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5/6/2020

Treasury Sanctions Kunlun Bank in China and Elaf Bank in Iraq for Business with Designated Iranian Banks

U.S. DEPARTMENT OF THE TREASURY
Press Center

Treasury Sanctions Kunlun Bank in China and Elaf Bank in Iraq for Business with
Designated Iranian Banks
7/31/2012

Action Imposes Sanctions on Foreign Financial Institutions under the Comprehensive Iran Sanctions, Accountability, and Divestment Act
WASHINGTON – The U.S. Department of the Treasury today announced the imposition of sanctions under the Comprehensive Iran
Sanctions, Accountability, and Divestment Act of 2010 (CISADA), against two financial institutions for knowingly facilitating significant
transactions and providing significant financial services for designated Iranian banks. The financial institutions sanctioned today are Bank
of Kunlun in China and Elaf Islamic Bank in Iraq.
Acting to expose and isolate Iranian financial institutions connected to Iran’s WMD proliferation or support for terrorism, the Treasury
Department has imposed sanctions against two dozen Iranian banks. As financial institutions around the world have cut ties with these
designated Iranian banks, Bank of Kunlun and Elaf Islamic Bank took the opposite approach by providing financial services to designated
Iranian banks and facilitating the movement of millions of dollars worth of international transactions.
“Our actions to cut off Kunlun and Elaf from the U.S. financial system underscore Treasury’s commitment to use all the tools at its disposal
to intensify financial pressure against Iran while protecting the U.S. financial system from illicit activity,” said Under Secretary for Terrorism
and Financial Intelligence David S. Cohen. “Any bank, anywhere, that seeks to provide a financial lifeline to Iran’s designated financial
institutions should know that it will be held accountable and its activity will be exposed.”
Today’s action against Bank of Kunlun and Elaf Islamic Bank effectively bars them from directly accessing the U.S. financial system. As a
result of the sanctions imposed today under CISADA, financial institutions may not open correspondent or payable-through accounts for
Bank of Kunlun or Elaf Islamic Bank in the United States and any financial institutions that currently hold such accounts must close them
within 10 days.

Bank of Kunlun
Bank of Kunlun has provided significant financial services to more than six Iranian banks that were designated by the United States in
connection with Iran's weapons of mass destruction (WMD) programs or its support for international terrorism. .
Bank of Kunlun has provided hundreds of millions of dollars worth of financial services to these designated banks, including holding
accounts, making transfers, and paying their letters of credit.
In early 2012, Bank of Kunlun transferred hundreds of payments totaling roughly $100 million dollars from accounts it holds for designated
Bank Tejarat. This activity happened after Bank Tejarat was designated by the United States (and the European Union) in January 2012
for providing financial services to several Iranian banks and firms already subject to sanctions for their involvement in Iran’s illicit
proliferation activities.
In addition to these transfers, in early 2012 Bank of Kunlun made at least one payment for an affiliate of Iran’s Islamic Revolutionary Guard
Corps pursuant to a letter of credit opened by Bank Tejarat.

Elaf Islamic Bank
Elaf Islamic Bank, a privately-owned Iraqi financial institution, has facilitated significant financial transactions and provided significant
financial services for a designated Iranian bank. Iraq's Elaf Islamic Bank has engaged in activity during the past year worth tens of millions
of dollars with the Export Development Bank of Iran, which was designated by the United States in October 2008 and also designated by
the European Union in July 2010 for its support of Iran’s proliferation activities.
https://www.treasury.gov/press-center/press-releases/Pages/tg1661.aspx

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Treasury Sanctions Kunlun Bank in China and Elaf Bank in Iraq for Business with Designated Iranian Banks

Financial Provisions of CISADA
CISADA was signed into law by President Obama in July 2010. It provides the Secretary of the Treasury with the authority to impose strict
conditions on, or prohibit the opening or maintaining of, correspondent accounts or payable-through accounts in the United States for
foreign financial institutions that the Secretary finds knowingly:
Facilitate the efforts of the Government of Iran, including Iran’s Islamic Revolutionary Guard Corps (IRGC), to acquire WMD or delivery systems for WMD or to support
international terrorism.
Facilitate the activities of a person subject to financial sanctions under certain United Nations Security Council Resolutions related to Iran.
Engage in money laundering, or facilitate the efforts of the Central Bank of Iran or any other Iranian financial institution, to carry out the activities described above.
Facilitate a significant transaction or provide significant financial services for the IRGC or its agents or affiliates whose property and interests in property are blocked under the
International Emergency Economic Powers Act (IEEPA); or a financial institution whose property and interests in property are blocked under IEEPA in connection with Iran’s
proliferation of WMD or delivery systems for WMD or Iran’s support for international terrorism.

The Treasury Department has issued the Iranian Financial Sanctions Regulations (IFSR) to implement these and other provisions of
CISADA.
To view more information on the IFSR, click here.

Identifying Information:
Bank of Kunlun Co. Ltd.
FKA: Karamay Urban Credit Cooperatives
FKA: Karamay City Commercial Bank Co Ltd.
Location 1: (Head Office) 9 Dongzhimen North Street, Dongcheng District, Beijing 100007, China
Location 2: (Registered Office) No. 7 Century Ave, Karamay 834000 Xinjiang, China
Location 3: (Daqing, Heilongjiang Branch) 172 Xibin Rd, Ranghulu District, Daqing 163453
Location 4: (Urumqi, Xinjiang Branch) No. 68 Zhongya South Rd, Economic and Technological Development Zone, Urumqi 830026
SWIFT/BIC: CKLB CN BJ
Elaf Islamic Bank
Address: PO Box 3440, Bldg No. 14, Street 99, Hai Al Wehda-Mahala 902, Alweih, Baghdad, Iraq
SWIFT/BIC: ELAF IQ BA

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