13 February 2024

In response to an article published in UK media on 4th February, Santander can say categorically that, after a thorough internal investigation, it has not found any direct nor indirect sanctions breach in any part of the group. We have distributed the following communication to our teams:

As we informed you last week, a UK media outlet published a report on 4 February 2024 about a Santander account allegedly linked to Iran. 

We have conducted a thorough investigation into the allegations and the circumstances related to the opening and use of the account referenced in the article, as well as connected individuals. Thus, we can state categorically that Santander has not found any breach by it of U.S. sanctions against Iran in connection with these allegations.

For both legal and reputational reasons, the allegations in this news report require a clear and firm response from us. We have taken action both internally and externally to address them. If this article is raised by concerned clients or customers, I would be grateful if you were to address them with the following points of fact: 

• The required standard screening undertaken in relation to this account determined that the account holder was not included on any sanctions lists, and that the business was, according to the relevant public records, owned by persons who were not identified as subject to sanctions. At no time was Santander UK aware that the account holder was owned in trust by a U.S.-sanctioned Iranian company, as is alleged in the article, nor could the bank have identified the trust based on a review of public records.
  
  
• The account was closed in 2022 for reasons unrelated to these allegations. Neither the account holder nor the identified owners of the business were targeted for sanctions during the life of the account and none is today. The amounts transacted in the account while it was open were negligible.
  
  
• We have also carried out a broader review of other persons associated with entities and individuals identified in the article and have not found any sanctions breach in any other part of Santander’s global operations.
  
  
• We reached out to appropriate regulatory authorities in the UK and US ahead of the publication of the article in order to inform them. Moreover, we continue to keep those authorities apprised, including highlighting that no transactions with a US jurisdictional nexus involving any of the sanctioned parties named in the article have been identified.
  
  
• As a global bank, Santander is acutely aware of its obligation to comply with all relevant sanctions regimes. In this case, both in the UK and across our global banking operations, we are confident that we did that.

Regards,

Juan Manuel Cendoya

Global head of Communications, Corporate Marketing & Research