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AMENDED COMPLAINT JURY TRIAL DEMANDED Case 1:18-Cv-07359-PKC-CLP Document 72 Filed 12/16/19 Page 2 of 539 Pageid #: 5972

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AMENDED COMPLAINT JURY TRIAL DEMANDED Case 1:18-Cv-07359-PKC-CLP Document 72 Filed 12/16/19 Page 2 of 539 Pageid #: 5972 Case 1:18-cv-07359-PKC-CLP Document 72 Filed 12/16/19 Page 1 of 539 PageID #: 5971 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF NEW YORK ----------------------------------------------------------------- x KATHALEEN FREEMAN, et al., : : Plaintiffs, : : Case No. 18-cv-7359 (PKC)(CLP) -against- : : HSBC HOLDINGS PLC, et al., : : Defendants. : ----------------------------------------------------------------- x AMENDED COMPLAINT JURY TRIAL DEMANDED Case 1:18-cv-07359-PKC-CLP Document 72 Filed 12/16/19 Page 2 of 539 PageID #: 5972 TABLE OF CONTENTS I. NATURE OF THE ACTION ............................................................................................... 1 II. JURISDICTION AND VENUE ......................................................................................... 19 III. THE DEFENDANTS .......................................................................................................... 19 A. THE HSBC DEFENDANTS .......................................................................................... 19 B. DEFENDANT BARCLAYS BANK PLC ..................................................................... 21 C. DEFENDANT STANDARD CHARTERED BANK ................................................... 21 D. DEFENDANT ROYAL BANK OF SCOTLAND N.V. ............................................... 22 E. DEFENDANT CREDIT SUISSE AG ........................................................................... 23 F. DEFENDANT BANK SADERAT PLC ........................................................................ 24 G. DEFENDANT COMMERZBANK AG ........................................................................ 24 IV. FACTUAL ALLEGATIONS ............................................................................................. 25 A. IRAN’S LONG HISTORY OF SUPPORTING AND FINANCING TERRORISM .................................................................................................................. 25 B. U.S. SANCTIONS AND IRAN’S RELIANCE ON U.S. DOLLARS ......................... 26 C. IRAN CONTINUOUSLY EVADED U.S., EUROPEAN UNION AND UNITED NATIONS SANCTIONS ................................................................................................ 28 D. THE EURODOLLAR MARKET – IRAN’S MONEY LAUNDERING AND ILLICIT EXPORT NEXUS WITH DEFENDANT BANKS ...................................... 31 1. The Conspiracy’s Shared Goals .............................................................................. 31 2. Eurodollar Market Operations ............................................................................... 32 E. THE IRANIAN U-TURN EXEMPTION AND ITS REVOCATION ........................ 33 F. LETTERS OF CREDIT – AN ALTERNATIVE METHOD OF UNDERMINING THE IRANIAN SANCTIONS PROGRAM ................................................................. 39 1. Terminology .............................................................................................................. 39 2. The U.S. Trade Embargo – United States Munitions List (USML) and Commerce Control List (CCL)................................................................................ 42 i Case 1:18-cv-07359-PKC-CLP Document 72 Filed 12/16/19 Page 3 of 539 PageID #: 5973 G. IRAN’S ILLEGAL ARMS SHIPMENTS THROUGH ISLAMIC REPUBLIC OF IRAN SHIPPING LINES (IRISL) ................................................................................ 43 H. THE IRGC AND HEZBOLLAH COMMITTED ACTS OF INTERNATIONAL TERRORISM AT IRAN’S DIRECTION IN WHICH PLAINTIFFS WERE FORESEEABLY INJURED .......................................................................................... 48 1. The IRGC .................................................................................................................. 51 2. The IRGC-QF ........................................................................................................... 54 3. Lebanese Hezbollah and Unit 3800 ......................................................................... 56 V. THE IRGC-QF’S AND HEZBOLLAH’S DEVELOPMENT AND DIRECTION OF SHI’A TERRORIST GROUPS AND CELLS IN IRAQ TO ATTACK COALITION FORCES. ............................................................................................................................. 60 A. THE BADR CORPS/BADR ORGANIZATION ......................................................... 60 B. JAYSH AL-MAHDI (“JAM” OR THE “MAHDI ARMY”) ...................................... 65 C. THE DEVELOPMENT OF THE JAM SPECIAL GROUPS AND THE PROMISED DAY BRIGADES ..................................................................................... 69 D. ASA’IB AHL AL-HAQ .................................................................................................. 76 E. KATA’IB HEZBOLLAH (“KH”) ................................................................................. 79 F. CASE IN POINT: SENIOR HEZBOLLAH COMMANDER ALI MUSA DAQDUQ’S DIRECTION OF TERRORIST ATTACKS ON COALITION FORCES IN IRAQ ......................................................................................................... 84 G. IRAN FUNDED THE DESIGN AND PRODUCTION OF EXPLOSIVELY FORMED PENETRATORS (“EFPS”) USED TO KILL OR MAIM COALITION FORCES, INCLUDING THE PLAINTIFFS ............................................................... 89 H. ALL OF THE ATTACKS AT ISSUE IN THIS COMPLAINT WERE ACTS OF INTERNATIONAL TERRORISM ............................................................................... 94 VI. OVERVIEW OF THE CONSPIRACY ............................................................................ 96 A. AGREEMENT AND KNOWLEDGE ........................................................................... 96 B. ACTS AND EFFECTS ................................................................................................... 99 C. BANK SADERAT PLC’s AGREEMENT TO, AND PARTICIPATION IN, THE CONSPIRACY .............................................................................................................. 103 ii Case 1:18-cv-07359-PKC-CLP Document 72 Filed 12/16/19 Page 4 of 539 PageID #: 5974 D. THE CENTRAL BANK OF IRAN’S AGREEMENT TO, AND PARTICIPATION IN, THE CONSPIRACY .............................................................................................. 108 E. BANK MELLI IRAN AND MELLI BANK PLC’S AGREEMENT TO, AND PARTICIPATION IN, THE CONSPIRACY ............................................................ 112 F. BANK MELLAT’S AGREEMENT TO, AND PARTICIPATION IN, THE CONSPIRACY .............................................................................................................. 119 G. BANK SEPAH’S AGREEMENT TO, AND PARTICIPATION IN, THE CONSPIRACY .............................................................................................................. 120 H. JOHN DOE DEFENDANTS’ 1-50 AGREEMENT TO, AND PARTICIPATION IN, THE CONSPIRACY .................................................................................................... 122 I. THE HSBC DEFENDANTS’ AGREEMENT TO, AND PARTICIPATION IN, THE CONSPIRACY .............................................................................................................. 123 1. HSBC-Europe’s 2001 “Bank Melli Proposal” ..................................................... 127 2. Defendant HSBC-US’s Agreement to, and Participation in, the Conspiracy in Violation of 18 U.S.C. § 2332d ............................................................................... 133 J. DEFENDANT BARCLAYS’ AGREEMENT TO, AND PARTICIPATION IN, THE CONSPIRACY .............................................................................................................. 143 K. DEFENDANT STANDARD CHARTERED BANK’S AGREEMENT TO AND PARTICIPATION IN THE CONSPIRACY ............................................................. 151 1. Standard Chartered Bank (“SCB”) Conspired to Conceal Iran’s Financial Activities and Transactions from Detection, Scrutiny, and Monitoring by U.S. Regulators, Law Enforcement, and/or Depository Institutions. ........................ 151 2. SCB Facilitated Transactions on Behalf of MODAFL, Mahan Air and Other Instrumentalities of Iranian State-Sponsored Terror (Including a Hezbollah Affiliated Entity) in Furtherance of Numerous Violations of the U.S. Trade Embargo, Thereby Substantially Contributing to the Plaintiffs’ Injuries. ....... 160 a. Standard Chartered Knowingly Provided Illegal Financing to Mahan Air. .... 162 b. Standard Chartered Knowingly Provided Illegal Financing to MODAFL Companies: AIO, IACI, IHRSC and HESA. ........................................................ 166 i. SCB Trade-Finance Transactions with MODAFL’s Aerospace Industries Organization (AIO) ............................................................................................. 167 ii. SCB Trade-Finance Transactions with MODAFL’s [Iran] Aviation Industries Organization (IAIO) ........................................................................................... 168 iii Case 1:18-cv-07359-PKC-CLP Document 72 Filed 12/16/19 Page 5 of 539 PageID #: 5975 (A) SCB’s Trade-Finance Transactions with MODAFL-IAIO Front Company Downtown Trading Ltd. .............................................................................. 169 (B) SCB’s Trade-Finance Transactions with MODAFL-IAIO Front Company Mac Aviation ................................................................................................ 170 (C) SCB’s Trade-Finance Transactions with MODAFL-IAIO Front Company Monarch Aviation (Singapore) ................................................................... 174 (D) SCB’s Trade Finance Transactions with MODAFL-IAIO
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