SEC Comment Letter for Banco Santander, S.A. (SAN, BCDRF) (CIK 0000891478) (SAN) — Dec 20, 2006
Banco Santander, S.A. (SAN, BCDRF) (CIK 0000891478)
Date: Dec. 20, 2006 · CIK: 0000891478 · Accession: 0000000000-06-062126
AI Filing Summary & Sentiment
Referenced dates: August 30, 2006, December 1, 2006, December 1, 2006, November 16, 2006, September 25, 2006
Show Raw Text
<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>
December 20, 2006
Via U.S. Mail and Facsimile
Alfredo Saenz
Chief Financial Officer
Banco Santander Central Hispano, S.A.
Ciudad Grupo Santander
28660 Boadilla del Monte
Madrid, Spain
RE: Banco Santander Central Hispano, S.A.
Form 20-F for the fiscal year ended December 31, 2005
Response letter dated September 25, 2006
Response letter dated December 1, 2006
File No. 1-12518
Dear Mr. Saenz:
We have reviewed your response letter dated December 1,
2006,
and have the following comments. Please be as detailed as
necessary
in your response. After reviewing this information, we may raise
additional comments. We welcome any questions you may have about
our
comments or on any other aspect of our review. Feel free to call
us
at the telephone numbers listed at the end of this letter.
General -
1. We note your response to comment 1 of our letter dated November
16, 2006. It appears to the staff that it would be appropriate
for
future filings to include disclosure regarding your Iran-related
operations, including the fact that you maintain a correspondent
relationship with Bank Saderat and the fact that the U.S. has
identified Bank Saderat as facilitating Iran`s transfer of funds
to
terrorist organizations.
Please advise us whether your dealings with Bank Saderat are
limited
to your correspondent relationship, and describe for us the nature
and extent of any additional dealings with Bank Saderat. Any
disclosure in future filings regarding your dealings with Bank
Saderat should make clear the nature and extent of your dealings
with
the bank.
Please provide us with the text of the disclosure you propose to
include in response to this comment prior to including it in a
filed
document.
2. We note the reference in your response to comment 1 to
"customers
who are nationals or residents in countries considered of high-
risk
in terms of money laundering or financing of terrorism." Please
identify for us the countries to which you refer. To the extent
that
you have contacts with additional countries identified by the U.S.
as
state sponsors of terrorism, provide the same type of information
and
analysis regarding your contacts with those countries as we
requested
regarding your contacts with Iran in our letter dated August 30,
2006.
3. We note your response to comment 2 of our letter dated November
16, 2006. If you participate in transactions that result,
directly
or indirectly, in the payment of cash to the Iranian government,
please address specifically the applicability of amended Section
5(b)
of ISA to your participation in such transactions.
Please respond to this comment within 10 business days or
tell
us when you will provide us with a response. Please file your
response letter on EDGAR.
Please understand that we may have additional comments after
we
review your response to our comment. Please contact Jack
Guggenheim
at (202) 551-3523 if you have any questions about the comment or
our
review. You may also contact me at (202) 551-3470.
Sincerely,
Cecilia D. Blye, Chief
Office of Global Security
Risk
cc: Todd Schiffman
Donald Walker
Division of Corporation Finance
Nicholas Kronfeld
Davis Polk & Wardwell
Alfredo Saenz
Banco Santander Central Hispano, S.A.
December 20, 2006
Page 1
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-5546
DIVISION OF
CORPORATION FINANCE
</TEXT>
</DOCUMENT>