May 15, 2018 STATEMENT BY BANK MELLI IRAN AND BANK SADERAT IRAN IN RESPONSE TO THE WASHINGTON POST’S ARTICLE OF APRIL 3, 2018 Bank Melli and Bank Saderat regret that Bahrain has considered it necessary to disclose to the Washington Post its own legal submissions filed in defence in the ICSID arbitration that was initiated against it by the banks, as the arbitration is confidential, and Bank Melli and Bank Saderat had not yet had an opportunity to address these submissions in the arbitration. Bank Melli and Bank Saderat incorporated Future Bank back in 2004 at the invitation of Bahrain. They each held a third of Future Bank’s share capital. Their local Bahraini partner, Ahli United Bank, held the remaining third. Under the management of Bank Melli and Bank Saderat, Future Bank managed in 2014 to rank as best performing Bahraini bank, and seventh bank in the GCC, according to industry standards such as the regional rankings published annually by the Darien Analytics Survey. Both Bahrain and its shareholders were enthusiast and in agreement that Future Bank would in 2015 take a greater share of the regional market with the forthcoming Joint Comprehensive Plan of Action ultimately signed in July 2015. Yet, on April 30, 2015, Future Bank, along with other Iranian interests, such Iran Insurance Company, was taken by Bahrain without any prior notice nor justification. This led Bank Melli and Bank Saderat to initiate an arbitration at the Hague under the auspices of the Permanent Court of Arbitration against Bahrain pursuant to the 2002 Bahrain-Iran bilateral investment treaty, to claim restitution of Future Bank or compensation for the fair market value of their interest in Future Bank quantified at over EUR 400 million. The hearing is scheduled to take place from December 3 to December 7, 2018, in Paris. The allegations of impropriety raised by Bahrain and echoed by the Washington Post were never raised by Bahrain to justify its taking of Future Bank back in April 2015, but are rather post facto allegations raised in February 2018 for the first time by Bahrain’s attorneys by way of defence in the arbitration, as respondent States often do in international arbitrations to escape liability, which allegations they then leak to the press, as Bahrain has done, so as to give some legitimacy thereto and to harm the opponent. The post facto allegations are untrue and irrational. May 15, 2018 As of 2007, Bahrain placed, via its Central Bank, nominees sitting on Future Bank’s Board of Directors, as well as on the Bank’s Audit Committee (which oversaw the Bank’s internal audit controls, compliance procedures, and risk management functions), and on the Executive Committee (which approved the Bank’s policies, objectives and strategies). These nominees at all relevant times closely scrutinized the activities of Future Bank, moreover to Bahrain’s complete satisfaction. For the avoidance of doubt, there is no evidence, nor was there ever even an allegation, including in the ongoing arbitration, of corruption, let alone of a “multibillion-dollar corruption scheme.” Any concerns regarding any improper handling by Future Bank of SWIFT messages date back to 2009, and were promptly addressed by Future Bank without further complaint from Bahrain. Nor is there or has Bahrain ever put forward any evidence of Future Bank having financed any money-laundering, terrorism, nuclear activities, or having allowed companies to “operate as fronts for Iran’s Islamic Revolutionary Guard Corps,” “secret access to the foreign markets and the international monetary system.” The reality is that Bank Melli and Bank Saderat are mere collateral victims of an entirely political decision, taken in the context of tensions and efforts by some Arab countries led by Saudi Arabia to isolate Iran. It is in this context that Bahrain suddenly targeted not just these Banks but all Iranian interests on its territory, including the Bahraini branch of the Iran Insurance Company, which was also placed under administration, and effectively taken, on April 30, 2015 without any prior notice nor justification. Even US observers, including the US Congressional Research Service in its report of February 15, 2018 (available online at https://fas.org/sgp/crs/mideast/95-1013.pdf), were taken aback by Bahrain’s decision to target Future Bank and the Iran Insurance Company in April 30, 2015, noting that this rather appeared to have been prompted under pressure from Saudi Arabia in the context of rising tensions with Iran, ironically as all sanctions against Iran were being lifted further to the Joint Comprehensive Plan of Action signed on July 14, 2015. In fact, officials from Bahrain’s Central Bank were at the time of the taking unable to provide any explanation other than the fact that it was a sovereign decision outside of their control.