You May Have Rights Under the Anti-Terrorism Act

Anti-Terrorism Lawsuite


If you are a U.S. Veteran, Service Member, or family member of a Veteran or Contractor who was injured, disabled, or killed in the Iraq War, you may have legal rights. MM~LAW LLC is helping people like you take legal action under the U.S. Anti-Terrorism Act against foreign banks that illegally financed Iran’s acts of terrorism during the Iraq War.

What You Need to Know


To date, nine foreign banks have admitted to entering into criminal conspiracies with Iran to provide it with billions of dollars in violation of U.S. and international laws—all while knowing Iran was a “State Sponsor of Terrorism” and a leading source of American injuries and casualties in the Iraq War.

Iran needed hard cash — U.S. dollars — to pay bounties to terrorists attacking civilians and U.S. and coalition forces as well as recruiting, training, arming, commanding and funding Shia and Sunni terrorist organizations engaged in murdering U.S. Soldiers and Citizen-contractors in Iraq.

The banks’ conspiracy with Iran facilitated the attacks responsible for the majority of U.S. casualties in Iraq between 2003 and 2011, killing and grievously wounding tens of thousands of Americans.

The Plaintiffs



The Plaintiffs include U.S. Veterans, Service Members, and Contractors who were disabled or injured between May 1, 2003 and 2011 because of Iranian-sponsored terrorism—the leading cause of harm to Americans in the Iraq War.

Plaintiffs also include families, survivors, and dependents of Veterans and Contractors who were killed or injured at the hands of these terrorists. Spouses, Parents, Siblings, and Children of harmed Veterans may have legal rights under the Anti-Terrorism Act and may be eligible to join the case.

People Affected by Iraq War Terrorism

How Many People Were Affected?

  • Tens of thousands of U.S. Veterans, Service Members, Contractors, and their families have been harmed by Iranian-sponsored terrorism.
  • Iranian sponsored terrorists were responsible for the majority of U.S. casualties in Iraq.
Source: March 2015 Report, Killing Americans and their Allies: Iran’s Continuing War against the U.S. and the West, Colonel (ret.) Richard Kemp & Major (ret.) Chris Driver-Williams. http://jcpa.org/killing-americans- allies-irans-war/

Common Service-Connected Disabilities and Conditions Incurred During OIF/OND

  • Physical Injury (broken bones, loss of limb)
  • Traumatic Brain Injury (TBI)
  • Polytrauma/TBI
  • Traumatic Amputation
  • Blast Injuries
  • Spinal Cord Injury
  • Vision Loss
  • Post-Traumatic Stress Disorder (PTSD)
The Defendants


The Defendants include foreign Banks that entered into a criminal conspiracy to provide Iran with illegal financing and access to the U.S. and international banking systems. The banks have already admitted to criminal violations of money laundering and providing billions of U.S. dollars to Iran—while knowing that Iran was designated a “State Sponsor of Terrorism” in Iraq and elsewhere.

Banks that admitted to having entered into criminal conspiracies with Iran and Iranian banks and illegally transferring billions of dollars to Iran and persons or entities sanctioned by the United States government as “Specially Designated Nationals” include the following banks:

  • HSBC Holding Group Plc.
  • Crédit Suisse AG and Crédit Suisse Asset Management Limited
  • Commerzbank A.G.
  • Standard Chartered Bank Plc.
  • Barclays Plc.
  • BNP Paribas S.A.
HSBC Holding Group Plc

HSBC Holding Group Plc

HSBC Holdings plc and HSBC Bank USA N.A. Admit to Anti-Money Laundering and Sanctions Violations, Forfeit $1.256 Billion in Deferred Prosecution Agreement

U.S. Department of Justice
December 11, 2012
Office of Public Affairs
(202) 514-2007/ (202) 514-1888
WASHINGTON—HSBC Holdings plc (HSBC Group)—a United Kingdom corporation headquartered in London—and HSBC Bank USA N.A. (HSBC Bank USA) (together, HSBC)—a federally chartered banking corporation headquartered in McLean, Virginia—have agreed to forfeit $1.256 billion and enter into a deferred prosecution agreement with the Justice Department for HSBC’s violations of the Bank Secrecy Act (BSA), the International Emergency Economic Powers Act (IEEPA) and the Trading with the Enemy Act (TWEA)… The HSBC Group violated IEEPA and TWEA by illegally conducting transactions on behalf of customers in Cuba, Iran, Libya, Sudan, and Burma—all countries that were subject to sanctions enforced by the Office of Foreign Assets Control (OFAC) at the time of the transactions…
A four-count felony criminal information was filed today in federal court in the Eastern District of New York charging HSBC with willfully failing to maintain an effective anti-money laundering (AML) program, willfully failing to conduct due diligence on its foreign correspondent affiliates, violating IEEPA and violating TWEA. HSBC has waived federal indictment, agreed to the filing of the information and has accepted responsibility for the criminal conduct of its employees…
The Sanctions Investigation
According to court documents, from the mid-1990s through September 2006, HSBC Group allowed approximately $660 million in OFAC-prohibited transactions to be processed through U.S. financial institutions, including HSBC Bank USA. HSBC Group followed instructions from sanctioned entities such as Iran…to omit their names from U.S. dollar payment messages … The bank also removed information identifying the countries from U.S. dollar payment messages; deliberately used less-transparent payment messages, known as cover payments; and worked with at least one sanctioned entity to format payment messages, which prevented the bank’s filters from blocking prohibited payments. Specifically, beginning in the 1990s, HSBC Group affiliates worked with sanctioned entities to insert cautionary notes in payment messages including “care sanctioned country,” “do not mention our name in NY,” or “do not mention Iran.”…
“Banks are the first layer of defense against money launderers and other criminal enterprises who choose to utilize our nation’s financial institutions to further their criminal activity,” said Richard Weber, Chief, Internal Revenue Service-Criminal Investigation (IRS-CI). “When a bank disregards the Bank Secrecy Act’s reporting requirements, it compromises that layer of defense, making it more difficult to identify, detect and deter criminal activity. In this case, HSBC became a conduit to money laundering…
Manhattan District Attorney Cyrus R. Vance Jr., said, “New York is a center of international finance, and those who use our banks as a vehicle for international crime will not be tolerated…Sanctions enforcement is of vital importance to our national security and the integrity of our financial system. The fight against money laundering and terror financing requires global cooperation, and our joint investigations in this and other related cases highlight the importance of coordination in the enforcement of U.S. sanctions.
Credit Suisse AG

Credit Suisse AG

Credit Suisse Agrees to Forfeit $536 Million in Connection with Violations of the International Emergency Economic Powers Act and New York State Law

U.S. Department of Justice
Office of Public Affairs
(202) 514-2007
Credit Suisse AG, a Swiss corporation headquartered in Zurich, has agreed to forfeit $536 million to the United States and the New York County District Attorney’s Office in connection with violations of the International Emergency Economic Powers Act (IEEPA) and New York state law.…
According to court documents, beginning as early as 1995 and continuing through 2006, Credit Suisse, in Switzerland and the United Kingdom, altered wire transfers involving U.S. sanctioned countries or persons. Specifically, according to court documents, Credit Suisse deliberately removed material information, such as customer names, bank names, and addresses, from payment messages so that the wire transfers would pass undetected through filters at U.S. financial institutions. Credit Suisse also trained its Iranian clients to falsify wire transfers so that such messages would pass undetected through the U.S. financial system. This scheme allowed U.S. sanctioned countries and entities to move hundreds of millions of dollars through the U.S. financial system.
For its Iranian clients, Credit Suisse promised that no message would leave the bank without being hand-checked by a Credit Suisse employee to ensure that the message had been formatted to avoid U.S. filters. If an Iranian client provided payment messages that contained identifying information, Credit Suisse employees would remove the detectable information so that the message could pass undetected through OFAC filters at U.S. financial institutions. According to court documents, Credit Suisse’s international communications showed a continuous dialogue about the scheme, assessing how to process Iranian transactions better to ensure increased business from existing and future Iranian clients. For example, in 1998, Credit Suisse provided its Iranian customers with a pamphlet entitled, “How to transfer USD payments,” which provided detailed payment instructions on how to avoid triggering U.S. OFAC filters or sanctions…
“This case provides a timely lesson about how Iran seeks to involve others in deceptive conduct to evade legal and regulatory controls,” said Treasury Under Secretary for Terrorism and Financial Intelligence Stuart Levey. “Those who do business with Iran expose themselves to the risk, and the consequences, of participating in transactions supporting proliferation, terrorism or sanctions evasion.”
Commerzbank A.G.

Commerzbank AG

Commerzbank AG Admits to Sanctions and Bank Secrecy Violations, Agrees to Forfeit $563 Million and Pay $79 Million Fine
Combined with Payments to Regulators, Commerzbank to Pay $1.45 Billion

U.S. Department of Justice
Office of Public Affairs
(202) 514-2007
Commerzbank AG, a global financial institution headquartered in Frankfurt, Germany, and its U.S. branch, Commerzbank AG New York Branch (Commerz New York), have agreed to forfeit $563 million, pay a $79 million fine and enter into a deferred prosecution agreement with the Justice Department for violations of the International Emergency Economic Powers Act (IEEPA) and the Bank Secrecy Act (BSA).
In entering the deferred prosecution agreement, Commerzbank admitted and accepted responsibility for its criminal conduct in violation of IEEPA, and Commerz New York admitted its criminal conduct in violation of the BSA..
“Commerzbank concealed hundreds of millions of dollars in transactions prohibited by U.S. sanctions laws on behalf of Iranian and Sudanese businesses,” said Assistant Attorney General Caldwell…
“Sanctions laws are designed to protect the national security of the United States and promote our foreign policy interests,” said U.S. Attorney Machen.  “Commerzbank undermined the integrity of our financial system and threatened our national security by hiding the business they were doing with entities in Iran and Sudan.  The bank tried to skirt our laws by hiding its illegal business with Iranian banks from its own employees in the United States.  Today’s resolution demonstrates that there will be consequences when global banks try to profit from the benefits of the U.S. financial system without respecting our laws.”
According to admissions contained in the deferred prosecution agreement, from 2002 to 2008, Commerzbank knowingly and willfully moved $263 million through the U.S. financial system on behalf of Iranian and Sudanese entities subject to U.S. economic sanctions.  Commerzbank engaged in this criminal conduct using numerous schemes designed to conceal the true nature of the illicit transactions from U.S. regulators…
Specifically, in 2003, Commerzbank designated a group of employees in the Frankfurt back office to review and amend Iranian payments so that the payments would not be stopped by U.S. sanctions filters.  In doing so, Commerzbank ensured that Iranian payment messages did not mention the Iranian entity, as transactions may have otherwise been stopped pursuant to the U.S. sanctions. ..
For example, in 2003, when two state-owned Iranian banks wanted to begin routing their U.S. dollar clearing business through Commerzbank, a Commerzbank back office employee emailed other Commerzbank employees directing: “If for whatever reason CB New York inquires why our turnover has increase[d] so dramatically, under no circumstances may anyone mention that there is a connection to the clearing of Iranian banks!!!!!!!!!!!!!.”
Commerzbank admitted that this conduct continued even though its senior management was warned that the bank’s practices for Iranian clients “raised concerns.”
Standard Charted Bank

Standard Charted Bank

Standard Chartered reaches $340 million settlement with Iran

Karen Freifeld and Carrick Mollenkamp
1:40 a.m. CDT, August 15, 2012
NEW YORK (Reuters) – Standard Chartered Plc agreed to pay $340 million to New York’s bank regulator over transactions linked to Iran, in a speedily arranged deal that helped push up the emerging market-focused lender’s shares…
The deal with New York Superintendent of Financial Services Benjamin Lawsky on Tuesday caps a week of transatlantic tension and a furor over why a state agency had upstaged other authorities.
Standard Chartered’s Hong Kong shares rose as much as 6.8 percent to HK$177, still nearly 6 percent below where they were before the allegations hit the bank early last week.
The settlement agreed by the bank is equal to less than 9 percent of its first-half pre-tax profit. At the latest levels, Standard Chartered’s market value is around $3.5 billion less than it was before Lawsky’s allegations…
Lawsky on August 6 called Standard Chartered a “rogue institution” that had broken U.S.sanctions on Iran, saying it hid Iran-linked transactions with a total value of $250 billion from regulators.
In his announcement on Tuesday, Lawsky said Standard Chartered “agreed that the conduct at issue involved transactions of at least $250 billion.” But he gave no details on what protections the deal gave Standard Chartered. (http://link.reuters.com/faq99s)
Barclays Bank Plc

Barclays Bank Plc

Barclays Bank PLC Agrees to Forfeit $298 Million in Connection with Violations of the International Emergency Economic Powers Act and Trading with the Enemy Act

U.S. Department of Justice
December 11, 2012
Office of Public Affairs
(202) 514-2007/ (202) 514-1888
WASHINGTON—Barclays Bank PLC, a United Kingdom corporation headquartered in London, has agreed to forfeit $298 million to the United States and to the New York County District Attorney’s Office in connection with violations of the International Emergency Economic Powers Act (IEEPA) and the Trading with the Enemy Act (TWEA), announced Assistant Attorney General Lanny A. Breuer of the Criminal Division and District Attorney Cyrus R. Vance Jr., of the New York County District Attorney’s Office. The violations relate to transactions Barclays illegally conducted on behalf of customers from Cuba, Iran, Sudan, and other countries sanctioned in programs administered by the Office of Foreign Assets Control (OFAC).…
A criminal information was filed Aug. 16, 2010, in the U.S. District Court for the District of Columbia charging Barclays with one count of violating the IEEPA and one count of violating the TWEA. Barclays waived indictment, agreed to the filing of the information, and has accepted and acknowledged responsibility for its criminal conduct. …
“Banks like Barclays will not be permitted to disregard sanctions put in place by the U.S. government,” said Assistant Attorney General Lanny A. Breuer of the Criminal Division. “Not just once, but numerous times over more than a decade, Barclays stripped vital information out of payment messages that would have alerted U.S. financial institutions about the true origins of the funds.”…
“Criminal activity of the type we found at Barclays does more than deceive our financial institutions, it threatens the  security of our country,” said District Attorney Cyrus R. Vance Jr.…
According to court documents, from as early as the mid-1990s until September 2006, Barclays knowingly and willfully moved or permitted to be moved hundreds of millions of dollars through the U.S. financial system on behalf of banks from Cuba, Iran, Libya, Sudan and Burma, and persons listed as parties or jurisdictions sanctioned by OFAC in violations of U.S. sanctions.
According to court documents, Barclays followed instructions, principally from banks in Cuba, Iran, Libya, Sudan, and Burma, not to mention their names in U.S. dollar payment messages sent to Barclays’ branch in New York and other financial institutions located in the United States. Barclays routed U.S. dollar payments through an internal Barclays account to hide the payments’ connection to OFAC-sanctioned entities and amended and reformatted the U.S dollar payment messages to remove information identifying the sanctioned entities. Barclays also deliberately used a less clear method of payment messages, known as cover payments, as another way of hiding the sanctioned entities identifying information.
BNP Paribas S.A.

BNP Paribas S.A.

BNP Paribas Agrees to Plead Guilty and to Pay $8.9 Billion for Illegally Processing Financial Transactions for Countries Subject to U.S. Economic Sanctions

U.S. Department of Justice
Office of Public Affairs
(202) 514-2007
WASHINGTON—According to court documents submitted today, 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. …
“By providing dollar clearing services to individuals and entities associated with Sudan, Iran, and Cuba—in clear violation of U.S. law—BNPP helped them gain illegal access to the U.S. financial system,” said Acting Assistant Attorney General Caldwell. “In doing so, BNPP deliberately disregarded U.S. law of which it was well aware, and placed its financial network at the services of rogue nations, all to improve its bottom line. Remarkably, BNPP continued to engage in this criminal conduct even after being told by its own lawyers that what it was doing was illegal.”
“BNPP banked on never being held to account for its criminal support of countries and entities engaged in acts of terrorism and other atrocities,” said U.S. Attorney Bharara. “But that is exactly what we do today. BNPP, the world’s fourth largest bank, has agreed to plead guilty and pay penalties of almost $9 billion for performing the hat trick of sanctions violations, unlawfully opening the doors of the U.S. financial markets to three sanctioned countries, Sudan, Iran, and Cuba. For years, BNPP provided access to billions of dollars to these sanctioned countries, as well as to individuals and groups specifically identified and designated by the U.S. government as being subject to sanctions. The bank did so deliberately and secretly, in ways designed to evade detection by the U.S. authorities.
BNPP processed approximately $6.4 billion through the United States on behalf of Sudanese sanctioned entities from July 2006 through June 2007, including approximately $4 billion on behalf of a financial institution owned by the government of Sudan, even as internal e-mails showed BNPP employees expressing concern about the bank’s assisting the Sudanese government in light of its role in supporting international terrorism and committing human rights abuses during the same time period. Indeed, in March 2007, a senior compliance officer at BNPP wrote to other high-level BNPP compliance and legal employees reminding them that certain Sudanese banks with which BNPP dealt “play a pivotal part in the support of the Sudanese government which . . . has hosted Osama Bin Laden and refuses the United Nations intervention in Darfur.”…
Further according to court documents, BNPP engaged in more than $650 million of transactions involving entities tied to Iran, and this conduct continued into 2012—nearly two years after the bank had commenced an internal investigation into its sanctions compliance and had pledged to cooperate with the Government.
Case Document

Banks Admitted Wrongdoing

All of the above British, French, German and Swiss banks admitted to knowingly violating U.S. economic sanctions enabling Iran to access the U.S. and international financial systems and transfer funds. These banks ordered their employees to conceal illegal wire transfers of funds to Iran. According to the U.S. Department of Treasury, at least $150 Million was moved to Iranian-controlled terrorists.

Escaped Prosecution

BNP Paribas plead guilty to felony charges under US and New York laws, and all of the other banks entered into deferred prosecution agreements with the Department of Justice. Each of these banks admitted to criminally financing Iran, paid a fine, and escaped further prosecution.

Anti-Terrorism Act


U.S. Law, under the Anti-Terrorism Act, declares that any “national of the United States” or his/her survivors may sue for injuries “by reason of an act of international terrorism.” 18 U.S. Code §2333. The law allows plaintiffs to hold accountable organizations in conspiracies that supported the international terrorism and sue them in U.S. federal courts for monetary damages.

For example, §2339B. Makes it a crime to knowingly provide material support or resources to designated foreign terrorist organizations.

In enacting this law, Congress found that –

“(1) international terrorism is a serious and deadly problem that threatens the vital interests of the United States;…

“(6) some foreign terrorist organizations, acting through affiliated groups or individuals, raise significant funds within the United States, or use the United States as a conduit for the receipt of funds raised in other nations; and

“(7) foreign organizations that engage in terrorist activity are so tainted by their criminal conduct that any contribution to such an organization facilitates that conduct.”

“(b) Purpose. – The purpose of this subtitle [subtitle A (Secs.301-303) of title III of Pub. L. 104-132, enacting this section and section 1189 of Title 8, Aliens and Nationality] is to provide the Federal Government the fullest possible basis, consistent with the Constitution, to prevent persons within the United States, or subject to the jurisdiction of the United States, from providing material support or resources to foreign organizations that engage in terrorist activities.”


The Conspiracy with Iran

Foreign banks knowingly conspired to illegally transfer hundreds of billions of U.S. Dollars to Iran at the same time Iran was paying its terrorist proxies bounties to injure and kill Americans in the Iraq War.

U.S. and International laws have long imposed sanctions on Iran for being a “State Sponsor of Terrorism.” These sanctions made it illegal for Iran to access the U.S. financial system.

Despite knowing that Iran was funding terrorists in the Iraq War, the banks illegally financed Iran with billions of U.S. Dollars. The banks altered documents to hide their actions from the U.S. Government.

Several of the banks have admitted transferring hundreds of billions of dollars to Iran in violation of U.S. and International laws, but have not been prosecuted.

These Banks were aware of Iran’s support of terrorism in the Iraq War yet continued to transfer hard-cash U.S. dollars to Iran illegally.

Knowledge of Iran’s Terrorism in Iraq

During the Iraq War, Iran’s extensive support and direction of terrorism in Iraq were widely reported in the media. Further, numerous military officials, diplomats, and heads of state disclosed Iran’s involvement in killing and injuring U.S. Service Members.

Public Knowledge of Iranian-Sponsored Terrorism in Iraq
“Iran’s . . . support for terrorist groups . . . its efforts to sow violence and undermine stability in Iraq, including lethal support for groups that are directly responsible for hundreds of U.S. Casualties.”
William Burns, U.S. Undersecretary of State for Political Affairs, July 9, 2008
“Iran also equips terrorists with technology and provides training in extremist ideology and militant techniques.”
Annual Report, 2005, U.S. Department of State.
Iranian-Made EFPs

EFP detonations were the most overt manifestations of Iranian influence in the Iraq War. The technology required to manufacture the copper warheads for these deadly weapons is believed to be Iranian, and not available in Iraq.

The Iranian-made EFPs were made of rounded copper and steel. The key component of most EFPs were the precision made copper disks that formed a molten slug when detonated that penetrated the most hardened armored vehicles.

Powerful roadside bomb

Iran’s Attacks Against Americans in Iraq

Iran needed and used access to hard cash U.S. dollars to recruit, train, pay salaries and bounties to, and arm terrorists for the purpose of injuring Americans throughout Iraq. Iranian-sponsored terrorism was responsible for more than a quarter of all U.S. casualties during Operation Iraqi Freedom and Operation New Dawn.

  • Iran trained, funded, and armed terrorist “special criminal groups” throughout Iraq.
  • Iran sponsored other terrorist groups such as Hezbollah and Ansar al-Islam, all for the purpose of attacking Americans.
  • Iran was the exclusive manufacturer of explosively-formed penetrators (EFPs), advanced rockets and munitions, which were the leading causes of injuries to U.S. and Coalition Forces.
  • Records show when and where Iranian-sponsored terrorism occurred in Iraq and how the unique Iranian-made weapons were used.


Iran’s co-conspirators violated the Anti-Terrorism Act by providing material support (defined by law to include financial services) to Iran, a “State Sponsor of Terrorism,” while knowing that such support would be used for committing acts of international terrorism against American civilians and soldiers.


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