Santander Holdings USA, Inc.

Disclosure Pursuant to Section 219 of the Iran Threat Reduction and Syria Human Rights Act

Pursuant to Section 219 of the Iran Threat Reduction and Syria Human Rights Act of 2012, which added Section 13(r) to the Exchange Act, an issuer is required to disclose in its annual or quarterly reports, as applicable, whether it or any of its affiliates knowingly engaged in certain activities, transactions or dealings relating to Iran or with individuals or entities designated pursuant to certain Executive Orders. Disclosure is generally required even where the activities, transactions or dealings were conducted in compliance with applicable law.

The following activities are disclosed in response to Section 13(r) with respect to Santander and its affiliates. During the period covered by this report:

•Frozen accounts and transactions: A limited number of accounts for customers subsequently designated over time by the U.S. under the SDGT sanctions programme, were or are maintained with certain non-U.S. affiliates of Santander. All accounts have been frozen or cancelled to comply with applicable legal requirements.

•Legacy contractual obligations related to guarantees: Santander also has certain legacy performance guarantees for the benefit of an Iranian bank that is currently designated by the U.S. under the SDGT sanctions programme (stand-by letters of credit to guarantee the obligations - either under tender documents or under contractual agreements - of contractors who participated in public bids in Iran) that were in place prior to April 27, 2007. Santander is not contractually permitted to cancel these arrangements without paying the guaranteed amount. As such, Santander intends to continue to provide the guarantees in accordance with company policy and applicable laws.

In the aggregate, all the transactions described above resulted in gross revenues and net profits in the year ended December 31, 2025 which were negligible relative to the overall revenues and profits of Santander. Santander has undertaken significant steps to withdraw from the Iranian market such as closing its representative office in Iran and ceasing all banking activities therein, including correspondent relationships, deposit-taking from Iranian entities and issuing export letters of credit, except for the legacy transactions described above.