The Middle East salesman had been wrestling with his conscience for more than a month when the barrel bombs broke and spilled their colourless, odourless gas over the Damascus suburbs. It was images of what followed that finally spurred him to act.
Syrian children with shrunken pupils and foaming mouths writhed and gasped for breath in grainy footage on the salesman’s computer screen in the London office of Reed Business Information (RBI), where he managed accounts across the Middle East. Watching in horror on the busy sales floor of the multinational financial data firm, surrounded by harried colleagues closing deals with banks around the world, he felt the full significance of the disturbing discovery he had made weeks before hit him again with sickening force.
The salesman had stumbled upon a trail of evidence showing how his own company had provided crucial data to financial institutions in Syria blacklisted under international sanctions against the despotic government of president Bashar al-Assad. Now, watching images of a chemical weapons attack in which hundreds of innocent Syrians were gassed to death with the nerve agent sarin in August 2013, he wanted to know whether his firm had aided the brutal regime by helping to keep its banks in business.
As the Middle East salesman began digging through the company’s records, he rapidly unravelled a web of deals his colleagues and managers had made to supply critical data to banks linked to terrorism, money-laundering, and nuclear weapons, not just in Damascus but in several more of the world’s most dangerous countries. The hundreds of documents he gathered have been reviewed by BuzzFeed News and their contents are published here for the first time. They reveal in extraordinary detail how RBI’s London branch dealt with blacklisted institutions in Syria, Iran, North Korea, and Iraq between 2008 and 2013, despite strict international sanctions designed to starve the rogue states of funds.
The revelations have emerged amid mounting international alarm about the bloody repression of the Syrian uprising against the Assad regime, during which more than 200,000 people have reportedly been killed so far. They come as fevered negotiations over the Iran nuclear deal near the finish line, with both America and Britain playing a leading role in using international sanctions as a bargaining chip to pressurise the regime to roll back its nuclear programme.
The salesman spoke to BuzzFeed News and shared his cache of documents on condition of anonymity for fear of being labelled a “troublemaker” at work. The story of how he uncovered RBI’s dealings with blacklisted banks was corroborated by a second whistleblower, who resigned from the firm following the chemical weapons attacks in August 2013. That person also asked not to be named.
RBI is one of the world’s leading suppliers of financial information, and among its most prized products is the Bankers’ Almanac, a register of all the payment codes and account numbers needed to make international transactions. The Almanac began life as a clothbound volume 170 years ago and has now swelled into a large database used by thousands of banks, governments, and other organisations around the world, on subscriptions ranging in value from about £2,000 to more than £50,000 per year. “Banks used to tell me it’s the air they breathe,” the salesman told BuzzFeed News. “Without it they can’t function."
Nigel Kushner, a leading sanctions lawyer at the London firm W Legal, said the Bankers’ Almanac is “vitally important” for banks when making cross-border payments. “Every large client I have uses the Bankers’ Almanac database,” he said. “It would be very difficult for someone to process payments without it – in some cases impossible.”
RBI has contracts worth more than half a million dollars to supply the Almanac and other information services to five government departments in the UK and three in the US.
Its US arm Accuity also offers its customers a sanctions screening service designed to help them avoid dealing with blacklisted institutions, which it markets as an “unparalleled defence against participation in illicit financial activities”.
But as the salesman delved though the company’s files in the London office after seeing the awful aftermath of Assad’s attack on his own people, he found it had sold its prized Almanac to two blacklisted state banks in Syria accused by the European Union of funding weapons of mass destruction and bankrolling the Assad regime’s “violent repression” of its citizens. It had also provided the critical transactions data to four blacklisted Iranian institutions, including Bank Sepah, sanctioned by the United Nations and the EU in 2007 and described by the US Treasury as the “financial linchpin of Iran’s missile network”. A deal had been done with a bank in Iraq whose pre-2003 funds were under sanctions. And in 2011, staff at RBI tried to sell its services to a North Korean state bank blacklisted by the EU and described by the US Treasury as one of the “key components” of the financial network behind the country’s “illicit and dangerous activities”. In the end, that deal did not go through.
By providing banks in rogue states with access to the Bankers’ Almanac, the Middle East salesman said, RBI had given them “a lifeline”. He explained: “It’s giving someone who’s blacklisted the knowhow to find ways of moving funds. We’re talking about millions of transactions that have been heavily reliant on our information and tools. If you’re going to help someone move those funds quickly, then they’ll be able to procure those goods and import arms quickly.”
The RBI files also paint a picture of a frenzied sales culture in which staff were put under constant pressure to close deals. In one email sent to the sales team by a manager at the end of 2012, staff were told that they should be “looking forward and thinking only of money in 2013 … basically, shutting the f**k up and getting on with it”.
Lawyers for RBI alleged that the two employees who blew the whistle were “motivated by malice”, and threatened to sue BuzzFeed News and the reporter who wrote this story if it was published. Their last letter before publication said: “To the extent that there might be any credence in assertions you have made based on confidential information the appropriate course is to give this information to the appropriate authority to investigate, thereby satisfying the public interest and preserving the confidentiality of the documents.”
However, RBI did concede that it provided information to six banks under EU sanctions in Syria and Iran. “BankersAlmanac made two sales to Iranian banks in 2008/09 when those banks were subject to EU sanctions,” a spokesperson said. “BankersAlmanac also failed to cancel access to four banks when they were placed under EU sanctions in 2011/12, and instead allowed these contracts to expire.” The dealings with sanctioned banks were an oversight and not the result of a high-pressure sales culture, the spokesperson insisted.
“Once discovered,” the spokesperson said, “the contracts were cancelled or not renewed, and robust processes put in place to prevent potential similar occurrences.” As for the attempted sales to North Korea, he claimed they never went through. Sanctions law in the UK is “incredibly complex”, he added, and it was “unclear” whether RBI had breached the law by selling to banks blacklisted under EU or UN sanctions, because the Almanac consists of “publicly available information”.
UK sanctions law bans firms from dealing with funds from institutions blacklisted by the EU or the UN either directly or indirectly, or providing any resources which could help them make money. Kushner, the sanctions lawyer at W Legal, said that although the payment codes listed in the Almanac are technically publicly available, it would be virtually impossible for banks to do business without access to the database, because “by the time they had got the information independently it would be too late to process the payment".
John Mann MP, a prominent member of the powerful House of Commons Treasury select committee, said it was “no defence” for RBI to claim that the law on dealing with blacklisted banks was unclear. “Any company trading in Syria and Iran knows what it is doing, and investing in these countries despite the sanctions is a disgrace,” he said. “Hiding behind the supposed ‘complexity’ of sanctions is no excuse.”
The sanctions screening service RBI offers its own clients through Accuity is designed to prevent banks from accidentally dealing with blacklisted entities. “No one should know sanction laws better than someone publishing sanctions screening information and data,” said Kushner.
The economic crime division of the City of London police has confirmed it is now examining evidence gathered by the Middle East salesman after it was passed information by investigators at the Serious Fraud Office in February this year. The National Crime Agency’s economic crime command and the criminal investigations division at HM Revenue and Customs have also been reviewing evidence of possible sanctions busting by RBI.
However, no action has yet been taken since the Middle East salesman first blew the whistle to the authorities in January last year, and RBI said that following an internal investigation, there was “no basis” for anyone at the firm to be sacked or disciplined for their role in fixing deals with sanctioned banks.
A spokesperson for the Foreign Office said: “The UK is committed to ensuring that sanctions are adhered to and properly enforced. A range of restrictive measures are in place on both Iran and Syria … It is the responsibility of economic operators in the UK to ensure they are compliant with sanctions. Failure to comply with sanctions can lead to criminal prosecution.”
Anyone found guilty of breaching EU or UN sanctions in the UK is liable to receive a fine or imprisonment of up to two years, and businesses can also face punishment. The penalties are much tougher in the US, where those convicted of busting sanctions can be imprisoned for up to 20 years and receive fines of as much as $1 million per violation.
As well as dealing with banks that were blacklisted by the EU and the UN, RBI provided services to a further 11 banks in countries sanctioned by the US Treasury over links to terrorism and nuclear weapons, the documents show.
While EU and UN sanctions tend to apply only to specifically blacklisted entities, the US regime uses more sweeping measures to ban trade with a wide range of organisations in sanctioned countries such as Syria, North Korea, and Iran.
RBI said the Bankers’ Almanac is not subject to US sanctions, because it is registered in the UK. But in 2011 its parent company, Reed Elsevier, bought the US-based financial information and sanctions-screening firm Accuity and RBI began selling the database using that brand. Like all US-based entities and individuals, Accuity is required to comply with the country’s sanctions regime.
The documents show RBI continued providing the Bankers’ Almanac to 13 entities under US sanctions in Syria, Iran, and Iraq after it acquired Accuity and began using the brand in November 2011.
A spokesperson for the company said that despite the acquisition, "BankersAlmanac has remained a UK entity, subject to EU and UK sanctions law." He insisted: "At no point did Accuity make any sales to any entity sanctioned by the US."
"Nonetheless," he said, "a decision was made in 2012 to stop BankersAlmanac sales to entities subject to US sanctions law, even when those sales would be legal." Despite this, documents seen by BuzzFeed News show that some of RBI's contracts with banks blacklisted by the US Treasury rolled on until the salesman blew the whistle in 2013.
A source at RBI said they had "slipped through".
RBI’s insistence that it was under no moral or legal obligation to obey US sanctions comes despite the fact that its parent company has been deeply entwined with American politics for many years. Reed Elsevier has made campaign donations totalling more than than $2 million to the Democrats and the Republicans since 1993, including $55,000 to Barack Obama. Mark Kelsey, chief executive of RBI, was invited to speak alongside the president at a White House cybersecurity conference in February this year.
The documents reveal that RBI has contracts to sell the Bankers’ Almanac to the US Treasury – the very government department in charge of the country’s sanctions regime – as well as the Department of Defense.
The Middle East salesman said it was plainly wrong for RBI to have done business with banks blacklisted by the US.
“These are banks that have been implicated in terrorism, in money laundering, in nuclear proliferation,” he said. “Banks who pose a huge risk to international peace and security. It’s very clear-cut: If you have a blacklisted bank, you shouldn’t be doing business with them.”
The unravelling of RBI’s dealings with blacklisted banks began, the salesman said, when he received an apparently innocuous phone call from a valued client at a big Middle Eastern bank in July 2013. It was time to renew its subscriptions to the Bankers’ Almanac for its branches in Bahrain and Jordan, but after initial chit-chat and a bit of haggling over prices, the customer finally dropped a bombshell. He also wanted to buy access to the database for a branch of the bank in Syria.
Alarmed by the request, the salesman turned to the company’s legal department for advice and received a clear instruction. “Even if the fees for the services are paid by the HQ of this entity which is based outside Syria, we should not be providing any services to this entity in Syria,” a lawyer replied.
But the salesman recalled that his manager had sold subscriptions to Syrian branches of another Middle Eastern bank the year before and had given assurances based on legal advice that it was legitimate on “strict condition that no transaction is made in or out of Syria”. The advice the salesman was now receiving from the firm’s lawyers seemed to contradict that assertion.
“I turned round and said, ‘But we are doing business in Syria. What the hell’s going on here?'” he recalled asking his superiors. “I’m being tasked with these renewals and it’s all illegal.”
The salesman said he became seriously worried that he might be implicated in sanctions-busting — as did the close colleague who also spoke to BuzzFeed News. Both men raised concerns with the firm’s senior managers, and, in August, the salesman filed a report under legal safeguards available to whistleblowers detailing his first discoveries of RBI's deals with blacklisted banks.
It was days later that the barrel bombs dropped on Damascus, unleashing their deadly cargo of toxic gas. The chemical weapons attack prompted the salesman’s colleague to resign in outrage over the company’s dealings with Syria. “It was the hypocrisy that got to me,” the colleague later told BuzzFeed News. “I couldn’t believe we were doing what we were telling other banks not to do as a sanctions screening service. And at the time we were looking to go to war, we were working with sanctioned entities.”
The salesman himself wondered whether to resign. But instead he decided to stay behind and gather as much evidence as he could muster of the deals his firm had done with state banks in Syria. If his company had helped the regime responsible for these attacks on its own people, he said, he was determined to bring those dealings to light.
He started laying the groundwork for his own investigation into the sales he had stumbled upon, he said, and began by ordering himself the equipment he needed to gather his evidence.
The delivery trolley arrived at his desk in the middle of the open-plan sales floor a few days later, and his colleagues eyed him suspiciously as boxes of hard drives, cardboard folders, ring binders, file dividers, and pens were unloaded, the salesman said. From then on, managers began circling his desk to peer at his computer screen as he worked. He had ordered the stationery in order to compile files of evidence of his company’s dealings with blacklisted banks, and by then, he said, he was so aerated that he hoped his bosses had guessed what he was doing.
The salesman suspected that the murky deals went much further than anyone realised, he said, and turned to the company’s own tools to try to prove it.
“I used Bankers’ Almanac to look up all banks in countries with wide sanctions, like Syria and Iran, to pull out a list of every bank in those countries, not just those blacklisted,”
“Next I went through our records to see which of those banks we had as customers. I had to go to each individual bank and look up contract dates … After that I went into their sanctions screening tool to put in the names of banks we had as customers, to find out if it was sanctioned. I basically used the tools they provide to their own customers.”
As he delved deeper into the company’s files, the salesman said he was “constantly on the phone” to the colleague who had resigned after the chemical weapons attacks in August, telling him, "'I’m uncovering more and more breaches.' And he would say, 'Maybe you should look into this bank or that bank.'”
The documents seen by BuzzFeed News include a list of contracts with banks under sanctions that RBI submitted to an employment tribunal last year in response to the salesman’s allegations. Of 28 blacklisted banks the whistleblower said the company had sold its data to, RBI admitted it had dealt with 18, 11 of which were covered by US sanctions the company said it had no duty to obey. But it also sold data to seven banks under EU sanctions, which are applicable in the UK, and BuzzFeed News has seen evidence that it had attempted to do a deal with an eighth but it fell through. In the remaining cases, the entities were not in fact under sanctions at the relevant times.
A database the salesman said he compiled from internal records suggests that the value of the contracts the company did hold with US- and EU-sanctioned banks totalled around £200,000. RBI said the value of the deals with banks under EU sanctions applicable in the UK was less than £50,000.
The records show that RBI continued providing the Bankers’ Almanac to the state-owned Commercial Bank of Syria and Central Bank of Syria after they were blacklisted by the EU in 2011 and 2012 respectively. Both institutions were accused by the EU of funding weapons of mass destruction and bankrolling the regime of Syrian president Bashar al-Assad in its “violent repression” of its citizens. The banks remain blacklisted today.
When EU sanctions are put in place, companies should immediately sever all commercial ties, but the documents show services continued to be provided to the Central Bank of Syria nearly a year after sanctions were imposed, and to the Commercial Bank of Syria six months after it was sanctioned.
The salesman also uncovered a chain of internal notes from 2011 showing that RBI attempted to sell the Bankers’ Almanac to the state-owned Korea Daesong Bank, which has been under strict EU sanctions since 2010.
The bank was blacklisted by the US Treasury the same year over its close ties to Office 39, a secretive branch of the North Korean government that Western authorities say props up Kim Jong Un’s regime by generating funds through organised crime, money laundering, and managing slush funds. US Treasury officials said the bank was “facilitating North Korea’s illicit financing projects” and was one of the “key components of Office 39’s financial network supporting North Korea’s illicit and dangerous activities”.
The notes reveal that sales staff repeatedly spoke to officials at Korea Daesong Bank from April 2010 to December 2011 in an attempt to sell them access to Bankers’ Almanac for £10,000. Under the heading “New Business”, staff had logged requests they had made to North Korean officials to provide the names and numbers of other banks in the country to which they could try to sell the product.
A note on the file dated November 2011 following a conversation with a North Korean official reads: “He thinks over £10,000 is too expensive, he will see what they can affored [sic].” Another note dated December said: “Other banks are not very interested becsue [sic] it’s too expensive. I need to tell him if we can charge them as book price.” A second note dated four days later reads: “told customer that I can’t sell to them.”
The company said its internal processes prevented the sale being completed. However, sanctions lawyers told BuzzFeed News that even attempting to trade knowingly with a blacklisted bank can be illegal.
The most extensive evidence gathered by the salesman relates to deals with six Iranian banks, four of which were under EU and UN sanctions applicable in the UK at the time and all of which were blacklisted by the US Treasury.
In 2008, RBI successfully sold a data subscription to the state-owned Bank Sepah in Tehran, which was placed under UN and EU sanctions in 2007. US Treasury officials said at the time: “Bank Sepah is the financial linchpin of Iran’s missile procurement network and has actively assisted Iran’s pursuit of missiles capable of carrying weapons of mass destruction.”
In an email to RBI staff dated 11 July 2009, an official at Bank Sepah warned: “Due to the sanction imposed by the UN Resolution No. 1747 of 24 March 2007, Bank Sepah itself is not able to pay funds in a conveniently safe manner.” The bank then asked sales staff to advise them on how they could make a payment of £3,676 through a third party.
RBI employees advised the bank to pay for the Almanac via its small London office instead of its sanctioned headquarters in Iran. RBI said its internal controls picked up the sale and that payment was stopped. But the documents seen by BuzzFeed News show that RBI continued to provide services to Bank Sepah for another six months.
Kushner, the sanctions lawyer at W Legal, said circumventing sanctions by rerouting payments in this way can be illegal. “You have to ask yourself, ‘Can I do it directly?’, and if the answer is no then it’s highly likely you can’t do it via a third party,” he said. “It’s very serious because it would show you know and intend to try and circumvent the sanctions regime in an illegitimate manner.”
The internal documents also show that in 2009, sales staff sold services to Iran’s largest state bank, Bank Melli, while it was under EU and UN sanctions. The bank has been linked by the US to the funding of nuclear weapons and terrorist groups, including the Taliban and Hamas. “Bank Melli goes to extraordinary lengths to assist Iran's pursuit of a nuclear capability and ballistic missiles, while also helping other designated entities to dodge sanctions,” US Treasury officials said in 2008. But a data subscription was still being provided to the bank more than a year after it was first blacklisted.
By November 2013, after months of trawling, the Middle East salesman felt he had accumulated enough evidence. He had downloaded hundreds of documents onto external hard drives and filled several large ring binder files with paperwork.
That month, he submitted a formal grievance to RBI setting out a list of sanctions breaches he believed he had uncovered. “Recently I was going about my daily workload when I noticed something shocking,” it began. “It seemed that we were doing business with sanctioned countries such as Syria and Iran. This was around the time that Syria was using chemical weapons against its own people. We were providing state of the art software to these countries that enabled them to complete international money transfer. This was akin to facilitating terrorist fundraising.”
His former colleague followed up with a letter echoing his concerns. “I’ve read [the] formal grievance … and I agree with everything in there,” the colleague wrote. “When [the salesman] first discovered the sanction relationships we emailed each other and we couldn’t believe that the company was telling us to renew sanctioned banks’ licenses.”
Two months later, the salesman received a response from the company’s compliance manager. She had concluded that although Bankers’ Almanac had indeed been sold to blacklisted entities, all the deals had since been cancelled and she did not believe any US sanctions had been breached. No mention was made of the allegations that the company had trampled over EU sanctions applicable in the UK, although she conceded that: “There is a need to ensure that better training is available for staff on the Accuity sanctions policy." Still, the upshot was: “There is no requirement on the business to report to any regulator.”
At that point, the salesman recalled, he felt he had no option but to blow the whistle to the authorities and walk away from his job. On 31 January 2014, he sat down at his computer and typed an email to the financial sanctions department at HM Treasury.
“I currently work at Accuity, part of Reed Business Information and Reed Elsevier, a FTSE 100 company,” he wrote. “I would like to bring to your attention Accuity’s potential breach of EU, UN and HMT sanctions imposed on Iran, Syria, Sudan and North Korea.” The salesman attached a selection of the documents he had gathered, including the list of the sanctioned banks he believed his firm had dealt with.
In the months that followed, the salesman was told that the criminal investigation division at HM Revenue and Customs had passed his evidence to the Serious Fraud Office (SFO) and the National Crime Agency. The SFO came back to request further evidence from him in January this year, and he was told in February by email that City of London police are now reviewing his files and considering whether to launch a criminal investigation.
A spokesperson for RBI said: “We provided the relevant authorities with information about our compliance programme more than a year ago and have had no requests for further information.” It said there was no evidence that it was under formal investigation.
The two whistleblowers took RBI to an employment tribunal last year, arguing they had been unfairly treated after blowing the whistle. The tribunal found that RBI had not mistreated them but did not rule on whether sanctions had been breached. One of them is now in the process of appealing the decision.
The Middle East salesman has settled into a new job at another City firm, but the mountain of information he compiled over months on the frenetic sales floor of RBI still weighs on his mind.
“Look at Syria and what the regime has done to its people,” he said. “Look at the formation of ISIS and the amount of weapons being procured by groups like that in Syria. How are they buying these weapons? Money is always involved, and you have to ask yourself — where has it come from?”
Jane Bradley is an investigations correspondent for BuzzFeed News and is based in London.
Contact Jane Bradley at firstname.lastname@example.org.
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