Shaffer v. Deutsche Bank

No. 3:16-cv-00497

This is a civil action under 18 U.S.C. § 2333(a) of the Anti-Terrorism Act (“ATA”) by American nationals for treble damages against Deutsche Bank AG, an international bank that knowingly conspired with, inter alia, the Islamic Republic of Iran (“Iran”) and its banking agents (including Bank Saderat, Bank Melli and Iran’s Central Bank) (the “Conspiracy”) from at least 1999 to 2011 to evade U.S. economic sanctions and disguise financial payments, thereby foreseeably enabling Iran’s involvement in the terrorist acts that injured the Plaintiffs.


Defendant committed acts of international terrorism by violating 18 U.S.C. § 2339A and § 2339B knowing, or being deliberately indifferent to the fact, that Iran would foreseeably use some of the funds it laundered through the United States to finance the U.S.-designated Foreign Terrorist Organization Hezbollah; the U.S.-designated Islamic Revolutionary Guard Corps (“IRGC”), and its lethal subdivision known as the Islamic Revolutionary Guard Corps-Qods Force (“IRGC-QF”); and Iran’s terrorist agents (including a litany of Iraqi Shi’a terror groups occasionally referred to herein collectively as “Special Groups”) that killed, injured, or maimed American nationals serving as part of the Coalition Forces’ peacekeeping efforts in Iraq from 2004 to 2011, including the Plaintiffs and/or their families.

The Facts, the Plaintiffs and the Defendants

The Facts

The Complaint alleges that Iran has long used terrorist surrogates to target U.S. forces, diplomats, and facilities in Iraq. From 2003 to 2011, Iranian agents led a network of Iraqi “Special Groups” – KH, Asa’ib Ahl al-Haq (“AAH”), and the Promised Day Brigades – that engaged in targeted kidnappings, assassinations, and attacks (including improvised explosive device (“IED”) attacks) on U.S. soldiers and civilians that killed hundreds of Americans and wounded many more.

The Plaintiffs

The Freeman Plaintiffs include individuals who were killed or injured between 2003 and 2011 by: (1) Iraqi terrorist groups trained, funded, and armed by the IRGC-QF; (2) Hezbollah; and/or (3) Iranian-manufactured IEDs. The lawsuit includes claims by members of their immediate families. The Complaint identifies more than 200 plaintiffs from 32 states across the country. The killed and injured include American servicemen ranging from privates to colonels. The

Complaint also includes the family of an American journalist, killed as a result of his fearless reporting from Basra, Iraq.

The Defendants

The Defendants include HSBC Bank plc, HSBC Bank Middle East Limited, and HSBC Bank USA, N.A. – all part of the HSBC Group, one of the world’s largest banking and financial services companies in the world. Other Defendants include Barclays Bank Plc, a global financial services provider headquartered in London, Standard Chartered Bank, also one of the world’s largest international banks, Royal Bank of Scotland N.V. (the successor of the Dutch banking giant ABN AMRO Bank N.V.), and Credit Suisse, all of which, as detailed in the Complaint, entered into DPAs or consent orders with regulators in which they acknowledged their efforts to evade U.S. sanctions concerning Iran.

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The Defendants also include Bank Saderat Plc, a bank incorporated in England and Wales that is a wholly-owned subsidiary of Bank Saderat Iran. In October 2007, Bank Saderat was designated a Specially Designated Global Terrorist (“SDGT”) by the United States. The Treasury Department press release announcing Bank Saderat’s designation stated:

For example, from 2001 to 2006, Bank Saderat transferred $50 million from the Central Bank of Iran through its subsidiary in London to its branch in Beirut for the benefit of Hezbollah fronts in Lebanon that support acts of violence.

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