REYCO GMBH.

Karlstrasse 19, Dinslaken, 46535, Nordrhein-Westfalen, Germany

Reyco was a German subsidiary of Rey Investment Company, although there were no public ties between Reyco and Rey Investment Company, TEACO, or the Iranian Government. Reyco owned MCS Engineering and MCS International. Reyco had the appearance of being a purely German company to circumvent sanctions restricting an Iranian Government-controlled entity’s ability to do business in Europe. Reyco was eventually transferred to the control of TEACO from Rey Investment Company, and TEACO planned to use Reyco to purchase a bank for Iran in Germany.

US

Subject to Secondary Sanctions

https://home.treasury.gov/news/press-releases/jl1968

2013-06-04

US

Iranian Transactions and Sanctions Regulations, 31 CFR part 560

OFAC country specific

Iran

Other financial restrictions, Trade sanctions

• https://ofac.treasury.gov/faqs/topic/1551

The Iranian Transactions Regulations, 31 C.F.R. part 560 (the “ITR”), financial institutions and other U.S. persons were prohibited from engaging in transactions with the GOI. Under those prior rules, U.S. financial institutions receiving instructions to execute transactions involving these entities were not required to block the transactions, but were instead required to reject those instructions rather than carry them out, unless the transactions were exempt, authorized, or not prohibited by OFAC.

SDN