen family’s involvement in diamond smuggling was a

red flag for terrorist finance based on numerous articles on the subject published by local and

global news media. For example, a regional diamond trade expert quoted in The Concord Times,

a Sierra Leonian newspaper, on February 5, 2002, stated that because Gambia produces no

diamonds of its own, diamonds sold from Gambia were obviously illicit conflict diamonds—

with proceeds going to Lebanese actors active in the West African diamond industry. This report

was syndicated globally.

684. Investigative journalist Douglas Farah’s reporting on Hezbollah’s use of

diamonds to finance terrorist violence was cited in African media and research reports available

to all SCB branches, including in Gambia. Most pointedly, on December 20, 2002, The Concord

Times covered a widely cited paper noting Farah’s reports linking Lebanese diamond traders in

West Africa—“especially The Gambia” which was “enmeshed in the diamond syndicate—to

Hezbollah’s attacks on “US installations.”

685. In an October 2004 paper, Farah highlighted that “Hezbollah has also been using

diamonds from West Africa to finance its activities,” becoming sophisticated in its “exploitation

of ‘grey areas’ where states are weak, corruption is rampant, and the rule of law is nonexistent.”

Farah thus explained that “over the course of more than twenty years,” Hezbollah had

“successfully embedded its financial structure within the diamond trade.” Newspapers published

op-eds by Farah and co-authors reiterating these lessons.

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686. Media sources also confirmed the Tajideen family’s status as Hezbollah

financiers. On August 12, 2007, The Sunday Telegraph reported that Tajideen used the money he

earned in Africa to acquire huge amounts of land in Lebanon, for the purpose of replacing

communities opposed to Hezbollah with pro-Hezbollah Shi’a. The IRGC and Tajideen’s

construction company were so successful in this enterprise that Lebanese politicians warned that

there was “an extraordinary demographic shift taking place” pursuant to “Hezbollah’s plan to

create a state within a state.” Tajideen, in his role as “a major player” in Jihad al-Bina provided

Hezbollah with control of strategic valleys along the Litani River, which borders Israel. This

territory was “ideal terrain” for Hezbollah’s guerilla tactics and fell outside of U.N. monitors’

jurisdiction. This was part of a “a grand scheme to create a strip of Shia-controlled land

connecting the south to Hezbollah’s other power centre in Lebanon, the Bekaa Valley.”

687. Tajideen’s land acquisitions and property developments provided Hezbollah with

fortified bases co-located with civilian housing, removed its opponents from strategic areas, and

enabled it to covertly build secure command, control, and communications infrastructure directly

connected with Syrian and Iranian systems. Discovered in 2008, this was declared Hezbollah’s

“No. 1 weapon” by its leader Hassan Nasrallah. When Lebanon’s Prime Minister demanded its

removal, Hezbollah launched an all-out assault on Beirut, overthrew the government, and

replaced it with a Hezbollah-controlled coalition.

688. On information and belief, SCB’s industry-standard due diligence, which

involved Know Your Customer investigations, flagged Tajco’s co-owners and alerted SCB to

public reports discussing Tajco and its owners. Despite these warnings, SCB chose to process

dollar transactions for these known Hezbollah financiers through at least August 2010. Not only

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did SCB maintain accounts in Gambia and process transactions in Dubai, but SCB also enabled

these Hezbollah fundraisers to access U.S. dollars through SCB New York.

F. SCB Repeatedly Misled and Obstructed U.S. Regulators

1. SCB Willfully Misled NYDFS About Its Anti-Money

Laundering/Combating the Financing of Terrorism Program

689. In 2003, following an investigation into significant AML/CFT violations—

violations that were distinct from SCB’s wire-stripping scheme—NYDFS ordered SCB to

improve its AML/CFT practices with respect to foreign bank correspondent accounts. That

agreement (the “Written Agreement”) also required SCB to hire an independent consultant to

conduct a retrospective transaction review for suspicious activity involving the NY Branch.177

SCB “vowed to regulators” that it would “comply” with the Written Agreement.178

690. To that end, SCB retained Deloitte & Touche, LLP (“Deloitte”) to perform an

independent review of suspicious activity and report its findings to NYDFS.179

691. SCB skewed Deloitte’s nominally independent investigation. SCB pressured

Deloitte to hide from regulators any references that “could ultimately reveal SCB’s Iranian U-

Turn practices”—i.e., references that could reveal SCB’s sanctions-evasion scheme.180 Deloitte

succumbed to SCB’s pressure, and ultimately submitted a “watered-down” report to NYDFS.181

692. Around that same time, SCB’s CEO of the Americas failed to disclose SCB’s

wire stripping to the NYDFS Deputy Superintendent for Foreign Banks. Instead, SCB “lied” to

NYDFS and claimed that the “bank was compliant in all matters related to Iran.”182

177
2012 NYDFS Consent Order ¶ 41.
178
2012 NYDFS Consent Order ¶ 43.
179
2012 NYDFS Consent Order ¶ 50.
180
2012 NYDFS Consent Order ¶ 45.
181
2012 NYDFS Consent Order ¶ 45.
182
2012 NYDFS Consent Order ¶ 46.

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693. In September 2006, NYDFS requested from SCB statistics on Iranian U-Turns,

including the number and dollar volume of such transactions for a 12-month period.183

694. In response, SCB searched its records for 2005 and 2006, and uncovered 2,626

transactions totaling over $16 billion.184 SCB’s Head of Compliance at the NY Branch provided

the data to SCB’s CEO for the Americas, who in turn, sent it to the SCB Group Executive

Director in London. In his memorandum to the Executive Director, the CEO expressed concern

that this data would be the “wildcard entrant” in the ongoing review of U-Turns by regulators

and could lead to “catastrophic reputational damage to the [bank].”185 SCB’s Head of

Compliance in New York ultimately provided only four days of data to regulators.186

695. The combined effect of SCB’s deceptive acts—a watered-down report from

Deloitte, lying about their compliance with Iran regulations, and misleading data—ultimately

convinced NYDFS to lift the Written Agreement in 2007.187

696. Years later, in the 2012 Consent Order, NYDFS excoriated SCB for its deception.

According to NYDFS, “SCB successfully misled New York regulators to believe that it had

corrected serious flaws” in its AML/CFT program.188 In reality, however, “the opposite was

true.” “SCB’s actions prevented regulators from doing their job in detecting potential threats to

the U.S. financial system and other national security interests.”189 Had NYDFS known the

183
2012 NYDFS Consent Order ¶ 48.
184
2012 NYDFS Consent Order ¶ 48.
185
2012 NYDFS Consent Order ¶ 48.
186
2012 NYDFS Consent Order ¶ 48.
187
2012 NYDFS Consent Order ¶ 50.
188
2012 NYDFS Consent Order ¶ 50.
189
2012 NYDFS Consent Order ¶ 51.

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truth—i.e., “had SCB not meticulously disguised its willful misconduct”—NYDFS “would have

kept the Written Agreement rigidly in place.”190

697. SCB’s documented willingness to mislead financial regulators further suggests

that its decision to provide atypical, illegal banking services for Iran’s Terrorist Sponsors and

fronts was deliberate.

2. SCB Willfully Misled NYDFS About Its Sanctions Compliance Efforts

698. SCB also misled NYDFS about the quality of its sanctions compliance efforts.

699. In 2009, SCB engaged Promontory Financial Group LLC (“Promontory”), a

reputable financial consultancy, to provide advice on sanctions compliance and regulatory issues,

and to identify and collect SCB’s historical records for cross-border transactions.

700. In 2010, SCB broadened Promontory’s mandate to identifying, collecting, and

analyzing historical transaction records with sanctioned countries and persons.191 SCB ostensibly

ordered Promontory to be “independent and transparent” in how it evaluated SCB’s behavior

because, at the conclusion of the project, Promontory was to submit factually accurate reports to

financial regulators.192

701. Between 2010 and 2011, Promontory did indeed produce and transmit several

reports and made several presentations to NYDFS (and other governmental authorities). Those

reports, however, were materially inaccurate. SCB exploited its relationship with Promontory to

improperly manipulate Promontory’s reports.

190
2012 NYDFS Consent Order ¶ 52.
191
NYDFS, Report on Investigation of Promontory Financial Group LLC (Aug. 2015) at 2-3.
192
NYDFS, Report on Investigation of Promontory Financial Group LLC (Aug. 2015) at 5.

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702. SCB knew that the engagement was lucrative for Promontory—with a contract

worth approximately $54.5 million193—and SCB knew that Promontory wanted to avoid

“jeopardizing [its] relationship” with SCB. So SCB’s in-house and outside counsel and other

SCB employees provided extensive markups and comments on Promontory’s draft reports to:

(i) make categories of illegal transactions appear more innocuous; (ii) conceal willful compliance

failures (such as when SCB’s sanctions filters correctly identified illegal transactions that SCB

processed anyway); (iii) remove branch-identifying information concerning the illegal

transactions; (iv) selectively remove certain timelines showing increases in violations during the

relevant period at some branches while keeping in others that portrayed SCB in a more positive

light; and (v) minimize the number of “violations” reported.194

703. Promontory implemented all SCB’s comments—whitewashing SCB’s bad

behavior, and in effect, serving as a de facto advocate for SCB’s interests with regulatory

authorities—even though Promontory was expected to exercise “independent judgment”

reporting SCB’s behavior to authorities.195

704. By essentially puppeteering Promontory, SCB managed to hide from NYDFS the

true extent of its illegal Iran-related transactions, undermining NYDFS’s enforcement efforts.196

705. SCB’s willingness to submit manipulated data to New York financial regulators is

further evidence that its decision to provide atypical, illegal banking services for Iran’s Terrorist

Sponsors and fronts was deliberate.

193
NYDFS, Report on Investigation of Promontory Financial Group LLC (Aug. 2015) at 3 n.1;
id. at 6.
194
NYDFS, Report on Investigation of Promontory Financial Group LLC (Aug. 2015) at 5-14.
195
NYDFS, Report on Investigation of Promontory Financial Group LLC (Aug. 2015) at 5-14.
196
NYDFS, Agreement, In the Matter of Promontory Financial Group, LLC (Aug. 18, 2015).
Promontory paid a $15 million penalty to NYDFS for its role in hiding SCB’s malfeasance. Id.

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3. SCB Promoted a Culture of Illegality by Retaliating Against

Whistleblowers

706. SCB promoted a culture of illegality throughout the institution. Not only did SCB

“fail[] to take reasonable steps to ensure a positive culture towards AML compliance was

embedded” throughout the Bank,197 but SCB also retaliated against multiple employees who

tried to blow the whistle on SCB’s illegal provision of financial services to customers affiliated

with the IRGC and other terrorist groups.

707. Between 2011 and 2016, two SCB employees reported to U.S. and New York

State authorities that, based on their own observations and experience and informed by reams of

SCB transaction data: (i) SCB was facilitating U.S. dollar-denominated transactions for Iranian

customers suspected of funding terrorist groups; and (ii) when it was under investigation, SCB

drastically underreported the volume of illegal Iran-linked transactions it facilitated.198

708. The first whistleblower was Julian Knight, SCB’s Global Head of Transaction

Banking Foreign Exchange Sales for SCB Dubai and SCB’s branches in Singapore. Knight

internally reported concerns about SCB’s Iranian transactions and proposed reforms to remedy

them. SCB responded by terminating him. Subsequently, after Knight reported his concerns to

NYDFS and other government regulators, SCB embarked on a retaliatory smear campaign

against him that essentially led to Knight being blacklisted in the financial services industry.199

709. The second whistleblower was Anshuman Chandra, who worked for SCB in

Dubai as the head of eCommerce Client Services, Financial Markets for the MENA region. After

197
2019 U.K. FCA Decision Notice § 5.16.
198
First Am. Compl. ¶¶ 9-13, Chandra, et al. v. Standard Chartered Bank, et al., No. 19-cv-
11739 (S.D.N.Y. May 26, 2020), ECF 21.
199
First Am. Compl. ¶¶ 43-46, 78-93, Chandra, et al. v. Standard Chartered Bank, et al.,
No. 19-cv-11739 (S.D.N.Y. May 26, 2020), ECF 21.

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Chandra reported concerns about SCB’s post-2013 Iran-related transactions to U.S. authorities

through an intermediary, SCB retaliated against him at work via harassing conduct, followed by

a layoff, and then harsher treatment of Chandra than other laid off employees who had not

engaged in whistleblowing.200

710. SCB’s willingness to retaliate against whistleblowers in an effort to conceal the

true scope of its transactions with Iran’s Terrorist Sponsors and fronts is further evidence that

SCB’s hundreds of millions in transactions with those entities was both conscious and culpable.

G. Plaintiffs’ Allegations Are Corroborated by SCB’s Pattern of Engaging in a

Variety of Other Illicit Behavior

711. SCB’s illegal conduct as alleged herein is no aberration; it is a reflection of SCB’s

corporate culture and business priorities. Plaintiffs’ allegations fit SCB’s consistent pattern of

disregarding red flags, typical banking practices, and, in many cases, legal obligations in service

of the bank’s appetite for market share and profitability in the geographies it targeted (which

were often high-risk, “frontier” markets).201 This pattern of illegal conduct—including conduct

demonstrating, at best, complete indifference to terrorism financing risk—goes well beyond the

misconduct complained of herein related to Iran, Hezbollah, and Iran’s Terrorist Sponsors.

712. Indeed, SCB has a long, sordid history as a rogue bank that has knowingly

providing assistance to money launderers, sanctions evaders, and financers and facilitators of

200
First Am. Compl. ¶¶ 47-59, 64-77, Chandra, et al. v. Standard Chartered Bank, et al.,
No. 19-cv-11739 (S.D.N.Y. May 26, 2020), ECF 21.

To be fair, SCB has exhibited a pattern of engaging in wildly reckless and criminal
conduct in established Western countries as well. For example, in 2015, SCB’s Swiss subsidiary
settled with DOJ and paid millions of dollars in penalties for unlawfully helping certain U.S.
persons evade their U.S. tax obligations. Separately, in 2019, NYDFS fined SCB $40 million
after an investigation confirmed, among other things, that bankers in SCB’s London and New
York branches used a range of illegal tactics to attempt to rig transactions in foreign exchange
markets between 2007 and 2013.

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terrorism. That history encompasses nearly all of its global operations, including those in the

Americas, Africa, South and Southeast Asia, and the Middle East.

713. Over the last few decades, SCB has been fined many millions of dollars by

regulators in multiple countries, including India, Japan, Singapore, and Kenya, for illegally

facilitating significant money laundering schemes and/or for deliberately maintaining a deficient

approach to anti-money laundering and terrorism finance prevention.

714. For example, SCB was implicated in a multi-billion-dollar bribery scandal in

Angola in the early 2000s, was accused by the U.S. government in 2015 of allowing its accounts

to be used to launder some of the key bribes in the FIFA/World Cup scandal, and was accused in

2019 by a U.K. lawmaker of culpably facilitating (and concealing) hundreds of millions of

dollars’ worth of alleged bribes paid to South African officials by the Guptas, an ultrawealthy

family of oligarchs. Other examples include when the South African Central Bank fined SCB in

2016 for its weak measures to combat money laundering and the financing of terrorism, and in

2018, when the Monetary Authority of Singapore imposed financial penalties on SCB for for

breaking terrorism financing rules.

715. SCB’s pattern of illegal conduct also includes providing financial and banking

services to transnational criminal organizations (“TCOs”)202 that were engaged in money

laundering and financing terrorism.

202
TCOs are organizations that the United States has determined engage in transnational
criminal activities that threaten the security of U.S. nationals or the national security of the
United States by, among other things, destabilizing international political and economic systems,
weakening democratic institutions, degrading the rule of law, and undermining economic
markets. TCOs also facilitate the violent activities of other dangerous persons and organizations.
Executive Order 13581.

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716. For example, SCB provided financial services to the Khanani Money Laundering

Organization (“Khanani MLO”), a TCO that facilitated the illicit movement of an estimated $14

billion to $16 billion dollars per year through the global financial system. The Khanani money

laundering MLO was known to fund the illicit activities of clients that included drug traffickers,

organized crime groups, and terrorist organizations, including al-Qaeda and the Haqqani

Network (both FTOs). SCB held accounts for at least two front companies that were part of the

Khanani MLO, processed a number of suspicious transactions involving those front companies,

and failed to report the suspicious transactions contemporaneously to the appropriate government

authorities—including, among others, a suspicious payment to an unidentified entity in the UAE

that SCB had flagged internally because of its reference to the “purchase of seismic explosives.”

717. SCB also knowingly provided bespoke financial services to a VAT fraud cell

operated by Samir Azizi, a teenaged al-Qaeda and Haqqani Network operative who funneled tens

of millions of dollars in VAT fraud proceeds to Afghan terror groups from 2009 until 2015

(when he was finally arrested). SCB did so despite the myriad public sources expressly linking

VAT fraud to terrorist finance beginning in 2006, including a widely reported statement by the

U.K. Home Secretary and a 2007 report from the Financial Action Task Force.

718. In one of the more shocking examples of SCB’s assistance to conduct that posed a

clear and obvious risk of terrorist violence, SCB’s Pakistan branch knowingly provided term

loans, foreign exchange, and export finance services to Fatima Fertilizer, the Pakistani company

which produced the overwhelming majority of calcium ammonium nitrate (CAN) fertilizer used

by terrorists in Afghanistan to make the bombs responsible for nearly 90 percent of U.S.

casualties there. SCB provided those services to Fatima despite years of press coverage and

government statements linking its CAN fertilizer to bombs and noting that Fatima was doing

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nothing to stop it. Indeed, SCB continued to provide services to Fatima even after a senior

Department of Defense official personally visited SCB’s New York office to tell the bank that its

customer was facilitating the killing and maiming of American troops and to implore SCB to

take actions to disrupt the terrorists’ bombmaking pipeline. The same DoD official subsequently

described SCB’s response to his entreaties as “utterly useless.”203 Instead, the bank continued to

service Fatima and thereby facilitate the terrorists’ bombmaking pipeline.

719. In sum, SCB has a long track record demonstrating that it will happily assist its

customers’ conduct even when it knows that acts of terrorism are a foreseeable risk of the

enterprises it assists.

VIII. SCB Knew That Iran-Sponsored Terrorist Attacks Committed By Hezbollah,

Hamas, PIJ, and JAM Were A Foreseeable Result Of Its Culpable Acts

720. As explained above, SCB engaged for over a decade in an intentional and

systematic scheme to move billions of dollars for Iran’s Terrorist Sponsors while helping them

evade counterterrorism controls. At the time SCB engaged in this culpable conduct, it knew that

its conduct financed Iran’s Terrorist Sponsors, and that terrorist attacks on Americans by the

IRGC’s Qods Force, Hezbollah, Hamas, PIJ, and JAM were a foreseeable result.

A. SCB Defied Numerous Warnings That Transacting with Fronts for Iran’s
Terrorist Sponsors Facilitated Terrorist Attacks by Hezbollah, Hamas, PIJ,
and JAM

721. SCB’s knowledge was informed by a deafening chorus of U.S. government

warnings that SCB received throughout the relevant period—and that increased in intensity as

SCB’s culpable conduct continued through at least 2015. This chorus reached a crescendo during

203
Adam Luck, US General Claims He Told Standard Chartered Its Client Helped the Taliban—
But the Bank Did Nothing, Daily Mail.com (Dec. 7, 2019),
https://www.dailymail.co.uk/money/news/article-7767683/US-general-told-Standard-Chartered-
client-helped-Taliban-did-nothing.html.

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the U.S. government’s “financial pressure campaign” to warn banks about Iran’s funding of

terrorism between 2006 and 2008.

722. In his memoir of the period, Treasury’s former Assistant Secretary for Terrorist

Financing and Financial Crimes Juan Zarate explained that the “cornerstone” of the financial

pressure campaign was to share information about “Iran’s own conduct” with the private sector.

Because Iran’s economy had become so intertwined with its terrorist activity and other malign

conduct, knowledge of that state of affairs would “spur the private sector to stop doing business

with Iran.” In the U.S. government’s estimation, “No reputable bank would want to be caught

facilitating Iran’s nuclear program or helping it make payments to Hezbollah terrorist cells

around the world.” The fact that Iran often used front companies and layers of entities to

accomplish these goals would only make things worse, as “[t]he more the Iranians tried to hide

their identities or evade sanctions, the more suspect their transactions would appear and the

riskier it would become for banks and other financial institutions to deal with them.”

723. Zarate elaborated on the state of Iran’s intertwined economic and terrorist activity

in 2006 (emphasis added):

[The Iranians] were blending legitimate business transactions with illicit ones by
funneling them through similar conduits. The Iranian regime often tried to hide the nature
of its transactions and the identities of the Iranian government entities involved.
Importantly, the predominant economic player was Iran’s Islamic Revolutionary Guard
Corps (IRGC), the elite military and security unit founded in 1979. The IRGC had gained
more power and influence over time as the protector and exporter of the revolution and
reported directly to the Supreme Leader, Ayatollah Ali Khamenei.

The IRGC—with its vast network—had embedded itself into more industries within Iran,
ultimately building what has been called a veritable business empire. . . . The IRGC is an
economic juggernaut, with responsibilities relating to the development of weapons of
mass destruction, missile systems, and overseas operations. It is deeply involved in the
Iranian nuclear program, and its international arm, the Qods Force (IRGC-QF), is
responsible for providing support for terrorist proxies and exporting the Iranian
Revolution. . . .

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From Treasury’s perspective, this blend of activities created the ultimate vulnerability,
particularly the blurred lines between legitimate industry and support for Iran’s nuclear
program and terrorist groups. The nefarious nature of the activities, tied with the
IRGC’s attempts to hide its hand in many of its economic dealings and operations,
made Iran’s financial activity inherently suspect. . . .

724. The fundamental message of the U.S. government’s financial pressure campaign

could thus be summed up simply: If you did business with Iranian companies in sectors

controlled by the IRGC—even ostensibly legitimate transactions with business entities—terrorist

attacks by IRGC-funded proxies are a foreseeable result. That sharp warning was emphasized

and reiterated repeatedly by the U.S. government throughout the financial pressure campaign.

725. As a European bank with a major presence in Dubai and a history of serving

Iranian clients, SCB was a prime target of the U.S. government’s financial pressure campaign,

during which SCB received warnings through a variety of means, including public statements by

U.S. officials and regulatory agencies and private outreach directly to SCB.

726. On information and belief, the private warnings that SCB received were even

more detailed and urgent than the public ones, and included direct warnings to SCB, including

the NY Branch and SCB Dubai, that transacting with Iranian banks, Iranian fronts, or companies

in Iran’s oil sector would facilitate IRGC-sponsored acts of terrorism committed by Hezbollah,

Hamas, and Iraqi Shiite terrorist groups. Although Plaintiffs expect discovery to reveal more

about these private warnings, Zarate’s memoir explains the form they took:

Treasury—led by [Under Secretary for Terrorism and Financial Intelligence] Levey—

would launch the financial pressure campaign . . . in large part by demonstrating to CEOs
and compliance officers around the world that the risk of doing business with Iran was
too high. Iranian obfuscation was too ubiquitous to be handled through normal
compliance efforts. . . . It was better to stop doing business with Iran altogether than to
risk facilitating Iran’s support for terror or its development of a nuclear program. . . .

Levey began his meetings with bank officials around the world with a briefing on Iranian
illicit activity and how it coursed through the international financial system. He would
take this argument from board room to board room, often meeting with bank CEOs

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before and after meeting with foreign government counterparts. Steve Hadley called it the
‘whisper campaign,’ because the mission entailed meeting quietly with bank executives
to explain the risks of doing business with Iran. At the heart of these meetings was a
presentation on what Iran was doing with front companies and layered financial
transactions to facilitate activity that was considered either illegal or risky. . . .

Levey would meet over one hundred times with bank officials around the world. At each
stop, he made the case that doing business with Iran was too risky—because the banks
could not be sure they knew who they were doing business with. . . . For each country
and institution, the Treasury team would provide specific tidbits of data about Iranian
transactions through a bank. The briefing packets would have general information about
the Iranian economy, structure, and financial system. The packets would contain
information about how the Iranian government and the IRGC used front companies and
obfuscation to finance and acquire what they needed for their military and nuclear
apparatus. The briefing would conclude with an explanation of what was happening in
the bank and how the Iranians were hiding their activity. This would inevitably be a
surprise to any bank CEO, though some banks would be caught later trying to hide
transactions with Iran.

727. Treasury Secretary Paulson increased the prominence of the warnings by

emphasizing them in his own private meetings with bank executives:

The former Wall Street executive could convincingly make a case to fellow bankers
about the danger of doing business with Iran. When Paulson talked, financial leaders
around the world listened. . . . [Paulson] made a point of putting the issue of Iran’s
suspect financial activity on the agenda of his meetings with foreign government officials
and banking friends with whom he met. . . . One would expect such talk from the director
of the CIA or FBI, but to hear this coming from the former CEO of Goldman Sachs and
the treasury secretary caused officials to take notice. The treasury secretary was speaking
a new language of national security that resonated with the CEOs of the world’s biggest
banks and businesses.

728. Publicly available warnings were also numerous, even well before the financial

pressure campaign began. Decades of U.S. government statements confirmed the tight nexus

between transacting with Iranian fronts and IRGC-sponsored acts of international terrorism

targeting the United States. In particular, decades of public U.S. government findings, reports,

statements, and warnings (often, all four in one item) alerted SCB that: (1) the Government of

Iran was a prolific funder and supporter of terrorist attacks against Americans; (2) Iran’s

Terrorist Sponsors facilitated terrorist attacks by fronts and proxies, including the Qods Force,

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Hezbollah, Hamas, PIJ, and JAM; (3) the Government of Iran systematically used a large

proportion of its profits from ostensibly ordinary business transactions, especially in its oil

sector, to fund those terrorist attacks; (4) the Government of Iran routinely used front companies

and layered financial transactions to do so while evading sanctions; and (5) by at least 2006, the

IRGC’s control and influence over key industries meant that any significant transaction with an

Iranian front company, especially in the oil sector, would foreseeably fund those terrorist attacks.

The U.S. government’s voluminous warnings made explicit what its comprehensive sanctions

implied: No country in the world had a major economy as saturated with terrorist finance as Iran.

729. From 1990 through 2015, such U.S. government findings, reports, statements, and

warnings included, but were not limited to:

a. State, April 1990: “In its various forms -- direct involvement, instigation and
encouragement, support to terrorist groups through provision of safehaven, financial
resources, arms, technical expertise, and documentation -- state sponsorship makes a
significant contribution to international terrorism. … Support in its various forms
enhances the capabilities of a … radical Shia groups throughout Western Europe, the
Middle East, and Africa; … Iran was the most active state sponsor … The United States
… designat[ed] … [Iran] … as [a] state supporter[] of terrorism … pursuant to Section 6
(j) of the Export Administration Act of 1979, which imposes certain trading restrictions
on countries determined by the Secretary of State to have repeatedly provided support
for acts of international terrorism.”

b. The President, 1995: “From the beginning of our administration, we have moved to
counter Iran’s support of international terrorism and in particular its backing for violent
opponents of peace in the Middle East. … Our policy has helped to make Iran pay a
price for its actions. The nation has effectively been cut off from receiving credit from
international financial institutions. … Even as prospects for the peace in the Middle East
have grown, Iran has broadened its role as an inspiration and paymaster to terrorists. … I
am convinced that instituting a trade embargo with Iran is the most effective way our
Nation can help to curb that nation’s drive to acquire devastating weapons and its
continued support for terrorism … It would be wrong to stand pat in the face of
overwhelming evidence of Tehran’s support for terrorists that would threaten the dawn
of peace.”

c. State, April 1998: “The Secretary of State has designated [the Iranian] government[] as
[a] state sponsor[] of terrorism … by providing arms, training, safehaven, diplomatic
facilities, financial backing, logistic and/or other support to terrorists. The US policy of

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bringing maximum pressure to bear on state sponsors of terrorism and encouraging other
countries to do likewise … [depends upon] [a] broad range of bilateral and multilateral
sanctions [that] serves to discourage state sponsors of terrorism from continuing their
support for international acts of terrorism, but continued pressure is essential. ... Iran
remains the most active state sponsor of terrorism … Iran continues both to provide
significant support to terrorist organizations.”

d. White House, National Strategy for Combating Terrorism, September 2006: “State
sponsors are a critical resource for our terrorist enemies, often providing funds,
weapons, training, safe passage, and sanctuary. Some of these countries have developed
or have the capability to develop WMD and other destabilizing technologies that could
fall into the hands of terrorists. The United States currently designates [Iran as a] state
sponsor[] of terrorism … We will maintain sanctions against [Iran] and promote [the
Iranian regime’s] international isolation until they end their support for terrorists …. To
further isolate these regimes and persuade other states not to sponsor terror, we will use
a range of tools and efforts to delegitimate terrorism as an instrument of statecraft. Any
act of international terrorism, whether committed by a state or individual, is
reprehensible, a threat to international peace and security, and should be unequivocally
and uniformly rejected. Similarly, states that harbor and assist terrorists are as guilty as
the terrorists, and they will be held to account. Iran remains the most active state sponsor
of international terrorism. Through its Islamic Revolutionary Guard Corps …, the
regime in Tehran plans terrorist operations and supports groups such as Lebanese
Hizballah, Hamas, and Palestine Islamic Jihad (PIJ)…. Most troubling is the potential
WMD-terrorism nexus that emanates from Tehran. … We will continue to stand with
the people of Iran … against the regime[] that oppress[es] them at home and sponsor[s]
terror abroad.”

e. Treasury (OFAC), September 2006: “Bank Saderat facilitates Iran’s transfer of hundreds
of millions of dollars to Hizballah and other terrorist organizations each year. We will
no longer allow a bank like Saderat to do business in the American financial system,
even indirectly, said Stuart Levey, Under Secretary for Terrorism and Financial
Intelligence (TFI). Bank Saderat is one of the largest Iranian-owned banks, with roughly
3400 branch offices. The bank is used by the Government of Iran to transfer money to
terrorist organizations, including Hizballah, Hamas, the Popular Front for the Liberation
of Palestine-General Command and Palestinian Islamic Jihad. A notable example of this
is a Hizballah-controlled organization that has received $50 million directly from Iran
through Bank Saderat since 2001. … By prohibiting U-turn and all other transactions
with Bank Saderat, the bank is denied all direct and indirect access to the U.S. financial
system.”

f. Treasury (Levey), March 2007: “Iran’s Revolutionary Guard Corps, or IRGC, is used by
the regime to provide a `train and equip program’ for terrorist organizations like
Hizballah, as well as to pursue other military objectives of the regime. The IRGC’s
control and influence in the Iranian economy is growing exponentially under the regime
of Ahmadinejad. More and more IRGC-associated companies are being awarded
important government contracts. An IRGC company, for example, took over

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management of the airport and runways in Tehran, while another company won the
contract to build the Tehran metro. When corporations do business with IRGC
companies, they are doing business with organizations that are providing direct support
to terrorism. . . . Iran sends hundreds of millions of dollars each year to terrorist groups
like Hizballah and other organizations. When a country has a nine-digit line item in its
budget for support to terrorist organizations and is actively seeking a WMD program,
there is no way to know how the regime will use its revenues. Corporations are in the
process of reconsidering their investments in Iran because they do not want revenue
generated from their projects diverted towards . . . terrorism.”

g. Treasury (Paulson), June 2007: “It is well known that Iran is pursuing nuclear weapons
in violation of international agreements and channeling hundreds of millions of dollars
to terrorist groups. . . . We explained how Iran uses front companies and other
mechanisms that make it difficult, if not impossible, for businesses dealing with Iran to
‘know their customer’ or counterparty. We also explained how the Iranian regime uses
its state-owned banks to pursue its missile procurement and nuclear programs, as well as
fund terrorism. Repeatedly, state-owned Iranian banks, including the Central Bank of
Iran, ask other financial institutions to remove their names from global transactions. . . .
To those banks that have decided to stop dollar-based business, but continue to transact
Iran’s business in other currencies, I would say that the risk of transacting Iran’s
business is present in every currency. . . . The IRGC, a paramilitary arm of the regime,
has been directly involved in the planning and support of terrorist acts, as well as
funding and training other terrorist groups to pursue the military objectives of the
regime. . . . The IRGC is so deeply entrenched in Iran’s economy and commercial
enterprises, it is increasingly likely that if you are doing business with Iran, you are
somehow doing business with the IRGC.”

h. Treasury (OFAC), October 2007: “The Financial Action Task Force, the world’s
premier standard-setting body for countering terrorist financing and money laundering,
recently highlighted the threat posed by Iran to the international financial system. FATF
called on its members to advise institutions dealing with Iran to seriously weigh the risks
resulting from Iran’s failure to comply with international standards. … Bank Melli also
provides banking services to the IRGC and the Qods Force. … When handling financial
transactions on behalf of the IRGC, Bank Melli has employed deceptive banking
practices to obscure its involvement from the international banking system. For
example, Bank Melli has requested that its name be removed from financial transactions.
… The IRGC has significant political and economic power in Iran, with ties to
companies controlling billions of dollars in business and construction and a growing
presence in Iran’s financial and commercial sectors. Through its companies, the IRGC is
involved in a diverse array of activities, including petroleum production and major
construction projects across the country. In 2006, Khatam al-Anbiya secured deals worth
at least $7 billion in the oil, gas, and transportation sectors, among others.… Bank
Saderat, which has approximately 3200 branch offices, has been used by the
Government of Iran to channel funds to terrorist organizations, including Hizballah and
EU-designated terrorist groups Hamas, PFLP-GC, and Palestinian Islamic Jihad. For
example, from 2001 to 2006, Bank Saderat transferred $50 million from the Central

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Bank of Iran through its subsidiary in London to its branch in Beirut for the benefit of
Hizballah fronts in Lebanon that support acts of violence. Hizballah has used Bank
Saderat to send money to other terrorist organizations, including millions of dollars on
occasion, to support the activities of Hamas. As of early 2005, Hamas had substantial
assets deposited in Bank Saderat, and, in the past year, Bank Saderat has transferred
several million dollars to Hamas.”

i. Treasury (Paulson), October 2007: “Iran also funnels hundreds of millions of dollars
each year through the international financial system to terrorists. . . . We are also
designating the Islamic Revolutionary Guard Corps for proliferation activities and its
Qods Force for providing material support to the Taliban and other terrorist
organizations. The IRGC is so deeply entrenched in Iran’s economy and commercial
enterprises, it is increasingly likely that if you are doing business with Iran, you are
doing business with the IRGC. We call on responsible banks and companies around the
world to terminate any business with Bank Melli, Bank Mellat, Bank Saderat, and all
companies and entities of the IRGC. As awareness of Iran’s deceptive behavior has
grown, many banks around the world have decided as a matter of prudence and integrity
that Iran’s business is simply not worth the risk. It is plain and simple: reputable
institutions do not want to be bankers to this dangerous regime.”

j. Treasury (FinCEN), October 2007: “The Financial Crimes Enforcement Network is issuing
this advisory to U.S. financial institutions so that they may guard against threats of illicit
Iranian activity related to money laundering, terrorist financing and weapons of mass
destruction proliferation financing. . . . [F]inancial institutions should be particularly
aware that there may be an increased effort by Iranian entities to circumvent
international sanctions and related financial community scrutiny through the use of
deceptive practices involving shell companies and other intermediaries or requests that
identifying information be removed from transactions. Such efforts may originate in Iran
or Iranian free trade zones subject to separate regulatory and supervisory controls,
including Kish Island. Such efforts may also originate wholly outside of Iran at the
request of Iranian-controlled entities.”

k. Treasury (FinCEN), March 2008: “The Financial Crimes Enforcement Network (FinCEN)
is issuing this advisory to supplement information previously provided on serious
deficiencies present in the anti-money laundering systems of the Islamic Republic of
Iran. . . . Iran’s AML/CFT deficiencies are exacerbated by the Government of Iran’s
continued attempts to conduct prohibited proliferation related activity and terrorist
financing.”

l. Treasury (Glaser), April 2008: “[The] Threat of Iran’s Support of Terrorism … [includes]
its provision of financial and material support to terrorist groups. Iran has long been a
state sponsor of terrorism and continues to support an unparalleled range of terrorist
activities. For example, Tehran arms, funds, and advises Hizballah, an organization that
has killed more Americans than any terrorist network except for al-Qa’ida, and does so
via the Qods Force, a branch of the Islamic Revolutionary Guard Corps. In addition, Iran
provides extensive support to Palestinian terrorist organizations, including the
Palestinian Islamic Jihad (PIJ) and Hamas. In the case of PIJ, Iran’s financial support

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has been contingent upon the terrorist group carrying out attacks against Israel. And we
are all familiar with Iran’s funding, training, and equipping of select Shi’a extremist
groups in Iraq, further destabilizing that country and resulting in deaths of Americans.
… Iran utilizes the international financial system as a vehicle to fund these terrorist
organizations. As Under Secretary Levey has previously testified, the Iranian regime
operates as the central banker of terrorism, spending hundreds of millions of dollars each
year to fund terrorism. … Iran uses its global financial ties to pursue [] the threat of
terrorism … through an array of deceptive practices specifically designed to avoid
suspicion and evade detection from the international financial community. Iran uses its
state-owned banks for … for financing terrorism. … [One] method Iranian banks use to
evade controls is to ask other financial institutions to remove their names when
processing transactions through the international financial system. This practice is
intended to elude the controls put in place by responsible financial institutions and has
the effect of potentially involving those institution [sic] in transactions they would never
engage in if they knew who, or what, was really involved. This practice allows Iran’s
banks to remain undetected as they move money through the international financial
system to pay for the Iranian regime’s … terrorist-related activities.”

m. Treasury (OFAC), November 2008: “Iran’s access to the international financial system
enables the Iranian regime to facilitate its support for terrorism and proliferation. The
Iranian regime disguises its involvement in these illicit activities through the use of a
wide array of deceptive techniques, specifically designed to avoid suspicion and evade
detection by responsible financial institutions and companies. Iran also is finding ways
to adapt to existing sanctions, including by turning to non-designated Iranian banks to
handle illicit transactions. … Iran is the world’s most active state sponsor of terror. …
Elements of Iran’s Islamic Revolutionary Guard Corps (IRGC) have been directly
involved in the planning and support of terrorist acts throughout the world, including in
the Middle East, Europe and Central Asia, and Latin America. … In a number of cases,
Iran has used its state-owned banks to channel funds to terrorist organizations. … It has
been a standard practice for Iranian financial institutions to conceal their identity to
evade detection when conducting transactions. … Iran hides behind front companies and
intermediaries to engage in ostensibly legitimate financial and commercial transactions
that are actually related to its nuclear or missile programs.”

n. Treasury (FinCEN), July 2009: “On June 26, 2009 the Financial Action Task Force
(FATF) issued a statement concerning these jurisdictions that reiterates previous FATF
concerns and calls for action on the part of its members. The FATF statement is copied
below and can be found on the FATF website. . . . ‘The FATF remains particularly
concerned about Iran’s failure to address the risk of terrorist financing and the serious
threat this poses to the integrity of the international financial system. . . . The FATF
reaffirms its call on members and urges all jurisdictions to advise their financial
institutions to give special attention to business relationships and transactions with Iran,
including Iranian companies and financial institutions.’”

o. Treasury (Levey), October 2009: “[T]he international private sector has amplified the
impact of [U.S., U.N., and E.U.] government actions, as banks and companies around

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the world have come to understand that, if they are dealing with Iran, it is nearly
impossible to protect themselves against becoming entangled in [the IRGC]’s illicit
conduct … [because] [IRGC] companies, some of which have been designated by the
United States and the UN Security Council …, operate under names that obscure their
IRGC affiliation, so many unwitting non-Iranians are in fact doing business with the
IRGC. In the name of privatization, the IRGC has taken over broad swaths of the Iranian
economy. Former IRGC members in Iranian ministries have directed millions of dollars
in government contracts to the IRGC for myriad projects …There is broad
acknowledgment that the Iranian government engages in a range of deceptive financial
and commercial conduct in order to obscure … and facilitate its support for terrorism.
International understanding of these practices – underscored by the UN Security Council
resolutions on Iran and six warnings issued by the [FATF] about the risks Iran poses to
the financial system – has been brought about in part by our efforts to share information
about Iran’s deception with governments and the private sector around the world. These
deceptive practices taint all Iranian business because they make it difficult to determine
whether any Iranian transaction is licit. Iranian banks request that their names be
removed from transactions so that their involvement cannot be detected; the government
uses front[s] … and intermediaries to engage in ostensibly innocent commercial
business to obtain prohibited … goods … To a greater extent than ever, private
companies across industries are now alert to these kinds of risks. Banks worldwide have
been repeatedly warned by regulatory and standard-setting bodies to regard Iranian
transactions with caution. Traders and shippers know that transactions with innocent-
sounding Iranian counterparts can expose them to risk – both reputational and legal.
Energy companies have put Iranian investments on indefinite hold, cautious of the
political risk of investing too heavily in Iran. And exporters of sensitive and dual-use
technologies know that supplying Iran can lead to severe sanctions and even
prosecution. Across the board, then, transactions with Iran are already handled
differently than transactions with any other country … engendering either heightened
suspicion or outright refusal to engage in them.”

p. Treasury (FinCEN), October 2009: “On October 16, 2009, the Financial Action Task
Force (“FATF”) issued a statement concerning these jurisdictions that explains its
concerns regarding each jurisdiction and calls for action on the part of its members. The
FATF statement is copied below and can be found on the FATF website. . . . ‘The FATF
reaffirms its call on members and urges all jurisdictions to advise their financial
institutions to give special attention to business relationships and transactions with Iran,
including Iranian companies and financial institutions.’”

q. Treasury (Levey), June 2010: “Because “[t]he IRGC plays a key role in Iran’s …
support for terrorism and [the IRGC] has taken over broad portions of the Iranian
economy, … [n]o IRGC entity should have any place in the world’s legitimate financial
system.”

r. Treasury (FinCEN), March 2011: “On February 25, 2011, the Financial Action Task
Force (“FATF”) issued a statement concerning these jurisdictions that explains its
concerns regarding each jurisdiction and calls for action on the part of its members. The

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FATF statement is copied below and can be found on the FATF website. . . . ‘The FATF
reaffirms its call on members and urges all jurisdictions to advise their financial
institutions to give special attention to business relationships and transactions with Iran,
including Iranian companies and financial institutions.’”

s. Treasury (OFAC), February 2012: “What activities by foreign financial institutions can
subject them to CISADA sanctions? As described in the Iranian Financial Sanctions
Regulations, the sanctionable activities of a foreign financial institution are: Facilitating
the efforts of the Government of Iran (GOI) to acquire or develop Weapons of Mass
Destruction (WMD) or delivery systems for WMD or to provide support for terrorist
organizations or acts of international terrorism; Facilitating the activities of a person
subject to financial sanctions pursuant to UNSCRs 1737, 1747, 1803, or 1929, or any
other Security Council resolution that imposes sanctions with respect to Iran; Engaging
in money laundering, or facilitating efforts by the Central Bank of Iran or any other
Iranian financial institution, to carry out either of the facilitating activities described
above; or Facilitating a significant transaction or transactions or providing significant
financial services for: (i) the Islamic Revolutionary Guard Corps or any of its agents or
affiliates whose property and interests in property are blocked pursuant to the
International Emergency Economic Powers Act (IEEPA), or (ii) a financial institution
whose property and interests in property are blocked pursuant to IEEPA in connection
with Iran’s proliferation of WMD, Iran’s proliferation of delivery systems for WMD, or
Iran’s support for international terrorism.”

t. State, April 2014: “In 2013, Iran’s state sponsorship of terrorism worldwide remained
undiminished through the Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF)
… and Tehran’s ally Hizballah, which remained a significant threat to the stability of
Lebanon and the broader region. The U.S. government continued efforts to counter
Iranian and proxy support for terrorist operations via sanctions and other legal tools. The
United States also welcomed the EU’s July 2013 designation of Hizballah’s military
wing as a terrorist organization. … Designated as a State Sponsor of Terrorism in 1984,
Iran continued its terrorist-related activity, including support for Palestinian terrorist
groups in Gaza, and for Hizballah. … Iran used the [Qods Force] and its regional proxy
groups to implement foreign policy goals, provide cover for intelligence operations, and
create instability in the Middle East. The IRGC-QF is the regime’s primary mechanism
for cultivating and supporting terrorists abroad.”

u. Representative Ted Poe (Chairman of the House Subcommittee on Terrorism, Non-

Proliferation and Trade), October 2015: “[The] Islamic Revolutionary Guard Corps
(IRGC) has funded, planned and executed terrorist attacks against the United States …
for decades … Treasury … has repeatedly cited the IRGC’s support for terrorism and
destabilizing activity throughout the Middle East and beyond. …There is also growing
concern that the IRGC is engaging in financial evasion practices that erode the efficacy
of the sanctions currently in place. Treasury currently sanctions companies that are 50%
owned or controlled by the Iranian government or in which Iran wields a controlling
interest. However, through control of a company’s board of directors, the IRGC can
exercise the same level of power over a company without meeting Treasury’s

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designation trigger. By exploiting this … legal loophole, the IRGC has managed to
become so deeply entrenched in the Iranian economy to the point that, as former
Treasury Secretary Henry Paulson pointed out, ‘it is increasingly likely that if you are
doing business with Iran, you are somehow doing business with the IRGC.’”

730. On November 25, 2011, Treasury took official action to determine that Iran was a

Jurisdiction of Primary Money Laundering Concern. This determination summarized the

message that had been delivered to banks throughout the financial pressure campaign and

represented the U.S. government’s formal conclusion that it was impossible for any bank,

including SCB, to conduct any Iran-related financial transaction without running a substantial

risk of financing IRGC-sponsored acts of terrorism committed by Hezbollah, Hamas, or other

proxies of Iran’s Terrorist Sponsors. Among other things, Treasury’s finding alerted SCB that

(emphases added):

a. “In recent years, many international financial institutions have severed ties with Iranian
banks and entities because of a growing body of public information about their illicit and
deceptive conduct designed to facilitate the Iranian government’s support for terrorism
…. This illicit conduct by Iranian banks and companies has been highlighted in a series
of … UN Security Council … resolutions related to Iranian proliferation sensitive
activities. [FATF] has also warned publicly of the risks that Iran’s deficiencies in
countering money laundering and, particularly, terrorism finance . . . . FinCEN has reason
to believe that Iran directly supports terrorism … and uses deceptive financial practices to
facilitate illicit conduct and evade sanctions. All of these factors, when taken together,
make the international financial system increasingly vulnerable to the risk that otherwise
responsible financial institutions will unwittingly participate in Iran’s illicit activities.”

b. “Support for Terrorism: . . . Iran remains the most active of the listed state sponsors
of terrorism, routinely providing substantial resources and guidance to multiple
terrorist organizations. Iran has provided extensive funding, training, and weaponry to
Palestinian terrorist groups, including Hamas and the Palestinian Islamic Jihad
(“PIJ”). In fact, Hamas, PIJ, and Hizballah have maintained offices in Tehran to help
coordinate Iranian financing and training of these groups.”

“Iran’s Islamic Revolutionary Guard Corps (“IRGC”) was founded in the aftermath of the
1979 Islamic Revolution to defend the government against internal and external threats.
Since then, it has expanded far beyond its original mandate and evolved into a social,
military, political, and economic force with strong influence on Iran’s power structure. In
addition, elements of the IRGC have been directly involved in the planning and support
of terrorist acts throughout the Middle East region.”

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“In particular, Iran has used the IRGC-Qods Force (‘Qods Force’) to cultivate and
support terrorists and militant groups abroad. The Qods Force reportedly has been active
in the Levant, where it has a long history of supporting Hizballah’s … terrorist
activities, and provides Hizballah with as much as $200 million in funding per year. …
[O]n October 11, 2011, the Department of Justice charged two individuals for their ...
participation in a plot directed by the Qods Force to murder the Saudi ambassador to the
United States with explosives while the Ambassador was in the United States. …”

“Finally, Iran is known to have used state-owned banks to facilitate terrorist financing.
In 2007, the Treasury designated Bank Saderat under E.O. 13224 for its [10] financial
support of terrorist organizations, noting that from 2001 to 2006 Bank Saderat
transferred $50 million from the Central Bank of Iran through its subsidiary in
London to its branch in Beirut for the benefit of Hizballah fronts in Lebanon that
support acts of violence.”

c. “As a result of the strengthened U.S. sanctions and similar measures taken by the [U.N.]
and other members of the global community, Iran now faces significant barriers to
conducting international transactions. In response, Iran has used deceptive financial
practices to disguise both the nature of transactions and its involvement in them in an
effort to circumvent sanctions. This conduct puts any financial institution involved with
Iranian entities at risk of [] facilitating transactions related to terrorism …”.

d. “The IRGC: The IRGC, which was designated by the Department of State as a primary
proliferator under E.O. 13382 in October 2007, owns and/or controls multiple
commercial entities across a wide range of sectors within the Iranian economy. For
example, the IRGC established Khatam al-Anbiya, the largest major Iranian
construction conglomerate, to generate income and fund IRGC operations while
presenting the company as a legitimate company working on civilian projects.”

e. “The IRGC has continued to expand its control over commercial enterprises within
Iran. … [T]he IRGC and the IRGC-QF engage in seemingly legitimate activities that ...
support terrorist groups such as Hizballah [and] Hamas …”.

f. “Iran’s serious deficiencies with respect to anti-money laundering/countering the

financing of terrorism (‘AML/CFT’) controls has long been highlighted by numerous
international bodies and government agencies. . . .”

731. On November 28, 2011, Treasury published its proposed special measure under

Section 311 of the USA PATRIOT Act, in which it found that a complete U.S. prohibition on all

Iranian banks’ correspondent account access to the U.S. financial system was necessary to

protect the United States from IRGC-sponsored acts of terrorism, including attacks committed by

Hezbollah, Hamas, PIJ, and other IRGC proxies:

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a. “The Effect of the Proposed Action on United States National Security …[.] The
exclusion from the U.S. financial system of jurisdictions that serve as conduits for … the
financing of terrorism … enhances U.S. national security by making it more difficult for
terrorists … to access the substantial resources of the U.S. financial system. To the extent
that this action serves as an additional tool in preventing Iran from accessing the U.S.
financial system, the proposed action supports and upholds U.S. national security …
goals. More generally, the imposition of the fifth special measure would complement the
U.S. Government’s worldwide efforts to expose and disrupt international … terrorist
financing.”

b. “The fifth special measure sought to be imposed by this rulemaking would prohibit
covered financial institutions from opening and maintaining correspondent accounts for,
or on behalf of, Iranian banking institutions. As a corollary to this measure, covered
financial institutions also would be required to take reasonable steps to apply special due
diligence, as set forth below, to all of their correspondent accounts to help ensure that no
such account is being used indirectly to provide services to an Iranian banking institution.
FinCEN does not expect the burden associated with these requirements to be significant
given that U.S. financial institutions have long been subject to sanctions regulations
prohibiting the provision of correspondent account services for banking institutions in
Iran.”

732. Moreover, decades of reports published and re-published throughout the United

States, Europe, and the Middle East by media outlets, scholars, NGOs, and IRGC victims

themselves confirmed the tight nexus between IRGC-facing sanctions violations and IRGC-

sponsored acts of international terrorism targeting the United States. Such reports included, but

were not limited to (all emphases added):

a. Cleveland Plain Dealer, May 23, 1996: “Secretary of State Warren Christopher is
publicly flaying U.S. allies for not doing enough to isolate Tehran. … In preparation for
[a] … meeting of the ‘Group of Seven’ …, Christopher … urged Congress to tighten
economic sanctions against Iran, charging Tehran’ s ayatollahs are behind the terrorist
attacks in the Middle East. ‘The United States believes Iran will change its behavior
when the world makes it pay a sufficiently high … economic price,’ Christopher said.”

b. Independent, October 26, 2007: “Washington justified the new sanctions by accusing the
elite Quds division of the Revolutionary Guard Corps of the devastating campaign of
roadside bombs by Shia militias against its troops in Iraq [and] supporting [JAM] in Iraq
and [other] terrorist[] [groups] in … Lebanon and the Palestinian territories, and denying
the existence of a fellow member of the United Nations, threatening to wipe Israel off the
map. … The sweeping new US sanctions affect Iranian banks, companies, officials and
government agencies which the White House says … support[ed] acts of terrorism
abroad. The sanctions specifically targeted [IRGC] finances and eight affiliated

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companies. They also named five [IRGC] officials as well as the Quds Force …. The US
hopes to cripple Iranian trade by isolating the banks from the world financial system.”

c. Prof. Raymond Tanter (University of Michigan), December 6, 2007: “I strongly concur in

the sanctioning for proliferation activities of IRGC-affiliated entities and individuals as
derivatives of the IRGC … The raison d’etre of the Islamic Revolutionary Guards Corps
is to … export the regime’s revolutionary ideology via acts of terrorism … [through] the
Islamic Revolutionary Guards Corps.”

d. Danny Eisen (Canadian Coalition Against Terror), February 10, 2010: “[T]he IRGC is
anything but a normal military body or state entity. The IRGC is hardly a conventional
branch of the military. … [T]he IRGC’s primary constitutional duty is not to protect Iran
from conventional military threats but to ‘protect the revolution and its ideals.’ This
amorphous and borderless mandate allows the IRGC to take on any … terrorist role []
that is required to ensure the continued export of Khomeini’s Islamic revolution. Given
its unconventional mandate and its extraordinary level of operational independence from
government hierarchy, the Guards are too autonomous to be []considered a normal state
agency. It therefore can and must be held accountable for its own actions like any other
terrorist body that commits acts of terrorism on its own initiative … [and there was no]
doubt as to the value of sanctioning the IRGC [to prevent acts of terrorism].”

733. SCB also knew about U.N. and E.U. sanctions targeting the IRGC, and knew that

such sanctions were designed to, and did, prevent IRGC-sponsored violence by impeding the

IRGC’s ability to develop, sell, and deploy sophisticated weapons like missiles, rockets, drones,

and next-generation RPGs. For example, the United Nations, European Union and their member

states sanctioned the IRGC and KAA from 2007 through 2024. Examples of reports of such

sanctions included, but were not limited to:

a. U.K. House of Commons, October 13, 2010: “[O]n 24 March 2007 the Security Council
broadened the sanctions. It imposed an embargo on all of Iranian arms exports and an
asset freeze and travel ban on further people it considered to be involved in the nuclear
programme, including top members of the [IRGC], listed in an annex to the Resolution.
… On 9 June 2010, the UN Security Council passed Resolution 1929 imposing a fourth
round of sanctions on Iran. … The Resolution decides that: … • All states shall prevent
the supply, sale or transfer to Iran of battle tanks, armoured combat vehicles, large calibre
artillery systems, combat aircraft, attack helicopters, warships, missiles or missile
systems. • States will take all necessary measures to prevent the transfer to Iran of
technology or technical assistance related to ballistic missiles capable of delivering
nuclear weapons. • Steps will be taken to block Iran’s use of the international financial
system, particularly its banks when they may be used to fund proliferation and nuclear
activities. …. At least 15 of the companies and groups named in the new sanctions list are

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linked to the [IRGC]. Most of the remainder are associated with the nuclear and ballistic
missile programmes, which are directly controlled by the Revolutionary Guard. … EU
sanctions[:] Some UN sanctions against Iran are partly implemented through EU law.
Like the US, however, the EU went further than the latest Security Council resolution
demanded. … On 26 July [2010], the new [E.U. Iran-related sanctions] measures were
announced. They consisted of: … [inter alia] restrictions in the financial sector, including
additional asset freezes against banks and restrictions on banking and insurance …[;]
trade restrictions, including a broad-ranging ban on dual use goods … [;] [and] new visa
bans and asset freezes, especially on the [IRGC].”

b. U.N. Security Council, June 4, 2012: “[A] number of key [IRGC] figures have been
identified by the Security Council as involved in … missile programmes and are subject
to asset freeze[s] … Activities related to the [IRGC] are also made subject to vigilance
exercised by States and their nationals, persons and firms if they have information that
provides reasonable grounds to believe that such business could contribute to the [Iranian
regime]’s proliferation-sensitive … activities … Such vigilance over business activities
extends to entities and individuals acting on behalf of the [IRGC] or at its direction, and
entities owned or controlled by it, including through illicit means.”

c. U.K. House of Commons, December 8, 2020: “Although no part of the IRGC has been
proscribed under this Act, its members and activities have more broadly been the targets
of UK and EU sanctions. Qasem Soleimani was designated under the terrorism and
terrorist financing regime and, as the Minister for the Middle East and North Africa noted
in correspondence to us, there are more than 200 sanctions in place through the EU
targeting Iran’s ballistic missiles and nuclear activities, many of which cover the
activities of the IRGC.”

734. As contemporaneous reports by the government, media, terrorism scholars, and

others warned, SCB knew that the IRGC’s use of front companies and layered transactions, and

its pervasive role in major sectors of the Iranian economy, made it impossible to determine with

any confidence that an Iranian company in one of those sectors was not funding the IRGC’s

terrorist activities. Under these circumstances, SCB knew that customer due diligence focused on

the company’s nominal owners and formal corporate structure would provide no more than a

pretext of deniability. It could not provide any reasonable assurance that the company’s

transactions were insulated from terrorism.

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735. SCB knew that, given the IRGC’s monopolization of large sectors of Iran’s

economy, it was highly likely that any U.S. dollar services it provided to large Iranian businesses

operating in those sectors would flow resources through to the IRGC and its terrorist proxies.

736. SCB knew that if designated terrorist groups, like Hamas and Hezbollah, received

money because of SCB’s conduct, it was a near certainty that those groups would kill and injure

innocent victims, as happened here against Plaintiffs.

737. Given these facts, SCB knew that its culpable conduct on behalf of its IRGC

customers risked violent, real-world consequences. On December 31, 2017, for example, SCB

admitted that “terrorist financing” and “sanctions compliance breaches” comprised “[f]inancial

crime” that SCB knew “harm[ed] communities.”

B. SCB Knew That Its Assistance to the Iranian Petrochemical Company

Facilitated Terrorist Attacks by Hezbollah, Hamas, PIJ, and JAM

738. Specifically with respect to the Iranian Petrochemical Company (a/k/a Caspian

Petrochemical FZE), SCB knew that its culpable conduct from at least 2007 through at least June

2012—processing millions of dollars in payments while helping the company evade

counterterrorism controls—provided direct and indirect assistance to the Qods Force, Hezbollah,

Hamas, PIJ, and JAM.

739. In addition to the extensive warnings about Iran and the IRGC’s funding of

terrorism discussed above, SCB had specific knowledge that the Iranian Petrochemical Company

was generating money to fund terrorist attacks by the IRGC and its proxies. When SCB Dubai

serviced the Iranian Petrochemical Company, SCB knew, among other things: (1) the company

was beneficially owned by the Government of Iran; (2) the company had substantial operations

in Iran’s oil and gas sector, which had been monopolized by the IRGC and SLO to fund terrorist

attacks; (3) the company was operating as a front with an Iranian individual as its nominal

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owner; and (4) the individual used a name associated with the SLO and the Supreme Leader’s

calls for terrorist violence.

1. SCB Knew That a Petrochemical Company Owned by the Iranian

Government Would Fund Terrorism

740. The fact that the Iranian Petrochemical Company was a government-owned oil

and gas company—a fact SCB recorded in its customer due diligence files as of 2007—was all

SCB needed to know in order to see clearly that it was a conduit for funding terrorist attacks.

This was made inescapable to SCB in a series of events and warnings over many years relating

to Iran’s oil and gas industry, of which SCB was aware. These events and warnings included: (1)

Iran’s own statements about its policy to fund terrorism with oil and gas revenue and its own

well-publicized actions demonstrating it was doing so; (2) public reports of how the Iranian

government was enshrining its terrorist-financing policy in the structure of the institutions that

controlled its oil and gas industry; and (3) numerous warnings from the U.S. government and

others specifically singling out Iran’s oil and gas industry as a primary source of its terrorist

financing.

i. Iran’s Own Statements and Actions

741. Although Iran’s statements of support for terrorism were frequent (and are

discussed elsewhere), Iranian leaders publicly explained with great specificity how Iran’s most

valuable economic resources would be used to finance the Ayatollah’s most steadfast objective

to “export the Islamic Revolution” through IRGC-sponsored acts of terrorism committed by

IRGC proxies. From those statements, SCB knew that Ayatollah Khamenei and the IRGC

followed a pattern and practice of earmarking a certain percentage of all Iran’s oil revenue for

redistribution to IRGC proxies, including Hezbollah, Hamas, and JAM. From 2000 through

2020, Ayatollah Khamenei regularly publicly touted his and the IRGC’s effective monopoly over

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Iran’s oil and gas sector—and attendant lucrative export base—and that this control comprised

one of the Ayatollah’s and IRGC’s greatest strategic weapons. In this context, Iran’s Terrorist

Sponsors, and Iranian officials who had to toe their line, always treated all Iran-based oil

revenues uniquely amongst all Iranian industry sectors by specifically earmarking a fixed

percentage of revenue from every oil-related transaction in Iran to directly flow to Hezbollah,

Hamas, and the IRGC’s other proxies in the Middle East.

742. SCB knew this for a host of reasons, including, but not limited to, because SCB

employees and agents in Iran were aware of such facts and because media outlets reported on

them. For example, a Reuters report published on May 30, 2006—after Hamas seized control of

the Gaza Strip—alerted SCB that former Iranian President Khatami publicly called for every oil-

producing Muslim government to follow Iran’s lead and earmark for Hamas a fixed percentage

of every oil dollar that their regime’s own respective oil resources generated, which the Iranians

would help ensure reached Hamas notwithstanding U.S. counterterrorism sanctions seeking to

deprive Hamas of the funds to pay for attacks:

Former Iranian President Mohammad Khatami called on Muslim oil-producing

countries to give 1 percent of their oil revenues to the cash-strapped Palestinian
government led by Hamas. …
Khatami said the [U.S.] and Israel were depriving Palestinians of their
rights by withholding funds and that Islamic states needed to do more to help. ….
Hamas … is cash-strapped because the United States and its allies have
cut off aid to the body to pressure Hamas to renounce violence and recognise
Israel. Hamas’s charter calls for the destruction of the Jewish state.
“Given the rise in oil prices the producer countries should expect to
deposit 1 percent of their oil revenues,” Khatami said.
Iran [is among the countries that] … have pledged funds totalling more
than $200 million. But the [Hamas] cannot access the money because local,
regional and international banks have balked at making the transfers, fearing
sanctions by Washington, which considers Hamas a terrorist group.

743. On December 20, 2006, similarly, Iranian President Ahmadinejad—whom SCB

knew was an outspoken supporter of Hamas’s terrorist attacks in Israel—gave a speech broadcast

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on Iranian state TV, which BBC then annotated as follows: “[Mahmoud Ahmadinejad:] The

believers and worshippers of God, who are in charge of the oil resources, put aside their own

personal needs, to present and donate their assets in order to help others, to elevate society and to

bring comfort to other people who share their faith [[BBC:] presumably, he is trying to justify

donating Iran’s oil money to the Palestinians and the Lebanese Hezbollah].”

744. Iran’s words were confirmed by vivid public reports of its deeds. As just one

example, on October 17, 2006, the Wall Street Journal reported that “the potent political forces

that roil Iranian business, including the heavy hand of elements close to Iran’s hard-line

president,” were exposed when the IRGC—“in a scene like something you . . . see only on

television”—raided a Romanian drilling rig off the coast of Iran in August and seized control of

the company that holds the rig’s lease, Oriental Oil. The Wall Steet Journal reported that this

seizure was emblematic of the IRGC’s “aggressive push into the backbone of Iran’s economy, its

oil and gas fields.” The Wall Street Journal also reminded its readers in the global business

community, including SCB, of the obvious connection between the IRGC’s role as “an active

player in business” in the oil sector and its sponsorship of terrorist attacks throughout the region:

The Guard has a long history of activity abroad, having helped set up Lebanon’s
Hezbollah militia in the early 1980s. More recently, it has reached into neighboring Iraq.
There, according to a senior Israeli security official, its quest for influence is spearheaded
by a special unit of the Guard called the Ramadan Headquarters, which trains and funds
Iraq Shiite fighters.

The Guard’s business activities include engineering, media, trading and energy. ‘They are
taking positions everywhere,’ says Mohsen Sazegara, a former aide to the late Ayatollah
Khomeini and a founder of the paramilitary force in 1979. The Guard, says Mr. Sazegara,
who broke with Iran’s regime a few years ago and now lives in the U.S., is a ‘unique
organization in the world: a political body, a military force and big, complex company.’

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ii. Iran’s Government Structure

745. SCB knew that the elements of Iran’s government responsible for facilitating

terrorist attacks by the IRGC’s proxies—including the SLO, the IRGC, and the Foundation for

the Oppressed (collectively, “Iran’s Terrorist Sponsors”)—were formalizing and

institutionalizing their control over petroleum industry profits.

746. SCB knew that IRGC front KAA had been awarded multi-billion-dollar contracts

to develop South Pars in June 2006.

747. SCB knew that the Supreme Leader ordered that the Foundation for the

Oppressed be given a substantial role in the negotiation for, and receipt of payment relating to,

Iranian oil exports in 2008. This further alerted SCB that any Iran-related energy transactions

directly aided the Qods Force, Hezbollah, Hamas, PIJ, and JAM because the Supreme Leader’s

decision inextricably connected the Foundation to Iran’s oil sector. SCB knew about the

Supreme Leader’s decision for several reasons, including its knowledge derived from SCB’s Iran

branch and contemporaneous media reports that discussed the decision and its implications. On

April 30, 2010, for example, the Economist’s flagship due diligence publication, the Economist

Intelligence Unit, reported that the “political influence” of the “Bonyad-e Mostazafan

(Foundation of the Oppressed)” “among [Iranian] decision-makers” who were “accountable only

to the Supreme Leader” was “exemplified by the extension of a lucrative privilege to this entity:

the minister of oil announced in June 2008 Bonyad-e Mostazafan’s newly acquired right as

Iran’s oil seller on international markets.”

748. SCB knew that Ayatollah Khamenei decreed in March 2011 that all oil and gas

contracts would be awarded to Petro Nahad, an entity established by the SLO and operated

jointly by, and for the benefit of, the SLO and the IRGC.

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749. SCB knew that IRGC commander Ghasemi was appointed in August 2011 to be

Minister of Petroleum, with control of the agency that controls NIOC. Public sources reported

that Ghasemi, speaking in parliament, described himself as a “soldier[] of the Islamic Republic’s

Revolutionary Guards.” President Ahmadinejad similarly described Ghasemi as a “child of the

revolution,” who would “transform” the oil industry “in line with national interests”

iii. U.S. Government Warnings

750. In the fact sheet accompanying OFAC’s October 25, 2007, designation of the

IRGC and its Qods Force, OFAC warned that they used the oil industry to finance terrorism. The

fact sheet alerted SCB that the IRGC and its Qods Force provided “material support to the

Taliban, Lebanese Hizballah, Hamas, Palestinian Islamic Jihad, and the Popular Front for the

Liberation of Palestine-General Command (PFLP-GC).” The fact sheet also explained that the

IRGC “had a long history of supporting Hizballah’s military, paramilitary, and terrorist

activities, providing it with guidance, funding, weapons, intelligence, and logistical support. The

Qods Force operates training camps for Hizballah in Lebanon’s Bekaa Valley and has reportedly

trained more than 3,000 Hizballah fighters at IRGC training facilities in Iran. The Qods Force

provides roughly $100 to $200 million in funding a year to Hizballah and has assisted Hizballah

in rearming in violation of UN Security Council Resolution 1701.” The fact sheet also

specifically alerted SCB that this support contributed to attacks on civilians in Iraq: “In addition,

the Qods Force provides lethal support in the form of weapons, training, funding, and guidance

to select groups of Iraqi Shi’a militants who target and kill Coalition and Iraqi forces and

innocent Iraqi civilians.” At the same time, the fact sheet alerted SCB to how the IRGC used

Iran’s oil industry to fund its operations: “It . . . has numerous economic interests involving . . .

the oil industry. . . . The IRGC has significant political and economic power in Iran, with ties to

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companies controlling billions of dollars in business and construction and a growing presence in

Iran’s financial and commercial sectors. Through its companies, the IRGC is involved in a

diverse array of activities, including petroleum production and major construction projects across

the country. In 2006, Khatam al-Anbiya secured deals worth at least $7 billion in the oil, gas, and

transportation sectors, among others.” OFAC’s designated several companies, including Oriental

Oil Kish, “on the basis of their relationship with the IRGC.”

751. In speeches and meetings with government officials during the U.S. government’s

financial pressure campaign, discussed supra, officials routinely emphasized how Iran’s oil

industry funded terrorism.

752. Under Secretary of State Nicholas Burns, for example, in March 6, 2007,

testimony to Congress explained: “In recent weeks, we have engaged relevant companies and

countries about their potential investment in Iran’s oil and gas sector,” and we have been

“making clear our opposition to such deals.” Burns emphasized that “[n]o discussion of Iran

would be complete without mentioning the regime’s record of supporting terrorism.” He added,

that “Tehran has long been the world’s leading state sponsor of terrorism,” who is “responsible

for the deaths of scores of Americans,” that Iran was seeking to “rearm Hizballah,” and that

“[r]ecognizing Iran’s role as the central banker of global terrorism, the Departments of State and

the Treasury have enlisted foreign support in efforts to deny suspect Iranian individuals and

entities access to the international financial system.”

753. Over the course of 2010 and 2011, the U.S. government issued a clarion call

consisting of at least fifteen events that warned SCB specifically about Iran’s oil sector, its use of

fronts, the dominance of the IRGC, and its funding of terrorism. These 2010-2011 warnings are

especially notable because they accompanied the most active period of SCB’s assistance to the

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Iranian Petrochemical Company, as documented in the government’s later enforcement actions.

More than $140 million of the approximately $151 million and fully 133 of the 190 transactions

SCB processed for the Iranian Petrochemical Company between 2009 and 2012 were processed

after the events of May 2010—when the Iranian Petrochemical Company was flagged by other

banks, was brought to the attention of SCB’s senior management, and was the subject of SCB’s

lie to OFAC that the company had “no direct or indirect involvement with Iran.”204 Thus, at the

same time as they were alerted to specific concerns about the Iranian Petrochemical Company

from other banks and their own compliance staff, SCB’s senior management was also receiving

some of the sharpest and most sustained warnings from the U.S. government about Iran, and

specifically about the IRGC’s use of front companies in the petrochemical sector to fund

terrorism. SCB’s response was to ignore the warnings and to continue processing the bulk of its

transactions for the Iranian Petrochemical Company over the ensuing two years.

754. SCB received the first of these warnings on February 10, 2010, when OFAC

designated IRGC General Rostam Qasemi and four companies associated with KAA, explaining

(emphasis added):

As the IRGC consolidates control over broad swaths of the Iranian economy, displacing
ordinary Iranian businessmen in favor of a select group of insiders, it is hiding behind
companies like Khatam al-Anbiya and its affiliates to maintain vital ties to the outside
world, said Under Secretary for Terrorism and Financial Intelligence Stuart Levey.
Today’s action exposing Khatam al-Anbiya subsidiaries will help firms worldwide avoid
business that ultimately benefits the IRGC and its dangerous activities. . . .

The IRGC has a growing presence in Iran’s financial and commercial sectors and
extensive economic interests in the defense production, construction, and oil industries,
controlling billions of dollars of business. The profits from these activities are available
to support the full range of the IRGC’s illicit activities, including WMD proliferation and
support for terrorism.

204
2019 OFAC Settlement ¶¶ 7, 25.

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OFAC also reiterated that the Qods Force had previously been designated in 2007 for “terrorism

support activities,” as described supra.

755. SCB received the second warning on June 16, 2010, when OFAC designated

numerous entities and individuals associated with the IRGC and identified 20 companies and 98

vessels in the shipping and petrochemical industries as fronts for the Iranian government. Several

entities were located and/or incorporated outside of Iran, including in Dubai, and many used a

variety of names to evade scrutiny. Of the vessels, 71 had also changed their names to avoid

scrutiny. For example, OFAC identified the following petrochemical company owned by NIOC

and using a variety of names:

MSP KALA NAFT CO. TEHRAN (A.K.A. KALA NAFT CO SSK; A.K.A. KALA
NAFT COMPANY LTD; A.K.A. KALA NAFT TEHRAN; A.K.A. KALA NAFT
TEHRAN COMPANY; A.K.A. KALAYEH NAFT CO; A.K.A. M.S.P.-KALA; A.K.A.
MANUFACTURING SUPPORT & PROCUREMENT CO.-KALA NAFT; A.K.A.
MANUFACTURING SUPPORT AND PROCUREMENT (M.S.P.) KALA NAFT CO.
TEHRAN; A.K.A. MANUFACTURING, SUPPORT AND PROCUREMENT KALA
NAFT COMPANY; A.K.A. MSP KALA NAFT TEHRAN COMPANY; A.K.A. MSP
KALANAFT; A.K.A. MSP-KALANAFT COMPANY; A.K.A. SHERKAT SAHAMI
KHASS KALA NAFT; A.K.A. SHERKAT SAHAMI KHASS POSHTIBANI VA
TEHIYEH KALAYE NAFT TEHRAN; A.K.A. SHERKATE POSHTIBANI SAKHT
VA TAHEIH KALAIE NAFTE): MSP Kala Naft Co. Tehran is a Tehran-based entity
that is responsible, along with other entities, for procurement on behalf of the National
Iranian Oil Company (‘NIOC’), which is an entity that is owned or controlled by the
Government of Iran.

In the same notice, OFAC warned about the IRGC’s control of the Iranian economy:

The IRGC maintains significant political and economic power in Iran. It has ties to
companies controlling billions of dollars in business and construction projects and it is a
growing presence in Iran’s financial and commercial sectors. The IRGC has numerous
economic interests related to defense production, construction, and the oil industry.

756. In announcing OFAC’s action, Treasury Secretary Geithner personally delivered

the clarion call, emphasizing the IRGC’s support for terrorism and sanctions evasion (emphasis

added):

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Our actions today are designed to deter other governments and foreign financial
institutions from dealing with these entities and thereby supporting Iran’s illicit activities.
...

[W]e are adding two individuals and four entities that are part of Iran’s Revolutionary
Guard, which plays a key role in Iran’s missile programs and support for terrorism. . . .

[W]e are identifying 22 petroleum, energy and insurance companies – located inside and
outside Iran – that are owned or controlled by the Iranian government. . . .

In the coming weeks, we will continue to increase the financial pressure on Iran.

We will continue to target Iran’s support for terrorist organizations.

We will continue to focus on Iran’s Revolutionary Guard.

And we will continue to expose Iran’s efforts to evade international sanctions. . . .

When major international institutions find out they’re actually working with a company
that supports Iran’s nuclear or missile programs, they realize it’s not worth the risk.

They cut off their business.

And over the years, this has made a major difference in limiting Iran’s ability to use the
global financial system to pursue illicit activities.

We have made important progress. But we cannot stop. Iran will never cease looking for
new ways to evade our sanctions. So our efforts must be ongoing and unrelenting.

We will keep working to intensify financial pressure on Iran.

757. Under Secretary Levey delivered a similarly pointed warning on the same day

(emphasis added):

Second, we are taking action against Iran’s national maritime carrier, IRISL. Since we
sanctioned IRISL in 2008, it has desperately attempted to evade those sanctions, setting
up new front companies, renaming and even repainting vessels to hide their true
ownership. Despite its deceptive maneuvers, IRISL has had to struggle to obtain
insurance and other services.

Third, we are taking further action against the IRGC, or Islamic Revolutionary Guards
Corps. The IRGC plays a key role in Iran’s missile program and support for terrorism
and it has taken over broad portions of the Iranian economy, to the detriment of the
Iranian people. With today’s designations, we have now sanctioned 26 entities and

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individuals connected to the IRGC, and we will continue to do so. No IRGC entity
should have any place in the world’s legitimate financial system. . . .

Finally, we are identifying 22 petroleum, energy, and insurance companies owned or

controlled by the Government of Iran, including 17 located outside Iran and many that
are not easily identifiable as Iranian. Americans have long been forbidden to do
business with Iranian entities. Companies around the world are increasingly deciding not
to do business with the government of Iran because of its illicit conduct and because, as
President Obama said last week, it is a government that brutally suppressed dissent and
murdered the innocent. . . .

We know that officials in Iran have been anxious about this new round of sanctions. If
the Iranian Government holds true to form, it will scramble to identify work-arounds –
hiding behind front companies, doctoring wire transfers, falsifying shipping documents.
We will continue to expose this deception thereby reinforcing the very reasons why the
private sector is increasingly shunning Iran.

758. SCB received its third warning on June 22, 2010, when Treasury Under Secretary

Levey and State Under Secretary Burns testified before Congress. Under Secretary Levey noted

that the U.S. government’s strategy for addressing “the Iranian threat,” including Iran’s “support

for terrorism” and “abuse of the financial system,” was at an “inflection point.” He explained

(emphasis added):

As you know, we have been working to address Iran’s illicit conduct and to protect the
international financial system from Iranian abuse for the past several years. . . . Our
strategy to hold Iran accountable for its failure to meet its international obligations has
two major fronts. . . . The first front is governmental action . . .

Perhaps as important as government action is the second front: private sector action. The
steps private sector firms around the world have taken in recent years to protect
themselves from Iran’s illicit and deceptive activity are extremely important. We have
found that when we use reliable financial intelligence to build cases against Iranian actors
engaged in illicit conduct, many members of the private sector go beyond their legal
requirements regarding their interactions with these and other Iranian actors because they
do not want to risk handling illicit business. This behavior is a product of good corporate
citizenship and a desire to protect their institutions’ reputations. The end result is that the
voluntary actions of the private sector amplify the effectiveness of government-imposed
measures. Thus, as we have taken action to target illicit Iranian conduct, we have shared
some of the information that forms the basis for our action s with our partners in the
private sector and, in response, virtually all major financial institutions have either
completely cut off or dramatically reduced their ties with Iran . We are now starting to
see companies across a range of sectors, including insurance, consulting, energy, and

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manufacturing, make similar decisions. Once some in the private sector decide to cut off
ties to Iran, it becomes an even greater reputational risk for others not to follow, and so
they often do. . . .

The impact of these actions on Iran has been significant, and is deepening as a result of
Iran’s own conduct. As international sanctions on Iran have increased, Iran’s response
has been to attempt to evade those sanctions. . . . We have used this conduct to our
advantage by exposing it and making it public, reinforcing the private sector’s pre-
existing fears about doing business with Iran. In this way, Iran’s own evasion and
deceptive conduct is increasing its isolation.

759. At the same time as Levey and Burns testified in Congress, SCB received a fourth

warning in the form of a June 22, 2010, advisory from FinCEN amplifying the U.S.

government’s message and directly advising banks about the need for extreme caution in the face

of the “serious threat of money laundering, terrorism finance, and proliferation finance

emanating from the Islamic Republic of Iran.” The advisory described the recent UN Security

Council Resolution 1929 regarding Iran’s proliferation activities and emphasized “the increasing

risk to the integrity of the international financial system posed by . . . commercial enterprises that

are owned or controlled by the IRGC.” The advisory explained (emphasis added):

Iran’s record of illicit and deceptive activity, coupled with its extensive integration into
the global financial system, increases the risk that responsible financial institutions will
unwittingly become involved in Iran’s illicit activities. Many of the world’s major
financial institutions have either cut off or dramatically reduced their relationships with
Iranian banks, leaving Iran’s financial institutions increasingly isolated. Despite the
degradation in Iran’s access to correspondent and other financial relationships with major
international financial institutions, Iran continues to maintain a visible presence in the
international financial system and is constantly seeking to expand its banking presence
internationally. . . . FinCEN continues to advise all U.S. financial institutions to take
commensurate risk-mitigation measures to diminish threats emanating from Iran. . . .

As required under 31 CFR § 103.176(a), covered financial institutions [including U.S.

branches of foreign banks] should ensure that their due diligence programs, which
address correspondent accounts maintained for foreign financial institutions, include
appropriate, specific, risk-based, and, where necessary, enhanced policies, procedures,
and controls that are reasonably designed to detect and report known or suspected money
laundering activity conducted through or involving any correspondent account
established, maintained, administered, or managed in the United States.

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With respect to correspondent accounts held with financial institutions that maintain
relationships with Iran, FinCEN reminds institutions of the increasing likelihood that
Iran will use its existing correspondent relationships to hide illicit conduct in an
attempt to circumvent existing sanctions. Financial institutions should be vigilant in
dealing with banks that might have a connection to Iran. . . .

The increasing infiltration of Iran’s legitimate economy by designated entities, including

especially the IRGC, exposes . . . international financial institutions and companies to
entities owned, controlled, or otherwise affiliated with the IRGC and other designated
entities. . . .

Iran’s demonstrated use of deceptive practices makes it difficult to determine whether

designated entities . . . are associated with any particular transaction involving Iran. . . .
FinCEN remains concerned that Iranian financial institutions are seeking to compensate
for the loss of access to financial sectors by establishing new financial relationships,
including the opening of new foreign branches, subsidiaries, representative offices, or
correspondent or other accounts either outside or within Iran, and the pursuit of joint
ventures. . . .

Additionally, as required under 31 CFR §§ 103.15 - 103.21, if a financial institution

knows, suspects, or has reason to suspect that a transaction involves funds derived from
illegal activity or that a customer has otherwise engaged in activities indicative of money
laundering, terrorist financing, or another violation or attempted violation of law or
regulation, the financial institution shall then file a Suspicious Activity Report.

760. SCB received its fifth warning on July 1, 2010, when President Obama signed

into law the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010

(CISADA), which passed unanimously in the Senate and near-unanimously in the House (408-

8). CISADA reauthorized the Iran Sanctions Act of 1996, which had passed unanimously in both

houses of Congress, and in which Congress found that Iran’s “support for acts of international

terrorism endanger the national security and foreign policy interests of the United States” and

declared it “the policy of the United States to deny Iran the ability to support acts of international

terrorism . . . by limiting the ability to explore for, extract, refine, or transport by pipeline

petroleum resources of Iran.” In CISADA, Congress added a number of new provisions targeting

Iran’s energy sector and made additional findings that Iran’s “support for international terrorism”

is “a threat to the security of the United States” and that Iran was engaged in “ongoing arms

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exports to, and support for, terrorists.” It also noted “the involvement of Iran’s Revolutionary

Guard Corps in . . . international terrorism.”

761. Upon CISADA’s signing, Secretary Geithner issued a statement emphasizing

“Iran’s continued . . . support for terrorists” and explaining that the new law would “strengthen

Treasury’s ongoing efforts to protect the international financial system from abuse.” To

underscore the message even more, Treasury issued guidance—a sixth warning to SCB—

summarizing the new Iran sanctions in five languages, including Arabic. The guidance explained

that the new law

strengthened existing U.S. sanctions with respect to the Iranian energy industry, and adds
the potential for the imposition of serious limits on foreign financial institutions’ access
to the U.S. financial system if they engage in certain transactions involving Iran.
CISADA is consistent with the global consensus regarding Iranian behavior and is in line
with the U.S. Government’s core role of protecting its domestic financial system from
exposure to Iran’s illicit and deceptive financial practices.

762. In a seventh warning, on July 26, 2010, the European Union and Canada adopted

new sanctions against Iran, including measures targeting its trade and energy sectors, as well as

the IRGC. Treasury Secretary Geithner and Secretary of State Clinton announced that they

welcomed those steps to restrict Iran’s ability to use its “energy proceeds” to support its illicit

activities, and observed that “companies around the world refuse to do business with Iran rather

than risk becoming involved in” those activities.

763. An eighth warning arrived on August 3, 2010, when OFAC issued a set of

designations “targeting the Government of Iran’s support for terrorism and terrorist

organizations, including Hizballah, Hamas, Palestinian Islamic Jihad (PIJ), the Popular Front for

the Liberation of Palestine-General Command (PFLP-GC) and the Taliban.” The accompanying

fact sheet warned that “Iran is the primary funder of Hizballah and has long been recognized as

the most active state sponsor of terrorism.” It explained how Iran uses “its state apparatus—

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including the Islamic Revolutionary Guard Corps-Qods Force—and state-run social service

organizations to support terrorism under the guise of providing reconstruction and economic

development assistance or social services.” It also explained that the IRGC’s Qods Force was

“the Government of Iran’s primary arm for executing its policy of supporting terrorist and

insurgent groups” and was providing “material, logistical assistance, training and financial

support to militants and terrorist operatives throughout the Middle East and South Asia.”

764. Also on August 3, 2010, SCB received a ninth warning when OFAC identified

another 21 entities in various economic sectors, often located or incorporated outside Iran, that

were Iranian fronts. The purpose of identifying these entities, according to the announcement,

was to make people “better able to identify Iranian Government entities and protect themselves

against the risks posed by such entities.” Under Secretary Levey also warned: “As its isolation

from the international financial and commercial systems increases, the Government of Iran will

continue efforts to evade sanctions, including using government-owned entities around the world

that are not easily identifiable as Iranian to facilitate transactions in support of their illicit

activities . . . .”

765. A tenth warning alerted SCB to the urgency when OFAC announced its

regulations implementing CISADA on August 16, 2010, well ahead of the 90-day deadline

mandated by Congress. Treasury’s announcement emphasized that CISADA “buil[t] on

continued efforts by the United States and our allies to protect the international financial system

from abuse by Iran. We are already seeing the private sector adjusting business practices in

response to CISADA in order to ensure that their access to the U.S. financial system is not put at

risk.”

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766. An eleventh warning, an August 16, 2010, op-ed by Under Secretary Levey in the

Financial Times, reminded SCB that “[s]ubstantial attention has already been paid to sanctions in

Iran’s banking and energy sector,” while the latest round of measures focused on shipping.

Levey also emphasized that the “broader private sector is restricting business with Iran, rather

than risk facilitating Iran’s illicit activities.”

767. On information and belief, SCB received a twelfth warning (and likely more)

during a three-week August campaign by senior Treasury officials. A Treasury summary

published on August 20, 2010, reported that Treasury’s three “leading officials on U.S. sanctions

crisscrossed the globe” for three weeks to conduct “face-to-face global engagement on Iran with

governments and the private sectors” in a number of countries, including the UAE. The officials

highlighted the impact of the latest financial pressure on Iran’s ability to “develop its oil and gas

fields, acquire financial services and maintain financial relationships with the international

community.” The report added (emphasis added):

At roundtable discussions with banking associations, Treasury continued its dialogue

with the private sector on the need for enhanced vigilance with respect to Iran’s
continued efforts to engage in a range of deceptive measures to conduct illicit
transactions and evade sanctions. U.S. officials also highlighted the need for intense
scrutiny from both regulators and financial institutions of all transactions involving Iran
to combat attempts by Iran to establish new and expand existing financial relationships as
sanctions tighten.

768. SCB received a thirteenth warning on December 21, 2010, when OFAC

announced yet another round of designations targeting the IRGC, and again warned (emphasis

added): “With the IRGC’s expanding influence and control over broader segments of the Iranian

economy—including the defense production, construction, and oil and gas industries—

increasing numbers of Iranian businesses are subsumed under the IRGC’s umbrella and

identified with its illicit conduct.” OFAC identified Pars Oil & Gas Company as an entity

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controlled by the government of Iran and again highlighted the IRGC’s role in development of

the South Pars gas field.

769. SCB received a fourteenth warning on June 20, 2011, when OFAC designated ten

shipping companies, including several based in the UAE, highlighting “Iran’s continued efforts

to evade sanctions and its ongoing creation and use of new front companies, subsidiaries, and

affiliates.” An accompanying announcement by New York District Attorney Cyrus R. Vance, Jr.

explained that, as part of investigations into “the misuse of banks in Manhattan by those seeking

to evade sanctions to support terrorism,” eleven corporations and five individuals had been

indicted for using “alias names and corporate alter egos,” including in the UAE, to obscure the

Iranian government’s involvement in shipping companies.

770. SCB received a fifteenth warning on November 21, 2011, when OFAC

announced expanded sanctions on the development of Iran’s petroleum resources and its

petrochemical industry, along with Treasury’s finding that Iran was a jurisdiction of primary

money laundering concern (discussed supra).

771. In sum, over the course of 2010 and 2011—as SCB was receiving no less than

fifteen different warnings about the IRGC’s use of front companies in the petrochemical sector to

fund terrorism—SCB was regularly processing approximately 130 funds transfers amounting to

approximately $140 million in transactions for a petrochemical company it knew to be an Iranian

front.

772. In addition, decades of other reports and statements by the United States,

terrorists, media outlets, terrorism scholars, and ordinary citizens alerted SCB that every time it

provided illicit financial services to any customer in connection with Iranian oil- or gas-related

transaction, it ran an extreme risk that the other side was funding the Qods Force, Hezbollah,

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Hamas, and JAM and, moreover, even if such person was not, the end revenues would likely

flow to such terrorists, given the Iranian regime’s long-standing and unique treatment of the

revenues it realized from its oil and gas monopoly. Such reports included, but were not limited

to:

a. Agence France Presse English Wire, February 6, 2006: “Iran … formally notified the
[IAEA] of its decision to restart sensitive nuclear work at the centre of concerns the
hardline regime could acquire nuclear weapons. Senior [Iranian] officials also played
down the threat of sanctions … emphasising [Iran]’s vast oil wealth … in an interview
with Handelsblatt, US Defence Secretary Donald Rumsfeld said the United States does
not rule out using military force against Iran. ‘All options, including the military one, are
on the table,’ Rumsfeld [said], repeating his fears that weapons of mass destruction could
fall into the hands of terrorists and branding Iran ‘the main sponsor of terrorist
organisations such as Hezbollah and Hamas.’ But [regime spokesman Gholam Hossein]
Elham said oil-rich Iran still had the upper hand when it came to enduring any eventual
sanctions. … ‘Any decision in this regard [i.e., for the United States to impose sanctions
targeting the IRGC, responsible for Iran’s nuclear program] will not hurt us. It will hurt
the consumers and not the producers. We are in a position of power when it comes to
energy, and it will not have any affect [sic] on our budget,’ he said.”

b. White House Press Secretary Scott McClellan, February 22, 2006: “[Reporter:] Iran, as
you probably know, has now said that it would help fund Hamas, has said that its oil
revenues ... will help amply pay for Hamas as needed. What’s the U.S. reaction? And
does this undercut any sanctions against Iran? [McClellan:] Well, … the regime in Iran
… [has] been a destabilizing force in the … Middle East. Our views are very clear when
it comes to the regime. ... And in terms of Hamas, ... we’ve made it very clear that ... they
continue to engage in terrorism and continue to advocate the destruction of Israel.”

c. President of Israel Shimon Peres, March 18, 2008: “Iranian oil money is funding world
terror, including Hamas and Hezbollah terror.”

d. Agence France Presse English Wire, March 18, 2008: “After meeting [German
Chancellor Angela] Merkel, [Israeli President Shimon] Peres stressed that … ‘the money
earned from oil enables Iran to finance international terrorism, particularly the terrorism
of Hezbollah and Hamas.’”

e. Jerusalem Post, March 19, 2008: “German Chancellor Angela Merkel told the Knesset ...
‘I say it in a clear voice - the [Hamas and PIJ] Kassam [rocket] fire [targeting Israeli
civilians] must stop,’ Merkel said. ‘Terror attacks are a crime, and do not resolve political
disputes.’ Prime Minister Ehud Olmert praised Merkel’s ‘strong and determined position
against the horrific calls from the president of Iran to wipe Israel off the map ….’ ...
Merkel, … also met with President Shimon Peres, who said … that Iranian oil revenue
was funding world terrorism - including Hamas and Hizbullah.”

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f. Reuters, May 5, 2008: “Israeli President Shimon Peres … said … ‘Oil ... is [] promoting
terror,’ said the 84-year-old Nobel Peace Prize winner … Peres argued that manifold
increases in oil prices in recent years had contributed to a rise in financing for terrorism
in the Middle East … Peres took particular aim at Iran, repeating recent comments that
Tehran’s nuclear programme and its rhetoric against Israel may pose a greater threat than
the Nazis in the 1930s and 40s. Israel accuses Iran, a major oil and gas producer, of
financing Hezbollah, the Lebanese guerrilla movement, and Hamas, which controls the
Palestinian Gaza Strip, both of which are sworn enemies of Israel.”

g. Joplin Globe, January 17, 2009: “Make no mistake; Iran is a strong and tenacious
adversary. Fueled with petro dollars from their abundance of oil reserves, Iran supports
strong anti-Israeli and anti-Western militias such as Hamas and Hezbollah. Iran is
responsible for many thousands of American and Iraqi deaths.”

h. Senator John Kerry, May 12, 2009: “[A] massive continuous transfer of American wealth
to oil exporting nations ... [flowed] revenues and power and sustained … global terror
funded indirectly by our expenditures on oil … Too often the presence of oil multiplies
threats ... Iran uses petrol dollars to fund Hamas and Hezbollah ....”

i. Newsweek, June 29, 2009: “In 2005 … Khamenei backed Ahmadinejad …, a veteran of
the … Revolutionary Guards and willing to kiss the Supreme Leader’s feet. Ahmadinejad
won. In the four years since, taking advantage of billions in windfall revenues from high
oil prices, Iran has … funded Hamas as it took over Gaza, and supported and armed
Lebanon’s Hizbullah in its 2006 war with Israel.”

j. APS Review Oil Market Trends, April 5, 2010: “Without money from oil, [Israeli
Infrastructure Minister Uzi] Landau argued, Iran would fade as a regional power and
‘terror groups’ such as Hamas … and Hizbullah … would cease to exist.”

k. Dr. Abdallah al-Nafisi (Academic; Al Jazeera Commentator), June 16, 2010: “Iran gets
on every boat to reach power and influence in the Arab region. A country very rich with
… oil revenues, Iran uses its establishment of and support for Hezbollah … and its
support for Hamas and … as bridges to get to its objectives. What harms Iran if it gives
Hamas $23 million monthly to run things in Gaza? What harms Iran if it gives the Islamic
Jihad $5 million or so to maintain the Palestinian gun? But in return, Iran gains much. It
is as if Iran is telling Israel: My border is in Gaza, not in Tehran, and my border is in Al-
Urqub [in south Lebanon] through Hezbollah, not in Tehran. So, Iran is gaining a great
deal of ... physical influence through its support for Hezbollah and Hamas. ... We
welcome Iran’s support for [Hezbollah] and its support for Hamas and others.”

l. Elliot Bartky and Allon Friedman (Jewish American Affairs Committee of Indiana),
August 1, 2011: “[D]eprive Iran of the oil revenue they’ve used to support terrorist
groups such as Hezbollah and Hamas, … and … kill American troops in Iraq.”

773. Decades of government reports and speeches published by the United States,

United Kingdom, European Union, and United Nations confirmed that Iran’s oil industry was

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inextricably connected with IRGC-sponsored acts of terrorism targeting the United States that

were committed by the Qods Force and the Axis of Resistance it led, including Hezbollah,

Hamas, and JAM. Such U.S., U.K., E.U., and/or U.N. government findings, reports, statements,

and warnings included, but were not limited to:

a. Treasury, June 16, 2010: “KAA … [is] the engineering arm of the IRGC that serves to
help the IRGC generate income and fund its operations. … The IRGC maintains
significant political and economic power in Iran. It has ties to companies controlling
billions of dollars in business and construction projects and it is a growing presence in
Iran’s financial and commercial sectors. The IRGC has numerous economic interests
related to … the oil industry.”

b. State, April 8, 2011: “Official Corruption … [:] … [T]he supreme leader continued to
transfer a large portion of the country’s … oil and gas … sectors to the IRGC. In recent
years [Khamenei] gave control over state enterprises to the IRGC through the granting of
special privileges. IRGC companies were large enough to underbid competitors and were
generally favored in the bidding process for large contracts.”

c. Treasury, March 28, 2012: “‘Treasury is sending a clear signal … that … [w]e will
continue to target the Iranian regime and specifically the IRGC as it … continue[s] its
nefarious infiltration of the Iranian economy,’ said Adam Szubin, Director of [OFAC].
The IRGC continues to be a primary focus of U.S. and international sanctions against
Iran because of the central role the IRGC plays in Iran’s … support for terrorism …. The
IRGC has continued to expand its control over the Iranian economy – in particular in the
… oil and gas industries – subsuming increasing numbers of Iranian businesses and
pressing them into service in support of the IRGC’s illicit conduct.”

d. State, May 24, 2012: “The IRGC operated numerous front companies that were engaged
in illicit trade and business activities. The IRGC includes a construction arm (Khatam ol-
Anbiya) that had extensive economic operations and ties to the oil sector and benefited
from corruption within that sector.”

774. Terrorism scholars also confirmed that KAA-related directly financed IRGC-

sponsored attacks committed by IRGC proxies, including Hezbollah, Hamas, and PIJ, and alerted

SCB to the same. On June 15, 2010, for example, IRGC scholars Mark Dubowitz and Emanuele

Ottolenghi publicly warned:

[KAA] is an integral part of the IRGC power structure. Its head is the IRGC’s
Commander in Chief, … Mohammad Ali Jafari, and its CEO, under his authority,
is always a high-ranking IRGC officer. Many IRGC projects are military in

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nature, and the group diverts much of the technology and expertise it acquires
from Western companies for seemingly innocuous projects to unsavory ends. …
Any company that does business in Iran risks becoming an unwitting
accomplice to the IRGC’s nefarious activities, tarnishing its reputation in the
process. Yet even when companies provide services and technologies that cannot
be diverted to illicit projects, partnering with the IRGC entails some complicity
with its activities. In June 2006, then-[KAA] deputy head [IRGC] Brigadier
General Abdol Reza Abed confirmed in an interview with a local daily that
[KAA]’s funds finance various national defense projects, including arming and
training Hezbollah. …
[B]oth the Iranian people and the Western companies that do business
with the regime end up paying the price for the IRGC’s cronyism, inefficiency
and incompetence.
No matter how you look at it, it’s clear that when [KAA] wins, everyone
else loses. … And the entire [Middle East] region loses, because the richer the
IRGC becomes, the more resources it has to perpetuate Iranian subversion and
repression at home and abroad.
The United States, and other western allies, have only just begun
designating the IRGC front companies that operate in the Iranian energy sector.
Business with the Iranian regime is going to get even riskier.

2. Other Evidence Further Shows SCB’s Awareness That the

Petrochemical Company Funded Terrorism

775. As explained supra, the name of the individual purporting to be the Iranian

Petrochemical Company’s nominal owner, on information and belief, was the name for Iran’s

Friday Prayer Leader, Imam Jomeh—a role closely associated with the SLO and Ayatollah

Khamenei himself.

776. SCB Dubai also received organization charts and other customer due diligence

information about the Iranian Petrochemical Company’s corporate structure, affiliates, facilities,

offices, business activities, personnel, and organization. On information and belief, SCB knew

based on this material and its knowledge from public sources that the Iranian Petrochemical

Company was directly connected to South Pars, NIOC, and/or NITC.

777. On information and belief, SCB knew that the Iranian Petrochemical Company’s

transactions concerned, among other things, petroleum deals relating to the South Pars project,

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which SCB knew was fully controlled by the IRGC and a direct funding source for Hezbollah,

Hamas, PIJ, and JAM. Terrorism scholars warned that facilitating transactions for Iranians that

involved South Pars directly financed IRGC-sponsored terrorist attacks committed by Hezbollah,

Hamas, and JAM. On March 15, 2007, for example, former Treasury official Dr. Matthew Levitt

testified before Congress that:

[T]he IRGC is precisely the element within Iran that should be targeted. … The
IRGC is … responsible for providing funds, weapons, improvised-explosive-
device technology and training to terrorist groups like Hezbollah and Hamas and
insurgents attacking coalition and Iraqi forces in Iraq. …
[T]he IRGC’s business and industrial activities -- especially those
connected to the oil and gas industries -- are heavily dependent on the
international financial system. Consider, for example, the $2.09 billion contract to
develop parts of the South Pars natural-gas field, or the $1.3 billion contract to
build parts of a pipeline, both meted out to the IRGC’s engineering arm, the
Khatam-ol-Anbia. …

778. Public admissions by IRGC leaders confirm the key role that funding from fronts

like the Iranian Petrochemical Company played in the South Pars project. On December 22,

2009, for example, an IRGC-controlled news agency reported (as summarized by the BBC):

[IRGC] Commander of Khatam al-Anbia base informed about the delay in

completing phases 15 and 16 of South Pars oil field …
Commenting on the latest updates on the development of phases 15 and 16
of common South Pars field, Islamic Revolution Guards Corps [IRGC] General
Rostam Qasemi said that the level of progress in both phases in the sea and land is
about 43 per cents. He added: Inability of the Ministry of Oil in providing
necessary financial resources in proper time was one of the most important
difficulties faced with regard to phases of South Pars field. Expressing hopes for
rapid resolution of the project’s financial troubles, he clarified: Employer (Pars
Oil and Gas Company) has not succeeded in injecting financial resources to the
project in accordance with its pace. …
According to [IRGC-controlled] Mehr news agency, at the moment the
construction of five phases of South Pars - 12, 15, 16, 17 and 18 - are in progress
and due to lack of financial resources, the operation has been delayed.

779. On August 6, 2011, similarly, Reuters reported that:

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Iran will need some $40 billion this year to spur the development of oil and gas
fields it shares with neighbouring countries, Oil Minister Rostam Qasemi said in
his first interview since being appointed …
Qasemi, a Revolutionary Guards commander … vow[ed] to prioritise
jointly owned fields, notably the giant South Pars gas reservoir …
“In order to launch the announced development plans (on the joint fields)
there is need for more than $40 billion in investment in the current (Iranian) year
(ending late March 2012),” Qasemi said in an interview with Iran, a state-owned
daily newspaper.
While Iran might seek foreign capital to finance energy projects, it did
not need foreign know-how, he said.
“There are currently very competent contractors domestically on which
we can rely for the development of oil and gas can be done ... For the
development of oil and gas fields we don’t need foreign contractors.”
One of those domestic companies is Khatam al-Anbia itself, which took
over parts of the South Pars development when European firms Royal Dutch
Shell and Total SA pulled out due to sanctions on Iran.
Both Khatam al-Anbia and Qasemi himself are under U.S. and European
Union sanctions …
Qasemi said Iran would seek foreign capital … for the energy projects, as
well as tapping … Iranian banks …
“We will be pursuing an active diplomacy to absorb foreign capital as
they form part of the required financial resources for the projects to be
developed,” Qasemi said.

780. Media reports about South Pars alerted SCB that U.S. sanctions were crushing the

IRGC’s ability to maximize the cash flow the IRGC received from South Pars and alerted SCB

that South Pars-related sanctions evasion directly aided IRGC efforts to raise money to finance

IRGC operations. On June 29, 2006, for example, Reuters reported that while “Iran ha[d]

awarded the Revolutionary Guards corps a contract to develop two phases of the … giant South

Pars gas field,” industry analysts confirmed that the Iranian regime could not “develop” its “oil

and gas industry,” including at South Pars, “without foreign companies’ help.” Moreover, on

May 28, 2010, Agence France Presse reported:

Iran [] awarded a business unit of the elite Revolutionary Guards the rights to
develop phases 13 and 14 of the giant South Pars gas field …
Guards unit Khatam al-Anbiya would form a consortium with the Sadra
and Khatam al-Ocia companies and the national drilling and national maritime

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installation companies to undertake the work. … [P]hases 22, 23 and 24 were

[also] to be awarded to Khatam al-Anbiya. …
The development of the giant offshore field has been delayed amid a lack
of investment …
Khatam al-Anbiya … is under US and UN sanctions related to Iran’s
refusal to abide by UN Security Council resolutions … Global energy majors
have come under increased pressure against doing business with Iran as
Washington has stepped up efforts to impose new sanctions on [Iran] ….

781. From 2005 through 2020, reports and statements by the United States, terrorists,

media outlets, due diligence resources, terrorism scholars, and ordinary citizens alerted SCB that

the IRGC had seized control of Iran’s interests in the South Pars petroleum and that everything

relating to any Iran-related party’s direct or indirect involvement in South Pars was inextricably

connected to, and ultimately financially benefited, the IRGC. Such reports included, but were not

limited to:

a. Islamic Republic News Agency, January 5, 2005: “A consortium … has won the tender
for Phases 15 and 16 of the giant South Pars gas field development project, … [which]
consortium [] includes Sadra and Khatam ol-Anbiya … companies of Iran.”

b. Agence France Presse, June 27, 2006: “[T]he Revolutionary Guards ... is set to enter the
oil and gas sectors in a move that would increase their stake in [Iran]’s economy. ‘The
Revolutionary Guards have obtained the contract to develop phases 15 and 16 of South
Pars,’ … General Abdolreza Abed said in an interview with the Shargh newspaper. Abed,
who heads up [KAA], said the contract was worth 2.09 billion dollars. The deal would be
a major boost to the operations of the [IRGC] .... It comes on the back of a string of
advances into Iran’s economy: several weeks ago ... the [IRGC] ... were awarded a 1.3-
billion-dollar contract to construct a 900-kilometre (570-mile) pipeline between South
Pars and southeastern Iran. In both South Pars cases, the projects were awarded after the
usual tendering process was abandoned. For the South Pars development deal, the
[IRGC] -- under the name of their economic nerve centre of [KAA] -- entered a
partnership with [a] Norwegian firm …, although this firm subsequently pulled out. The
oil ministry then moved to open another tender process, but this was cut short. ... For
many observers, the wave of lucrative deals going to the [IRGC] is connected to last
year’s shock presidential election win by hardliner Mahmoud Ahmadinejad -- a veteran
of the [IRGC] -- who promised to favour domestic entrepreneurs. ... [IRGC] General
Abed [head of KAA] told the centrist Shargh newspaper that there was nothing wrong
with the [IRGC] … branching out. ‘Since when do the [IRGC] have to stick to building
roads, dams, small tunnels or short pipelines?” he argued. “If we take on big projects we
can put small entrepreneurs to work.’ ... [W]ith foreign investment in the oil sector
limited, the Guards appear ready to shift into top gear by filling the gap -- with General

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Abed also revealing [the IRGC]’s involvement in a new petrochemical port. ‘Thirty
percent of the [IRGC]’s engineering capacity is dedicated to economic activities, and 70
percent to military,’ [IRGC General Abed] said.”

c. Reuters, June 29, 2006: “Iran has awarded the Revolutionary Guards corps a contract to
develop two phases of [Iran]’s giant South Pars gas field … The two phases were
originally awarded to a consortium of international and domestic companies led by
Norway’s Aker Kvaerner, which quit the deal in May 2005. ‘It is a $2.09 billion contract.
Phases 15 and 16 will produce 56.6 million cubic meters of natural gas,’ state radio said.
… Khatam al-Anbia firm, the engineering arm of the [IRGC], will take charge of the
onshore work for the two phases. Iran is in dispute with the international community over
its nuclear programme and Tehran could face United Nations sanctions, which would
make operating there even more difficult for foreign companies. Signing big contracts
with foreign firms is politically toxic in Iran, which sits on the world’s second largest
reserves of natural gas but has been slow to develop it for export. … Earlier this month,
the [IRGC] won a $1.3 billion project to build a … pipeline from South Pars to the
eastern province of Sistan-Baluchestan, the route for Iran’s gas export to Pakistan.”

d. Economist Intelligence Unit, July 21, 2006: “The engineering arm of the … IRGC … has
made further inroads into the oil and gas sector, having been selected as the main
contractor for the development of Phases 15 and 16 of the South Pars gas scheme. Sharg,
a local newspaper, quoted General Abdolreza Abed, head of the IRGC’s [KAA], as
saying that the order will be worth some US$2bn. The order follows a US$1.3bn contract
to build a … pipeline linking South Pars fields to southeastern Iran. … IRGC will be
working with local partners on the two South Pars phases, which envisage production of
some 1.8bn cu ft/day of natural gas, 1m tonnes/year of liquefied petroleum gas, a similar
quantity of ethane and 80,000 barrels/day of condensates. … Much of the work in Iran’s
oil and gas sector is now being allocated to local firms, because of the difficulty facing
foreign companies in concluding financial and commercial terms.”

e. Economist Intelligence Unit, August 3, 2006: “Evidence of any direct consequences of

the changed political and economic environment on the amount of foreign trade and
investment in Iran is hard to come by. The re-awarding of contracts such as those related
to the giant South Pars gasfield … [by] the Revolutionary Guards … ha[s] undoubtedly
made foreign companies cautious. … [T]here have been reports in the Western press that
four European banks, under pressure from the US government, have reduced their
presence in Iran (May 2006, Foreign trade and payments) … It is expected that bank
charges for doing business in or with Iran will have risen, possibly in response to a
perceived increase in the complications of doing trade.”

f. Economist Intelligence Unit, August 3, 2006: “Mahmoud Ahmadinejad … appears to be

increasingly favouring domestic companies when awarding government contracts, and
giving a growing role to those linked to the … IRGC … in particular. In June a US$1.3bn
contract for a gas pipeline linking Assalouyeh, Bandar Abbas and Iranshah was awarded
to the [KAA]. The pipeline is to supply gas from the South Pars field to Sistan-
Baluchestan, Hormuzgan and Kerman, and the contract was signed in the uniformed
presence of Major-General Yahya Rahim-Safavi, the IRGC’s commander. In June the

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IRGC also scooped the main exploration contract for phases 15 and 16 of South Pars. The
deal was originally made in January 2005 with a consortium of Aker Kvaerner (Norway),
Sadra (Iran) and the [IRGC]. It now seems—the news emerged from an interview given
by General Abdolreza Abed to Shargh, a reformist daily, before a signing ceremony at
South Pars—that the IRGC has edged out Aker Kvaerner. [KAA] will lead a local
consortium that includes Saaf Offshore, Isolco (the Iran Shipbuilding and Offshore
Industries Company) and IOEC (the Iran Offshore Engineering and Construction
Company). Phases 15 and 16 are scheduled to involve the production of 50m cu
metres/day of treated gas for domestic use, 1m tonnes/year (t/y) of liquefied petroleum
gas for export, 80,000 barrels/day (b/d) of condensates for export and 1m t/y of ethane for
domestic petrochemical works. The news prompted fears among local contractors that the
government would award other contracts to [KAA].”

g. Investor’s Business Daily, November 8, 2006: “Mahmoud Ahmadinejad’s terrorist

regime needs billions in foreign investment in the coming years to compete with other
OPEC countries. That means serious international sanctions can be a powerful weapon.
The Islamofascists … have repeatedly made it clear they’re … the backers of terrorist
outfits like Hezbollah …. Iran may have lots of oil and natural gas in the ground, but if it
doesn’t get ahold of tens of billions of dollars in outside capital in the years ahead, it
won’t be able to extract and refine those commodities. … The world has plenty of
leverage available: … European and Asian companies run gas and petrochemical plants
in South Pars …, the largest natural gas field in the world. Shut all that down, along with
all energy-related exports and imports, and Ahmadinejad and supreme leader Ayatollah
Ali Khamenei just might find themselves fighting for survival.”

h. Washington Times, August 16, 2007: “The [U.S.] … decision to designate [the] … IRGC
[Qods Force] … as a ‘specially designated global terrorist’ (SDGT) organization strikes a
huge blow against one of the world’s most deadly jihadist groups. The IRGC, through its
longstanding relationship with Hezbollah, has the blood of hundreds of Americans on its
hands … Earlier this year, [Dr.] Matthew Levitt … (a former deputy assistant secretary of
the treasury specializing in terrorism-finance issues) wrote in The] Washington Times
that … ‘the IRGC’s business and industrial activities - especially those connected to the
oil and gas industries - are heavily dependent on the international financial system.’ In
other words, these are precisely the kind of projects where Iranian regime elites are
vulnerable to American and international economic pressure. These [IRGC] projects
include a contract worth $1.3 billion to build parts of a pipeline and another worth more
than $2 billion to develop part of [] South Pars …. [R]ecently, the IRGC - and in
particular, a section known as the Quds Force - has been heavily involved in aiding
Hezbollah, as well as … Hamas …. At a press conference last month, U.S. military
officials in Iraq said that the Quds Force is bringing groups of up to 60 Iraqi insurgents at
a time to training facilities near Tehran, where they are taught how to carry out
kidnappings and use rockets and improvised explosive devices to kill and maim
American troops. American officials also say that the IRGC is responsible for smuggling
explosively formed penetrators (EFPs) into Iraq. The EFPs, which can penetrate the
armor of a Humvee and are used almost exclusively by Shi’ite militias, accounted for
one-third of the combat deaths suffered by coalition forces last month. The 99 strikes that

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occurred with EFPs in July were the highest total since the war began. Earlier this year,
Mr. Khamenei vowed to hit back at U.S. interests worldwide if Iran were attacked. … By
hitting the Revolutionary Guards with sanctions, the Bush administration is weakening
their capacity to finance more terror, and clearly it hopes to shame the Europeans and the
Japanese in cutting their financial ties to these serial killers of Americans.”

i. Washington Times, August 16, 2007: “[The] Revolutionary Guard Corps, which faces the
prospect of severe U.S. financial sanctions as a ‘terrorist organization,’ represents a
tempting target given its multibillion-dollar commercial empire ranging from oil fields to
honeybee farms. … The U.S. terrorist designation would freeze any U.S. assets of the
IRGC, but financial analysts say its greater practical effect would be to discourage
companies and banks from other nations from working with the corps’ various
subsidiaries. … the IRGC’s financial scope has expanded dramatically with the election
of Islamic hard-liner Mahmoud Ahmadinejad as president in 2005. According to a survey
by the … International Crisis Group, [KAA] won a string of major contracts from the
Ahmadinejad government, including … a $1.3 billion oil pipeline contract, and a no-bid
$2.09 billion commission to develop parts of the vast South Pars natural gas field. …
U.S. officials say such profits matter because it is IRGC’s foreign military arm, known as
the Quds Force, that is suspected of providing funds, training and equipment to anti-U.S.
forces in Iraq, … Lebanon and the Palestinian territories.”

j. Christian Science Monitor, August 6, 2009: “The Bush administration regularly accused
the Guards of supplying advanced explosives to insurgents in Iraq … In a rare disclosure,
businesses were put at 30 percent of IRGC ‘capacities’ in a 2006 interview by Brig. Gen.
Abdol-Reza Abed, an IRGC deputy commander and head of Khatam-ol-Anbia, one of its
many companies. The IRGC’s economic role has clearly increased with projects awarded
by Ahmadinejad. Within a year of his taking office, [KAA] won a $1.3 billion contract
for a gas pipeline …, and … for developing part of the South Pars gas field.”

k. Economist Intelligence Unit, August 19, 2009: “The [Iranian regime] has approved an
additional US$1bn investment to be allocated to [KAA], a company owned by the
[IRGC], to develop Phases 15 and 16 of the giant South Pars gasfield. … Total said in
2008 that it could not proceed …, in the face of increased costs and the tense
international situation over Iran.”

l. Rasool Nafisi (IRGC Scholar and Author), September 18, 2009: “Symbiotic
Relationship[:] Upon becoming president, Ahmadinejad wasted no time in awarding the
juiciest government contracts to the IRGC. [KAA], the industrial and construction wing
of the IRGC, was given no-bid contracts to develop the 15th and 16th phases of the South
Pars Gas Field, and to build a … pipeline to Pakistan and India. It was also allowed to
take over the Kish Oil Company. These deals turned the already massive [KAA] into one
of the largest conglomerates in the Middle East.”

m. Mehr News Agency, April 18, 2010: “[A]n all-Iranian consortium will be vested with
developing the South Pars … phases 22-24. … The consortium is consisted of [KAA],
Industrial Development and Renovation Organization of Iran (IDRO), and some offshore
contractors such as Iran Shipbuilding & Offshore Industries Complex Co (ISOICO),

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Sadaf, Sadra, and Iranian Offshore Engineering and Construction Company … Iran,
having the world’s second largest gas reserves and third largest oil reserves, is trying to
play a more active role in oil and petrochemical transactions in international markets.”

n. Agence France Presse, May 28, 2010: “Iran has awarded a business unit of the elite
Revolutionary Guards the rights to develop phases 13 and 14 of the giant South Pars gas
field, the Mehr news agency … Guards unit [KAA] would form a consortium with the
Sadra and Khatam al-Ocia companies and the national drilling and national maritime
installation companies to undertake the work. He also confirmed reports earlier this week
that phases 22, 23 and 24 were to be awarded to [KAA]. … The development of the giant
offshore field has been delayed amid a lack of investment in a country faced with severe
gas needs of its own and because of difficulties in procuring the technology to develop
these fields. [KAA] … is under US and UN sanctions … Global energy majors have
come under increased pressure against doing business with Iran as Washington has
stepped up efforts to impose new sanctions on [Iran] ….”

o. Agence France Presse, June 15, 2010: “Iran … signed contracts worth 21 billion dollars
with local firms to develop six gas fields, some of them awarded to the [IRGC], state
media reported. The state television website said the ‘contracts to develop the South Pars
gas fields -- phases 13, 14, 19, 22, 23 and 24 -- were inked with three consortia including
[KAA],’ the [IRGC’s] industrial conglomerate. … Iran previously discussed handing
over phases 13 and 14 to Royal Dutch-Shell and Spain’s Repsol YPF, but the two giants
held off on a final decision as new UN sanctions loomed against Tehran … The [IRGC]
… has been targeted in the fresh UN sanctions … Last month the [IRGC] said it was
ready to take over energy projects in Iran if Western firms stayed away ….”

782. On information and belief, SCB knew that the Iranian Petrochemical Company’s

transactions concerned NIOC. Media reports alerted SCB to the key role that funding from fronts

like the Iranian Petrochemical Company played in facilitating NIOC’s activities. On April 26,

2010, for example, IHS Global Insight reported that IRGC companies were “increasingly being

awarded tenders by NIOC and its subsidiaries . . . creating potential significant problems for . . .

foreign firms” dealing with NIOC and its subsidiaries “given the specific international sanctions

against dealing with Revolutionary Guards affiliates and the U.S. classification of the outfit as a

terrorist organisation.”

783. Congressional testimony confirmed the well-known fact that NIOC-related

transactions directly enabled IRGC-sponsored terrorist attacks. On November 15, 2011, for

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example, Mark Dubowitz, president of the Foundation for Defense of Democracies, testified in

front of the House Subcommittee on National Security, Homeland Defense, and Foreign

Operations. Dubowitz advocated for stronger sanctions against Iran, specifically targeting the

IRGC’s control of the oil industry. Dubowitz testified that the IRGC was “unquestionably the

dominant force throughout Iran’s energy sector, including the sale of Iran’s oil,” and that “the

United States should also consider designating Iran’s state-owned National Iranian Oil Company

(NIOC). NIOC is a party to every Iranian oil transaction. Leveraging its position as a state-

owned institution, NIOC operates as the ultimate front company in obscuring the role of the

IRGC in the oil trade.” Dubowitz further testified that “[t]he Central Bank of Iran, like the

National Iranian Oil Company, and other IRGC entities discussed above—are critical links in the

IRGC-dominated oil supply chain and key enablers of the IRGC’s proliferation activities,

terrorist operations and human rights abuses.”

784. NGO public pressure campaigns also alerted SCB that its NIOC-related

transactions enabled IRGC-sponsored terrorist attacks. In November 2011, for example, UANI

publicly called on Italian energy company Edison SpA to stop doing business in Iran, and stated

that “[t]he IRGC is a known terrorist entity in control of Iran’s oil, gas, and petrochemical

sectors. . . . The IRGC also ‘bankrolls’ groups in Iraq and Afghanistan that execute attacks

against American and NATO servicemen. . . . By working with NIOC and the IRGC to develop

Iran’s oil sector, Edison is directly contributing to Iran’s capabilities to sponsor terrorism, kill

and maim NATO servicemen and develop its weapons of mass destruction programs.”

785. On information and belief, SCB knew that the Iranian Petrochemical Company’s

transactions concerned NITC. Media reports alerted SCB that the IRGC effectively controlled

NITC. In 2012, for example, Reuters reported that “[s]upporters of tougher Iran sanctions

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measures are aiming to get NITC on a U.S. blacklist for what they say are links to the Iranian

Revolutionary Guards Corps (IRGC).” In 2014, Iran Briefing reported that “[t]he IRGC has a

major stake in the petrochemical industry, including … the National Iranian Tanker Company.”

786. Terrorism scholars alerted SCB that the IRGC effectively controlled NITC. In

2012, for example, Mark Dubowitz, of the Foundation for Defense of Democracies, warned that

“NITC is a critical element of the IRGC-controlled oil supply chain. Its tankers enjoy free access

to global ports around the world despite the IRGC’s reputation as an international outlaw.”

787. Congressional hearings alerted SCB that the IRGC effectively controlled NITC.

In 2012, for example, Congresswoman Ileana Ros-Lehtinen and Mark Dubowitz confirmed in an

exchange that NITC played a key role in the logistics chain upon which the IRGC relied to

sponsor acts of terrorism:

ROS-LEHTINEN: Now, Iranian tankers [operated by the NITC] have been

turning off their outboard/onboard vessel tracking system even though the
International Maritime Organization requires that those systems stay on. Can
multilateral actions be taken against the National Iranian Tanker Company to
penalize Iran for its activities? And what specific role does the National Iranian
Tanker Company play within the IRGC supply chain? ...
DUBOWITZ: We -- we’ve -- there already is existing authority under U.S. law.
The president has the power to really crack down on the Iranian economy, on the
Iranian oil sector.
We should be designating the National Iranian Oil Company and all its
subsidiaries. We should be designating the National Iranian Tanker Company and
make it very difficult for the Iranians to ship [oil].

788. Decades of reports by the media, United States, United Nations, NGOs, terrorism

scholars, and others confirmed that transactions on behalf of, or for the benefit of, NITC directly

enabled IRGC-sponsored acts of terrorism targeting the United States and committed by the

Qods Force, Hezbollah, and their proxies.

789. For example, the international news agency Reuters consistently warned about

such risk since the 1990s, as it did in 1995:

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Iran has minimised the impact of a U.S. trade ban by finding alternative markets
for its crude oil in Europe, Asia and South America, an Iranian oil source said …
“We have had a general policy of trying to diversify our customers and
only a few months after the ban was imposed we have been successful to a large
extent in lowering the effects of the embargo,” the source told Reuters.
“The National Iranian Oil Company (NIOC) has done its best to seek other
markets in countries such as South Asia, Europe and South America. The
feedback has been good,” said the source …
“We have been successful in selling our crude oil and keeping its price
almost intact and competitive. This shows that NIOC has been able to tolerate the
situation,” the source said.
Washington accuses Iran of sponsoring international terrorism …
The trade ban has pushed Iran … to … resort to the international shipping
market.
The source said the efforts to offset the U.S. trade ban was reflected in
the fact that Iran’s National Iranian Tanker Co. (NITC) has ordered new
tankers … and accelerated chartering activity.
“[NITC] has ordered new vessels such as double hull tankers and other
types of ships. NITC has also been scrapping its old vessels and chartering
tankers,” the source said. (Emphasis added.)

Other Reuters reports similarly warned about NITC’s direct enabling of Iranian evasion of U.S.

counterterrorism sanctions targeting Iran. Reuters even specifically warned that NITC-related

transactions in Dubai were designed to evade U.S. counterterrorism sanctions.

790. Terrorism scholars also alerted SCB that transactions with NITC foreseeably

enabled IRGC-sponsored acts of terrorism. In 2011, for example, Mark Dubowitz warned “IRGC

companies that are part of the crude oil supply chain” included “National Iranian Tanker

Company (NITC)” such that transactions with such IRGC companies furnished “Iran’s oil

revenues” and provided “the regime the hard currency it needs to operate” by financing

“companies doing business with Islamic Revolutionary Guard Corps (IRGC) entities in the crude

oil trade” that directly enabled Iranian efforts “supporting … terrorism.”

791. Public advocacy campaigns also alerted SCB that transactions with NITC

foreseeably enabled IRGC-sponsored acts of terrorism. In 2012, for example, UANI sponsored a

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public campaign alerting European entities that the IRGC had seized NITC and was using it to

sponsor terrorism.

792. On information and belief, SCB knew that the Iranian Petrochemical Company’s

transactions concerned the Caspian. Regular reports of IRGC terrorist activity in the vicinity of,

and connected to the IRGC’s desire to dominate, the Caspian alerted SCB that Caspian

petroleum-related transactions foreseeably involved the IRGC. On February 10, 2008, for

example, the L.A. Times reported that the IRGC had been conducting operations in the area near

the Caspian as part of the Ayatollah’s strategy to dominate the region.

793. Ayatollah Khamenei specifically, and regularly, touted that Iran was inextricably

connected to all things relating to Caspian Sea-related petroleum issues. On May 3, 2001, for

example, Iranian state TV covered a speech by Khamenei, contemporaneously reported upon by

BBC, as follows:

Ayatollah Khamenei, … [said] “[T]he Islamic Republic of Iran will defend its
rights and the rights of the Iranian nation on every front. … The Caspian Sea is
a[n] enclosed sea which belongs to its littoral states. No power from anywhere in
the world has the right to interfere in or exert influence on … the affairs of that
sea. According to international laws there are five littoral states. The fate of that
sea lies in the hands of those five countries. And, here and now, I take this
opportunity to declare that the legal status of the Caspian Sea and the balance
between the various activities of the five countries in that sea should be
maintained between those five countries - all the five countries. It cannot be done
through bilateral contacts and agreements.”
Stressing the importance of realizing Iran’s rights in the Caspian Sea in the
fields of oil and gas, … Khamenei added: “Everybody knows that the Iranian
nation and the Islamic system do not permit their right be undermined in the
slightest, whether on land or at sea.”

On May 4, 2001, similarly, media outlets reported that Ayatollah Khamenei repeated this

message, and underscored Iran’s—and Khamenei’s—direct connection to all issues relating to

the development, extraction, and trade of petrochemical products in the Caspian.

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794. Finally, SCB’s advice to change the Iranian Petrochemical Company’s name, and

the company’s decision to do so by creating a new entity on November 15, 2011 (on information

and belief, Caspian Petrochemical FZE) shows SCB’s awareness that it was an IRGC front

because it followed on the heels of twelve events over six days from November 8, 2011 through

November 14, 2011, that alerted SCB (and its IRGC front customers) that the United States,

United Kingdom, United Nations, and European Union would imminently impose major new

sanctions targeting the Iranian regime’s use of Iranian fronts and banks to finance IRGC

operations.

795. On November 8, 2011, the International Atomic Energy Agency (“IAEA”)

published a bombshell report exposing the Iranian regime’s comprehensive nuclear weapons

program, including its lies and cheating while promising that such program was peaceful.

796. On November 9, 2011, the Israeli government responded to the IAEA report by

publicly messaging that it was preparing for a potential military strike targeting Iran, which

Israel warned could come as early as the following month.

797. On November 10, 2011, Ayatollah Khamenei—in a speech before the IRGC,

which was then posted to his official website—directly threatened IRGC-sponsored attacks

against the United States and Israel: “The firm Iranian nation is not one to sit back and observe

threats by fragile and material-minded powers … The enemies, especially America and its

stooges and the Zionist regime (Israel), should know that … Iran[] … will respond with full

force to any aggression or even threats in a way that will demolish the aggressors from within. …

The Revolutionary Guards ... will answer attacks with strong slaps and iron fists.”

798. On November 10, U.K., French, and other E.U. member state diplomats also

warned that, inter alia, the United Kingdom, France, and European Union were preparing to

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impose “new powerful sanctions” at the European Union’s scheduled meeting on December 1,

2011, which would likely forbid direct interactions with the Central Bank of Iran and/or any

Iranian person involved in the Iranian regime’s monopoly in the petroleum trade.

799. On November 11, 2011, IRGC-controlled Press TV publicly taunted Israel and

messaged that “the Israeli regime will never have the courage to … attack … Iran” because

“Israel … has suffered humiliating defeats in Lebanon and … Gaza.”

800. On November 12, 2011, Hezbollah leader Hassan Nasrallah threatened that

Hezbollah and its Axis of Resistance allies—which SCB knew included Hamas, PIJ, and JAM—

were prepared to launch a wave of devastating attacks in the Middle East in support of

Hezbollah’s (and its Axis allies’) patron, the IRGC, stating: “Whoever dares to launch a war

against Iran will be met with double that force. Iran is strong; Iran is powerful and has a leader

unique to the whole world. … They [i.e., the United States and Israel] must understand well that

a war on Iran and a war on Syria will not be confined to Iran or Syria. This war will roll over

throughout the entire region.”

801. On November 12 and 13, 2011, the U.S. government hosted the annual Asia

Pacific Economic Cooperation summit, during which President Obama and other leaders

indicated that the United States would likely work with other nations to impose severe new

sanctions in response to both the IAEA news as well as the Iranian regime’s support for proxy

terror violence in the Middle East.

802. On November 13, 2011, during the Republican Party presidential primary debate,

the leading candidates all promised to impose unprecedented additional sanctions targeting the

Iranian regime’s support for terrorism, if they became president.

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803. On November 14, 2011, U.S. and E.U. officials confirmed that significant new

sanctions targeting the IRGC’s use of banks and Iran’s energy sector were imminent:

a. U.S. Senator John McCain—widely known as a key American thought leader regarding
Iran sanctions—appeared on global media outlet CNN and urged powerful new sanctions
targeting the Iranian regime: “We have to make it clear to the Iranians that they cannot
and will not have a nuclear weapon. And one of the greatest conundrums that we face
today is whether Israel will take unilateral action in order to remove that possibility, as
well [i.e., an Israeli military strike]. …[T]his … situation … cries out for American
leadership and we should lay down a marker on the Iranians … because we can squeeze
them harder with sanctions on their banking system and their oil exports, as well.”

b. U.K. Foreign Secretary William Hague publicly stated that the U.K. government would
“look over the coming months … to placing more pressure on Iran through sanctions”
and pointedly declined to rule out a British military strike against the Iranian regime by
observing that “all options … remain[ed] on the table.”

c. French Foreign Minister Alain Juppe publicly urged all governments to impose “a very
firm” round of newly toughened sanctions “to avoid an irreparable intervention,” i.e., an
armed conflict involving the western world and the Iranian regime.

d. E.U. member states’ foreign ministers coordinated a united front and released this draft
statement to the western media: “Iran [was] in violation of international regulations …
We urge Iran to address international concerns ... Strong new restrictive measures will be
taken at a next meeting taking into account Iran’s actions.”

Media outlets widely reported each of these events in real-time.

804. SCB—and its terrorist-sponsor customer, the Iranian Petrochemical Company—

knew about all the above. Among other reasons, each event from November 8 to 14, 2011

received widespread, real-time coverage in the global media, including in the United States,

Europe, and the Middle East. Yet, upon the culmination all these dramatic developments, SCB’s

response was not to cease assisting the Iranian Petrochemical Company, but rather to help it

evade the tightening vise of U.S. sanctions yet again by telling it change its name. SCB then

continued to help the company access the U.S. financial system until at least June 2012.

805. SCB knew that providing illegal atypical banking services to the Iranian

Petrochemical Company (a/k/a Caspian Petrochemical FZE) would directly facilitate terrorist

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attacks funded, supplied, and encouraged by the SLO and IRGC, including attacks by Hezbollah,

Hamas, PIJ, and JAM; SCB knew that its Caspian Petrochemical transactions flowed funds to the

SLO and IRGC, and that the SLO and the IRGC used such funds to sponsor attacks by

Hezbollah, Hamas, PIJ, and JAM.

C. SCB Knew That Its Assistance to Elyassi Facilitated Terrorist Attacks by

Hezbollah, Hamas, PIJ, and JAM

806. From 2007 through at least 2011, SCB helped the IRGC evade U.S.

counterterrorism sanctions through its transactions with Mahmoud Reza Elyassi and his

businesses.

807. Elyassi was an agent for the IRGC and SLO. Elyassi operated a sophisticated,

transnational, U.S.-dollar denominated currency exchange in Mashhad, Iran that was connected

to essentially every major sector in which the IRGC and SLO exercised a monopoly on behalf of

the Qods Force and Hezbollah, including, but not limited to, import/export, communications,

construction, and energy.

808. Elyassi also had essentially no public profile, was based in Iran but frequently

traveled to Dubai, and attempted to recruit one or more SCB-related persons by inviting them to

visit him in Tehran.

809. Only one thing explains all these features: Elyassi’s status as an agent for the

IRGC and SLO. Simply put, as SCB knew, no Iranian national could have displayed the profile,

or engaged in the transactions, like Elyassi, without the IRGC’s and SLO’s knowledge. The

enduring nature of the scheme, combined with its cross-border (Qods Force domain) conduct

permits only one conclusion: that his conduct was blessed by the IRGC (including the Qods

Force). And that conclusion, in turn, requires—at a minimum—the conclusion that Elyassi was

acting at the IRGC’s (and Qods Force’s) behest because the IRGC did not simply permit Iranians

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to launder vast sums of U.S. dollars for years while in contact with westerners without Qods

Force involvement.

810. SCB Dubai knew these facts, employed personnel with sophisticated regional

knowledge, and benefited from the knowledge of SCB’s office in Tehran through SCB’s “One

Bank” approach in which its various branches shared information and knowledge with one

another seamlessly across borders. On March 3, 2009, for example, SCB stated: “Standard

Chartered is a rather different bank and we want to keep it like that. We run as one bank across

geographies and businesses.”

811. Regardless of whether SCB Dubai personnel connected the “Elyassi was an IRGC

and SLO agent” dots in real time—and, on information and belief, SCB Dubai employees and

agents did, in fact, figure it out—SCB Dubai knew that the subject matter of the Elyassi-related

transactions was exclusively indicative of IRGC and SLO involvement. That was enough to alert

SCB that its role in the transactions would flow funds to the terrorist proxies sponsored by the

IRGC and SLO, the most notorious of which always being Hezbollah, Hamas, and PIJ.

812. When SCB Dubai serviced Elyassi, SCB knew, among other things: (1) Elyassi

was an Iranian national; (2) Elyassi worked from Iran, but also traveled to Dubai; (3) Elyassi was

running a sophisticated sanctions evasion scheme, which SCB knew was an exclusive province

of the IRGC’s monopoly; (4) Elyassi was operating a currency exchange, which SCB knew was

also subject to an IRGC monopoly; (5) Elyassi held himself out as an import/export business,

which was yet another IRGC monopoly; and (6) Elyassi’s currency exchange activities likely

involved energy and communications technology-related transactions—two more areas of IRGC

monopoly. Simply put, SCB knew that every industry sector in which Elyassi purportedly

transacted was one for which the IRGC held a monopoly. When SCB helped Elyassi evade U.S.

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counterterrorism sanctions, it helped flow money into all these IRGC monopolies, which directly

funded the Qods Force, Hezbollah, Hamas, and JAM.

813. Statements by U.S. and U.K. prosecutors and regulators confirm that Elyassi was

an agent for the IRGC and/or the SLO. This is ineluctable for a simple reason: in connection with

SCB’s mine run of 2019 resolutions, every government authority that issued a statement

emphasized, in sum and substance, that SCB’s Elyassi-related conduct threatened the national

security of the United States and/or United Kingdom. Such statements could only have been true

if Elyassi was an agent for the IRGC and/or SLO for a simple reason that SCB knew given its

sophistication and employment of in-house and outside intelligence professionals: the IRGC and

SLO were the only two organizations in Iran that (a) directly threatened the United States and

United Kingdom, while (b) playing a large role in the international financial system and having

an insatiable need for U.S. dollars to conduct their operations. As SCB well knew, no other

Iranian organizations fit that description.205 For another simple reason, this conclusion would not

change even if one were to infer (incorrectly) that such officials were only describing the Iranian

regime’s acquisition of weapons of mass destruction, like ballistic missiles: that program was

entirely within the purview of the IRGC. Accordingly, no matter how one explains the official

statements described above, they necessarily confirm that the IRGC and/or SLO benefited from

Elyassi’s transactions with SCB because the government’s statements would be false if Elyassi

had been acting for anyone else.

205
Iran’s Ministry of Intelligence and Security (“MOIS”) provided intelligence to support IRGC
operations, and on occasion participated in attacks alongside the IRGC, e.g., kidnapping attempts
targeting enemies of the Iranian regime. Unlike the IRGC and SLO, however, MOIS does not
operate a vast network of terrorist fronts requiring U.S. dollars to operate. Moreover, MOIS
generally financed its activities through official Iranian budget processes, while the IRGC and
SLO, in contrast, drew all or nearly all the funds for their operations from off-budget sources,
most of all, their network of commercial fronts.

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814. Every transaction that SCB conducted for Elyassi was atypical. SCB Dubai used

all or nearly all its illegal tactics, techniques, and procedures as alleged in the previous section

when it provided services to Elyassi.

815. SCB’s financial services were essential to the IRGC’s ability to profit from the

Elyassi-related transactions because the IRGC needed access to New York’s financial system for

his currency exchange to work and for the ultimate IRGC beneficiaries to receive their money in

the most valuable form possible: U.S. dollars.

816. SCB defied decades of direct U.S. government warnings about the consequences

that occur when a bank helps the IRGC obtain U.S. dollars through the American financial

system in violation of U.S. sanctions targeting Iran.

817. From 2007 through at least 2011, SCB’s provision of financial services to Elyassi

flowed millions of dollars of terrorist finance each year directly and indirectly to the Qods Force,

Hezbollah, Hamas, PIJ, and JAM.

D. SCB’s Other Schemes

818. While Caspian Petrochemical and Elyassi were SCB’s two most shocking long-

term relationships with the IRGC, they were hardly the only ones. As described supra, SCB

engaged in years of misconduct on behalf of Iranian banks with clear ties to the IRGC and the

SLO—i.e., wire-stripping through the year 2007 involving billions of dollars.

819. This misconduct did not cease in 2007. As the subsequent enforcement actions

showed, SCB continued its unlawful conduct for several years thereafter.

820. According to public reports, a whistleblower who was employed at SCB from

2009 to 2011 claims to have identified many billions of dollars in additional transactions

occurring from 2008 to 2012. According to the whistleblower, data hidden in 53 spreadsheets

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reveals that SCB processed at least 500,000 additional transactions, adding up to billions of

dollars, for what SCB called its “Iran Group,” which included front companies for the IRGC,

Hamas, and Hezbollah, as well as other Iran-related entities.

821. Based on these reports as well as SCB’s documented willingness to engage in

nearly unprecedented sanctions violations, Plaintiffs allege the following facts on information

and belief:

822. On information and belief, from at least 2007 through at least late 2014 or early

2015, SCB Dubai helped the SLO access millions of dollars from New York banks through other

transactions in addition to the ones alleged above, and did so even though it knew that the SLO

directly sponsored Hezbollah, Hamas, and PIJ, and that its transactions would enable attacks by

Hezbollah, Hamas, and PIJ.

823. On information and belief, from at least 2007 through at least late 2014 or early

2015, SCB Dubai helped KAA access millions of dollars from New York banks through other

transactions in addition to the ones alleged above, and did so even though it knew that KAA was

sanctioned, and that its transactions would enable the Foundation to finance attacks by

Hezbollah, Hamas, and PIJ.

824. On information and belief, from at least 2007 through at least late 2014 or early

2015, SCB Dubai helped the Foundation for the Oppressed access millions of dollars from New

York banks through other transactions in addition to the ones alleged above, and did so even

though it knew that the Foundation was sanctioned, and that its transactions would enable the

Foundation to finance attacks by Hezbollah, Hamas, and PIJ.

825. On information and belief, from at least 2007 through at least late 2014 or early

2015, SCB Dubai helped NIOC access millions of dollars from New York banks through other

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transactions in addition to the ones alleged above, and did so even though it knew that NIOC was

sanctioned, and that its transactions would enable the Foundation to finance attacks by

Hezbollah, Hamas, and PIJ.

826. In addition, as explained supra, from at least 2008 through at least 2012, SCB

Dubai and SCB Gambia knowingly helped Hezbollah access millions of dollars through New

York banks, knowing that it would enable Hezbollah to finance attacks committed by Hezbollah

or Iran’s other terrorist proxies.

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IX. SCB Substantially Assisted The Terrorist Attacks By Hezbollah, Hamas, PIJ, and
JAM That Caused Plaintiffs’ Injuries

827. SCB substantially assisted attacks against Plaintiffs committed by Hezbollah,

Hamas, and PIJ, and JAM. When SCB willfully flowed billions of dollars into the budgets of

Iran’s Terrorist Sponsors—the Foundation for the Oppressed, Hezbollah, IRGC, SLO, and their

fronts NIOC, NITC, and KAA, among others—SCB was pouring money into a well-oiled

terrorist finance and logistics machine that ensured most of the profits Iran’s Terrorist Sponsors

generated would enable the attacks their proxies committed. At least three factors ensured an

efficient and ineluctable flow of the profits facilitated by SCB to the terrorists who committed

the attacks.

828. Logistics Policy Directive. From 2003 through 2020, the operation of the

Logistics Policy Directive, supra, meant that the IRGC earmarked most of the funds its fronts

generated to directly fund terrorist attacks committed by Hezbollah, Hamas, PIJ, and JAM.

829. Mandatory Donations (Khums). From 1979 through 2024, Ayatollah Khamenei,

the SLO, IRGC, and Hezbollah relied upon mandatory donations, or khums, comprising 20% of

all income, which flowed up to Khamenei and then back down to the Khamenei Cell and,

through the Khamenei Celll, to IRGC proxies Hamas, PIJ, and JAM, to finance terrorist attacks.

Shiite theological traditions call for donations (khums), usually equal to 20% of a person’s

income on every transaction, to support the cause. The IRGC, however, has twisted this religious

tradition, like tithing in Christianity, into something far different.

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830. Under the IRGC’s approach to khums, zakat, and other means of raising funds, the

IRGC emphasized simplicity in terms of percentages, analogous to terrorist flat taxes.206

831. Per governing IRGC and Hezbollah doctrine, the IRGC emphasizes the need to

consistently collect donations (or taxes) as something that is universally required from all profit-

generating activities and transactions—without exception—including, but not limited to, profits

generated through official business, criminal rackets, bribery and kickbacks, and a broad array of

other illicit cash flow schemes. The IRGC’s “no exceptions” rule ensures that the terrorist have

an administratively simple scheme (analogous to a terrorist flat tax), which ensures ease of

implementation, and comports with the broader IRGC emphasis on its terrorists and proxies

embracing administrative simplicity in their jihad.

832. Under IRGC doctrine, khums donations are mandatory on multiple different

transaction types, all of which ultimately flow back to fund the IRGC, including Hezbollah and

the Qods Force. First, if income flows through and IRGC-controlled front (i.e., KAA) to the

IRGC shareholders behind that front (i.e., the IRGC and Hezbollah), the respective shareholders

provide a donation to the others. Thus, for example, if SCB flowed through $100 million to the

IRGC, one may infer that the IRGC would, in turn, donate approximately 20%—$20 million—to

Hezbollah and the Qods Force in order to export Iran’s Islamist revolution abroad through anti-

American terror.

206
For example, as Ayatollah Khomeini instructed in his 1975 treatise, “superfluous
bureaucracies and the system of file-keeping and paper-shuffling that is enforced in them, all of
which are totally alien to Islam, impose further expenditures on our national budget not less in
quantity than the illicit expenditures of the first category. This administrative system has nothing
to do with Islam. These superfluous formalities, which cause our people nothing but expense,
trouble, and delay, have no place in Islam. For example, the method established by Islam for
enforcing people’s rights, adjudicating disputes, and executing judgments is at once simple,
practical, and swift.”

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833. Second, if a member of the IRGC—or a cutout acting on their behalf—receives a

substantial economic benefit, e.g., a profit from a baking transaction, IRGC doctrine mandates

that the bribe recipient kickback, mafia-style, 20% of their income to the IRGC.

834. The IRGC’s universal practice of tithing a portion of each IRGC member’s

income back to the leadership of the IRGC was under the direct, public, widely known, edict of

Ayatollah Khomeini. For example, in Ayatollah Khomeini’s seminal 1975 instruction-manual-

for-terror titled Velayat-e Faqeeh—which was always the foundation of all IRGC doctrine—the

Ayatollah decreed:

The taxes Islam levies … khums is a huge source of income that accrues to the
treasury and represents one item in the budget. According to our Sh‘ia school of
thought, khums is to be levied in an equitable manner on all agricultural and
commercial profits and all natural resources whether above or below the
ground—in short, on all forms of wealth and income. It applies equally to the
greengrocer with his stall outside this mosque, and to the shipping or mining
magnate. They must all pay one-fifth of their surplus income, after customary
expenses are deducted, to the Islamic ruler, so that it enters the treasury. … If an
Islamic government is achieved, it will have to be administered on the basis of the
taxes that Islam has established—khums, zakat …[,] jizyah, and kharaj. … The
provision of such a huge budget … was established with the aim of providing for
[inter alia] … defense [i.e., terrorism].207 … The budget of the Islamic state is
constructed in such a way that every source of income is allocated to specific
types of expenditures. Zakat, voluntary contributions and charitable donations,
and khums are all levied and spent separately. … God Almighty says concerning
the khums: “Know that of whatever booty you capture, a fifth belongs to God and
His Messenger and to your kinsmen” (8:41). Concerning zakat He says: “Levy a
tax on their property” (9:103). There are also other divine commands concerning
other forms of taxation. Now the Most Noble Messenger had the duty not only of
expounding these ordinances, but also of implementing them; just as he was to
proclaim them to the people, he was also to put them into practice. He was to levy
taxes, such as khums, zakat and kharj, and spend the resulting income for the

207
While Ayatollah Khomeini referenced the use of khums, zakat, and similar donations to
support things like the public’s welfare, that was, as Defendants knew, merely code for the “soft”
IRGC activities upon which the IRGC relied to facilitate its acts of terrorism—e.g., the IRGC
charities that served as fronts for IRGC operatives overseas. Everything the Ayatollah referenced
for which khums and similar donations were directed had a sole purpose: exporting the Islamic
Revolution, i.e., propagating acts of terrorism targeting the United States.

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benefit of the Muslims; establish justice among peoples and among the members
of the community … God has entrusted to him the task of … command, and
accordingly, in conformity with the interests of the Muslims, he [uses such taxes
to] arrange[] for the equipping and mobilization of the army.

835. Indeed, Ayatollah Khomeini specifically decreed that khums were mandatory on

any oil-related profits. Per Khomeini: “Those who work in oil deposits … must pay the khoms to

the Islamic Treasury if the profit made by him from such activities.”

836. Financial Auditors and Aggregators. Ayatollah Khamenei, the SLO, the IRGC,

and Hezbollah exercised programmatic control over their respective profits generated by their

stake in terrorist fronts operated by them or for their benefit, which the Irnaian Terrorist

Sponsors used to maximize the IRGC’s ability to convert such value into acts of terrorism

targeting the United States. For starters, as Radio Free Europe reported on September 18, 2009,

“all the IRGC’s economic activities are monitored only by internal IRGC auditors.”

837. In so doing, the Terrorist Sponsors were comporting with a terrorist version of

best financial practices. As FATF reported in 2015:

Terrorist financial management requires planning and accounting for all resources
and assets that the group controls, as well as its liabilities. Analysis of publicly-
available financial documents originally from a variety of terrorist organisations
demonstrates that financial management practices (such as documenting revenue
levels and sources, expenditure reporting, accounting) are particularly important
for terrorist groups with advanced capabilities, and particularly those that are
territorially based. Large terrorist groups will often rely on terrorist financial
managers to accumulate revenue, establish financial shelters (such as bank
accounts, front and holding entities), and oversee financial disbursements. Their
activities also include provisioning funds to the group’s leadership, members, and
operators and considering opportunities to invest any excess capital. Groups…
have actively recruited … accountants, and other financial professionals,
specifically to monitor the activities of financial entities within their areas of
control in order to better manage revenues and minimise losses.

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838. Accordingly, FATF concluded that an “area of focus” for counterterrorism

practitioners “could include identifying and targeting financial collection/aggregation/accounting

points within a terrorist organisation.”

A. SCB’s Conduct Flowed Hundreds of Millions of Dollars from the U.S.

Financial System to the Qods Force, Hezbollah, Hamas, PIJ, and JAM

1. Foundation for the Oppressed

839. SCB’s transactions directly enabled the terrorist attacks that killed or injured

Plaintiffs. Among other reasons, the Foundation for the Oppressed’s profits, assets, data, real

estate, and operatives supplied Hezbollah, Hamas, PIJ, and JAM the violent instruments such

terrorists needed to commit its attacks, including, but not limited to: (1) key, off-the-books

financing for terrorist operations, supra; (2) a transnational logistics infrastructure, including in

Iraq, Lebanon, the Palestinian territories, and Syria; and (3) the mechanisms by which Hezbollah

and the Qods Force routed attack-related payments that, by their very nature, had a direct

connection to each attack against Plaintiffs.

840. Financial transactions that benefited the Foundation for the Oppressed directly

financed Hezbollah, Hamas, PIJ, and JAM terrorist attacks in Israel, the Palestinian territories,

and Iraq because that was, always, such Foundation’s primary reason for being. Indeed, at least

two of its formal and informal leaders have publicly admitted that the Foundation funds the Qods

Force and Hezbollah: Fattah, who currently (publicly) runs the Bonyad Mostazafan, did so in

2020, and Rafiqdoost did so, at least, in 2014.

841. Accordingly, SCB’s vast direct and indirect financial assistance that flowed

through the Foundation for the Oppressed ultimately reached Hezbollah’s, Hamas’s, PIJ’s, and

JAM’s operations cells, including such groups Joint Cells in the Lebanon, Syria, and the

Palestinian territories. The Foundation was purpose-built specifically to finance Hezbollah by

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providing a transnational funding, asset, real estate, corporate, and personnel structure that was

tailor-made to access U.S. banks, markets, and institutions and purpose-built for to enable acts of

terrorism by Hezbollah and allied proxies like Hamas throughout the footprint of both

Hezbollah’s and the Qods Force’s shared, interlocking, complex, global, terrorist enterprise. The

Foundation for the Oppressed was also designed to provide complete financial, logistical, and

operational sustenance and cover to the Hezbollah and Qods Force operatives who were

embedded inside it by supporting, among other things, the Khamenei Cell, which included key

Hezbollah leaders like Hassan Nasrallah, as well as Hezbollah’s top attack planners, e.g., Imad

Mugniyeh, who was a member of the Khamenei Cell from 1983 until his death in 2008.

842. Accordingly, from 1979 through at least 2019, whenever a bank, including SCB,

directly or indirectly routed substantial value to the Foundation for the Oppressed, such value

flowed through the Foundation (including, if necessary, through applicable IRGC fronts, agents,

and “orbits”) to ultimately reach, among others, the Khamenei Cell. Indeed, such an outcome

was the entire reason the IRGC seized the Pahlavi Foundation in 1979 and converted its assets

into the Foundation. Accordingly, value transfers to the Foundation ultimately flowed through to,

and were deployed by: (1) Qassem Soleimani; (2) Hassan Nasrallah; (3) Rostum Ghasemi;

(4) Mohsen Rafiqdoost; (5) Mohsen Rezai; (6) Mohammad Forouzandeh; (7) Parviz Fattah; and

(8) Mojtaba Khamenei.

843. From 1979 through 2024, the Qods Force and Hezbollah notoriously used the

Foundation for the Oppressed’s profits to finance terrorist attacks committed by the Qods Force,

Hezbollah, and such FTOs’ proxies. As the BBC reported on March 27, 2001,

the Foundation for the Oppressed … is an organization that gives financial

support to Iran’s … acts of terrorism abroad. … The organization is supervised by
… Ayatollah Khamene’i …and is a subsidiary of the IRGC [and its investments
are] … under the control of Hezbollah like other large commercial enterprises in

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Iran. These are organizations operating under the supervision of the IRGC … [and
are] engaged in controlling people visiting Iran, selecting and training people for
Iran, financing pro-Iranian people and so on …[,] under the guise of cultural
centres and humanitarian structures.
844. United States sanctions against the Foundation for the Oppressed confirmed that

the IRGC and SLO used the Foundation’s profits, personnel, facilities, and resources to sponsor

attacks targeting the United States, including attacks targeting regime enemies. On November

18, 2020, for example, the United States imposed counterterrorism sanctions on the Foundation

pursuant to Executive Order 13876. In the same designation, Treasury confirmed that the

Foundation for the Oppressed served primarily as a front for terror and performed little

legitimate charitable work: “[w]hile the Supreme Leader enriches himself and his allies, the

Foundation’s primary mission to care for the poor has become a secondary objective. According

to the Foundation’s previous president, in past years as little as seven percent of the Foundation’s

profit has been spent on projects aimed at reducing poverty.”

845. As Treasury confirmed in 2020, the Foundation for the Oppressed always served

as a “bridge to the IRGC.” “As of 2020,” per Treasury, “according to [Foundation] President

[Parviz] Fattah, Foundation properties have been occupied by the IRGC.” Per Treasury, the

Foundation’s “vast economic wealth is partly the result of … business with … those involved

with Iran’s support of international terrorism” including trade with “the IRGC and … MODAFL,

… which have been previously designated under multiple authorities, including counterterrorism

authorities.”

846. As Treasury explained in 2020, the Foundation for the Oppressed “maintain[ed]

close ties to the IRGC, personified by current Foundation president and former IRGC officer

Parviz Fattah,” who served as a “bridge to the IRGC.” In such role, the Foundation always

served to “line the pockets of [Ayatollah Khamenei’s] allies,” including Fattah, who was

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appointed to lead the Foundation “in July 2019,” after previously serving as, inter alia,

“managing director of the IRGC-linked Bonyad Taavon Sepah” and “head of the Imam

Khomeini Relief Committee, whose Lebanon branch was designated pursuant to counter-

terrorism authorities in 2010 for being owned or controlled by, and for providing financial and

material support to, Hizballah.” “Known for his loyalty to the Supreme Leader, Fattah has also

forged ties to senior IRGC-Qods Force … officials,” including “former IRGC-QF commander

Qassem Soleimani.” Indeed, “Soleimani sought Fattah’s assistance to finance the Fatemiyoun

Brigade, an IRGC-QF-led militia composed of Afghan migrants and refugees in Iran coerced to

fight, … including children as young as 14 years old,” which, “like the IRGC-QF itself, is

designated pursuant to both counterterrorism and human rights authorities.”

847. Treasury also confirmed that the Iranian regime used the Foundation for the

Oppressed’s “assets” to finance designated terrorists who served in “the Supreme Leader’s inner

circle” including Gholam-Ali Haddad-Adel, a Khamenei confidant,” against whom the U.S.

government imposed counterterrorism sanctions pursuant to Executive Order 13876 in

November 2019.

848. Per Treasury, the IRGC used Foundation for the Oppressed resources to directly

finance attacks targeting the Iranian regime’s perceived enemies. While the Foundation was

“ostensibly a charitable organization charged with providing benefits to the poor and oppressed,

its holdings [were] expropriated from the Iranian people and are used by … Ali Khamenei to …

persecute the regime’s enemies.” As Treasury Secretary Mnuchin observed when the U.S.

sanctioned the Foundation in 2020, “Iran’s Supreme Leader use[d]” the Foundation “to reward

his allies under the pretense of charity” by using it as a “revenue generating source[] that

enable[d] the regime’s ongoing repression of its own people.”

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849. U.S. government statements confirming the Foundation for the Oppressed’s direct

connection to IRGC- and Hezbollah-sponsored, proxy-committed, terrorist attacks targeting the

United States described a consistent pattern of conduct that existed at all relevant times

throughout Defendants’ scheme with the IRGC and Hezbollah. These sources show that the

Foundation for the Oppressed was closely intertwined with terrorist violence because the Qods

Force and Hezbollah used Foundation profits to fund attacks.

850. Hezbollah and the Qods Force used the Foundation’s profits to finance terrorist

attacks committed by their proxies in at least six ways. Among other ways, the Qods Force and

Hezbollah notoriously used the Foundation’s profits to finance: (1) martyr payments to the

families of Qods Force and Hezbollah terrorists who were killed while executing such FTOs’

attacks; (2) bounty payments directly to Qods Force and Hezbollah proxies Hamas, PIJ, Kataib

Hezbollah, the Houthis, and the Taliban to reward successful attacks targeting the United States

in which an American was killed or taken hostage; (3) operations payments to finance the costs

of specific attacks (e.g., pre-attack lodging); (4) salary payments paid to Qods Force and

Hezbollah leadership, and to the leaders of Qods Force and Hezbollah proxies Hamas, PIJ,

Kataib Hezbollah, the Houthis, and the Taliban; (5) logistics payments to finance terrorist

ratlines and training; and (6) laundered payments routed through Foundation-affiliated

charities, like the Imam Khomeini Relief Committee, which served as cut-outs for the Qods

Force and Hezbollah, and helped such FTOs build their logistics networks in countries like the

Palestinian territories, Iraq, Yemen, and Afghanistan.

851. Contemporaneous reports and findings by U.S. and E.U. counterterrorism

officials confirm Plaintiffs’ allegations. On June 22, 2006, for example, senior Treasury

counterterrorism official Pat O’Brien publicly testified that “Iran [] actively sponsors terrorism

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and violence across the Middle East … [through] [t]he Islamic Revolutionary Guard Corps

(IRGC),” which was “directly involved in the planning and support of terrorist acts by non-state

actors and continue to sponsor and train a variety of violent groups that act as surrogates on

Iran’s behalf” as IRGC proxy “terrorist … groups in Lebanon, the Palestinian territories,

and Iraq,” which in “posed” a “very real threat” to the United States “by Iran’s sponsorship of

terrorism” and depended upon “the lines of support that fuel terrorist activities” for which the

IRGC’s “money flows … draw[] upon a large network of state-owned banks and parastatal

companies,” i.e., foundations.

852. On July 27, 2010, the E.U. found that, inter alia: (i) “Bonyad-e Mostazafan” was

among the IRGC fronts that “contributes to the financing of the strategic interests of the regime

and of the Iranian parallel State”; and (ii) the Iranian regime pursued such strategic interests

through IRGC-sponsored terrorist attacks targeting the United States: “[The] … Qods Force is

responsible for operations outside Iran and is Tehran’s principal foreign policy tool for special

operations and support to terrorists and Islamic militants abroad. Hizballah used Qods Force-

supplied rockets, anti-ship cruise missiles (ASCMs), man-portable air defense systems

(MANPADS), and unmanned aerial vehicles (UAVs) in the 2006 conflict with Israel and

benefited from Qods Force training on these systems, according to press reporting. According to

a variety of reporting, the Qods Force continues to re-supply and train Hizballah on advanced

weaponry, anti-aircraft missiles, and long-range rockets.”

853. Former senior U.S. officials confirmed that U.S. sanctions targeting the

Foundation for the Oppressed recognized that the Foundation’s profits financed IRGC-sponsored

proxy attacks. On March 3, 2022, Gabriel Noronha, Former Special Advisor for Iran at the State

Department, publicly observed: “[S]anctions on some of the regime’s worst terrorists …

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[included] sanctions on Khamenei’s personal slush funds known as ‘bonyads,’ including …

[s]anctions … on Bonyad Mostazafan [Foundation for the Oppressed], a massive conglomerate

that … is enmeshed with the IRGC and is a corruption network used to enrich top Iranian

terrorists. … [U.S. Department of State] lawyers were clear when we released this [Executive

Order sanctioning entities like the Foundation for the Oppressed in November 2020]: it was a

response to actions by Iran & its proxies to …. promote international terrorism … [and sponsor]

attack[s] against US military assets [and] civilian vehicles.”

854. Public decrees by Ayatollah Khamenei confirmed that the Foundation for the

Oppressed served as a front for Hezbollah and the Qods Force, and alerted SCB to the same. For

example, in 1989, 2012, and other occasions when he appointed a new executive director of the

Foundation, the Ayatollah publicly touted how the Foundation promoted “resistance,” supported

“martyrs,” and helped liberate the “oppressed”—which were all widely known, and infamous,

euphemisms for IRGC-sponsored attacks targeting America.

855. IRGC admissions confirmed that the Foundation for the Oppressed’s support

enabled terrorist attacks by Hezbollah, the Qods Force, and their proxies. On November 3, 2012,

for example, a “reporter” for IRGC-controlled media outlet Aftab acknowledged that the

Foundation supported IRGC proxies “[i]n countries like Syria and Palestine, where Iran’s

interests are outside the country... that means the activities of the Foundation [for the Oppressed]

to help [IRGC proxies like] Bashar al-Assad’s government.” Under the same rationale, the IRGC

used the Foundation for the Oppressed to sponsor acts of terrorism in Iraq, Yemen, and

Afghanistan, just as the IRGC did elsewhere.

856. Terrorism scholars also confirmed, and alerted SCB, that the Foundation for the

Oppressed was a front for Hezbollah and the Qods Force, and its notorious reputation for directly

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funding IRGC terrorist proxies in the Middle East continued at all relevant times. In 2016, for

example, Mehran Riazaty—who served the U.S. military as an Iran Analyst attached to Multi-

National Forces, Iraq—observed that “[t]actically, Bonyads are often connected to the Iranian

Revolutionary Guard Corps [and] Operatives from the IRGC [i.e., IRGC-IO], along with

members of Al-Qods [i.e., Qods Force] and Hezbollah, and often go undercover, representing

themselves as employees or officials of trading companies, banks, and cultural centers, or as

representatives of the Bonyad of the Oppressed and Dispossessed [i.e., the Foundation for the

Oppressed].”

857. Decades of other reports and statements published by the United States, Iranian

regime, Iranian opposition, media, terrorism scholars, and NGOs confirmed that the Foundation

for the Oppressed was a front for Hezbollah and the Qods Force that enabled such FTOs’ attacks,

and alerted Defendants that their value flow-through to the Foundation for the Oppressed as one

of their counterparties’ ultimate beneficial owners fueled Qods Force and Hezbollah-committed

terrorist attacks, including, but not limited to:

a. Montreal Gazette, June 4, 1994: “The United States, most crucially, continues to classify
Iran as a state sponsoring terrorism. It makes no distinction between official and
unofficial Iranian actions, though there is strong reason to believe that directing many of
Iran’s more dubious overseas activities - including support for the Hezbollah in Lebanon
- is not the core of government but the ‘bonyads.’”

b. Christian Science Monitor, February 1, 1995: “[D]espite corruption allegations[,] …

[IRGC] General [Mohsen] Rafiqdoost is the managing director of Iran’s Foundation of
the Oppressed … [M]any analysts hold that Rafiqdoost’s interests go beyond helping the
poor of Iran. Western security sources believe the bonyads are used by Iran’s religious
authorities as deniable vehicles to finance … Hizbollah … ‘There is bonyad money going
to Lebanon, for sure,’ said one source in Iran …. ‘Look, the bonyad works in harmony
with the government,’ explained Rafiqdoost. ‘At times we go to their aid.’”

c. Newsday, May 28, 1995: “[I]n a four-month investigation based on dozens of interviews
with law-enforcement officials and U.S. government specialists, knowledgeable Iranians
who support the regime as well as dissidents, and public and private documents,
Newsday has found that: [The Foundation for the Oppressed] … is controlled by Iran’s

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clerical leadership, federal officials say. … [The Foundation] finances [entities] in the
United States that support Iran’s militant … Islam and provides safe haven for groups and
individuals supporting the Islamic terrorist group[] … Hezbollah. … In a classified report
… the FBI asserted that [the Foundation] was ‘entirely controlled by the government of
Iran,’ which used [the Foundation for the Oppressed] to set up ‘covert subbranches
disguised as educational centers, mosques and other centers.’ … The FBI report,
according to a U.S. official, claims that [the Foundation] funds ‘fundamentalist extremist
groups’ and that Iranian students who received scholarships from [the Foundation] to
study in the United States ‘gather[ed] intelligence’ … and collected “technical and
scientific information” for the Iranian regime. In 1989, Oliver Revell, then the No. 2
official at the FBI, told the Senate terrorism subcommittee that some of the ‘students’
receiving [the Foundation’s] grants were in fact [IRGC, including Qods Force] agents. …
Revell … said much of [the Foundation]’s funds go to ‘a great number of mosques (in the
United States) . . . where there are organizations which directly support Hezbollah…[,]’
an Iranian-supported [] group … that has launched terrorist attacks under the tutelage of
the Revolutionary Guards. … The [Foundation] is administered by Mohsen Rafiqdoost,
founder of the Revolutionary Guards.”

d. Financial Times Mandate, April 23, 1996: “[B]onyad[s] have a reputation for …
corruption. The richest and most notorious, according to Iranian analysts, is the
Mostazafan (the foundation for the deprived [i.e., the Foundation for the Oppressed]),
which is controlled by the Islamic Revolutionary Guard Corps. … Everywhere, … there
is talk of greater economic liberalism … But Iran continues to spend money … on
exporting Islamic revolution.”

e. Financial Times Mandate, July 17, 1997: “Of all the state-vested interests competing for
… scarce hard currency, Tehran businessmen say the most formidable are the bonyad, the
state foundations set up by the clergy after the revolution and directed by political
nominees without regard to business experience … Many economic commentators say it
is the opacity and power of such privileged corporations, their reputation for
mismanagement, obsessive secrecy and covert operations that are a greater deterrent to
foreign investors than the fear of running foul of US sanctions, which Tehran blames.
Among the Bonyad, the most notorious is the Bonyad Mostazafan, the ‘foundation for the
oppressed and disabled’. … The autonomy of the bonyad is not confined to banking,
commerce or industry. One of them unilaterally took the initiative in 1989 to offer the
Dollars 2m [] ‘bounty’ for Mr Salman Rushdie, the British author.”

f. Newsday, December 8, 1998: “[T]he … Mostazafan Foundation [] controls billions of

dollars of investments in Iran and around the world … [and] has been accused by western
intelligence services of … supporting terrorism.”

g. BBC, June 14, 2002: “Iran has been financing the Islamic Jihad Organization … since the
group’s establishment but its budget reached it through Hezbollah. The latter’s budget is
paid by Iranian establishments [i.e., foundations a/k/a bonyads], the vali-e faqih office
[i.e., the Supreme Leader’s Office], the Revolutionary Guards’ liberation movements’
office, in addition to the Qods Forces and exceeds 200m dollars. … Regarding the
increase in Hezbollah’s budget, the source said the party receives aid from various

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sources in addition to its annual budget and these come from … Iran … [including] [the]
‘Mostaza’fin’ (Foundation for the Oppressed) …”

h. Forbes, July 21, 2003: “[Under the IRGC’s] The Cosa Nostra meets fundamentalism
[approach,] [t]heoretically the Mostazafan Foundation is a social welfare organization. …
Why does this foundation [i.e., the Foundation for the Oppressed] exist? … A picture
emerges from one Iranian businessman who used to handle the foreign trade deals for one
of the big foundations. Organizations like the Mostazafan [i.e., Foundation] serve as giant
cash boxes, he says, to pay off supporters of the mullahs, … [including] Hezbollah …
and, not least, the foundations serve as cash cows for their managers [i.e., the IRGC
including the senior IRGC terrorists who ran the Foundation].”

i. Newsmax, June 3, 2009: “Once Iran created Hezbollah in 1983, Mousavi coordinated the
financing for it as the head of the Bonyad Mostazafan, which he chaired as prime
minister. ‘For example, … Mousavi set up a scheme so that Hezbollah would get a share
of Iranian [] sales,’ Mesbahi said. … Under the scheme, [an agent of the Foundation for
the Oppressed] established front companies for the [] transactions in [Europe], ‘and the
banks would do the rest, putting commissions into the Hezbollah accounts under
fictitious names,’ [former Iranian intelligence officer, Abdolghassem] Mesbahi said.”

j. Kerry Patton (Combat-Disabled Veteran; Senior Analyst, Wikistrat), January 2, 2012:

“Bonyads assist in fueling world terror, enhanced military might, and promotion of
propaganda and ‘comfort for the oppressed.’ … Enforcement of Iran’s Bonyads is both
strategic and tactical. … Tactically, Bonyads are often interrelated to the Iranian
Revolutionary Guard Corp (IRGC). Operatives from the IRGC along with members
founded in Al Quds and Hezbollah go undercover portraying themselves as employees or
officials of trading companies, banks, cultural centers or as representatives of the
Foundation of the Oppressed and Dispossessed (Bonyad-e- Mostazafan) ... Bonyads are
funded actively and passively. The Islamic alms giving known as Zakat often serves as a
Bonyad contributor.”

k. Robert A. Manning (Atlantic Council), April 30, 2015: “The IRGC … controls much of
economy through the Bonyads [the largest of which was the Foundation for the
Oppressed]. In addition there is the Qods Force, an elite group in the IRGC that leads
interventions abroad – [including by partnering with] … Hezbollah …”

l. Dr. Hesam Forozan (Middle East Scholar), 2015: “In addition to its internal organization
units designed for its personnel, the [IRGC] has at its disposal a host of units and
departments, … Many of these units exert an indirect influence on and are in close liaison
with other governmental, extra governmental and revolutionary organizations. These
include … the Foundation of the Oppressed .… Partly because of their connection with
the [IRGC], the directors and managers of these foundations were capable of gaining
access to sources of capital and government tender. For example, both the current and
former heads of the [Foundation for the Oppressed], Mohammad Forouzandeh and
Mohsen Rafiqdust, come from the ranks of former [IRGC] officers. Following the post-
war reduction of the military budget, the [IRGC] augmented its ties with clerical-
controlled foundations, in particular the [Foundation for the Oppressed]. … the

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[F]oundation apparently undertakes international endeavors that transgress the traditional

definition of trade – the [Foundation] is commonly cited as a generous supporter and
active political patron of the Lebanese Hezbollah terrorist organization.”

m. Dr. Mohammad al-Sulami (PhD, International Relations), August 31, 2020: “Systemic
state corruption in Iran … ha[s] reached record-breaking levels within … the … IRGC …
Parviz Fattah, the head of the … Foundation for the Oppressed … admitted this month
that the IRGC … had used the foundation to engage in projects worth billions. This
means the revenues generated from these projects have gone to the IRGC, not the
foundation. … Fattah’s revelations have once again exposed the Iranian regime’s claim
that it defends the vulnerable and oppressed, with the regime-backed IRGC profiteering
from a foundation that is supposedly dedicated to helping the oppressed.”

n. Cyrus Yaqubi (Iran Scholar), January 24, 2021: “[W]here does the [Foundation for the
Oppressed’s] revenue go? … Since US sanctions caused a sharp decline in Iran’s official
revenues, the regime is facing financial difficulties and cannot fund its proxies to meddle
in the [Middle East] region or as the mullahs’ call it ‘expand its strategic scope’. Iran
cannot fund its proxies including Hezbollah, and its multitude of militia forces in Iraq and
Yemen, or its Afghan Fatemiyoun Division … in Syria using its official annual budget.
The millions of dollars used to fund these group must be provided from other financial
sources. …[B]onyads such as Bonyad-e-Mostazafan [Foundation for the Oppressed], are
among the organizations that have directly assisted the Quds Force in this regard. Iranian
opposition sources have previously stated that the Quds Force receives most of its funds
from [bonyads]. … The US’s decision to sanction [bonyads] will definitely be welcomed
by Iranians who are tired of having their stolen wealth used for terrorism.”

o. Dr. Mark D. Silinsky (Former DOD Military Intelligence Analyst and Adjunct Professor
at the U.S. Army War College), 2021: “Today, bonyads … acquir[e] and distribut[e]
wealth to the Guards [i.e., the IRGC]. The operations and business models of bonyads are
very opaque because of corruption and mismanagement. One financial analyst snickered,
‘Who know how they function? They are like a black hole.’ Similar to nonprofit
organizations, bonyads are tax-exempt charitable entities. Senior personnel are adept at
transferring funds from one element to another to subvert U.S. sanctions and channel
funds toward terrorist operations. ... The largest bonyad [i.e., the Foundation for the
Oppressed] funds Hezbollah and operates in Europe and Asia.”

2. The Iranian Petrochemical Company

858. By providing financial services to the Iranian Petrochemical Company (a/k/a

Caspian Petrochemical FZE) from 2007 through at least June 2012, SCB provided direct and

indirect assistance to the Qods Force, Hezbollah, Hamas, and JAM from at least 2007 through at

least 2019. For example, facilities that Caspian Petrochemical built with SCB’s services

continued flowing value to these terrorist groups until at least 2019.

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859. SCB’s financial services were essential to the Iranian Petrochemical Company’s

ability to profit from the oil and gas it sold. Access to the U.S. financial system was essential

because nearly all oil and gas transactions are denominated in U.S. dollars. Similarly, giving the

Iranian Petrochemical Company access to New York banks allowed it to maintain its cover as

front; transacting through New York imbued its transaction with legitimacy.

860. SCB knew that, by helping the Iranian Petrochemical Company transact, the bank

was providing Iran’s Terrorist Sponsors—through the Iranian Petrochemical Company’s

revenue—the seed capital to allow it to grow, operationalize, and monetize its factory in the

South Pars field, both at the time SCB provided the services and for years thereafter. SCB’s

services provided long-lasting financial benefits to the Iran’s Terrorist Sponsors and their

proxies, even years after SCB stopped providing them. As SCB knew at the time it helped the

Iranian Petrochemical Company, financial services provided to oil and gas producers, and their

associated market contracts, usually have a long “tail”—i.e., if a bank helps an oil producer

finance a big facility or transaction, the customer will benefit from the financing facility for years

thereafter. Accordingly, when SCB helped the Iranian Petrochemical Company access the U.S.

financial system to support its transactions, SCB knew that it would be helping the Iranian

Petrochemical Company—and, in turn, the IRGC—realize sustainable profits for years after

SCB processed its final transaction.

861. The Iranian Petrochemical Company was a company that sought to help the

Iranian regime generate more oil revenue. Decades of reports confirm that such fact alone—and

nothing else—alerted SCB that its transactions likely facilitated IRGC-sponsored terrorism by

groups like Hezbollah, Hamas, and PIJ. Decades of reports and statements by the United States,

terrorists, media outlets, terrorism scholars, and ordinary citizens alerted SCB that every time it

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provided illicit financial services to any customer in connection with Iranian oil- or gas-related

transaction, it ran an extreme risk that the other side was funding the Qods Force, Hezbollah,

Hamas, and JAM and, moreover, even if such person was not, the end revenues would likely

flow to such terrorists, given the Iranian regime’s long-standing and unique treatment of the

revenues it realized from its oil and gas monopoly. Such reports included, but were not limited

to:

a. Agence France Presse English Wire, February 6, 2006: “Iran … formally notified the
[IAEA] of its decision to restart sensitive nuclear work at the centre of concerns the
hardline regime could acquire nuclear weapons. Senior [Iranian] officials also played
down the threat of sanctions … emphasising [Iran]’s vast oil wealth … in an interview
with Handelsblatt, US Defence Secretary Donald Rumsfeld said the United States does
not rule out using military force against Iran. ‘All options, including the military one, are
on the table,’ Rumsfeld [said], repeating his fears that weapons of mass destruction could
fall into the hands of terrorists and branding Iran ‘the main sponsor of terrorist
organisations such as Hezbollah and Hamas.’ But [regime spokesman Gholam Hossein]
Elham said oil-rich Iran still had the upper hand when it came to enduring any eventual
sanctions. … ‘Any decision in this regard [i.e., for the United States to impose sanctions
targeting the IRGC, responsible for Iran’s nuclear program] will not hurt us. It will hurt
the consumers and not the producers. We are in a position of power when it comes to
energy, and it will not have any affect [sic] on our budget,’ he said.”

b. White House Press Secretary Scott McClellan, February 22, 2006: “[Reporter:] Iran, as
you probably know, has now said that it would help fund Hamas, has said that its oil
revenues ... will help amply pay for Hamas as needed. What’s the U.S. reaction? And
does this undercut any sanctions against Iran? [McClellan:] Well, … the regime in Iran
… [has] been a destabilizing force in the … Middle East. Our views are very clear when
it comes to the regime. ... And in terms of Hamas, ... we’ve made it very clear that ... they
continue to engage in terrorism and continue to advocate the destruction of Israel.”

c. President of Israel Shimon Peres, March 18, 2008: “Iranian oil money is funding world
terror, including Hamas and Hezbollah terror.”

d. Agence France Presse English Wire, March 18, 2008: “After meeting [German
Chancellor Angela] Merkel, [Israeli President Shimon] Peres stressed that … ‘the money
earned from oil enables Iran to finance international terrorism, particularly the terrorism
of Hezbollah and Hamas.’”

e. Jerusalem Post, March 19, 2008: “German Chancellor Angela Merkel told the Knesset ...
‘I say it in a clear voice - the [Hamas and PIJ] Kassam [rocket] fire [targeting Israeli
civilians] must stop,’ Merkel said. ‘Terror attacks are a crime, and do not resolve political
disputes.’ Prime Minister Ehud Olmert praised Merkel’s ‘strong and determined position

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against the horrific calls from the president of Iran to wipe Israel off the map ….’ ...
Merkel, … also met with President Shimon Peres, who said … that Iranian oil revenue
was funding world terrorism - including Hamas and Hizbullah.”

f. Reuters, May 5, 2008: “Israeli President Shimon Peres … said … ‘Oil ... is [] promoting
terror,’ said the 84-year-old Nobel Peace Prize winner … Peres argued that manifold
increases in oil prices in recent years had contributed to a rise in financing for terrorism
in the Middle East … Peres took particular aim at Iran, repeating recent comments that
Tehran’s nuclear programme and its rhetoric against Israel may pose a greater threat than
the Nazis in the 1930s and 40s. Israel accuses Iran, a major oil and gas producer, of
financing Hezbollah, the Lebanese guerrilla movement, and Hamas, which controls the
Palestinian Gaza Strip, both of which are sworn enemies of Israel.”

g. Joplin Globe, January 17, 2009: “Make no mistake; Iran is a strong and tenacious
adversary. Fueled with petro dollars from their abundance of oil reserves, Iran supports
strong anti-Israeli and anti-Western militias such as Hamas and Hezbollah. Iran is
responsible for many thousands of American and Iraqi deaths.”

h. Senator John Kerry, May 12, 2009: “[A] massive continuous transfer of American wealth
to oil exporting nations ... [flowed] revenues and power and sustained … global terror
funded indirectly by our expenditures on oil … Too often the presence of oil multiplies
threats ... Iran uses petrol dollars to fund Hamas and Hezbollah ....”

i. Newsweek, June 29, 2009: “In 2005 … Khamenei backed Ahmadinejad …, a veteran of
the … Revolutionary Guards and willing to kiss the Supreme Leader’s feet. Ahmadinejad
won. In the four years since, taking advantage of billions in windfall revenues from high
oil prices, Iran has … funded Hamas as it took over Gaza, and supported and armed
Lebanon’s Hizbullah in its 2006 war with Israel.”

j. APS Review Oil Market Trends, April 5, 2010: “Without money from oil, [Israeli
Infrastructure Minister Uzi] Landau argued, Iran would fade as a regional power and
‘terror groups’ such as Hamas … and Hizbullah … would cease to exist.”

k. Dr. Abdallah al-Nafisi (Academic; Al Jazeera Commentator), June 16, 2010: “Iran gets
on every boat to reach power and influence in the Arab region. A country very rich with
… oil revenues, Iran uses its establishment of and support for Hezbollah … and its
support for Hamas and … as bridges to get to its objectives. What harms Iran if it gives
Hamas $23 million monthly to run things in Gaza? What harms Iran if it gives the Islamic
Jihad $5 million or so to maintain the Palestinian gun? But in return, Iran gains much. It
is as if Iran is telling Israel: My border is in Gaza, not in Tehran, and my border is in Al-
Urqub [in south Lebanon] through Hezbollah, not in Tehran. So, Iran is gaining a great
deal of ... physical influence through its support for Hezbollah and Hamas. ... We
welcome Iran’s support for [Hezbollah] and its support for Hamas and others.”

l. Elliot Bartky and Allon Friedman (Jewish American Affairs Committee of Indiana),
August 1, 2011: “[D]eprive Iran of the oil revenue they’ve used to support terrorist
groups such as Hezbollah and Hamas, … and … kill American troops in Iraq.”

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m. Jerusalem Post, May 28, 2013: “[E]ntrenched oil interests … [in] Iran … and the
downstream industries their petro-dollars support worldwide [mean that] … [a]s long as
Iran … can export oil profitably, Hamas [and] Hezbollah … can have their weapons
underwritten by the oil addictions of the regular oil consumers of the world.”

n. Kevin McGee (Univ. of Wisconsin-Oshkosh), September 13, 2015: “[Acts] that will
allow Iran to sell much more oil [are inextricably connected to the IRGC’s] … use [of]
some of the [resulting oil] revenue to support Hamas, Hezbollah and its other cronies.”

862. The U.S. government has directly confirmed that a European bank’s decision to

finance the transactions related to the Iranian Petrochemical Company from 2008 through 2012

funded IRGC-sponsored terrorist attacks targeting the United States. On June 30, 2014, the

United States announced that, per DOJ, “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.” Per DOJ, by

“providing dollar clearing services to individuals and entities associated” with “Iran” in “clear

violation of U.S. law,” the bank “helped [Iran] gain illegal access to the U.S. financial system,”

and in “doing so,” the bank “deliberately disregarded U.S. law of which it was well aware, and

placed its financial network at the services of rogue nations” through its “criminal support of

countries and entities engaged in acts of terrorism and other atrocities.” (Emphasis added.) On

information and belief, DOJ’s statements above were specifically about a European bank’s

violation of Iran-facing sanctions, including Iran-facing petroleum-related sanctions, on behalf of

the same Iranian Petrochemical Company that SCB assisted during the same period. On

September 21, 2015, for example, CNBC reported that a “[a]mong the French bank’s violations

were transactions with Caspian Petrochemical FZE” and “[e]vidence from the BNP probe led

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investigators to believe that StanChart [i.e., SCB] may also have breached sanctions in its

transactions with Caspian Petrochemical FZE.”

863. SCB’s transactions on behalf of the Iranian Petrochemical Company fueled

Hezbollah’s and Hamas’s acts of terrorism against Plaintiffs. Decades of government reports and

speeches published by the United States, United Kingdom, European Union, and United Nations

confirmed the IRGC’s oil-related financial transactions that benefited the IRGC were

inextricably connected with IRGC-sponsored acts of terrorism targeting the United States that

were committed by the Qods Force and the Axis of Resistance it led, including Hezbollah,

Hamas, and JAM. As Secretary of State Pompeo confirmed in 2020, while describing country-

wide oil-related sanctions targeting Iran and the IRGC like the sanctions that SCB schemed to

help the IRGC evade years earlier:

[S]anctions have denied Iran more than 90% of its oil export revenue, depriving the
regime access to well over $70 billion in income that could have otherwise gone to fund
terror operations …. These actions have saved the lives of innumerable Iranians, Syrians,
Iraqis, Yemenis, and other innocent civilians in the regime’s crosshairs … [through] the
full spectrum of Iran’s malign influence [including] its support to Shia militia groups in
Iraq, [and] its longstanding sponsorship of Hizballah in Lebanon …
In September 2019, the U.S. Department of the Treasury exposed a large oil shipping
network that was directed by, and financially supported, the IRGC-QF and its partner
Hizballah. The network was overseen by senior IRGC-QF official and former Iranian
Minister of Petroleum Rostam Qasemi and employed an extensive network of ship
managers, vessels, and facilitators in order to move oil worth hundreds of millions of
dollars or more for the benefit of … Hizballah, and other illicit actors. The networks
complex system of intermediaries allowed the IRGC-QF to obfuscate its involvement.
The IRGC-QF relied heavily on Hizballah officials and front companies to broker
associated contracts.

864. From the 2010 through the present, such U.S., U.K., E.U., and/or U.N.

government findings, reports, statements, and warnings included, but were not limited to:

a. Treasury, June 16, 2010: “KAA … [is] the engineering arm of the IRGC that serves to
help the IRGC generate income and fund its operations. … The IRGC maintains
significant political and economic power in Iran. It has ties to companies controlling
billions of dollars in business and construction projects and it is a growing presence in

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Iran’s financial and commercial sectors. The IRGC has numerous economic interests
related to … the oil industry.”

b. State, April 8, 2011: “Official Corruption … [:] … [T]he supreme leader continued to
transfer a large portion of the country’s … oil and gas … sectors to the IRGC. In recent
years [Khamenei] gave control over state enterprises to the IRGC through the granting of
special privileges. IRGC companies were large enough to underbid competitors and were
generally favored in the bidding process for large contracts.”

c. Treasury, March 28, 2012: “‘Treasury is sending a clear signal … that … [w]e will
continue to target the Iranian regime and specifically the IRGC as it … continue[s] its
nefarious infiltration of the Iranian economy,’ said Adam Szubin, Director of [OFAC].
The IRGC continues to be a primary focus of U.S. and international sanctions against
Iran because of the central role the IRGC plays in Iran’s … support for terrorism …. The
IRGC has continued to expand its control over the Iranian economy – in particular in the
… oil and gas industries – subsuming increasing numbers of Iranian businesses and
pressing them into service in support of the IRGC’s illicit conduct.”

d. State, May 24, 2012: “The IRGC operated numerous front companies that were engaged
in illicit trade and business activities. The IRGC includes a construction arm (Khatam ol-
Anbiya) that had extensive economic operations and ties to the oil sector and benefited
from corruption within that sector.”

e. Treasury, May 23, 2013: “‘As long as Iran continues [its] … defiance of multiple UN
Security Council Resolutions, the U.S. will target and disrupt those involved in Iran’s
illicit activities,’ said Treasury Under Secretary for Terrorism … David S. Cohen. ‘We
will continue to work with our international partners to intensify this pressure and tighten
sanctions on Iran’s energy sector as it provides much needed financial support for the
Iranian regime’s proliferation activity.’”

f. DOJ, July 1, 2020: “In 2014, … Treasury further noted that under the current Iranian
regime, the IRGC’s influence has grown within NIOC. For example, on August 3, 2011,
Iran’s parliament approved the appointment of Rostam Qasemi, a Brigadier General in
the IRGC, as Minister of Petroleum. Prior to his appointment, Qasemi was the
commander of [KAA], a construction and development wing of the IRGC that generates
income and funds operations for the IRGC. … On April 8, 2019, the President designated
the IRGC as a Foreign Terrorist Organization. The designation noted that the IRGC
actively finances and promotes terrorism. On April 15, 2019, the Secretary of State
designated the IRGC, including the IRGC-QF, as Foreign Terrorist Organization.
According to … Treasury, the IRGC and its major holdings have a dominant presence in
Iran’s … oil industry and the profits from these activities support the IRGC’s full range
of nefarious activities, including … support for terrorism … abroad. … “[IRGC] profits
from [commercial] activities support the IRGC’s full range of nefarious activities,
including … support for terrorism… abroad. ‘The IRGC systemically infiltrates critical
sectors of the Iranian economy to enrich their coffers, while engaging in a host of other
malign activities,’ said then-Under Secretary for Terrorism … Sigal Mandelker.”

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865. When the IRGC priced its black market oil, liquefied petroleum gas (“LPG”), and

other petroleum products, it took a simple approach: take the then-existing, publicly reported

global market price for such commodity, and then haggle with their black market buyer over the

size of a discount from that prevailing price to reflect the IRGC’s inability to sell to any

customer. At all times, the average price for LPG imports ranged between $600 - $1,200 per ton,

IRGC fronts that sold LPG to black market buyers reportedly offered discounts for around $100

per ton for large shipments. Thus, for example, if the price of LPG was $1,000 per ton, the IRGC

would offer to sell the LPG at a discounted price of $900 per ton. On that sales price, the IRGC

kept around 75% of that sum as the profit. Accordingly, from 2007 through 2020 each ton of

IRGC LPG sold by the IRGC likely caused, at least, $300 in terrorist finance to flow through the

transaction to the IRGC (including its Qods Force) and SLO and, through the Qods Force and

SLO, to Hezbollah, Hamas, PIJ, and JAM to finance their terrorist attacks in the Middle East.

866. Given the IRGC’s oil- and gas-production-related profit margins, SCB’s

facilitation of the IRGC’s sales of oil and gas through SCB’s transactions on behalf of, or

otherwise involving, Iranian Petrochemical Company produced a financial windfall for the Qods

Force, Hezbollah, and proxies, including Hamas, PIJ, and JAM.

867. Representative transactions involving Caspian Petrochemical-related sales in

2017 and 2018—the direct product of SCB’s years of illegal aid—confirm the point:

868. In or about July 2017, Caspian Petrochemical coordinated with other IRGC fronts

described herein to deliver about 44,000 tons of LPG produced by IRGC front PGPIC (affiliated

with IRGC front KAA)—which PGPIC extracted from the IRGC’s crown jewel, the South Pars

gas field—and was shipped to a customer outside of Iran aboard the Gas Commerce.

a. In or about July 2017, Caspian Petrochemical coordinated with other IRGC fronts
described herein to deliver about 44,000 tons of LPG produced by IRGC front PGPIC

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(affiliated with IRGC front KAA)—which PGPIC extracted from the IRGC’s crown
jewel, the South Pars gas field—and was shipped to a customer outside of Iran aboard the
Gas Commerce.

b. In or about December 2017, Caspian Petrochemical helped IRGC front PGPIC (affiliated
with IRGC front KAA) export 44,000 tons of LPG that the IRGC produced at the IRGC’s
South Pars field, which the IRGC (through Caspian Petrochemical, among others)
shipped, aboard the Gas Commerce, to a buyer in Asia.

c. In or about January 2018, Caspian Petrochemical helped IRGC front PGPIC (affiliated
with IRGC front KAA) export 44,000 tons of LPG that the IRGC produced at its South
Pars field, which the IRGC (through Caspian Petrochemical, among others) shipped,
aboard the Pacific Rizhao, to a buyer in Asia.

d. In or about January 2018, Caspian Petrochemical helped IRGC front PGPIC (affiliated
with IRGC front KAA) export 44,000 tons of LPG that the IRGC produced at its South
Pars field, which the IRGC (through Caspian Petrochemical, among others) shipped,
aboard the Gas Dignity, to a buyer in Asia.

869. At the IRGC’s prevailing profit margins, each of these four transactions likely

yielded more than $10 million in funds that the SLO and IRGC caused to be distributed to

Hezbollah, the Qods Force, Hamas, PIJ, and JAM to finance their terrorist attacks in the Middle

East.

870. Indeed, the total scale of Iranian Petrochemical Company’s terrorist finance likely

exceeded $300 million between 2011 and 2017 alone. Plaintiffs’ review of market data suggests

that Iranian Petrochemical Company was likely involved in at least five or more transactions,

analogous to each of the four described above, each year from 2011 through 2017—and likely

substantially more than that. For example, just one of Caspian Petrochemical’s strategic partners,

Oriental Oil, reportedly exported more than 300,000 tons of LPG during one six-month stretch in

2017, which is equal to about seven of the above-described shipments, and Oriental Oil likely

used Caspian Petrochemical for all or nearly all such transactions.

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871. From 2007 through at least 2019, SCB’s provision of financial services to the

Iranian Petrochemical Company flowed at least several hundred million dollars of terrorist

finance each year directly and indirectly to the Qods Force, Hezbollah, Hamas, PIJ, and JAM.

3. Khatam al-Anbiya

872. Terrorism scholars also confirmed that KAA-related profits—which described

those of Caspian Petrochemical—directly financed IRGC-sponsored attacks committed by IRGC

proxies, including Hezbollah, Hamas, and PIJ, and alerted SCB to the same. On June 15, 2010,

for example, IRGC scholars Mark Dubowitz and Emanuele Ottolenghi publicly warned:

[KAA] is an integral part of the IRGC power structure. Its head is the IRGC’s
Commander in Chief, … Mohammad Ali Jafari, and its CEO, under his authority, is
always a high-ranking IRGC officer. Many IRGC projects are military in nature, and the
group diverts much of the technology and expertise it acquires from Western companies
for seemingly innocuous projects to unsavory ends. …
Any company that does business in Iran risks becoming an unwitting accomplice to the
IRGC’s nefarious activities, tarnishing its reputation in the process. Yet even when
companies provide services and technologies that cannot be diverted to illicit projects,
partnering with the IRGC entails some complicity with its activities. In June 2006, then-
[KAA] deputy head [IRGC] Brigadier General Abdol Reza Abed confirmed in an
interview with a local daily that [KAA]’s funds finance various national defense projects,
including arming and training Hezbollah. …
[B]oth the Iranian people and the Western companies that do business with the regime
end up paying the price for the IRGC’s cronyism, inefficiency and incompetence.
No matter how you look at it, it’s clear that when [KAA] wins, everyone else loses. …
And the entire [Middle East] region loses, because the richer the IRGC becomes, the
more resources it has to perpetuate Iranian subversion and repression at home and abroad.
The United States, and other western allies, have only just begun designating the IRGC
front companies that operate in the Iranian energy sector. Business with the Iranian
regime is going to get even riskier.

873. In 2017, Matthew McInnis, of the American Enterprise Institute, publicly testified

before Congress that KAA profits funded IRGC-sponsored acts of terrorism committed by IRGC

proxies throughout the Middle East, including by Hezbollah and JAM:

Iran seeks to … assert its regional hegemony by displacing the United States as the
dominant regional power. … Iran has utilized its “Resistance Network” of partners,

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proxies, and terrorist groups, including … Lebanese Hezbollah, and Iraqi groups like the
Badr Corps, Khataib Hezbollah, and Asaib Ahl al-Haq. …
Iran continues to invest in training and arming its proxies and partners with increasingly
advanced equipment, with its most trusted groups receiving the best weaponry. Lebanese
Hezbollah acquired unmanned aerial vehicles and an estimated 100,000 to 150,000
rockets and missiles through Iranian assistance, including advanced air-to-ground and
ground-to-sea missiles. Iran’s Iraqi proxies employed the QFs’ signature improvised
explosive device, the explosively formed projectiles against coalition forces in the last
decade….
How do we then stand up to Iran’s destabilizing activities in the region and begin to
dismantle Tehran’s global terror network?
A re-invigorated economic warfare campaign against the [IRGC] should be one
component - along with well-coordinated political, military, intelligence and information
campaigns - of a larger U.S. strategy against Iran’s malign influence in the region. Since
the end of the Iran-Iraq War, the IRGC slowly expanded its role in the Iranian economy
with at least 20 percent estimated to be now under the [IRGC]’s control. The IRGC owns
the state’s largest construction firm, Khatam al-Anbiya, and has major stakes in the
banking, energy, extractive, and manufacturing sectors. This is how the Guard is able to
fuel so much of its operations, …[including] weapons production [and] … proxy support
worldwide. The United States has also often designated IRGC front companies that help
Iran evade sanctions, acquire illicit technologies and transport weapons to partners. The
[IRGC] also operates most Iranian ports and is deeply involved in the commercial
shipping … sectors, which are critical elements in building and sustaining its proxy and
terror networks in the Middle East.

874. A wide array of terrorism scholars concluded that KAA profits directly financed

IRGC-sponsored acts of terrorism committed by IRGC proxies like Hezbollah. For example,

Ambassador Mark D. Wallace, CEO of UANI, observed that “Iran’s aviation and engineering

sectors are dominated by the Islamic Revolutionary Guards Corps (“IRGC”) … the main

instrument used in Iran’s … global terrorist activities. The IRGC widely operates in these sectors

through its engineering arm, Khatam al-Anbiya, which is also blacklisted by the EU, the U.S.

and the United Nations. Surely, the risks associated with potential (even inadvertent) partnership

with the IRGC and IRGC-affiliated entities are much too great for any responsible and law-

abiding company.” Mehran Riazaty, a former Iran Analyst for Multi-National Forces, Iraq (i.e.,

the U.S. military), observed that key Qods Force terrorists—who were direct beneficiaries of

Khatam al-Anbiya profits—were tasked with using such profits to help the Qods Force and

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Hezbollah support IRGC-sponsored, JAM-involved attacks targeting the United States in Iraq

after 2003. Saeed Ghasseminejad and Richard Goldberg, of the Foundation for Defense of

Democracies, observed that “Khatam al-Anbiya is controlled by the IRGC … and helps finance

Iran’s … terrorist activities.”

4. Elyassi

875. From 2007 through at least 2011, SCB helped the IRGC evade U.S.

counterterrorism sanctions through its transactions with Mahmoud Reza Elyassi and his

businesses.

876. Elyassi was an agent for the IRGC and SLO. Elyassi operated a sophisticated,

transnational, U.S.-dollar denominated currency exchange that was connected to essentially

every major sector in which the IRGC and SLO exercised a monopoly on behalf of the Qods

Force and Hezbollah, including, but not limited to, import/export, communications, construction,

and energy. Elyassi also had essentially no public profile, was based in Iran but frequently

traveled to Dubai, and attempted to recruit one or more SCB-related persons by inviting them to

visit him in Tehran. Only one thing explains all these features: Elyassi’s status as an agent for the

IRGC and SLO. Simply put, as SCB knew, no Iranian national could have displayed the profile,

or engaged in the transactions, like Elyassi, without the IRGC’s and SLO’s knowledge. The

enduring nature of the scheme, combined with its cross-border (Qods Force domain) conduct

permits only one conclusion: that his conduct was blessed by the IRGC (including the Qods

Force). And that conclusion, in turn, requires—at a minimum—the conclusion that Elyassi was

acting at the IRGC’s (and Qods Force’s) behest because the IRGC did not simply permit Iranians

to launder vast sums of U.S. dollars for years while in contact with westerners without Qods

Force involvement.

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877. SCB Dubai knew these facts, employed personnel with sophisticated regional

knowledge, and benefited from the knowledge of SCB’s office in Tehran through SCB’s “One

Bank” approach in which its various branches shared information and knowledge with one

another seamlessly across borders. On March 3, 2009, for example, SCB stated: “Standard

Chartered is a rather different bank and we want to keep it like that. We run as one bank across

geographies and businesses.”

878. Regardless of whether SCB Dubai personnel connected the “Elyassi was an IRGC

and SLO agent” dots in real time—and, on information and belief, SCB Dubai employees and

agents did, in fact, figure it out—SCB Dubai knew that the subject matter of the Elyassi-related

transactions was exclusively indicative of IRGC and SLO involvement. That was enough to alert

SCB that its role in the transactions would flow funds to the terrorist proxies sponsored by the

IRGC and SLO, the most notorious of which always being Hezbollah, Hamas, and PIJ.

879. When SCB Dubai serviced Elyassi, SCB knew, among other things: (1) Elyassi

was an Iranian national; (2) Elyassi worked from Iran, but also traveled to Dubai; (3) Elyassi was

running a sophisticated sanctions evasion scheme, which SCB knew was an exclusive province

of the IRGC’s monopoly; (4) Elyassi was operating a currency exchange, which SCB knew was

also subject to an IRGC monopoly; (5) Elyassi held himself out as an import/export business,

which was yet another IRGC monopoly; and (6) Elyassi’s currency exchange activities likely

involved energy and communications technology-related transactions—two more areas of IRGC

monopoly. Simply put, SCB knew that every industry sector in which Elyassi purportedly

transacted was one for which the IRGC held a monopoly. When SCB helped Elyassi evade U.S.

counterterrorism sanctions, it helped flow money into all these IRGC monopolies, which directly

funded the Qods Force, Hezbollah, Hamas, and JAM.

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880. Statements by U.S. and U.K. prosecutors and regulators confirm that Elyassi was

an agent for the IRGC and/or the SLO. This is ineluctable for a simple reason: in connection with

SCB’s mine run of 2019 resolutions, every government authority that issued a statement

emphasized, in sum and substance, that SCB’s Elyassi-related conduct threatened the national

security of the United States and/or United Kingdom. Such statements could only have been true

if Elyassi was an agent for the IRGC and/or SLO for a simple reason that SCB knew given its

sophistication and employment of in-house and outside intelligence professionals: the IRGC and

SLO were the only two organizations in Iran that (a) directly threatened the United States and

United Kingdom, while (b) playing a large role in the international financial system and having

an insatiable need for U.S. dollars to conduct their operations. As SCB well knew, no other

Iranian organizations fit that description. For another simple reason, this conclusion would not

change even if one were to infer (incorrectly) that such officials were only describing the Iranian

regime’s acquisition of weapons of mass destruction, like ballistic missiles: that program was

entirely within the purview of the IRGC. Accordingly, no matter how one explains the official

statements described above, they necessarily confirm that the IRGC and/or SLO benefited from

Elyassi’s transactions with SCB because the government’s statements would be false if Elyassi

had been acting for anyone else.

881. Every transaction that SCB conducted for Elyassi was atypical. SCB Dubai used

all or nearly all its illegal tactics, techniques, and procedures as alleged in the previous section

when it provided services to Elyassi.

882. SCB’s financial services were essential to the IRGC’s ability to profit from the

Elyassi-related transactions because the IRGC needed access to New York’s financial system for

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his currency exchange to work and for the ultimate IRGC beneficiaries to receive their money in

the most valuable form possible: U.S. dollars.

883. U.S. government findings confirm Plaintiffs’ allegations. In 2024, for example,

FinCEN published an advisory that confirmed that sanctions violations by self-styled Iran-related

“general trading companies” had a tight nexus to attacks by Hezbollah, Hamas, PIJ, and JAM:

Iranian government agencies, such as the Central Bank of Iran (CBI) and the IRGC-QF,
as well as state-sponsored organizations such as Hizballah, play a key role in channeling
funds to terrorist proxies using overseas front companies and financial institutions.
Financial institutions located outside Iran can—wittingly or unwittingly—become
intermediaries for the IRGC-QF’s illicit transactions. IRGC-QF officials have been
known to collect funds in various currencies from CBI-held accounts at financial
institutions in neighboring countries and transfer those funds back to Iran or to terrorist
organizations. According to BSA analysis, third-country front companies—often
incorporated as “trading companies” or “general trading companies”—and exchange
houses act as a global “shadow banking” network that processes illicit commercial
transactions and channels money to terrorist organizations on Iran’s behalf. Exchange
houses and front companies rely on banks with correspondent accounts with U.S.
financial institutions, especially to process dollar-denominated transactions. In such
cases, Iranian banking customers may omit or falsify identifying details connecting
themselves or the transfers to Iran or attempt to pass the transactions off as remittances.

884. Simply put, SCB defied decades of direct U.S. government warnings about the

consequences that occur when a bank helps the IRGC obtain U.S. dollars through the American

financial system in violation of U.S. sanctions targeting Iran.

885. From 2007 through at least 2011, SCB’s provision of financial services to Elyassi

flowed millions of dollars of terrorist finance each year directly and indirectly to the Qods Force,

Hezbollah, Hamas, PIJ, and JAM

5. Other Fronts

886. While the Iranian Petrochemical Company and Elyassi were SCB’s two most

shocking long-term relationships with Iran’s Terrorist Sponsors, they were hardly the only ones.

As described supra, SCB engaged in years of misconduct on behalf of Iranian banks with clear

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ties to the IRGC and the SLO—i.e., wire-stripping through the year 2007 involving billions of

dollars.

887. That misconduct did not cease in 2007. On information and belief, from at least

2007 through at least late 2014 or early 2015, SCB Dubai helped the SLO access millions of

dollars from New York banks through other transactions in addition to the ones alleged above,

and did so even though it knew that the SLO directly sponsored Hezbollah, Hamas, and PIJ, and

that its transactions would enable the Foundation to finance attacks by Hezbollah, Hamas, and

PIJ.

888. On information and belief, from at least 2007 through at least late 2014 or early

2015, SCB Dubai helped KAA access millions of dollars from New York banks through other

transactions in addition to the ones alleged above, and did so even though it knew that the KAA

was sanctioned, and that its transactions would enable the Foundation to finance attacks by

Hezbollah, Hamas, and PIJ.

889. On information and belief, from at least 2007 through at least late 2014 or early

2015, SCB Dubai helped the Foundation for the Oppressed access millions of dollars from New

York banks through other transactions in addition to the ones alleged above, and did so even

though it knew that the Foundation was sanctioned, and that its transactions would enable the

Foundation to finance attacks by Hezbollah, Hamas, and PIJ.

890. On information and belief, from at least 2007 through at least late 2014 or early

2015, SCB Dubai helped NIOC access millions of dollars from New York banks through other

transactions in addition to the ones alleged above, and did so even though it knew that NIOC was

sanctioned, and that its transactions would enable the Foundation to finance attacks by

Hezbollah, Hamas, and PIJ.

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B. SCB’s Conduct Made a Vital Contribution to IRGC-Sponsored Attacks by

Hezbollah, JAM (Including Kataib Hezbollah), Hamas, and PIJ In Iraq and
Israel

891. From 2000 through at least 2019, SCB’s scheme financed Hezbollah’s, Hamas’s,

PIJ’s, and JAM’s terrorist attacks, including those against Plaintiffs. All such terrorist groups

relied on Ayatollah Khamenei, the SLO, IRGC, and Hezbollah to pay for, organize, train, arm,

and logistically sustain such Iranian proxies. In that respect, every group participated in a

network of joint organizations and entities—i.e., joint cells—not unlike the latticework of joint

organizations common to NATO and U.S. coalition-based structures in the Middle East.

1. SCB’s Conduct Enabled Key Lanes of Iranian Regime Financial

Support for Hezbollah’s, Hamas’s, PIJ’s, and JAM’s Attacks

892. From 2000 through at least 2019, Ayatollah Khamenei, the SLO, the IRGC, and

Hezbollah always relied on at least three key types of aid to sponsor attacks committed by

Hezbollah, Hamas, PIJ, and JAM targeting the United States in the Middle East, including in

Israel and Iraq: (1) attack incentive and reward payments directly to the Hezbollah, Hamas, PIJ,

and/or JAM operatives, or their families, responsible for attacks; (2) fundraising and recruitment

through Ayatollah Khamenei’s, the SLO’s, and the IRGC’s control (in the event of Khamenei

and the SLO) and/or use (all three) of the Iranian regime’s Friday Prayers Organization, which

was a comprehensive apparatus that Ayatollahs Khomeini and Khamenei notoriously used since

1979 to support terrorist attacks by Hezbollah, Hamas, PIJ, and Iraq; and (3) weapons, training,

logistics, and tunnel payments to the RGB – which was such terrorist sponsors’ Axis of

Resistance ally, as the external terrorist operations arm of their fellow Axis member North

Korea, often routed through, or facilitated by, China and/or Russia – by such Iranian terrorist

sponsors on behalf of, and to secure the RGB’s provision of, such goods and services to

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Hezbollah, Hamas, PIJ, and JAM used in their attacks. SCB’s criminal scheme powered all;

Plaintiffs discuss each in turn.

i. Attack Incentive and Reward Payments to Hezbollah, Hamas,

PIJ, and JAM

893. From 2000 through at least 2019, SCB’s schemes enabled hundreds of millions, if

not billions, in illicit petroleum-related profits to collectively flow to the SLO, IRGC, Foundation

for the Oppressed, KAA, and Bank Saderat and, through such terrorist sponsors, flow on to

Hezbollah’s, Hamas’s, PIJ’s, and JAM’s respective operations cells to fund – on an expressly,

earmarked, basis – each attack committed by such Iranian proxies. Ayatollah Khamenei, the

SLO, IRGC, and Hezbollah relied upon petroleum profits – that SCB Helped such terrorist

sponsors finance through SCB’s illicit support of their U.S.-dollar-denominated, New York

bank-blessed petroleum-, Foundation for the Oppressed-, KAA-, and Bank Saderat-related

transactions to fund at least five distinct categories of U.S. dollar-denominated attack payments

that notoriously, and empirically, incentivized attacks, including, but not limited to:

a. U.S. dollar-denominated salary payments to finance attacks by Hezbollah’s, Hamas’s,

PIJ’s, and JAM’s relevant attack-related operations, intelligence, logistics, and leadership
cell operatives, including Khamenei Cell members, including such groups’ attacks
against Plaintiffs, which salaries were usually around $200 per month for rank-and-file
fighters and $400 per month for cell leaders;208

b. U.S. dollar-denominated martyr payments to the families of such Hezbollah, Hamas,

PIJ, JAM, and IRGC, including Khamenei Cell, martyrs in attacks targeting the United
States in which the attacker died (i.e., was “martyred”, including their attacks against
Plaintiffs, which always included a lump sum bonus payment to the martyr’s family,

208
For the avoidance of all doubt, while Plaintiffs’ salary numbers are applicable to
Hezbollah, Hamas, PIJ, and JAM personnel in general, the 25-30 terrorists who comprise the
membership of the Khamenei Cell – i.e., Khamenei’s closest inner circle allies – were paid
salaries that were orders of magnitude higher than the sums paid to everyone else in such groups.
For example, Ayatollah Khamenei, the SLO, IRGC, Hezbollah, and the Foundation for the
Oppressed likely paid key Khamenei assets like Hassan Nasrallah and Abu Mahdi al-Muhandis
salaries of at least several thousand U.S. dollars per month.

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usually in amounts like $3,000, $5,000, or $7,000 (depending on the group and year for
the martyr), and smaller payments thereafter to the martyr’s spouse and parents;

c. U.S. dollar-denominated bounty payments to Hezbollah, Hamas, PIJ, JAM, or IRGC

operatives for successful attacks targeting the United States or its allies in the Middle
East, including Israel, which payments were usually in amounts ranging from $2,000 to
$20,000, with most payments being less than $10,000, and calibrated to especially
promote such attacks through larger bounties awarded for successful attacks killing,
injuring, or capturing a U.S. victim as compared to non-U.S.-victims;

d. U.S. dollar-denominated disability payments to Hezbollah, Hamas, PIJ, JAM, or IRGC

operatives, and their families, if such operatives were injured while supporting a terrorist
attack committed by such group, which often cost at least several thousand U.S. dollars
per year, and were thus about as costly as martyr payments in terms of per-capita spend;

e. U.S. dollar-denominated orphan payments to the caretakers of the children of

Hezbollah, Hamas, PIJ, or JAM operatives who were killed while supporting a terrorist
attack committed by such group, which carried a similar cost as martyr and disability
payments in terms of per capita spend, and were made to reward and incentivize terrorist
attacks (by ensuring that the operative’s child will be looked after by the terrorist group),
and enable recruitment of child terrorists by all such groups, all of which recruit – and
deploy children aged 8-17 to commit attacks by the group.

894. Ayatollah Khamenei, the SLO, IRGC, Hezbollah, and Foundation for the

Oppressed financed each of these types of attack incentive and reward payments to support

attacks by Hezbollah, Hamas, PIJ, and JAM in the Middle East through means that were both

direct (e.g., sponsor-to-terrorist) and indirect (e.g., sponsor-to-Hezbollah-to-terrorist).

Throughout this period, all five types of such attack incentive and reward payments were

notorious, intended to promote terrorist attacks, and did, in fact, promote such attacks.

895. Ayatollah Khamenei’s, the SLO’s, the IRGC’s, Hezbollah’s, and Foundation for

the Oppressed’s support for, and facilitation of, such attack payments was programmatic because

of the custom and practice of each person, and the tactics, techniques, and procedures of the

IRGC (which all followed). Throughout, Hezbollah’s, Hamas’s, PIJ’s, and JAM’s, use of – and

distribution of – such attack payments was equally programmatic because of the custom and

practice of Hezbollah, Hamas, OIJ, and JAM, and the IRGC-derived, Hezbollah-exported tactics,

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techniques, and procedures common to each group. Simply put, every terrorist sponsor and

terrorist group in this paragraph actively, affirmatively, promoted attack payments – they sought

to get the word out, were highly effective in doing so, and had a rigorous monitoring, record-

keeping, and follow-up process to ensure that attack payments were ordinarily paid for every

applicable attack throughout the period from 2000 through 2019.

896. Accordingly, for each attack against Plaintiffs, the custom and practice, and

tactics, techniques, and procedures of Ayatollah Khamenei, the SLO, the IRGC, Hezbollah, the

Foundation for the Oppressed, Hamas, PIJ, and JAM meant that a counterterrorism analyst

experienced in the field would usually conclude based on nothing more than the fact that

Hezbollah, Hamas, PIJ, or JAM committed an attack targeting the United States in Iraq, Israel, or

the Palestinian territories in which an American was killed or injured, or a terrorist was killed or

injured, that Ayatollah Khamenei, the SLO, the IRGC, Hezbollah, and the Foundation for the

Oppressed likely made, and Hezbollah’s, Hamas’s, PIJ’s, and JAM’s terrorist attacks were likely

aided by, one or more of attack incentive and reward payments as described herein.

897. SCB provided the key services that powered the terrorists’ attack incentive and

reward payments. Ayatollah Khamenei, the SLO, IRGC, Hezbollah, and the Foundation for the

Oppressed relied upon, inter alia, U.S. dollar-denominated transactions on behalf of Iranian

regime-owned or beneficiary customers and accounts relating to Iran’s petroleum sector

(including NIOC, NITC, and Iranian government-owned companies affiliated with either), the

Foundation for the Oppressed (including affiliated entities and persons), and Bank Saderat to

underwrite all five types of attack payments to Hezbollah, Hamas, PIJ, JAM, and the IRGC.

898. When SCB helped finance Iranian Terrorist Sponsors’ martyr payments to

Hezbollah, Hamas, PIJ, and JAM terrorists, SCB provided direct support to terrorist attacks by

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such groups. Decades of government reports and speeches published by the United States,

United Kingdom, European Union (“E.U.”) and United Nations (“U.N.”), confirmed the IRGC’s

programmatic emphasis on “martyrs,” “martyrdom,” “martyr attacks,” and compensating the

families of martyrs as key tools that facilitated IRGC-sponsored acts of terrorism targeting the

United States that were committed by the Qods Force and the Axis of Resistance it led, including

Hezbollah, Ka’taib Hezbollah, the Houthis, al-Qaeda, and the Taliban. As Ayatollah Khomeini

wrote in 1979, “the … Islamic Revolutionary Guard Corps … [is] armed with the divine power.

[The IRGC’s] weapon is the ‘Allähu akbar’ and there is no weapon like it in the world. … The

… Päsdar [i.e., IRGC member] who says his night prayers in the trench … fights as a lion.”

899. The U.S. government has confirmed the inextricable connection between martyr

payments and terrorist attacks. In 2015, for example, Treasury reported to Congress:

Evidence suggests that terrorists and their support networks are aware of the ways
in which charitable organizations can be abused as a cover to raise, move, and use
funds and actively seek to exploit them. … U.S. prosecutors demonstrated at trial
that [a religious foundation] intentionally cloaked its financial support for Hamas
by funneling money through Zakat Committees and Charitable Societies in the
West Bank and Gaza. In some cases, the defendants targeted financial aid
specifically for families related to well-known Hamas operatives who had been
killed or jailed. In this manner, the defendants effectively rewarded past and
encouraged future terrorist activities.

900. Moreover, in Country Reports on Terrorism 2020, State observed that, with

respect to “transfers to” the “families of terrorists who died in attacks,” i.e., “prisoner and

‘martyr’ payments,” the “United States and Israel argue the payments incentivize and reward

terrorism, particularly given the higher monthly payments the longer an individual remains

imprisoned, which corresponds to more severe crimes.”

901. Terrorism scholars also confirmed that financing martyr payments results in more

terrorist attacks. In 2006, for example, counterterrorism scholar Boaz Ganor observed:

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[T]he family of the shahid (martyr) is given a very tangible reward of thousands
of dollars (until the Al Aksa Intifada, the amount that the family of the Palestinian
shahid received from the terrorist organization was some $5,000 and during the
Intifada, when Iraq allocated huge sums of money for this purpose, the amount
awarded to the family of a suicide attacker rose to $25,000—an enormous sum
compared with the average yearly salary in the West Bank). From this
perspective, perpetrating suicide attacks could be considered by a youngster from
a large family as an altruistic act for his family’s benefit. … [T]hese rewards are
so tangible that they can make an essentially irrational act—the act of suicide—
into a rational act whose benefit is many times greater than its cost.

902. In 2017, likewise, Dr. Bruce Hoffman, of Georgetown University, observed:

The Palestinian terrorist organizations have also worked hard to endow suicide
operations with a positive social imprimatur and to ensure the support for this
tactic by the Palestinian people. They have deliberately created an inverted sense
of normality throughout much of Palestinian society whereby suicide—the
senseless taking of one’s life, an act that is usually negatively regarded as
aberrant, if not abnormal—becomes something routinely accepted and applauded,
and indeed endowed with demonstrably positive connotations.164 The veneration
routinely accorded martyrs reinforces this view. … the terrorist organizations—
and their supporters through financial contributions—provide material as well as
spiritual encouragement to both the suicide terrorists and their families.
According to one authoritative account, until at least 2001, Hamas paid the
families of suicide terrorists a death benefit of $3,000 to $5,000—more than
double the financial compensation paid to families of terrorists killed in other,
non-suicidal attacks. Later, during the al-Aqsa Intifada, this amount increased to
$10,000 and then, courtesy of then–Iraqi dictator Saddam Hussein’s largesse, to
$25,000. There were additional material benefits as well, including nicer living
accommodations and gifts of consumer goods—“appliances, rugs and stuffed
furniture … gaudy wall clocks, even … [a] bracelet and rings”—bestowed on the
families of martyrs.

903. SCB’s financial support for martyr payments assisted knife attacks committed by

Hamas and PIJ. In 2016, for example, Deutsche Presse-Agentur reported on how the Iranian

regime intensified its support for such payment to accelerate Hamas’s and PIJ’s “knife intifada”:

Iran’s ambassador to Lebanon announced … that the families of every Palestinian

knife attacker shot dead by Israeli security forces will receive financial assistance
from Tehran. “Based on the principles of the Islamic republic and its support of
the Palestinian people ... it has been decided to give the families of each martyr
7,000 US dollars,” Mohammed Fathali said during a press conference. …
Fathali’s statement was condemned by Israel, saying it “demonstrates again Iran’s
role in encouraging terror.” “Following the nuclear agreement, Iran continues

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being a major player in international terror,” Israeli Foreign Ministry spokesman

Emmanuel Nahshon said in a statement. Palestinians have launched scores of
knife attacks against Israelis since early October, … Israel has blamed the wave of
violence on inflammatory rhetoric by radical Muslim leaders who “brainwash”
youths and “glorify martyrdom.”

904. SCB’s financial support for martyr payments assisted vehicle ramming attacks

committed by Hamas and PIJ. In 2016, for example, the Jerusalem Post reported that the Iranian

regime encouraged “car-ramming attacks against Israelis in recent months” when “Iran [] offered

financial assistance to the families of Palestinian terrorists involved in” such “attacks.”

905. From 2000 through at least 2019, Khamenei’s, the SLO’s, the IRGC’s,

Hezbollah’s and the Foundation for the Oppressed’s ability to finance and route such attack

payments to Hezbollah, Hamas, PIJ, JAM, and the IRGC depended upon the Iranian regime’s

ability to find a Global Financial Institution with a branch in New York that would process

enormous volumes of U.S. dollar-denominated transactions over more than a decade in direct

violation of at least four distinct types of sanctions regimes imposed by actors based in the

United States and designed to prevent terrorist attacks:

a. U.S. government country-wide sanctions targeting Iran, which were in force from
1995 through 2019 and always included, and reflected, a unique focus on country-wide
mechanisms that were designed to reduce the frequency of Iranian regime-sponsored
terrorist attacks committed by Hezbollah, Hamas, and PIJ against the United States in the
Middle East, including against U.S. allies like Israel, by making it harder for the Iranian
regime to finance, develop, refine, transport, and transact its petroleum resources.

b. U.S. government industry-wide sanctions targeting Iran’s petroleum sector, financial,

and shipping sectors, which were in force from 1995 through 2019 and always included,
and reflected, the U.S. government’s focus on the inextricable – and linear – relationship
between the Iranian regime’s ability to lever the U.S. financial system to transact in,
profit from, and redistribute the spoils of, the regime’s petroleum monopoly, and
associated interests in the banks and shipping sectors.

c. U.S. government targeted entity and individual sanctions specifically linked to

Hezbollah, Bank Saderat, the IRGC and KAA, NIOC, and NITC – including their
respective fronts, agents, and operatives – which featured a heavy emphasis on such

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terrorist sponsors’ use of the U.S. financial system to support petroleum-, Foundation for
the Oppressed-, and/or other foundation- or charitable front-related transactions.

d. U.N. Security Council targeted entity and individual sanctions specifically linked to
the IRGC, Hezbollah, Qasem Soleimani, Rostum Ghasemi, Mohammad Ali Jafari, and
KAA, which were in force from at least 2006 through at least 2019, and which always
prohibited transactions that benefited any such terrorist sponsors.

906. From 2000 through at least 2014, SCB’s above-described sanctions violations

directly flowed enough money to make tens of thousands, if not more, attack payments as

described above. At then-prevailing rates as described above, SCB’s conduct was enough to fund

every salary payment, martyr payment, bounty payment, disability payment, and orphan

underwritten by Ayatollah Khamenei, the SLO, IRGC, Hezbollah, and/or Foundation for the

Oppressed for every attack that killed and injured Plaintiffs and their loved ones – many times

over. In fact, SCB’s conduct would have financed the attack payments for thousands of such

attacks, enough to cover every attack against Plaintiffs many times over.

ii. Weapons, Training, Logistics, and Tunnel Payments to North

Korea’s RGB on Behalf of Hezbollah, Hamas, PIJ, and JAM

907. From 2000 through 2019, Ayatollah Khamenei, the SLO, IRGC, Hezbollah,

Foundation for the Oppressed, and NIOC relied upon their shared, decades-long, partnership

with the North Korean regime, as operationalized by the latter’s external terror arm, the RGB.

908. SCB’s conduct financed at least three distinct types of lethal aid that amplified the

killing power of Hezbollah’s, Hamas’s, and PIJ’s attacks against Plaintiffs. First, by deliberately

helping known petrochemical fronts that SCB knew to be ultimately owned by NIOC, SCB

facilitated the enormous volume of annual oil shipments from Iran to North Korea which allowed

the Iranian Terrorist Sponsors to avoid spending much of their precious dollars on needed

weapons (since they were paying with oil instead of cash), which freed up such funds for more

productive purposes form the perspective of the terrorists’ desire to kill people. Simply put, a

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single oil tanker shipped to North Korea as facilitated by SCB produced enough economic value

to finance thousands of attacks. And SCB helped facilitate at least several such deliveries per

year given the scale of SCB’s assistance and Iranian shipments to North Korea (both large).

909. Second, RGB trainers and technical specialists used SCB’s resources to enhance

the potency, accuracy, reliability, and range of Hamas’s and PIJ’s rocket arsenals – directly

increasing the lethality of their attacks against Plaintiffs.

910. Third, RGB tunnel experts built terrorist attack tunnels for Hamas, which

amplified the effectiveness of every Hamas attack, and were widely viewed as Hamas’s single

most important terrorist weapon.

911. Contemporaneous reports confirm the above points. On July 27, 2014 , for

example, the Telegraph, a U.K. newspaper, reported as follows:

Hamas is attempting to negotiate a new arms deal with North Korea for missiles and
communications commitment that will allow it to maintain its offensive against Israel,
according to Western security sources.
Security officials say the deal between Hamas and North Korea is worth hundreds of
thousands of dollars and is being handled by a Lebanese-based trading company with ties
to the militant Palestinian organization.
Hamas officials are believed to have already made an initial cash downpayment to secure
the deal and are hoping that North Korea will soon begin shipping extra supplies of
weapons to Gaza.
"Hamas is looking for ways to replenish its stocks of missiles because of the large
numbers it has fired at Israel in recent weeks," said a security official. "North Korea is an
obvious place to seek supplies because Pyongyang already has close ties with a number
of militant Islamist groups in the Middle East."
Using intermediaries based in Lebanon, Hamas officials are said to be intensifying their
efforts to sign a new agreement with Pyongyang to provide hundreds of missiles together
with communications equipment that will improve the ability of Hamas fighters to
coordinate operations against Israeli forces.
Like other Islamist terrorist groups in the region such as Hezbollah, Hamas has forged
close links with North Korea, which is keen to support groups opposed to Western
interests in the region.
The relationship between Hamas and North Korea first became public in 2009 when 35
tons of arms, including surface-to-surface missiles and rocket-propelled grenades, were
seized after a cargo plane carrying the equipment was forced to make an emergency
landing at Bangkok airport. Investigators later confirmed that the arms had been destined

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for Iran, which then planned to smuggle them to Hezbollah in Lebanon and Hamas in
Gaza.
Israeli military commanders supervising operations against Gaza believe North Korean
experts have given Hamas advice on building the extensive network of tunnels in Gaza
that has enabled fighters to move weapons without detection by Israeli drones.
The North Koreans have one of the world's most sophisticated network of tunnels
beneath the demilitarized zone with South Korea, and Israeli commanders believe Hamas
has used this expertise to improve their own.
The Hamas arsenal has become increasingly sophisticated with foreign assistance and
now boasts five variants of rockets and missiles.

912. On March 11, 2016 , similarly, the Jerusalem Post reported as follows:

In 2014, North Korea and Hamas struck a deal for the sale of 107-mm. and 102- mm.
multiple rocket launchers. Hamas installed some of these systems on pickup trucks. “The
tunnels that Hamas dug under Gaza into Israel – the concrete reinforcements – those are
North Korean characteristics. I don't know whether North Korea got people into Gaza
and trained them, or whether that training occurred in Lebanon. But it is a North Korean
modus operandi," [Korea scholar Bruce] Bechtol said. The pattern repeats itself all over
the region. In Iran, on a much grander scale, North Korea constructed underground
nuclear facilities that can withstand bunker- busting bombs. “They built them in such a
way that only a suicide commando mission could get to them,” the professor said.

2. SCB’s Conduct Financed Thousands of Iranian-Sponsored Attacks

Committed by Hezbollah, Hamas, PIJ, and JAM

913. The significance of SCB-facilitated transactions with IRGC agents and fronts was

especially pronounced given the low marginal cost of individual attacks. As Dr. Daniel Byman

of Georgetown University observed in 2005, an “advantage of terrorism over conventional force

is that it is cheap. Small numbers of terrorists can wreak havoc.”

914. Studies consistently confirmed that the cost of nearly all attacks in by terrorist

groups in the Middle East in the post-9/11 era ranged from around $2,000 per attack to around

$20,000 per attack, mostly on the low end of that spectrum. IEDs, for example, usually cost

around $100 per bomb. Generally, Hamas and Hezbollah fighters were paid around $200 per

month, while leaders were paid around $400. As terrorism scholars Jessica Stern and J. M.

Berger explained in 2016:

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Asymmetrical warfare is defined by asymmetry. Any terrorist ideology that can

attract five recruits and the contents of their checking accounts can make
headlines for months. A terrorist group with twenty willing recruits and half a
million dollars can make headlines for years.

915. At those rates, even a single SCB transaction that flowed $5,000 to Hezbollah or

Hamas would have financed substantial terrorist violence. At the time, a $5,000 payment would

have put 10 terrorists (at $200 per fighter) and two commanders (at $400 per commander) in the

field for a month and with about 20 IEDs. Or the terrorists could have spent the $5,000 to

purchase dozens of bomb components or to finance multiple complex attacks. SCB’s payments

were orders of magnitude higher. Those payments materially strengthened the terrorists’ ability

to commit the attacks that killed and injured Plaintiffs.

916. U.S. government studies confirmed the dramatic impact of even marginal

financial contributions to Islamists operating in the Middle East. For example, one DoD study of

al-Qaeda-in-Iraq—which followed a substantially similar organizational approach as Hezbollah,

Hamas, and PIJ when it came to attack logistics—found a statistically significant relationship

between small-dollar contributions and terrorist attacks, concluding that each successful terror

attack in Iraq required on average only $2,732 to execute. The study thus demonstrated that even

marginal reductions in terrorist funds corresponded with a statistically significant reduction in

terrorist violence. The converse was also true. For every $2,700 (or its rough equivalent) SCB

flowed to the IRGC, Hezbollah, Hamas, and JAM, they financed roughly one new terrorist

attack. Consequently, even a handful of transactions involved in the schemes detailed herein,

e.g., transactions related to the Caspian Petrochemical scheme or the Elyassi scheme, were more

than enough to fund thousands of attacks—enough to kill and injure every Plaintiff in this case

hundreds of times over. SCB knew all of this when it provided the services alleged herein.

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917. This effect was linear. Simply put, more money equaled more acts of terrorism.

As Dr. Margaret Sankey of the U.S. Naval Institute and Air University, concluded in 2022:

With the caveat and reminder that operations don’t cost a large amount in proportion to
sustainment, VNSAs [Violent Non-State Actors] whose budgets have been reduced have
to make hard decisions about maintaining their capabilities. In some cases, [297] there’s
a clear pattern that more money means more attacks, with al-Qaeda in Iraq
consistently increasing by one attack for every $2,700 sent by the central leadership to
sectors. Mustafa Abu al-Yazid, an al-Qaeda financing chief, put it starkly: “There are
hundreds wishing to carry out martyrdom-seeking operations, but they can’t find the
funds to equip themselves. So funding is the mainstay of jihad.” (Emphasis added.)

918. Moreover, Ayatollah Khamenei, the SLO, IRGC, Hezbollah, and Foundation for

the Oppressed spent most of the profits that SCB helped them generate to directly or indirectly

sponsor terrorist attacks targeting the United States and its allies in the Middle East. For the

avoidance of all doubt, Plaintiffs do not allege that a small percentage of such profits flowed

through to the Terrorist Sponsors and their proxies – Plaintiffs allege that more than half of all

such dollars foreseeably enabled Iranian-sponsored attacks.

919. For starters, regardless of the general merits of the view that it is difficult to

ascertain whether, or how much, regime profit flowed through SCB and onto support terrorist

violence, such considerations have no relevance with respect to Foundation fort the Oppressed

profits, given the Foundation’s status as the Iranian regime’s first purpose-bult terrorist

operations front. Especially so given the U.S. government’s publicly-stated finding on November

18, 2020 that the Khamenei, the SLO, and their terrorist allied used most of the Foundation’s

profits to enrich Khamenei’s most important inner circle allies – a direct and unmistakable

reference to the Iranian regime’s programmatic use of the Foundation’s profits to finance the

operations s of the Khamenei Cell, which was essentially a who’s-who of Khamenei’s longest-

lasting, closest, and most important allies within the IRGC and Hezbollah.

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920. Terrorism scholars have also confirmed the same. In 2018, for example, Dr.

Farhad Rezaei, of the Association for the Study of the Middle East and Africa, observed:

Iran would use the influx of capital which it would receive from the sanction relief to
invest in what is known as ‘revolutionary export,” that is a program to destabilize
neighboring countries through direct or proxy involvement in … terror activities. …
[T]here are indications that the regime has spent part of it on its foreign adventurism, …
[and] that the regime has spent some money on other proxies like … Hezbollah in
Lebanon and Hamas in Gaza strip, to expand its Shiite influence. … Some of the
money comes from … the foundations like Bonyad-e Mostazafan-e Enghelab-e Eslami
[Foundation for the Oppressed]. ... However, the evidence supports the [] concern that
Iran would utilize the money it had received from the sanctions relief to sponsor
terrorism … Iran has been using the influx of capital which it has received … to invest in
what is known as ‘revolutionary export,’ a code name for spreading the ideology of [Iran]
in the region. (Emphasis added.)

C. SCB’s Conduct Contributed to the Individual Attacks That Targeted

Plaintiffs and Their Family Members

921. SCB’s illicit conduct aided the specific terrorist cell leaders and operatives who

committed, planned, or authorized the attacks that killed and injured Plaintiffs.

922. Under their custom and practice, the IRGC and Hezbollah worked hand-in-glove

with the SLO to ensure that the Terrorist Sponsors’ financial apparatus was highly centralized,

which enhanced the link between SCB’s transactions and the attacks by Hezbollah, Hamas, PIJ

and JAM. Moreover, the application of the Logistics Policy Directive, mandatory donations

(khums), and in-house Hezbollah, IRGC, and SLO auditors and accountants ensured that the

terrorists maintained an ironclad grip over their money – and that Khamenei, in particular, could

ensure that funds were being spent on attacks – which was the reason Khamenei revolutionized

the SLO in the first place back in 1989-1990.

923. SCB’s illicit transactions also had a close nexus to the specific terrorist cells and

operatives who killed and injured Plaintiffs. The following Hezbollah, Hamas, PIJ, and JAM

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cells used the profits generated by SCB’s illicit services payments to help orchestrate the attacks

that targeted Plaintiffs and their family members.

924. The Khamenei Cell was the most prominent cell that ensured a direct link

between Defendants and the attacks that targeted Plaintiffs. Leadership cells can function as the

means by which terrorist groups plan, coordinate, and execute attacks. Few groups better

embodied that phenomenon than the IRGC and Hezbollah.

925. Consistent with the mandatory donations (khums), about 20% of all profits

generated by SCB flowed up to the Khamenei Cell as khums, before Khamenei (and Soleimani,

to whom Khamenei usually delegated such decisions) redistributed the funds back to Khamenei

Cell members, e.g., Qasem Soleimani and Hassan Nasrallah, to finance the attacks they

sponsored.

926. Senior U.S. government officials have confirmed that Qasem Soleimani was the

primary beneficiary of the illicit profits realized by the Iranian regime through sanctions evasion,

which Soleimani redeployed to sponsor proxy attacks by Hezbollah, Hamas, PIJ, and JAM. On

May 21, 2018, for example, Secretary of State Pompeo publicly observed as follows:

The JCPOA permitted the Iranian regime to use the money from the JCPOA to
boost the economic fortunes of a struggling people, but the regime’s leaders
refused to do so. Instead, the government spent its newfound treasure fueling
proxy wars across the Middle East and lining the pockets of the Islamic
Revolutionary Guard Corps, Hizballah, Hamas, and the Houthis. Remember: Iran
advanced its march across the Middle East during the JCPOA. Qasem Soleimani
has been playing with house money that has become blood money. Wealth
created by the West has fueled his campaigns. …
***
JAMES: It’s clear through your comments this morning that you truly want tough
sanctions. ... [C]an you explain for us the sanctions structure and how you
intend to target the Iranian regime without hurting our European friends?
POMPEO: Well, any time sanctions are put in place, countries have to give up
economic activity. So the Americans have given up economic activity now for an
awfully long time, and I’ll concede there are American companies who would
love to do business with the Islamic Republic of Iran. There’s a huge market

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there. It’s a big, vibrant, wonderful peoples. But everyone is going to have to
participate in this. Every country is going to have to understand that we cannot
continue to create wealth for Qasem Soleimani. Right, that’s what this is. At the
end of the day, this money has flowed to him. The economics have permitted
them to run roughshod across the Middle East. Our effort is to strangle his
economic capacity to do harm to the Middle East and to the world.

927. Defendants’ payments helped the Khamenei Cell play a key role in the attacks

that killed and injured Plaintiffs. From 2000 through 2020, the Khamenei Cell typically captured

about 20% of the income generated through any entity he controlled, including the Foundation

for the Oppressed, SLO, IRGC, and Hezbollah – including the profits caused by the transactions

that SCB illicitly managed. Given this standard practice, and the volume of profits generated by

SCB, the Bank’s illicit conduct likely delivered well in excess of $20 million per year to the

Khamenei Cell.

928. Khamenei, Soleimani, and the Khamenei Cell directly participated in the attacks

that killed and injured Plaintiffs as follows:

a. Rocket Attacks: Khamenei, Soleimani, and the Khamenei Cell participated in

Hezbollah’s, Hamas’s, and PIJ’s rocket attacks in Israel from 2010-2019, by ordering or
authorizing the decision to: (1) launch the attacks in the first instance; (2) help
Hezbollah’s, Hamas’s, PIJ’s and JAM’s terms for de-escalation; and (3) facilitate the
regular re-supply of the rockets from North Korea’s RGB; (4) approve, and fund, the
attack incentive and reward payments alleged herein, including, but not limited to, martyr
payments and salary payments; and (5) through Qasem Soleimani’s in-person leadership
role coordinating the Hezbollah’s, Hamas’s, and PIJ’s rocket operations.

b. Knife and Vehicle Ramming Attacks: Khamenei, Soleimani, and the Khamenei Cell
participated in Hezbollah’s, Hamas’s, and PIJ’s knife and vehicle ramming attacks in
Israel from 2010-2019, by ordering or authorizing the decision to: (1) launch the attacks
in the first instance; (2) help Hezbollah’s, Hamas’s, PIJ’s and JAM’s terms for de-
escalation; and (3) regularly issue calls for additional martyrs and support for the knife
and vehicle intifadas; and (4) approve, and fund, the attack incentive and reward
payments alleged herein, including, but not limited to, martyr payments and salary
payments.

c. Small Arms/Assassination Attacks: Khamenei, Soleimani, and the Khamenei Cell

participated in Hezbollah’s, Hamas’s, and PIJ’s rocket attacks in Israel from 2010-2019,
by ordering or authorizing the decision to: (1) launch the attacks in the first instance; (2)

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help Hezbollah’s, Hamas’s, PIJ’s and JAM’s terms for de-escalation; and (3) facilitate the
regular re-supply of the small arms, sniper rifles, and ammunition from North Korea’s
RGB; (4) approve, and fund, the attack incentive and reward payments alleged herein,
including, but not limited to, martyr payments and salary payments.

d. Hostage-Taking Attacks: Khamenei, Soleimani, and the Khamenei Cell participated in

Hezbollah’s, Hamas’s, and PIJ’s hostage-taking attacks in Israel from 2010-2019, by
ordering or authorizing the decision to: (1) continue seeking to kidnap American and
Israeli hostages; (2) approve, and fund, the attack incentive and reward payments alleged
herein, including, but not limited to, martyr payments and salary payments; and (3)
through Qasem Soleimani’s in-person leadership role coordinating the Hezbollah’s,
Hamas’s, and PIJ’s rocket operations.

e. EFP Attacks: Khamenei, Soleimani, and the Khamenei Cell participated in Hezbollah’s and
JAM’s EFP attacks in Iraq in 2011 by ordering or authorizing the decision to: (1) launch the
attacks in the first instance; (2) help Hezbollah’s, Hamas’s, PIJ’s and JAM’s terms for de-
escalation; (3) approve, and fund, the attack incentive and reward payments alleged herein,
including, but not limited to, martyr payments and salary payments; and (4) through Qasem
Soleimani’s in-person leadership role coordinating the Hezbollah’s and JAM’s EFP attacks.

D. SCB’s Conduct Supplied Long-Lasting Assistance That Continued Aiding

Iranian Regime-Sponsored Terrorist Attacks Committed by Hezbollah,
Hamas, PIJ, and JAM Until at Least 2019

929. SCB’s conduct supplied unusually long-lasting assistance to attacks committed by

Hezbollah, Hamas, PIJ, and JAM in at least five ways.

930. First, the uniquely long “tail” of petroleum industry investments ensured that

projects and contractual relationships that SCB helped the Iranian Terrorist Sponsors secure in

2014 or 2015 continued flowing profits for years thereafter.

931. Second, SCB’s assistance allowed key terrorists who sponsored the attacks

against Plaintiffs to enhance the personal jihad networks upon which they relied to maximize the

power of their attacks. For example, when Qasem Soleimani had more money, he could pay

more people to assist on matters like intelligence, logistics, and recruitment. The larger the

operatives’ network, the more lethal their attacks.

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932. Third, SCB’s conduct helped Hezbollah, Hamas, PIJ, and JAM stockpile weapons

for future attacks years later. Consistent with IRGC and Hezbollah practice, Hezbollah, Hamas,

PIJ, and JAM all emphasized long-term logistical planning, and massing weapons stockpiles.

933. Fourth, SCB’s conduct helped the Iranian Terrorist Sponsors finance the

construction of a latticework of terrorist attack tunnels in Gaza and southern Lebanon, which led

to a corresponding increase in terrorist attacks. Among other things, the tunnels facilitated rocket

attacks because terrorists fired rockets from inside purpose-bult tunnels, thus maintaining cover,

and the tunnel network allowed terrorists to continuously change the location form which they

fired, which increased the survivability (for the terrorists) and therefore led to more attacks.

934. Fifth, SCB supplied the terrorists with an impossible-to-overstate sum likely

ranging into the billions of dollars. At such amounts, the financial windfall SCB bestowed upon

Hezbollah, Hamas, PIJ, and JAM (via the Terrorist Sponsors) continued powering attacks for

many years after SCB stopped its conduct.

E. The Iranian Regime Used Most of the Profits Generated by SCB’s Schemes
to Directly and Indirectly Sponsor Attacks Committed, Planned, or
Authorized by the IRGC, Hezbollah, Hamas, PIJ, JAM, and Their Axis of
Resistance Allies

935. Ayatollah Khamenei, the SLO, IRGC, Hezbollah, and Foundation for the

Oppressed spent most of the profits that SCB helped them generate to directly or indirectly

sponsor terrorist attacks targeting the United States and its allies in the Middle East. For the

avoidance of all doubt, Plaintiffs do not allege that a small percentage of such profits flowed

through to the Terrorist Sponsors and their proxies – Plaintiffs allege that more than half of all

such dollars foreseeably enabled Iranian-sponsored attacks.

936. For starters, regardless of the general merits of the view that it is difficult to

ascertain whether, or how much, regime profit flowed through SCB and onto support terrorist

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violence, such considerations have no relevance with respect to Foundation fort the Oppressed

profits, given the Foundation’s status as the Iranian regime’s first purpose-bult terrorist

operations front. Especially so given the U.S. government’s publicly-stated finding on November

18, 2020 that the Khamenei, the SLO, and their terrorist allied used most of the Foundation’s

profits to enrich Khamenei’s most important inner circle allies – a direct and unmistakable

reference to the Iranian regime’s programmatic use of the Foundation’s profits to finance the

operations s of the Khamenei Cell, which was essentially a who’s-who of Khamenei’s longest-

lasting, closest, and most important allies within the IRGC and Hezbollah.

937. Terrorism scholars have also confirmed the same. In 2018, for example, Dr.

Farhad Rezaei, of the Association for the Study of the Middle East and Africa, observed:

Iran would use the influx of capital which it would receive from the sanction
relief to invest in what is known as ‘revolutionary export,” that is a program to
destabilize neighboring countries through direct or proxy involvement in …
terror activities. … [T]here are indications that the regime has spent part of it on
its foreign adventurism, … [and] that the regime has spent some money on other
proxies like … Hezbollah in Lebanon and Hamas in Gaza strip, to expand its
Shiite influence. … Some of the money comes from … the foundations like
Bonyad-e Mostazafan-e Enghelab-e Eslami [Foundation for the Oppressed]. ...
However, the evidence supports the [] concern that Iran would utilize the money
it had received from the sanctions relief to sponsor terrorism … Iran has been
using the influx of capital which it has received … to invest in what is known as
‘revolutionary export,’ a code name for spreading the ideology of [Iran] in the
region. (Emphasis added.)

938. On December 2, 2015, Representative Eliot Engel, publicly warned companies

and banks, including Defendants, that “logic says that if the goal of the Iranian regime, the

Revolutionary Guards and the entire regime, is to sponsor terrorism to destabilize the region,

now that they have money and it is not going to be a sacrifice, they are going to use it for

terrorism. When the Rial, their currency was in the toilet, when their people clamored for more

freedoms or more things that they needed, Iran, the government, the regime didn’t care. The

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regime made sure, though, that groups like Hezbollah and even Hamas, which of course is the

other side of the Sunni-Shia spectrum, had enough money. So now that Iran has money and it is

not going to be so painful, … it is very easy to imagine, and it is not imagination, that [the

IRGC] will have more money to support more terrorism.”

939. On December 2, 2015, Representative Ileana Ros-Lehtinen, publicly warned

companies and banks, including Defendants, that “the IRGC is one of the major actors in the

Iranian economy with a presence in nearly every sector” and given the IRGC’s anti-American

mission, the IRGC “will use the” money “it gets …. for its terror activities, instead of [choosing]

that the [IRGC’s additional] money will be used to shore up a failing Iranian economy.”

Representative Ros-Lehtinen continued:

[W]hen you think about … whether or not the Iranian Government is going to
take [new money it earns] … and direct it into the IRGC[,] … think … about the
fact that after the negotiations began in 2014, the IRGC budget went up …, and
this was just in anticipation of sanctions relief. This was publicly stated. This was
publicly declared. So … if you are asking yourself how the [IRGC] [is] going to
spend [new] money [it earns], [the IRGC] ha[s] already been very clear in
indicating it. [And remember that] … it is cheap to pull off a terrorist attack.

940. On December 2, 2015, Ali Alfoneh (Senior Fellow, Foundation for Defense of

Democracies), testified before Congress that when complex Iranian transactions produce

substantial value transfers to fronts owned or controlled by the IRGC, “[m]uch of the money …

is going to be channeled … directly to the military budget of the Revolutionary Guards …

[while] … the … Revolutionary Guard is pursuing policy objectives in the Middle East region

which are … totally opposed to U.S. objectives.”

941. When the U.S. government announced new counterterrorism sanctions against the

IRGC on May 1, 2020, for example, Treasury Secretary Mnuchin warned companies and banks,

including Defendants, that “[t]he Iranian regime and its supporters continue to prioritize the

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funding of international terrorist organizations over the health and well-being of the Iranian

people.”

942. From 2017 through 2024, the U.S. government regularly found—on a bipartisan

basis—that the Iranian regime used most of the profits resulting from the lack of application of

sanctions to sponsor terrorism. Such statements and reports included, but were not limited to:

a. Amb. Nathan Sales (Coordinator for Counterterrorism, U.S. Dep’t of State), November
13, 2018: “And who ultimately pays the price of this support? The Iranian people. The
resources Iran uses to fund its global terrorist campaign come directly out of the pockets
of ordinary Iranians. The regime robs its own citizens to pay its proxies abroad. Tehran’s
priorities are clear. It doesn’t seek to boost economic growth at home, or to improve
Iranian living standards. It doesn’t seek to reduce Iran’s growing unemployment. What
the regime prioritizes, despite the country’s increasing economic distress, is buying guns
and bombs for foreign terrorists. Tragically, this vast waste of the Iranian people’s assets
has resulted in bloodshed and instability across the globe.”

b. U.S. Department of the Treasury, November 20, 2018: “‘The Iranian regime continues to
prioritize spending money on fomenting terror over supporting its own people,’ said
Undersecretary for Terrorism and Financial Intelligence, Sigal Mandelker. ‘This is yet
another example of the regime using the proceeds of millions of barrels of its oil to fund
terrorists and the murderous Assad regime to the detriment of its own people.’”

c. Wally Adeyemo (United States Deputy Secretary of the Treasury), April 9, 2024:
“Senator, you’re right that in democracy, money is fungible. But what we’ve seen time
and time [again] from the Iranian regime is [that] they fail to feed their people and they
put the IRGC first. Any dollar they have will go towards their violent activity before they
deal with the people. That’s partially why almost none of the humanitarian money has
been used for humanitarian purposes is because they don’t care about getting food and
drugs for their people but the difference is the United States of American has made, as a
values proposition, that we are always going to provide humanitarian relief for people.
And that’s what we said is the only purpose for this money. So while in our country
money is fungible, in Iran, they’ve proven that any dollar they get that they have direct
access to in the country will be used for the IRGC before it’s ever used for their people.”

d. U.S. Senate Committee on Banking, Housing, and Urban Affairs (Minority Staff), April
12, 2024: “After U.S. Department of Treasury Deputy Secretary Wally Adeyemo
admitted in testimony that any dollar Iran has access to funds terrorism, Ranking Member
Tim Scott (R-S.C.) continues to press the Biden administration on U.S. enabled payments
to Iran. In a letter to Treasury Secretary Janet Yellen, Ranking Member Scott … wrote,
‘As we have previously discussed, I have serious concerns with U.S.-enabled efforts that
increase Iran’s access to sanctioned funds—funds that directly support Iran’s terror
proxies throughout the Middle East. Unfortunately, the testimony that was delivered

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before the Committee has only elevated those concerns by making it abundantly clear
that the current sanctions relief and humanitarian assistance scheme provided to Iran are
not viable solutions, and rather deteriorate U.S. national security interests. … Given the
proven track-record Iran has on redirecting so-called humanitarian assistance to ‘violent
activity,’ as characterized by Treasury, we must operate under the assumption that every
dollar made available to Iran is another dollar that will be used to put U.S.
servicemembers in harm’s way or threaten our allies, especially Israel…In light of this, I
am requesting an accounting of all international high-value Iranian assets around the
world that are currently blocked by U.S. sanctions as well as additional steps Treasury
will now take to actively account for current funds that have already been released to
Iran. Not a single dollar, euro, or dinar, sanctioned by the United States should ever be
released to Iran when this Administration actively recognizes that any money to Iran
supports terrorism.’”

943. COVID offered a grim case study that confirmed, in real-time, that the IRGC

always directed all or nearly all IRGC income from fronts, black markets, and other IRGC

sources to the IRGC’s primary mission: sponsoring acts of international terrorism targeting the

United States as part of the IRGC’s “Resistance” on behalf of the “Oppressed.” On October 9,

2020, the U.S. government imposed additional counterterrorism sanctions on the IRGC and

warned companies and banks, including Defendants, that:

[W]hile COVID-19 was spreading through Iran, regime officials asked Supreme
Leader Khamenei to urgently release funds to respond to the outbreak. Despite
Khamenei’s assurances to do so, Iran’s Health Minister revealed last week that
the Health Ministry had received only a small fraction of those funds. The Health
Minister asked[,] “What are they using it for that could be more important?” We
know the answer. In 2018 and 2019, Khamenei raided $4 billion from the Iranian
National Development Fund for military expenses. And while the Health Ministry
was pleading for resources to protect the Iranian people from the outbreak,
Khamenei instead increased funding for the Islamic Revolutionary Guard Corps, a
designated Foreign Terrorist Organization, by a third, and doubled the funding for
the regime’s Basij forces that terrorize the Iranian people every single day.
Our sanctions are directed at the regime and its corrupt officials that have
used the wealth of the Iranian people to fuel a radical, revolutionary cause that has
brought untold suffering across the Middle East and beyond.

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F. U.S. Government Findings from 2017 through 2024 Confirm That SCB’s
Illicit Services Funded Iranian Regime-Sponsored Terrorist Attacks by
Hezbollah, Hamas, PIJ, and JAM

944. From 2017 through 2024, The U.S. government explicitly confirmed that

sanctions-busting transactions like those of SCB directly financed Iranian-sponsored terrorist

attacks committed by Hezbollah, Hamas, PIJ, and JAM from 2006 through 2020

945. Official United States sanctions announcements, legislative findings enshrined by

Congress in the U.S. code, and Executive Branch reports to Congress under penalty of perjury

operated as one-way ratchet with respect to the plausibility of Plaintiffs’ allegations: while such

U.S. reports can confirm a point, the absence of a report (or a particular finding) usually means

little (if anything) in the sort of counterterrorism analysis that a counterterrorism practitioner

following the normal custom and practice of the counterterrorism would follow to offer an

opinion as to the likelihood that a particular entity or persons sponsors terrorist violence if other

indicators warrant such conclusion. This one-way-ratchet existed for at least four reasons. First,

to impose sanctions, the Executive Branch follows a standard that is effectively more demanding

than a simple “more likely than not” analysis. Accordingly, the mere fact that a person or entity

is more likely than not a terrorist is not, on its own, usually enough to cause the U.S. to impose

sanctions. Second, given the extensive U.S. government interagency process that the United

States follows every time it imposes sanctions – which ordinarily takes at least several years, and

often longer – U.S. sanctions announcements often reflect a multi-year time-lag as compared to

then-publicly known facts about terrorists and associated terrorist finance. Third, while the

United States government sometimes makes diplomatic decisions to hold off announcing

sanctions – or avoid imposing sanctions at all – even when the U.S. government concluded that

the subject entity or person sponsors terrorists, Plaintiffs are aware of no reported instance – or

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credible allegation – in which the United States imposed counterterrorism sanctions for

pretextual purposes.

946. Foundation for the Oppressed. On September 25, 2018, President Trump told

the U.N. General Assembly in a globally televised address that “Iran’s leaders sow chaos, death,

and destruction” by “plunder[ing] the nation’s resources to enrich themselves and to spread

mayhem across the Middle East and far beyond,” “seiz[ing] valuable portions of the economy,

and loot[ing” the people’s religious endowments” – the largest of which was the Foundation for

the Oppressed – “all to line their own pockets and send their proxies to wage war.”

947. On November 18, 2020, the United States designated the Foundation for the

Oppressed, confirmed that it served as a “bridge to the IRGC,” and announced:

OFAC … act[ed] … against a key patronage network for the Supreme Leader of
Iran, the … Bonyad Mostazafan [Foundation for the Oppressed] … While Bonyad
Mostazafan is ostensibly a charitable organization charged …, its holdings are
expropriated from the Iranian people and are used by [Ayatollah] Khamenei to …
enrich his office, reward his political allies, and persecute the regime’s enemies.
… “Iran’s Supreme Leader uses Bonyad Mostazafan to reward his allies under the
pretense of charity,” said Secretary Steven T. Mnuchin. …

PARVIZ FATTAH, BONYAD MOSTAZAFAN’S BRIDGE TO THE IRGC

Bonyad Mostazafan maintains close ties to the IRGC, personified by current
Foundation president and former IRGC officer Parviz Fattah. Appointed to the
presidency of the Foundation by the Supreme Leader in July 2019, Fattah
previously . . . . served as head of the Imam Khomeini Relief Committee, whose
Lebanon branch was designated pursuant to counterterrorism authorities in 2010
for being owned or controlled by, and for providing financial and material support
to, Hizballah. Known for his loyalty to the Supreme Leader, Fattah has also
forged ties to senior IRGC-Qods Force (IRGC-QF) officials. According to Fattah,
former IRGC-QF commander Qassem Soleimani sought Fattah’s assistance to
finance the Fatemiyoun Brigade, an IRGC-QF-led militia composed of Afghan
migrants and refugees in Iran coerced to fight in Syria under threat of arrest or
deportation. . . . The Fatemiyoun Brigade, like the IRGC-QF itself, is designated
pursuant to [] counterterrorism … authorities. …

948. In the same designation, Treasury confirmed that the Foundation for the

Oppressed served primarily as a front for terror and performs little legitimate charitable work:

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“[w]hile the Supreme Leader enriches himself and his allies, the Foundation’s primary mission to

care for the poor has become a secondary objective. According to the Foundation’s previous

president, in past years as little as seven percent of the Foundation’s profit has been spent on

projects aimed at reducing poverty.”

949. On January 13, 2021, Treasury imposed additional sanctions on Iranian bonyads,

and again noted the Foundation for the Oppressed’s direct role in IRGC-sponsored terrorism:

[P]urportedly charitable organizations (bonyads) …control large swaths of the

Iranian economy … to the benefit of Supreme Leader Ali Khamenei and senior
Iranian … officials. Alongside the previously designated Bonyad Mostazafan,
itself controlled by the Supreme Leader, and the IRGC-owned Khatam al-Anbiya,
bonyads are said to control more than half of the Iranian economy.
“These institutions enable Iran’s elite to sustain a corrupt system of
ownership over large parts of Iran’s economy,” said Secretary Steven T. Mnuchin.
“The United States will continue to target those who enrich themselves while
claiming to help the Iranian people.” …
This action follows Treasury’s November 2020 designation of the Bonyad
Mostazafan [Foundation for the Oppressed], an immense conglomerate with
holdings in key sectors of Iran’s economy. … Bonyad Mostazafan has been the
beneficiary of favorable treatment by Iran’s corrupt leadership, and its assets have
been used by the Supreme Leader Ali Khamenei to enrich his office, reward his
political allies, and persecute the regime’s perceived enemies.

IRANIAN BONYADS
Bonyads are opaque, quasi-official organizations generally controlled by
current and former government officials and clerics that report directly to the
Supreme Leader. Bonyads receive benefits from the Iranian government,
including tax exemptions, but are not required to have their budgets publicly
approved. This lack of accountability has enabled the bonyads to expand their
economic activities far beyond their original remit and has led to the accumulation
of vast amounts of wealth without …benefit to the people of Iran.

950. The U.S. government statements confirming the Foundation for the Oppressed’s

direct connection to IRGC sponsored, proxy-committed, acts of terrorism targeting the United

States described a consistent pattern of conduct that existed at all relevant times throughout

SCB’s scheme with the IRGC and Hezbollah. These sources show that the Foundation was

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closely intertwined with terrorist violence because the Qods Force and Hezbollah used

Foundation revenues to finance terrorist attacks.

951. Supreme Leader’s Office. On June 26, 2019, the United States issued Executive

Order 13,876, which formally found that the SLO directly facilitated IRGC-sponsored acts of

“international terrorism committed by “Iranian-backed proxies” in the “Middle East.”

952. On November 5, 2019, the United States imposed IRGC counterterrorism-related

sanctions against the SLO to target its sponsorship of terrorist attacks committed by the Qods

Force, Hezbollah, and their proxies, based upon findings that included as follows:

OFAC … act[ed] … against … individuals who are appointees of, or have acted
for or on behalf of, Ali Khamenei, the Iranian regime’s unelected Supreme Leader
whose office is responsible for advancing Iran’s radical agenda. This action seeks
to block funds from flowing to a shadow network of Ali Khamenei’s military and
foreign affairs advisors who have for decades oppressed the Iranian people,
exported terrorism, and advanced destabilizing policies around the world.
Specifically, the action targets Ali Khamenei’s appointees in the Office of the
Supreme Leader ….
“Today the Treasury Department is targeting the unelected officials who
surround Iran’s Supreme Leader, Ayatollah Khamenei, and implement his
destabilizing policies,” said Treasury Secretary Steven T. Mnuchin. “These
individuals [in the SLO] are linked to a wide range of malign behaviors by the
regime, including bombings of the U.S. Marine Barracks in Beirut in 1983 and the
Argentine Israelite Mutual Association in 1994, as well as torture, extrajudicial
killings, and repression of civilians. This action further constricts the Supreme
Leader’s ability to execute his agenda of terror and oppression.”
This action is being taken pursuant to President Donald J. Trump’s
Executive Order (E.O.) 13876, signed on June 24, 2019. The E.O. imposed
sanctions on the Supreme Leader of the Islamic Republic of Iran and the Supreme
Leader’s Office (SLO), and authorized sanctions on others associated with the
Supreme Leader or the SLO. …
Mojtaba Khamenei, the second son of [Khamenei], is designated today for
representing the Supreme Leader in an official capacity despite never being
elected or appointed to a government position aside from work in the office of his
father. The Supreme Leader has delegated a part of his leadership responsibilities
to Mojataba [sic] Khamenei, who worked closely with the commander of the …
Qods Force [i.e., Qasem Soleimani] … to advance [Ayatollah Khamenei]’s
destabilizing regional ambitions ….
Also designated today is Gholam-Ali Hadad-Adel, father-in-law of
Mojtaba Khamenei, a member of the Expediency Council and also an advisor to

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Ali Khamenei. Hadad-Adel is known to be among those in the Supreme Leader’s

inner circle. … Gholam-Ali Hadad-Adel is being designated [pursuant to E.O.
13876] for having acted or purported to act for or on behalf of, directly or
indirectly, the Supreme Leader of Iran.

953. Notably, Mojtaba Khamenei and Gholam-Ali Hadad-Adel both operated through

Petro Nahad, and thus, the above findings also confirm the tight nexus between Petro Nahad and

Qods Force-sponsored attacks supported by Qasem Soleimani—which describes every attack

against Plaintiffs and their loved ones.

954. On November 3, 2022, the United States imposed additional IRGC

counterterrorism-related sanctions against the SLO to target its direct and indirect sponsorship of

acts of terrorism committed by the Qods Force, Hezbollah, and their proxies, based upon

findings that included as follows:

[OFAC] designated members of an international oil smuggling network that

facilitated oil trades and generated revenue for Hizballah and the … Qods Force
… in support of Hizballah and the IRGC-QF.
“The individuals running this illicit network use a web of shell companies
and fraudulent tactics including document falsification to obfuscate the origins of
Iranian oil, sell it on the international market, and evade sanctions,” said Under
Secretary of the Treasury for Terrorism … Brian E. Nelson. “Market participants
should be vigilant of Hizballah and the IRGC-QF’s attempts to generate revenue
from oil smuggling to enable their terrorist activities around the world.” …
[An] Iranian national … oversaw … the network’s illegal … exportation
of Iranian oil in support of Hizballah and the IRGC-QF … [and] received orders
from high-ranking Iranian officials associated with the U.S.-designated []
Supreme Leader’s Office to direct the network’s oil smuggling operation profits
to companies and bank accounts associated with Hizballah and the IRGC-QF.

955. That same day, Secretary of State Antony J. Blinken confirmed that the U.S. had

sanctioned this SLO-directed, Hezbollah- and Qods Force-operated “sanctions evasion network”

and “11 vessels” because the United States determined that they “provid[ed] support to Hizballah

and the Islamic Revolutionary Guard Corps-Qods Force” when they “facilitate[d] the sale of

hundreds of millions of dollars’ worth of oil for these organizations [i.e., Hezbollah and the Qods

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Force]” through the use of “shell and front companies established to facilitate the illegal blending

and exportation of Iranian oil around the world,” which the United States determined “provid[ed]

support to terrorists or acts of terrorism” by Hezbollah and the Qods Force.

956. From at least 2021 through 2024, the United States publicly sanctioned “Ali

Husseini Khamenei, Supreme Leader, for support of the IRGC, a Foreign Terrorist

Organization,” and “Mojtaba Khamenei, son of Supreme Leader,” which identified Ayatollah

Khamenei and Mojtaba Khamenei as persons whom the U.S. had sanctioned pursuant to

“Section 221 of the Iran Threat Reduction and Syria Human Rights Act of 2012, Public Law

112-158 (TRA), enacted on August 10, 2012, codified at 22 U.S.C. 8727, requires the President

to publish a list of individuals that the President has determined are senior officials of the

Government of Iran, as defined in the statute, that are involved in Iran’s illicit nuclear activities

or proliferation of weapons of mass destruction (WMD) or delivery systems for WMD; support

for international terrorism; or the commission of serious human rights abuses against Iranian

citizens or their family members.”

957. The U.S. government statements confirming the SLO’s direct connection to IRGC

sponsored, proxy-committed, acts of terrorism targeting the United States described a consistent

pattern of conduct that existed at all relevant times throughout SCB’s scheme with the IRGC and

Hezbollah. These sources show that the SLO was closely intertwined with terrorist violence

because the Qods Force and Hezbollah used the SLO’s profits to finance terrorist attacks.

958. IRGC. On July 17, 2017, the United States announced new IRGC-related

sanctions, and warned that “[t]he United States remains deeply concerned about” how the

“Islamic Revolutionary Guard Corps (IRGC)” enabled “Iran’s malign activities across the

Middle East,” because the IRGC “continues to support terrorist groups such as Hizballah.”

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959. On August 2, 2017, Congress enacted, and the President signed, the Countering

America’s Adversaries Through Sanctions Act, an amendment to the U.S. Code that formally

codified that “Congress makes the following findings: ... (2) The Iranian Revolutionary Guard

Corps–Quds Force (in this section referred to as the ‘‘IRGC–QF’’) … support[s] terrorist and

insurgent groups [by] … provid[ing] material, logistical assistance, training, and financial

support to militants and terrorist operatives throughout the Middle East and South Asia”; and

“(3) The IRGC, not just the IRGC–QF, is responsible for implementing Iran’s international

program of … support for acts of international terrorism ….” § 105, 22 U.S.C. § 9404, Pub. L.

No. 115-44, 131 Stat. 892 (2017). Moreover, the updated U.S. Code noted “the IRGC, including

the Quds Force … [provided] support, including funding, lethal and nonlethal contributions, and

training, … to Hezbollah, Hamas, special groups in Iraq, … and other violent groups across the

Middle East.” § 103(b)(5), 22 U.S.C. § 9402, Pub. L. No. 115-44, 131 Stat. 889 (2017).

960. On October 13, 2017, the United States designated the entirety of the IRGC as a

Specially Designated Global Terrorist, and stated, in part, as follows:

a. Treasury: “OFAC … designated [the] Islamic Revolutionary Guard Corps (IRGC)

pursuant to the global terrorism Executive Order (E.O.) 13224 and consistent with the
Countering America’s Adversaries Through Sanctions Act. OFAC designated the IRGC
today for its activities in support of the IRGC-Qods Force (IRGC-QF), which was
designated pursuant to E.O. 13224 on October 25, 2007, for providing support to a
number of terrorist groups, including Hizballah and Hamas …. The IRGC has provided
material support to the IRGC-QF, including by providing training, personnel, and
military equipment.”

b. Treasury: “‘The IRGC has played a central role to Iran becoming the world’s foremost
state sponsor of terror. … Treasury will continue using its authorities to disrupt the
IRGC’s destructive activities,’ said Treasury Secretary Steven T. Mnuchin. ‘We are
designating the IRGC for providing support to the IRGC-QF, the key Iranian entity
enabling … the lethal activities of Hizballah, Hamas, and other terrorist groups. We urge
the private sector to recognize that the IRGC permeates much of the Iranian economy,
and those who transact with IRGC-controlled companies do so at great risk.’”

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c. Treasury: “The IRGC was designated today for the activities it undertakes to assist in,
sponsor, or provide financial, material, or technological support for, or financial or other
services to or in support of, the IRGC-QF.”

d. White House: “[T]he Iranian regime continues to fuel … terror … throughout the Middle
East and beyond” through “[t]he Revolutionary Guard[’s]” deployment as “the Iranian
Supreme Leader’s corrupt personal terror force.”

e. White House: “In Iraq and Afghanistan, groups supported by Iran have killed hundreds of
American military personnel. The Iranian dictatorship’s aggression continues to this day.
The regime remains the world’s leading state sponsor of terrorism, and provides
assistance to … Hezbollah, Hamas, and other terrorist networks.”
f.
White House: “The Revolutionary Guard … has hijacked large portions of Iran’s
economy and seized massive religious endowments [i.e., bonyads or foundations, e.g., the
Foundation for the Oppressed] to fund … terror abroad. This includes … supplying
proxies and partners with missiles and weapons to attack civilians in the region[] and
even plotting to bomb a popular restaurant right here in Washington, D.C.”

g. White House: “I am authorizing … Treasury … to further sanction the entire [IRGC] for
its support for terrorism and to apply sanctions to its officials, agents, and affiliates.”

961. On October 16, 2017, Treasury Under Secretary Sigal Mandelker publicly

confirmed how the entire IRGC was involved in supporting terrorist attacks in the Middle East

committed by Hezbollah, Hamas, PIJ, and JAM:

a. “[T]here are few more pressing national security concerns for the United States and the
international community right now than the growing threat posed by … [t]he Iranian
regime,” which was “wreaking havoc on the Middle East and beyond” and providing
“state support of terrorism” that was “second-to-none” by “financ[ing] and support[ing]
Hizballah, Hamas, and … Iraqi … militant groups” by “seed[ing] these terror groups with
increasingly destructive weapons as they try to establish footholds from Iran to Lebanon
and Syria” and such “aid [was] primarily delivered by … the IRGC[] and its Quds Force,
which … [existed as] vehicles to cultivate and support terrorists abroad.”

b. “The IRGC has even threatened terrorist attacks right here in the United States, plotting
the murder of Saudi Arabia’s Ambassador to the United States on American soil in 2011.
Such an attack—if not thwarted by our terrific law enforcement and intelligence
officers—would have not only killed a Saudi diplomat, but likely innocent bystanders
here in Washington, DC.”

c. “[The United States’s] Iran strategy … is designed to neutralize Iran’s destabilizing

influence and support for terrorists and militants. It includes four strategic objectives:
First, we must neutralize Iran’s destabilizing activities and constrain Iran’s aggression,
particularly its support for terrorism and militants with a focus on its activities in the

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Middle East …[,] includ[ing] its actions in Syria, which threatens Israel, and its support
to terrorism through groups like Hizballah, Hamas, Iraqi Shia militant groups and others.
Second, we must work to deny Iran and especially the IRGC funding for its malign
activities, including its funding for terrorists and militant proxies …”

d. “On [October 13, 2017], OFAC designated the IRGC for support to terrorism under
Executive Order 13224, consistent with section 105 of the Countering America’s
Adversaries Through Sanctions Act passed in August. The President also authorized us to
take additional action against the IRGC’s officials, agents, and affiliates later this month.
The IRGC designation … further increases the pressure on the IRGC. It also highlights
the nefarious nature of the organization. Beyond being a proliferator of weapons and a
supplier of militants and military equipment – actions for which it has been previously
sanctioned by the United States – the IRGC has helped make Iran the world’s leading
state sponsors of terrorism.”

e. “The IRGC provides the organizational structure that allows them to export their militant
extremism across the globe. It has been the Iranian regime’s main weapon in pursuit of its
radical goals and is a lifeline for Hizballah, … Shia militant groups in Iraq, and others.
The IRGC’s control over large portions of the Iranian economy furthers its ability to
support these groups and enrich its members. In order to deny the IRGC the resources
and financing it needs to spread instability, we must and we have been engaging our
allies and partners, including those in the private sector.”

f. “[T]o deny the IRGC the resources and financing it needs to spread instability, we …
have been engaging … the private sector. We have consistently raised concerns regarding
the IRGC’s malign behavior, the IRGC’s level of involvement in the Iranian economy,
and its lack of transparency. We have pointed out that the IRGC continues to be an
integral part of the Iranian economy, including in the energy, construction, mining, and
defense sectors. And as we have urged the private sector to recognize that the IRGC
permeates much of the Iranian economy, we have told them that those who transact with
IRGC-controlled entities do so at their own risk.”

962. On May 8, 2018, the United States announced new sanctions against the IRGC

confirming:

The Iranian regime is the leading state sponsor of terror. It exports dangerous
missiles … and supports terrorist proxies and militias such as Hezbollah [and]
Hamas …. Over the years, [the IRGC] and its proxies have bombed American
embassies and military installations, murdered hundreds of American
servicemembers, and kidnapped, imprisoned, and tortured American citizens. The
Iranian regime has funded [the IRGC’s] long reign of chaos and terror by
plundering the wealth of its own people.

963. On October 1, 2018, the United States published its counterterrorism strategy,

confirming that the IRGC continued to seek to leverage its global networks of financiers,

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logisticians, and recruits, including persons in the United States, to sponsor acts of terrorism

targeting the United States:

Iran remains the most prominent state sponsor of terrorism, supporting militant
and terrorist groups across the Middle East and cultivating a network of
operatives that pose a threat in the United States and globally. These groups, most
notably Lebanese Hizballah (Hizballah), use terrorism … in partnership with Iran
to expand their influence in Iraq, Lebanon, [and] the Palestinian territories ….
Hizballah fields powerful military and intelligence elements, possesses large
stocks of sophisticated arms, and maintains extensive networks of operatives and
sympathizers overseas, including individuals in the [United States] homeland.

964. On October 11, 2018, FinCEN published its Advisory On The Iranian Regime’s

Illicit And Malign Activities And Attempts To Exploit The Financial System, in which FinCEN

warned multinational companies and banks, including SCB, that whenever a company or bank

enables the IRGC’s “Abuse of the International Financial System … to access the financial

system through covert means and to further [the IRGC’s] malign activities [by] … misusing

banks and exchange houses, operating procurement networks that utilize front or shell

companies, exploiting commercial shipping, and masking illicit transactions using senior

officials, … [o]ften, these efforts serve to fund the regime’s nefarious activities, including

providing funds to the Islamic Revolutionary Guard Corps (IRGC) and its Islamic

Revolutionary Guard Corps-Qods Force (IRGC-QF), as well to Lebanese Hizballah, … and

other [IRGC proxy] terrorist groups.” (Emphasis added.) Treasury’s rollout confirmed, inter

alia:

a. “[T]he Iranian regime has masked illicit transactions using senior officials of the CBI,
who used their official capacity to procure hard currency and conduct transactions for the
benefit of the Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF) and its
terrorist proxy group, Lebanese Hizballah. Accordingly, financial institutions are advised
to exercise appropriate due diligence when dealing with transactions involving exchange
houses that may have exposure to the Iranian regime and/or designated Iranian persons,
and the advisory details examples of exchange house-related schemes. Iran-related actors
use front and shell companies around the world in procurement networks through which

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the Iranian regime has gained goods and services related to currency counterfeiting, dual-
use equipment, and the commercial aviation industry.”

b. “In order to help financial institutions identify deceptive activity potentially linked to the
Iranian regime, FinCEN has included red flags in its advisory. For example, CBI
officials’ routing transactions to personal accounts rather than central bank or
government-owned accounts, and individuals or entities with no central bank or
government affiliation withdrawing funds from such accounts, may be a red flag for
financial institutions to investigate. Similarly, wire transfers or deposits that do not
contain any information on the source of funds, contain incomplete information about the
source of funds, do not match the customer’s line of business, or that involve jurisdictions
where there is a higher risk of dealing with entities linked to the Iranian regime may be
red flag indicators of illicit Iranian attempts to gain access to the U.S. financial system or
evade sanctions.”

965. On April 8, 2019, the U.S. announced its intention to formally designate the entire

IRGC—including regular IRGC, the Qods Force, and the Basij—as an FTO, which the U.S. did

on April 15, 2019. During the rollout, U.S. officials warned, in part, as follows:

a. President Donald J. Trump, April 2019: “Today, I am formally announcing my

Administration’s plan to designate Iran’s Islamic Revolutionary Guard Corps (IRGC),
including its Qods Force, as a Foreign Terrorist Organization (FTO) under Section 219 of
the Immigration and Nationality Act. This unprecedented step, led by the Department of
State, recognizes the reality that Iran is not only a State Sponsor of Terrorism, but that the
IRGC actively participates in, finances, and promotes terrorism as a tool of statecraft. The
IRGC is the Iranian government’s primary means of directing and implementing its
global terrorist campaign. This designation will be the first time that the United States has
ever named a part of another government as a FTO. It underscores the fact that Iran’s
actions are fundamentally different from those of other governments. … If you are doing
business with the IRGC, you will be bankrolling terrorism.”

b. Secretary of State Michael R. Pompeo, April 2019: “I’m here to make an important
foreign policy announcement concerning the Islamic Republic of Iran. Today the United
States is continuing to build its maximum pressure campaign against the Iranian regime. I
am announcing our intent to designate the Islamic Revolutionary Guard Corps, including
its Qods Force, as a foreign terrorist organization in accordance with Section 219 of the
Immigration and Nationality Act. … This is the first time that the United States has
designated a part of another government as an FTO. We’re doing because the Iranian
regime’s use of terrorism as a tool of statecraft makes it fundamentally different from any
other government. This historic step will deprive the world’s leading state sponsor of
terror the financial means to spread misery and death around the world. … Our [IRGC
FTO] designation makes clear to the world that Iranian regime not only supports terrorist
groups, but engages in terrorism itself. This designation also brings unprecedented
pressure on figures who lead the regime’s terror campaign, individuals like Qasem

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Soleimani. He is the commander of the Qods Force and oversees Iran’s forces deployed
to advance the Islamic Revolution through terrorism and other forms of violence. He
doles out the regime’s profits to terrorist groups across the region and around the world.
… [T]he mission of this [U.S.] designation [of the IRGC as a Foreign Terrorist
Organization is] … to achieve the outcomes that we laid out back in May [2018] to …
[stop the IRGC from] … risking American lives each and every day.”

c. State, April 2019: “The IRGC – primarily through its Qods Force – is the primary arm of
the Iranian government that carries out and directs Tehran’s dangerous and destabilizing
global terrorist campaign. The IRGC provides funding, equipment, training and logistical
support to a broad range of terrorist and militant organizations, totaling approximately
one billion dollars annually in assistance. The IRGC has also been directly involved in
terrorist plotting and related activity in many countries … The IRGC is integrally woven
into the Iranian economy, operating front companies and institutions around the world
that engage in both licit and illicit business activity. The profits from what appear to be
legitimate business deals could end up … supporting Iran’s terrorist agenda.”

966. On April 15, 2019, the United States designated the entire IRGC, including

regular IRGC, the Qods Force, and the Basij, as an FTO for, inter alia, “provid[ing] financial

and other material support, training, technology transfer, advanced conventional weapons,

guidance, or direction to a broad range of terrorist organizations, including Hizballah, Palestinian

terrorist groups like Hamas and Palestinian Islamic Jihad, Kata’ib Hizballah in Iraq, … and other

terrorist group[s]….” In support, State concluded that the IRGC “has engaged in terrorist activity

since its inception 40 years ago,” that “its support for terrorism is foundational and institutional,”

that it “has killed U.S. citizens,” and that it “has the greatest role among Iran’s actors in directing

and carrying out a global terrorist campaign.” Announcing the designation, Secretary of State

Pompeo emphasized that the IRGC “plans, organizes, and executes terror campaigns all around

the world,” and that the “IRGC institutionalized terrorism shortly after its inception, directing

horrific attacks . . . alongside the terror group it midwifed, Lebanese Hizballah.” Secretary

Pompeo described the designation as “simply recognizing a basic reality,” placing the IRGC in

“its rightful place on the same list as terror groups it sponsors.” As State reported to Congress in

2020, its “designat[ion]” of the “IRGC as an FTO in April 2019” was a “historic action” and

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“unprecedented step,” which “reflected the Iranian regime’s unique place among the

governments of the world in its use of terrorism as a central tool of its statecraft.”

967. On January 14, 2020, President Trump implemented Executive Order 13,902,

which imposed additional counterterrorism sanctions on the IRGC, and found, inter alia:

a. “[The President] find[s] that Iran continues to be the world’s leading sponsor of terrorism
and that Iran has threatened United States military assets and civilians through the use of
military force and support to Iranian-backed militia groups. It remains the policy of the
United States to …counter the totality of Iran’s malign influence in the region. In
furtherance of these objectives, it is the policy of the United States to deny the Iranian
government revenues, including revenues derived from the export of products from key
sectors of Iran’s economy, that may be used to fund and support its … terrorism and
terrorist proxy networks ….”

b. “[The President] hereby determine[s] that the making of donations of the types of articles
specified in section 203(b)(2) of IEEPA (50 U.S.C. 1702(b)(2)) by, to, or for the benefit
of any person whose property and interests in property are blocked pursuant to section 1
of this order would seriously impair the President’s ability to deal with the national
emergency declared in Executive Order 12957 [i.e., the IRGC’s sponsorship of acts of
terrorism targeting the United States].”

968. On March 26, 2020, Treasury announced new counterterrorism sanctions against

the IRGC pursuant to E.O. 13,324 and reported findings as follows:

a. “OFAC … today designated 20 Iran- and Iraq-based front companies, senior officials,
and business associates that provide support to or act for or on behalf of the Islamic
Revolutionary Guards Corps-Qods Force (IRGC-QF) in addition to transferring lethal aid
to Iranian-backed terrorist militias in Iraq such as Kata’ib Hizballah (KH) and Asa’ib Ahl
al-Haq (AAH). Among other malign activities, these entities and individuals perpetrated
or supported: smuggling through the Iraqi port of Umm Qasr; money laundering through
Iraqi front companies; selling Iranian oil to the Syrian regime; smuggling weapons to Iraq
…; promoting propaganda efforts in Iraq on behalf of the IRGC-QF and its terrorist
militias …. The terrorist militias supported by the Iranian regime such as KH and AAH
have continued to engage in attacks on U.S. and Coalition forces in Iraq.”

b. “‘Iran employs a web of front companies to fund terrorist groups across the region,
siphoning resources away from the Iranian people and prioritizing terrorist proxies over
the basic needs of its people,’ said Treasury Secretary Steven T. Mnuchin.”

969. On May 1, 2020, the United States announced new counterterrorism sanctions

against the IRGC and confirmed that “senior officials of [the] Islamic Revolutionary Guard

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Corps-Qods Force (IRGC-QF)” were “involved in IRGC-QF efforts to generate revenue and

smuggle weapons abroad” through an IRGC front “company owned, controlled, or directed by”

an IRGC member, thereby “violat[ing] [U.S.] sanctions and money laundering laws” by

committing “crimes” that caused valuable “assets” to flow to “a foreign terrorist organization.”

On June 1, 2023, the United States imposed counterterrorism sanctions” pursuant to E.O.

13224 against numerous” members and affiliates of” the “IRGC-QF” and “IRGC-IO” based on

Treasury’s determination that such persons “participated in a series of terrorist plots including

assassination plots targeting former United States government officials, dual U.S. and Iranian

nationals, and Iranian dissidents”; with respect to IRGC-IO, Treasury “target[ed] … two senior

officials of the IRGC’s Intelligence Organization (IRGC-IO)[] who have been involved in

plotting [such collaborative IRGC-QF/IRGC-IO] external lethal operations against [U.S.

national] civilians including journalists and activists.” In the same finding, Treasury also

observed: “Treasury has consistently acted to address external terrorist plotting by the IRGC-QF

and Iran’s intelligence service [i.e., IRGC-IO].

X. Plaintiffs’ Claims Are Timely

970. The ATA provides that suits for damages must be brought “within 10 years after

the date the cause of action accrued.” 18 U.S.C. § 2335. This statute of limitations applies to all

ATA claims, including claims for aiding and abetting under JASTA. JASTA, however, was not

enacted until September 28, 2016, and was expressly made retroactive. Accordingly, Plaintiffs’

claims could not have accrued before that date, and Plaintiffs’ claims are all timely because they

are being brought within 10 years after September 28, 2016, the date they accrued.

971. If the Court concludes that Plaintiffs’ causes of action accrued earlier (e.g., on the

date of the terrorist attacks that injured them), and to the extent tolling is required for any

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particular Plaintiff’s claim, Plaintiffs are entitled to tolling because SCB fraudulently concealed

its misconduct, and no plaintiff exercising reasonable diligence could have discovered that

misconduct prior to April 9, 2019, when the United States publicly filed the Amended DPA that

revealed SCB’s knowing and willful processing of U.S. dollar transactions for Iran’s Terrorist

Sponsors and fronts from 2007 to 2011.

972. SCB’s misconduct—which involved providing Iran’s Terrorist Sponsors and

fronts back-door access to the U.S. financial system, while deceiving financial regulators and

financial institutions—was inherently self-concealing. Indeed, the entire point of SCB’s

misconduct was to help Iran’s Terrorist Sponsors and fronts transact in U.S. dollars, through U.S.

financial institutions, in ways that would not reveal those entities’ connections to the IRGC or

Iran. None of the transactions were visible to third parties, let alone to individuals in Plaintiffs’

position.

973. SCB went to extreme lengths to conceal its wrongdoing. Among other things,

SCB misled several financial regulators and law enforcement agencies about its sanctions

compliance and AML practices, lied to other financial institutions for its IRGC-connected

clients, and retaliated against whistleblowers who threatened to reveal the bank’s misconduct.

974. Accordingly, to the extent the statute of limitations began running before April 9,

2019, it must be tolled prior to that date because no plaintiff exercising diligence could have

uncovered SCB’s support for terrorists prior to that date.

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XI. Plaintiffs And Their Family Members Were Killed Or Injured In Terrorist Acts
Committed, Planned, Or Authorized By Iran-Sponsored Foreign Terrorist
Organizations

A. The December 18, 2010 Kidnapping Attack in Israel (Luken Family)

975. On December 18, 2010, a joint cell comprised of Hezbollah and Hamas

committed a kidnapping attack in Jerusalem, Israel, in which Hamas managed the abduction,

which was jointly planned by Hamas and Hezbollah, and funded by the Khamenei Cell,

Foundation for the Oppressed, and Hezbollah with money supplied by the SLO and IRGC (the

“December 18, 2010 Attack”).

976. On information and belief, the Joint Logistics Cell furnished the tunnels that

facilitated the December 18, 2010 Attack.

977. The December 18, 2010 Attack would have violated the laws of war if these

terrorists were subject to them because, among other reasons, the victim of this attack was a

civilian not taking part in hostilities. Further, the terrorist(s) who committed the attack neither

wore uniforms nor otherwise identified themselves as enemy combatants, and the attack

indiscriminately placed civilians at risk.

978. Kristine Luken was in Israel, as a civilian, hiking at the time of attack. Kristine

Luken was injured in the December 18, 2010 Attack. She died on December 18, 2010, as a result

of injuries sustained during the attack.

979. Kristine Luken was a U.S. national at the time of the attack and her death.

980. Plaintiff Kathleen Alt is the twin sister of Kristine Luken and a U.S. national. She

brings claims in both her personal and representative capacity on behalf of Kristine Luken’s

estate.

981. Plaintiff Lawrence Luken is the father of Kristine Luken and a U.S. national.

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982. Plaintiff Gerald Luken is the brother of Kristine Luken and a U.S. national.

983. Plaintiff Margaret Luken is the stepmother of Kristine Luken and a U.S. national.

Ms. Luken lived in the same household as Kristine Luken for a substantial period of time and

considered Kristine Luken the functional equivalent of a biological daughter.

984. As a result of the December 18, 2010 Attack and Kristine Luken’s injuries and

death, each member of the Luken family has experienced severe mental anguish, emotional pain

and suffering, and the loss of Kristine Luken’s society, companionship, and counsel.

985. As a result of the December 18, 2010 Attack, Kristine Luken was injured in her

person and/or property. The Plaintiff members of the Luken Family are the survivors and/or heirs

of Kristine Luken and are entitled to recover for the damages Kristine Luken sustained.

B. The August 19, 2011 Rocket Attack in Israel (Brauner Family)

986. On August 19, 2011, a joint cell comprised of Hezbollah and Hamas committed a

rocket attack in Ashdod, Israel, in which a Hamas terrorist detonated a rocket supplied by the

IRGC for which Hamas was trained and directed to attack by Hezbollah, and funded by the

Khamenei Cell, Foundation for the Oppressed, and Hezbollah with money supplied by the SLO

and IRGC (the “August 19, 2011 Attack”).

987. On information and belief, the Joint Logistics Cell furnished the rockets and

tunnels used in the August 19, 2011 Attack.

988. The August 19, 2011 Attack would have violated the laws of war if these

terrorists were subject to them because, among other reasons, the victim of this attack was a

civilian not taking part in hostilities. Further, the terrorist(s) who committed the attack neither

wore uniforms nor otherwise identified themselves as enemy combatants, and the attack

indiscriminately placed civilians at risk.

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989. Shmuel Brauner was a citizen living in Israel attending Synagogue during the

August 19, 2011 Attack. The attack severely wounded Shmuel Brauner, who suffered from

shrapnel to his back and stomach, loss of a kidney, loss of partial small intestine, and is

permanently disabled.

990. As a result of the August 19, 2011 Attack and his injuries, Shmuel Brauner has

experienced severe physical and emotional pain and suffering.

991. Plaintiff Shmuel Brauner was a U.S. national at the time of the attack and remains

one today.

992. Plaintiff Nechama Brauner is the wife of Shmuel Brauner and a U.S. national.

993. Plaintiff C.B., by and through his next friend Shmuel Brauner, is the minor son of

Shmuel Brauner and an Israeli national.

994. Plaintiff Esther Brauner is the mother of Shmuel Brauner and a U.S. national.

995. Plaintiff Mordechai Brauner is the father Shmuel Brauner and a U.S. national.

996. As a result of the August 19, 2011 Attack and Shmuel Brauner’s injuries, the

Plaintiff members of the Brauner family have experienced severe mental anguish as well as

emotional pain and suffering.

C. The June 12, 2014 Kidnapping Attack in Israel (Fraenkel Family)

997. On June 12, 2014, a joint cell comprised of Hezbollah and Hamas committed a

kidnapping attack in Gush Etzion, Israel, in which Hamas managed the abduction, which was

jointly planned by Hamas and Hezbollah, and funded by the Khamenei Cell, Foundation for the

Oppressed, and Hezbollah with money supplied by the SLO and IRGC (the “June 12, 2014

Attack”).

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998. On information and belief, the Joint Logistics Cell furnished the tunnels that

facilitated the June 12, 2014 Attack.

999. The June 12, 2014 Attack would have violated the laws of war if these terrorists

were subject to them because, among other reasons, the terrorist(s) who committed the attack

neither wore uniforms nor otherwise identified themselves as enemy combatants.

1000. Sixteen-year-old Yaakov Fraenkel was traveling with two other teenaged friends

in Gush Etzion in the West Bank of Israel when all three were abducted. Yaakov Fraenkel’s

remains were discovered on June 30, 2014, and it was determined that he was murdered shortly

after abduction.

1001. Yaakov Fraenkel was a U.S. national at the time of the attack and his death.

1002. Plaintiff Abraham Fraenkel is the father of Yaakov Fraenkel and an Israeli

national. He brings claims in both his personal capacity and representative capacity on behalf of

Yaakov Fraenkel’s estate.

1003. Plaintiff Rachelle Fraenkel is the mother of Yaakov Fraenkel and a U.S. national.

1004. Plaintiff Avigail Fraenkel is the sister of Yaakov Fraenkel and a U.S. national.

1005. Plaintiff Ayala Fraenkel is the sister of Yaakov Fraenkel and a U.S. national.

1006. Plaintiff N.F., by and through her next friend Abraham Fraenkel, is the minor

sister of Yaakov Fraenkel. She is a U.S. national.

1007. Plaintiff Noga Fraenkel is the sister of Yaakov Fraenkel and a U.S. national.

1008. Plaintiff S.F., by and through his next friend Abraham Fraenkel, is the minor

brother of Yaakov Fraenkel. He is a U.S. national.

1009. Plaintiff Tzvi Fraenkel is the brother of Yaakov Fraenkel and a U.S. national.

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1010. As a result of the June 12, 2014 Attack and Yaakov Fraenkel’s injuries and death,

each member of the Fraenkel Family has experienced severe mental anguish, emotional pain and

suffering, and the loss of Yaakov Fraenkel’s society, companionship, and counsel.

1011. As a result of the June 12, 2014 Attack, Yaakov Fraenkel was injured in his

person and/or property. The Plaintiff members of the Fraenkel Family are the survivors and/or

heirs of Yaakov Fraenkel and are entitled to recover for the damages Yaakov Fraenkel sustained.

D. The October 22, 2014 Vehicle Attack in Israel (Braun Family)

1012. On October 22, 2014 Hamas committed a vehicle attack in Jerusalem, Israel,

which was funded by the Khamenei Cell, Foundation for the Oppressed, and Hezbollah with

money supplied by the SLO and IRGC (the “October 22, 2014 Attack”).

1013. The October 22, 2014 Attack would have violated the laws of war if these

terrorists were subject to them because, among other reasons, the terrorist(s) who committed the

attack neither wore uniforms nor otherwise identified themselves as enemy combatants, and the

attack indiscriminately placed civilians at risk.

1014. Three-month-old Chaya Braun was traveling in Israel with her parents during the

October 22, 2014 Attack. Chaya Braun was injured in the October 22, 2014 Attack. Chaya Braun

died on October 22, 2014 as a result of injuries sustained during the attack.

1015. Chaya Braun was a U.S. national at the time of the attack and her death.

1016. Plaintiff Samuel Braun is the father of Chaya Braun and a U.S. national. He

brings claims in both his personal capacity and co-representative capacity, with Chana Braun, on

behalf of Chaya Braun’s estate.

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1017. Plaintiff Chana Braun is the mother of Chaya Braun and a U.S. national. She

brings claims in both her personal capacity and co-representative capacity, with Sameul Braun,

on behalf of Chaya Braun’s estate.

1018. As a result of the October 22, 2014 Attack and Chaya Braun’s injuries and death,

each member of the Braun Family has experienced severe mental anguish, emotional pain and

suffering, and the loss of Chaya Braun’s society, companionship, and counsel.

1019. As a result of the October 22, 2014 Attack, Chaya Braun was injured in her

person and/or property. The Plaintiff members of the Braun Family are the survivors and/or heirs

of Chaya Braun and are entitled to recover for the damages Chaya Braun sustained.

1020. Samuel Braun was traveling in Israel with his wife and baby daughter during the

October 22, 2014 Attack. The attack severely wounded Mr. Braun who suffered from broken ribs

and a torn ligament in his knee. Mr. Braun’s knee continues to be painful to this day.

1021. Plaintiff Samuel Braun was a U.S. national at the time of the attack and remains

one today.

1022. Plaintiff Chana Braun is the wife of Mr. Braun and a U.S. national.

1023. Plaintiff Esther Braun is the mother of Mr. Braun and a U.S. national.

1024. Plaintiff Murray Braun is the father of Mr. Braun and a U.S. national.

1025. As a result of the October 22, 2014 Attack and Mr. Braun’s injuries, each member

of the Braun family has experienced severe mental anguish as well as emotional pain and

suffering.

1026. Chana Braun was traveling in Israel with her husband and baby daughter during

the October 22, 2014 Attack. The attack severely wounded Ms. Braun who suffered from severe

psychological and emotional trauma.

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1027. Plaintiff Chana Braun was a U.S. national at the time of the attack and remains

one today.

1028. Plaintiff Samuel Braun is the husband of Ms. Braun and a U.S. national.

1029. Plaintiff Sara Halperin is the mother of Ms. Braun and a U.S. national.

1030. Plaintiff Shimshon Halperin is the father of Ms. Braun and a U.S. national.

1031. As a result of the October 22, 2014 Attack and Ms. Braun’s injuries, each member

of the Braun family has experienced severe mental anguish as well as emotional pain and

suffering.

E. The October 29, 2014 Assassination Attack in Israel (Glick Family)

1032. On October 29, 2014, the Palestinian Islamic Jihad committed an assassination

attack in Jerusalem, Israel, which was jointly planned by Hezbollah and PIJ, for which PIJ was

trained and directed to attack by Hezbollah, and funded by the Khamenei Cell, Foundation for

the Oppressed, and Hezbollah with money supplied by the SLO and IRGC (the “October 29,

2014 Assassination Attack”).

1033. On information and belief, the Joint Logistics Cell furnished the small arms and

ammunition used in the October 29, 2014 Assassination Attack.

1034. The October 29, 2014 Assassination Attack would have violated the laws of war

if these terrorists were subject to them because, among other reasons, the victim of this attack

was a civilian not taking part in hostilities. Further, the terrorist(s) who committed the attack

neither wore uniforms nor otherwise identified themselves as enemy combatants, and the attack

indiscriminately placed civilians at risk.

1035. Yehudah Glick was packing up his car after giving a speech at the time of the

October 29, 2014 Assassination Attack. Yehudah Glick was shot four times during this attack.

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The attack severely wounded Yehudah Glick, who suffered from gunshot wounds injuring his

chest, including his throat, lung, and causing multiple broken ribs. Gunshot wounds also injured

his liver, spine, one hand, and both intestines.

1036. As a result of the October 29, 2014 Assassination Attack and his injuries,

Yehudah Glick has experienced severe physical and emotional pain and suffering.

1037. Plaintiff Yehudah Glick was a U.S. national at the time of the attack. He brings

claims in his individual capacity and in his representative capacity on behalf of Yaffa Glick’s

estate. Yaffa Glick is the deceased wife of Yehudah Glick and was an Israeli national at the time

of the attack and her death.

1038. Plaintiff Hallel Glick is the son of Yehudah Glick and a U.S. national.

1039. Plaintiff Neria Glick is the son of Yehudah Glick and a U.S. national.

1040. Plaintiff Shahar Glick is the son of Yehudah Glick and a U.S. national.

1041. Plaintiff Shlomo Glick is the son of Yehudah Glick and a U.S. national.

1042. Plaintiff Rachel Glick is the foster daughter of Yehudah Glick and an Israeli

national. Rachel Glick lived in the same household as Yehudah Glick for a substantial period of

time and considered Yehudah Glick the functional equivalent of a biological father.

1043. Plaintiff Tatiana Glick is the foster daughter of Yehudah Glick and an Israeli

national. Tatiana Glick lived in the same household as Yehudah Glick for a substantial period of

time and considered Yehudah Glick the functional equivalent of a biological father.

1044. Plaintiff Avital Breuer is the stepdaughter of Yehudah Glick and an Israeli

national. Avital Breuer lived in the same household as Yehudah Glick for a substantial period of

time and considered Yehudah Glick the functional equivalent of a biological father.

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1045. As a result of the October 29, 2014 Assassination Attack and Yehudah Glick’s

injuries, the Plaintiff members of the Glick family have experienced severe mental anguish as

well as emotional pain and suffering.

F. The October 13, 2015 Shooting and Stabbing Attack in Israel (Lakin Family)

1046. On October 13, 2015, Hamas committed a shooting and stabbing attack in

Jerusalem, Israel, which was funded by the Khamenei Cell, Foundation for the Oppressed, and

Hezbollah with money supplied by the SLO and IRGC (the “October 13, 2015 Attack”).

1047. The October 13, 2015 Attack would have violated the laws of war if these

terrorists were subject to them because, among other reasons, the terrorist(s) who committed the

attack neither wore uniforms nor otherwise identified themselves as enemy combatants, and the

attack indiscriminately placed civilians at risk.

1048. Richard Lakin was riding a bus in Israel returning from a doctor’s appointment

during the October 13, 2015 Attack. Mr. Lakin was shot and stabbed during the October 13,

2015 Attack, which resulted in a series of invasive surgeries. Mr. Lakin died on October 27,

2015 as a result of injuries sustained during the attack.

1049. Mr. Lakin was a U.S. national at the time of the attack and his death.

1050. Plaintiff Micah Lakin is the son of Mr. Lakin and a U.S. national. He brings

claims in both his personal capacity and representative capacity on behalf of Mr. Lakin’s estate.

1051. Plaintiff Manya Lakin is the daughter of Mr. Lakin and a U.S. national.

1052. As a result of the October 13, 2015 Attack and Mr. Lakin’s injuries and death,

each member of the Lakin Family has experienced severe mental anguish, emotional pain and

suffering, and the loss of Mr. Lakin’s society, companionship, and counsel.

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1053. As a result of the October 13, 2015 Attack, Mr. Lakin was injured in his person

and/or property. The Plaintiff members of the Lakin Family are the survivors and/or heirs of Mr.

Lakin and are entitled to recover for the damages Mr. Lakin sustained.

G. The November 6, 2015 Sniper Attack in Israel (Borochov Family)

1054. On November 6, 2015, Hamas committed a sniper attack in Mearas Hamachpela,

Israel, which was jointly planned by Hezbollah and Hamas, for which Hamas was trained and

directed to attack by Hezbollah, and funded by the Khamenei Cell, Foundation for the

Oppressed, and Hezbollah with money supplied by the SLO and IRGC (the “November 6, 2015

Attack”).

1055. On information and belief, the Joint Logistics Cell furnished the small arms and

ammunition used in the November 6, 2015 Attack Assassination Attack.

1056. The November 6, 2015 Attack would have violated the laws of war if these

terrorists were subject to them because, among other reasons, the terrorist(s) who committed the

attack neither wore uniforms nor otherwise identified themselves as enemy combatants.

1057. Mr. Ronen Borochov was traveling in Israel visiting the Cave of Patriarchs, a

sacred Jewish site, at the time of the November 6, 2015 Attack. The attack caused Mr. Borochov

to fear for his life as well as his sons’ lives. Mr. Borochov suffers from psychological and

emotional trauma as a result of the November 6, 2015 Attack.

1058. Plaintiff Ronen Borochov was a U.S. national at the time of the attack and

remains one today.

1059. Plaintiff Devora Borochov is the wife of Mr. Borochov and a U.S. national.

1060. Plaintiff Josef Borochov is the son of Mr. Borochov and U.S. national.

1061. Plaintiff Eli Borochov is the son of Mr. Borochov and a U.S. national.

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1062. Plaintiff Avraham Borochov is the son of Mr. Borochov and a U.S. national.

1063. Plaintiff Shira Borochov is the daughter of Mr. Borochov and a U.S. national.

1064. As a result of the November 6, 2015 Attack and Mr. Borochov’s injuries, each

member of the Borochov Family has experienced severe mental anguish as well as emotional

pain and suffering.

1065. Mr. Eli Borochov was traveling in Israel visiting the Cave of Patriarchs, a sacred

Jewish site, at the time of the November 6, 2015 Attack. The attack severely wounded Mr.

Borochov who suffered from gunshot wounds to the thigh and testicles, which resulted in

surgery and months of severe pain. Mr. Borochov also suffers from psychological trauma and

nightmares as a result of the November 6, 2015 Attack.

1066. Plaintiff Eli Borochov was a U.S. national at the time of the attack and remains

one today.

1067. Plaintiff Shari Borochov is the wife of Mr. Borochov and a U.S. national.

1068. Plaintiff Ronen Borochov is the father of Mr. Borochov and a U.S. national.

1069. Plaintiff Devora Borochov is the mother of Mr. Borochov and a U.S. national.

1070. Plaintiff Josef Borochov is the brother of Mr. Borochov and U.S. national.

1071. Plaintiff Avraham Borochov is the brother of Mr. Borochov and a U.S. national.

1072. Plaintiff Shira Borochov is the sister of Mr. Borochov and a U.S. national.

1073. As a result of the November 6, 2015 Attack and Mr. Borochov’s injuries, each

member of the Borochov Family has experienced severe mental anguish as well as emotional

pain and suffering.

1074. Mr. Josef Borochov was traveling in Israel visiting the Cave of Patriarchs, a

sacred Jewish site, at the time of the November 6, 2015 Attack. The attack severely wounded Mr.

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Borochov who suffers from severe psychological and emotional trauma. Mr. Borochov was only

sixteen years old at the time of the attack.

1075. Plaintiff Josef Borochov was a U.S. national at the time of the attack and remains

one today.

1076. Plaintiff Ronen Borochov is the father of Mr. Borochov and a U.S. national.

1077. Plaintiff Devora Borochov is the mother of Mr. Borochov and a U.S. national.

1078. Plaintiff Eli Borochov is the brother of Mr. Borochov and U.S. national.

1079. Plaintiff Avraham Borochov is the brother of Mr. Borochov and a U.S. national.

1080. Plaintiff Shira Borochov is the sister of Mr. Borochov and a U.S. national.

1081. As a result of the November 6, 2015 Attack and Mr. Borochov’s injuries, each

member of the Borochov Family has experienced severe mental anguish as well as emotional

pain and suffering.

H. The December 14, 2015 Vehicle Attack in Israel (Golan and Shamba
Families)

1082. On December 14, 2015, Hamas committed a vehicle attack in Jerusalem, Israel,

which was funded by the Khamenei Cell, Foundation for the Oppressed, and Hezbollah with

money supplied by the SLO and IRGC (the “December 14, 2015 Attack”).

1083. The December 14, 2015 Attack would have violated the laws of war if these

terrorists were subject to them because, among other reasons, the victim of this attack was a

civilian not taking part in hostilities. Further, the terrorist(s) who committed the attack neither

wore uniforms nor otherwise identified themselves as enemy combatants, and the attack

indiscriminately placed civilians at risk.

1084. Mr. Yoav Golan was waiting at a bus stop in Israel at the time of the December

14, 2015 Attack. The attack severely wounded Mr. Golan who suffered injuries to his leg and

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shoulder. The leg injury caused him to be wheelchair-bound for a substantial period after the

attack. Mr. Golan continues to suffer from psychological and emotional trauma as a result of the

December 14, 2015 Attack.

1085. Plaintiff Yoav Golan was a U.S. national at the time of the attack and remains one

today.

1086. Plaintiff Rotem Golan is the wife of Mr. Golan and an Israeli national.

1087. Plaintiff Yehudit Green-Golan is the mother of Mr. Golan and a U.S. national.

1088. Plaintiff Raphael Golan is the father of Mr. Golan and an Israeli national.

1089. Plaintiff Matan Golan is the brother of Mr. Golan and a U.S. national.

1090. As a result of the December 14, 2015 Attack and Mr. Golan’s injuries, each

member of the Golan Family has experienced severe mental anguish as well as emotional pain

and suffering.

1091. Noam Shamba was waiting at a bus stop in Jerusalem, Israel at the time of the

December 14, 2015 Attack. The attack severely wounded Noam Shamba, who suffered from

severe pains in his chest. He was taken to the hospital and diagnosed as having a massive heart

attack. His doctors concluded that it was a result of the terror attack as he was only 32 years old

and had no prior health conditions.

1092. As a result of the December 14, 2015 Attack and his injuries, Noam Shamba has

experienced severe physical and emotional pain and suffering.

1093. Plaintiff Noam Shamba was a U.S. national at the time of the attack and remains

one today.

1094. Plaintiff Yana Shamba is the wife of Noam Shamba and a U.S. national.

1095. Plaintiff Hadar Shamba is the daughter of Noam Shamba and a U.S. national.

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1096. Plaintiff M.S., by and through his next friend Noam Shamba, is the minor son of

Noam Shamba. He is a U.S. national.

1097. Plaintiff N.E.S., by and through his next friend Noam Shamba, is the minor son of

Noam Shamba. He is a U.S. national.

1098. Plaintiff N.S., by and through her next friend Noam Shamba, is the minor

daughter of Noam Shamba. She is a U.S. national.

1099. Plaintiff O.S., by and through her next friend Noam Shamba, is the minor

daughter of Noam Shamba. She is a U.S. national.

1100. Plaintiff T.S., by and through her next friend Noam Shamba, is the minor

daughter of Noam Shamba. She is a U.S. national.

1101. As a result of the December 14, 2015 Attack and Noam Shamba’s injuries, the

Plaintiff members of the Shamba family have experienced severe mental anguish as well as

emotional pain and suffering.

I. The January 27, 2016 Stabbing Attack in Israel (Rivkin Family)

1102. On January 27, 2016, Hamas committed a stabbing attack in Givat Ze’ev, Israel,

which was funded by the Khamenei Cell, Foundation for the Oppressed, and Hezbollah with

money supplied by the SLO and IRGC (the “January 27, 2016 Attack”).

1103. The January 27, 2016 Attack would have violated the laws of war if these

terrorists were subject to them because, among other reasons, the terrorist(s) who committed the

attack neither wore uniforms nor otherwise identified themselves as enemy combatants, and the

attack indiscriminately placed civilians at risk.

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1104. Menachem Rivkin was walking to a restaurant in Givat Ze’ev, Israel during the

January 27, 2016 Attack. The attack severely wounded Mr. Rivkin who suffered from a stab

wound to his neck.

1105. Plaintiff Menachem Rivkin was a U.S. national at the time of the attack and

remains one today.

1106. Plaintiff Bracha Rivkin is the wife of Mr. Rivkin and an Israeli national.

1107. Plaintiff M.R., by and through her next friend Menachem Rivkin, is the minor

daughter of Mr. Rivkin. She is a U.S. national.

1108. Plaintiff R.R., by and through her next friend Menachem Rivkin, is the minor

daughter of Mr. Rivkin. She is a U.S. national.

1109. Plaintiff S.R., by and through his next friend Menachem Rivkin, is the minor son

of Mr. Rivkin. He is a U.S. national.

1110. Plaintiff S.Z.R., by and through his next friend Menachem Rivkin, is the minor

son of Mr. Rivkin. He is a U.S. national.

1111. Plaintiff Sterna Rivkin is the daughter of Mr. Rivkin and a U.S. national.

1112. As a result of the January 27, 2016 Attack and Mr. Rivkin’s injuries, each

member of the Rivkin Family has experienced severe mental anguish as well as emotional pain

and suffering.

J. The March 8, 2016 Stabbing Attack in Israel (Force Family)

1113. On March 8, 2016, Hamas committed a stabbing attack in Tel Aviv, Israel, which

was funded by the Khamenei Cell, Foundation for the Oppressed, and Hezbollah with money

supplied by the SLO and IRGC (the “March 8, 2016 Attack”).

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1114. The March 8, 2016 Attack would have violated the laws of war if these terrorists

were subject to them because, among other reasons, the terrorist(s) who committed the attack

neither wore uniforms nor otherwise identified themselves as enemy combatants, and the attack

indiscriminately placed civilians at risk.

1115. Taylor Force was in Israel for a graduate school trip through Vanderbilt

University. Mr. Force was injured in the March 8, 2016 Attack. Mr. Force died on March 8,

2016, resulting from injuries sustained during the attack.

1116. Mr. Force was a U.S. national at the time of the attack and his death.

1117. Plaintiff Stuart Force Jr. is the father of Mr. Force and a U.S. national. He brings

claims in both his personal capacity and representative capacity on behalf of Mr. Force’s estate.

1118. Plaintiff Robbi Force is the mother of Mr. Force and a U.S. national.

1119. Plaintiff Kristen Boswell is the sister of Mr. Force and a U.S. national.

1120. As a result of the March 8, 2016 Attack and Mr. Force’s injuries and death, each

member of the Force Family has experienced severe mental anguish, emotional pain and

suffering, and the loss of Mr. Force’s society, companionship, and counsel.

1121. As a result of the March 8, 2016 Attack, Mr. Force was injured in his person

and/or property. The Plaintiff members of the Force Family are the survivors and/or heirs of Mr.

Force and are entitled to recover for the damages Mr. Force sustained.

K. The December 23, 2016 Stabbing Attack in Israel (Lisker Family)

1122. On December 23, 2016, Hamas committed a stabbing attack in Efrat, Israel,

which was funded by the Khamenei Cell, Foundation for the Oppressed, and Hezbollah with

money supplied by the SLO and IRGC (the “December 23, 2016 Attack”).

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1123. The December 23, 2016 Attack would have violated the laws of war if these

terrorists were subject to them because, among other reasons, the terrorist(s) who committed the

attack neither wore uniforms nor otherwise identified themselves as enemy combatants, and the

attack indiscriminately placed civilians at risk.

1124. Raphael Lisker was in Israel walking home after Sabbath services at the time of

the December 23, 2016 Attack. The attack severely wounded Mr. Lisker who suffered from stab

wounds to his neck.

1125. Plaintiff Raphael Lisker was a U.S. national at the time of the attack and remains

one today.

1126. Plaintiff Shoshana Lisker is the wife of Mr. Lisker and a U.S. national.

1127. Plaintiff Tamar Gutman is the daughter of Mr. Lisker and a U.S. national.

1128. Plaintiff Avital Lejzor is the daughter of Mr. Lisker and a U.S. national.

1129. Plaintiff Daniel Lisker is the son of Mr. Lisker and a U.S. national.

1130. Plaintiff Jonathan Lisker is the son of Mr. Lisker and a U.S. national.

1131. As a result of the December 23, 2016 Attack and Mr. Lisker’s injuries, each

member of the Lisker Family has experienced severe mental anguish as well as emotional pain

and suffering.

1132. Shoshana Lisker was in Israel walking home after Sabbath services at the time of

the December 23, 2016 Attack. The attack severely wounded Ms. Lisker who suffers from severe

emotional and psychological trauma.

1133. Plaintiff Shoshana Lisker was a U.S. national at the time of the attack and remains

one today.

1134. Plaintiff Raphael Lisker is the husband of Ms. Lisker and a U.S. national.

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1135. Plaintiff Tamar Gutman is the daughter of Ms. Lisker and a U.S. national.

1136. Plaintiff Avital Lejzor is the daughter of Ms. Lisker and a U.S. national.

1137. Plaintiff Daniel Lisker is the son of Ms. Lisker and a U.S. national.

1138. Plaintiff Jonathan Lisker is the son of Ms. Lisker and a U.S. national.

1139. As a result of the December 23, 2016 Attack and Ms. Lisker’s injuries, each

member of the Lisker Family has experienced severe mental anguish as well as emotional pain

and suffering.

L. The May 5, 2019 Rocket Attack in Israel (Przewozman Family)

1140. On May 5, 2019, a joint cell comprised of Hezbollah, Hamas, and PIJ committed

a rocket attack in Ashdod, Israel, in which Hamas and PIJ terrorists detonated a rocket supplied

by the IRGC for which Hamas and PIJ were trained and directed to attack by Hezbollah, and

funded by the Khamenei Cell, Foundation for the Oppressed, and Hezbollah with money

supplied by the SLO and IRGC (the “May 5, 2019 Attack”).

1141. On information and belief, the Joint Logistics Cell furnished the rockets and

tunnels used in the May 5, 2019 Attack.

1142. The May 5, 2019 Attack would have violated the laws of war if these terrorists

were subject to them because, among other reasons, the victim of this attack was a civilian not

taking part in hostilities. Further, the terrorist(s) who committed the attack neither wore uniforms

nor otherwise identified themselves as enemy combatants, and the attack indiscriminately placed

civilians at risk.

1143. Pinchas Przewozman was a civilian living in Israel who was attempting to get to

the bomb shelter in his apartment building in Ashdod, Israel at the time of the attack. Pinchas

Przewozman paused to allow others to enter the shelter ahead of him when the rocket struck.

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Pinchas Przewozman was injured in the May 5, 2019 Attack. He died on May 5, 2019, as a result

of injuries sustained during the attack.

1144. Pinchas Przewozman was a U.S. national at the time of the attack and his death.

1145. Plaintiff Hadassah Przewozman is the widow of Pinchas Przewozman and an

Israeli national. She brings claims in both her personal capacity and representative capacity on

behalf of Pinchas Przewozman’s estate.

1146. Plaintiff Y.P., by and through his next friend Hadassah Przewozman, is the minor

son of Pinchas Przewozman. He is a U.S. national.

1147. Plaintiff Chaim Przewozman is the father of Pinchas Przewozman and a U.S.

national.

1148. Plaintiff Chaya Przewozman is the mother of Pinchas Przewozman and an Israeli

national.

1149. Plaintiff Avraohom Przewozman is the brother of Pinchas Przewozman and a

U.S. national.

1150. Plaintiff F.P., by and through her next friend Chaim Przewozman, is the minor

sister of Pinchas Przewozman. She is a U.S. national.

1151. Plaintiff Zvi Przewozman is the brother of Pinchas Przewozman and a U.S.

national.

1152. Plaintiff Sara Rozenbaum is the sister of Pinchas Przewozman and a U.S.

national.

1153. Plaintiff Yafa Shechter is the sister of Pinchas Przewozman and a U.S. national.

1154. As a result of the May 5, 2019 Attack and Pinchas Przewozman’s injuries and

death, the Plaintiff members of the Przewozman family have experienced severe mental anguish,

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emotional pain and suffering, and the loss of Pinchas Przewozman’s society, companionship, and

counsel.

1155. As a result of the May 5, 2019 Attack, Pinchas Przewozman was injured in his

person and/or property. The Plaintiff survivors and/or heirs of Pinchas Przewozman are entitled

to recover for the damages Pinchas Przewozman sustained.

M. The June 23, 2011 EFP Attack in Iraq (Everhart/Zobay Family)

1156. On June 23, 2011, a joint cell comprised of Hezbollah and Jaysh al-Mahdi

committed an EFP attack in Baghdad, Iraq, which detonated an EFP supplied by the IRGC for

which Jaysh al-Mahdi was trained and directed to attack by Hezbollah, which was funded by the

Khamenei Cell, Foundation for the Oppressed, and Hezbollah with money supplied by the SLO

and IRGC (the “June 23, 2011 Attack”).

1157. The June 23, 2011 Attack would have violated the laws of war if these terrorists

were subject to them because, among other reasons, the terrorist(s) who committed the attack

neither wore uniforms nor otherwise identified themselves as enemy combatants, and the attack

indiscriminately placed civilians at risk.

1158. Dr. Stephen Everhart was in Iraq on a short-term consultancy to the U.S.

Agency for International Development, introducing entrepreneurship education in schools of

business and commerce at Iraqi universities. Dr. Everhart was injured in the June 23, 2011

Attack. Dr. Everhart died on June 23, 2011, resulting from injuries sustained during the attack.

1159. Dr. Everhart was a U.S. national at the time of the attack and his death.

1160. Plaintiff Stephanie Zobay is the widow of Dr. Everhart and a U.S. national. She

brings claims in both her personal capacity and representative capacity on behalf of Dr.

Everhart’s estate.

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1161. Plaintiff Hannah Everhart is the daughter of Dr. Everhart and a U.S. national.

1162. Plaintiff Lindsay Everhart is the daughter of Dr. Everhart and a U.S. national.

1163. Plaintiff Hayden Everhart is the son of Dr. Everhart and a U.S. national.

1164. As a result of the June 23, 2011 Attack and Dr. Everhart’s injuries and death, each

member of the Everhart Family has experienced severe mental anguish, emotional pain and

suffering, and the loss of Dr. Everhart’s society, companionship, and counsel.

1165. As a result of the June 23, 2011 Attack, Dr. Everhart was injured in his person

and/or property. The Plaintiff members of the Everhart Family are the survivors and/or heirs of

Dr. Everhart and are entitled to recover for the damages Dr. Everhart sustained.

CLAIM FOR RELIEF

Aiding and Abetting Under the Anti-Terrorism Act

18 U.S.C. § 2333(d)(2)

1166. Plaintiffs incorporate their factual allegations above.

1167. To establish a claim for aiding and abetting under JASTA, 18 U.S.C. § 2333(d),

Plaintiffs must show: (1) that they are U.S. nationals, or the estates, survivors, or heirs of U.S.

nationals; (2) that they were injured by an act of “international terrorism,” as defined by 18

U.S.C. § 2331(1); (3) that the act of international terrorism was committed, planned, or

authorized by a designated FTO; (4) that SCB was generally aware that it was playing a role in

an overall illegal or tortious activity from which the act of international terrorism was a

foreseeable consequence; and (5) that SCB knowingly provided substantial assistance.

1168. Every Plaintiff is a U.S. national, or the estate, survivor, or heir of a U.S. national.

1169. The terrorist attacks that injured Plaintiffs were acts of “international terrorism”

because:

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a. the attacks involved violent and dangerous acts that violate the criminal laws of the

United States and many States (or would if committed in the United States). In particular,

each attack constituted one or more of murder, attempted murder, conspiracy to murder,

kidnapping, and arson, in violation of state law; and the destruction of U.S. property by

fire or explosive, conspiracy to murder in a foreign country, killing and attempted killing

of U.S. employees performing official duties, hostage taking, damaging U.S. government

property, killing U.S. nationals abroad, use of weapons of mass destruction, commission

of acts of terrorism transcending national boundaries, and bombing places of public use,

in violation of 18 U.S.C. §§ 844(f)(2) or (3), 956(a)(1), 1114, 1203, 1361, 2332, 2332a,

2332b, and 2332f, respectively;

b. the attacks, carried out by terrorists bent on expelling the United States and its allies from

Iraq and the Middle East, appear to have been intended (i) to intimidate or coerce the

civilian populations of Iraq, Israel, the United States, and other nations, (ii) to influence

the policy of the U.S., Israeli, Iraqi, and other governments by intimidation and coercion,

and (iii) to affect the conduct of the U.S., Israeli, Iraqi, and other governments by mass

destruction, assassination, and kidnapping; and

c. the attacks occurred primarily outside the territorial jurisdiction of the United States, in

Israel.

1170. Each attack was committed, planned, or authorized by one or more FTOs. Every

attack was committed by one or more of Hezbollah, Hamas, and PIJ, all of which were FTOs at

all relevant times.

1171. Every attack, regardless of who committed it, was planned or authorized by

Hezbollah and/or Hamas and/or PIJ, each of which was always an FTO.

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1172. SCB was generally aware that it was playing a role in illegal activity, and that the

terrorist attacks that injured Plaintiffs were a natural and foreseeable consequence of that

activity.

1173. SCB provided assistance knowingly, and not innocently or inadvertently. SCB did

so with knowledge that it was aiding terrorist organizations carrying out attacks on Americans.

1174. SCB’s assistance was substantial.

1175. SCB’s assistance was pervasive and systemic, involving the highest levels of

SCB’s management, years of willful misconduct, and tremendous sums of money that provided

critically important assistance to the IRGC and its terrorist proxies.

1176. As a result of SCB’s liability under 18 U.S.C. § 2333(d), Plaintiffs are entitled to

recover economic and non-economic damages, including solatium damages.

JURY DEMAND

1177. In accordance with Federal Rule of Civil Procedure 38(b), Plaintiffs demand a

trial by jury on all issues so triable.

PRAYER FOR RELIEF

1178. Wherefore, Plaintiffs pray this Court:

a. Enter judgment against SCB finding it liable under the Anti-Terrorism Act, 18

U.S.C. § 2333;

b. Award Plaintiffs compensatory and punitive damages to the maximum extent

permitted by law, and treble any compensatory damages awarded under the

Anti-Terrorism Act pursuant to 18 U.S.C. § 2333(a);

c. Award Plaintiffs their attorneys’ fees and costs incurred in this action,

pursuant to 18 U.S.C. § 2333(a);

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d. Award Plaintiffs prejudgment interest; and

e. Award Plaintiffs any such further relief the Court deems just and proper.

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Dated: October 29, 2024

Respectfully submitted,

SPARACINO PLLC

/s/ Adam J. Goldstein

Adam J. Goldstein
Ryan R. Sparacino (pro hac vice)
Geoffrey P. Eaton (pro hac vice)
Tejinder Singh
Jacob R. Loshin (pro hac vice forthcoming)
Stacey L. Wilson (pro hac vice forthcoming)
Matthew J. Fisher (pro hac vice)
SPARACINO PLLC
1920 L Street, NW, Suite 835
Washington, D.C. 20036
Tel: (202) 629-3530
[email protected]
[email protected]
[email protected]
[email protected]
[email protected]
[email protected]
[email protected]

Counsel for Plaintiffs

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