Settlement Agreement Between the Office of Foreign Assets Control and Clearstream Banking, S.A.

January 15, 2014


3. Following a request for information from OFAC, Clearstream met with OFAC in late 2007 and early 2008 to discuss accounts it maintained in Luxembourg for Iranian entities. One such account was ultimately identified as an account for the Central Bank of Iran ("CBI").

4. Securities entitlements held in the CBI's account at Clearstream at that time included entitlements related to securities held in the United States. Specifically, Clearstream held interests in 26 corporate and sovereign bonds in its omnibus account at a U.S. financial institution in New York in which the CBI had a beneficial ownership interest, with a total nominal value of $2.813 billion. Central securities depositories in the United States served as the ultimate place of safekeeping for these securities.

5. Clearstream, as intermediary, exported custody and related services from the United States to the CBI with respect to the 26 securities described above. Clearstream served as the channel through which the CBI was able to hold an interest in these securities, as well as to transfer or sell those interests at a later date.


11. From at least December 2007 through June 2008, Clearstream maintained an account at a U.S. financial institution in New York through which the CBI maintained a beneficial ownership interest in securities held in the United States, and performed certain associated services on behalf of the CBI, in apparent violation of the prohibition against the "exportation ... directly or indirectly, from the United States ... of any ... services to Iran or the Government of Iran" (the "Apparent Violations"). See 31 C.F.R. § 560.204 of the Iranian Transactions and Sanctions Regulations (the "Regulations").