Ireland

Jazz Pharmaceuticals PLC

Industry
Pharmaceuticals
Country
Ireland
Sources

According to its Annual Report filed with the SEC for fiscal year 2012: "In June 12, 2012, we completed the EUSA Acquisition. Prior to the completion of the EUSA Acquisition, a French subsidiary of EUSA Pharma entered into a contract to sell Kidrolase (Escherichia coli L-asparaginase), a life-saving cancer drug produced outside of the United States, to Medical Equipment and Pharmaceutical Holding Co., or MEPH, which we understand is an affiliate of the Iranian Ministry of Health. Following the completion of the EUSA Acquisition, the French subsidiary of EUSA Pharma shipped Kidrolase to MEPH pursuant to the pre-existing contract. The Kidrolase contract was entered into prior to our acquisition of EUSA Pharma, was performed entirely by the French subsidiary, and we believe that the post-acquisition shipment of Kidrolase was not prohibited by or sanctionable under applicable law at the time. Our anticipated gross revenue from this shipment of Kidrolase was approximately 92,000 Euros. The French subsidiary of EUSA Pharma, which is now our wholly-owned subsidiary, has sought payment from MEPH for this shipment. To date, no such payment has been received. No additional sales or shipments of Kidrolase to MEPH were made following the June 2012 shipment.
Our mission is to improve patients’ lives by identifying, developing and commercializing products that address unmet medical needs. As part of fulfilling our mission, we intend to provide access to important and life-saving pharmaceutical products to patients wherever they may be located, including in Iran, to the extent permitted by applicable U.S. and non-U.S. laws and regulations. For that reason, we expect that we may make future sales of Kidrolase to MEPH in accordance with applicable law."

Bank of Ireland

Industry
Banking
Country
Ireland
Sources

According to its Annual Report filed with the SEC for fiscal year 2014: "On 5 November 2014, the Group terminated its customer relationship with the Embassy of Iran in Ireland and related Embassy personnel; and closed all related accounts on that day also. These accounts were used for local expenses and were operated in accordance with applicable local law and authorisations. For the period covered by this report, the Group had €386 (three hundred and eighty six euro) in gross revenues for all Iranian bank-related activity described in this section, which includes fees and / or commissions. The Group does not allocate direct costs to fees and commissions and therefore has not disclosed a separate profits measure."

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According to its Annual Report filed with the SEC in 2013: "The Group holds certain accounts for the Embassy of Iran in Ireland, and certain Embassy personnel, and process payments into and out of those accounts related to official Embassy business, scholarship payments to Iranian students in Ireland and the personal expenses of Embassy personnel. These accounts are used for local expenses and are operated in accordance with applicable local law and authorisations. For the period covered by this report, the Group had €1,021 in gross revenues for all Iranian bank-related activity described in this section, which includes fees and/or commissions. The Group does not allocate direct costs to fees and commissions and therefore has not disclosed a separate profits measure. The Group intends to maintain these accounts, in accordance with applicable local law and authorisations."

Aercap

Industry
Aviation
Country
Ireland
Sources

"Aercap Holdings NV, the world’s biggest aircraft lessor, said it’s cooperating with a U.S. investigation into the supply of Airbus Group NV jetliners to Iran and that it previously sold some of the nine planes concerned. The aircraft were purchased by Tehran-based Mahan Air from Al-Naser Airlines of Iraq, which appears to have sourced two of them from Aercap, the lessor said in a filing, adding that it is assisting in the U.S. Office of Foreign Asset Control-led probe." (2015)

Avolon

Industry
Aircraft
Symbol
NASDAQ: AVDL
Country
Ireland
Sources

"Among the Irish leasing companies linked to possible Iranian deals has been Avalon, which is owned by China's Bohai Leasing. The Irish Times reported on February 11 that Avalon's chief commercial officer John Higgins had spoken about a recent trip to Iran when addressing an event held by the Ireland China Business Association a day earlier." (Forbes, "Iran Reaches Lease Financing Deal for 77 Boeing, Airbus Planes," 2/17/2017).

Irish Aviation Authority (IAA)

Industry
Aviation
Country
Ireland
Sources

"Irish leasing companies appear to be in a strong position to get involved in any contracts being negotiated. Ireland is one of the world's leading locations for aircraft leasing companies and, on February 11, the Civil Aviation Organization of Iran (CAOI) signed a cooperation agreement with the Irish Aviation Authority (IAA), covering aircraft leasing, flight supervision and maintenance and repair among other areas... Iran Aseman Airlines is set to be one of the first to take advantage of that agreement. It is planning to lease seven Airbus A320neo aircraft and "the terms of this contract [with the IAA] will apply as soon as these aircrafts land in Iran after being registered in Ireland," according to the CAOI." (Forbes, "Iran Reaches Lease Financing Deal for 77 Boeing, Airbus Planes," 2/17/2017).

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"Iran and Ireland signed a memorandum of understanding (MoU) early on Wednesday morning, Iran’s Civil Aviation Organization (CAO.IRI) announced. The agreement, signed by CAO.IRI’s Mohammad Javad Taghvaei and the Irish Aviation Authority’s Ralph James is reportedly the first ever aviation agreement between the two countries." (February 8, 2017)
 

AdaptiveMobile

Industry
Software
States
TX
Country
Ireland
Sources

In 2016 AdaptiveMobile reconfirmed its position to UANI.

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"AdaptiveMobile Security Ltd. ended its contracts with an Iranian phone company following the disclosure that the closely held firm supplied and serviced technology for monitoring and storing text messages. AdaptiveMobile, based in Dublin, stopped doing business with MTN Irancell, Iran's second-largest mobile provider, as of May 24, according to United Against Nuclear Iran, a New York- based advocacy organization that pressures companies to cut business ties to Iran. The group cited an e-mail from AdaptiveMobile. Iranian authorities use surveillance technologies to round up and interrogate political activists, according to accounts provided by victims and human rights groups. AdaptiveMobile sold technology for monitoring and storing text messages to Irancell in 2008, Bloomberg News reported last October. The company was still servicing the commercial gear. Police have access to the system, two former MTN Irancell managers said. 'We applaud AdaptiveMobile for ending its business in Iran,' said Kristen Silverberg, president of United Against Nuclear Iran, in a statement. 'AdaptiveMobile has made the responsible decision, and we encourage other telecommunications companies to follow suit.'" (Bloomberg, "AdaptiveMobile Drops Iran Contracts On Gear For Text Monitoring," 6/7/12)

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"Stockholm-based Ericsson AB, Creativity Software Ltd. of the U.K. and Dublin-based AdaptiveMobile Security Ltd. marketed or provided gear over the past two years that Iran's law enforcement or state security agencies would have access to, according to more than 100 documents and interviews with more than two dozen technicians and managers who worked on the systems... AdaptiveMobile, backed by the investment arm of Intel Corp. (INTC), proposed a system in partnership with Ericsson for Iran’s largest mobile provider in 2010 that would filter, block and store cell phone text messages, according to two people familiar with the discussions. An Ericsson spokesman confirmed the proposal... AdaptiveMobile says its technologies are for fighting spam, viruses and 'inappropriate content,' not designed or sold for law enforcement. It says it plans to cease doing business in Iran when its contract is up in late 2012, because continuing in Iran’s current political climate could damage its reputation... Ericsson, which bid on the system, was told by MCI, the country’s largest wireless operator, to partner with AdaptiveMobile for monitoring and filtering technology, according to Ericsson spokesman Fredrik Hallstan. Ericsson didn’t win the contract, he says... The 3.9 million-euro ($5.5 million) system AdaptiveMobile proposed could handle more than 10,000 messages per second and archive them for a period of 180 days, according to a company proposal. The archive would contain 54 terabytes of storage, according to the document. That’s big enough for all the data gathered by the Hubble Space Telescope over 20 years... In 2008, AdaptiveMobile sold Irancell technology to filter, block and store text messages. Text message monitoring was required by security forces, who use the technology for their own purposes, according to two former Irancell managers... An Adaptive document detailed the system requirements. It would analyze all messages in English, Persian or Arabic for keywords or phrases; store them; and flag those caught by filters for review... Two former Adaptive employees say there were discussions within the company about law enforcement requests as the project came together... While Adaptive’s executives confirm the Irancell deal and an upgrade to the system to handle more messages, they say it was intended only for commercial purposes. They deny any involvement with Iran security or police... 'We are sure our product is not being used in this way,' says AdaptiveMobile CEO Brian Collins... Asked if AdaptiveMobile’s systems could scour for political content on activists, Chief Operating Officer Gareth Maclachlan said, 'Technically, yes, it is possible.' He says he doubted they would be practical for that purpose... As recently as 2010, AdaptiveMobile attempted to sell a similar product to MCI, the one on which it partnered with Ericsson. Collins and Maclachlan say they were not familiar with details of the proposal... Intel Capital, the investment arm of the world’s largest chipmaker, has invested 6 million euros in AdaptiveMobile, which was founded in 2003. Kristof Sehmke, an Intel Capital spokesman, said in a statement that his company strives to comply with all legal requirements... According to data compiled by Bloomberg, Ericsson signed at least 27 contracts worth $5.25 million with the U.S. government from the start of 2009 to the end of 2010. The data showed no U.S. government business with AdaptiveMobile or Creativity Software." (Bloomberg, "Iranian Police Seizing Dissidents Get Aid of Western Companies" 10/30/2011)

Response

“AdaptiveMobile’s position concerning business activities in Iran remains unchanged from our last communication to UANI on June 7, 2012, when we confirmed that the Company no longer has any business in the Country. It is not our intention to pursue new opportunities in the Country.” (August 18, 2016)

Medtronic PLC

Industry
Medical*
Symbol
NYSE:MDT
Country
Ireland
Sources

According to its Annual Report filed with the SEC in 2015: "As part of its ongoing compliance program, the Company identified certain sales of medical devices made during fiscal year 2015 by one of its non-U.S. affiliated entities to parties in Iran that were not covered by a general license issued by the U.S. Treasury Department's Office of Foreign Assets Controls ("OFAC"). Those sales, which were generally conducted through distributors, whose customers include public hospitals which may be owned or controlled directly or indirectly by the Iranian government, resulted in approximately $4 million in gross revenues and approximately $3 million in net profits (excluding selling, general, and administrative expenses and allocations) in fiscal year 2015. At the time of these sales, the Company believed, based on correspondence received from OFAC in response to a request to renew the specific licenses the Company had to cover these sales, that the sales were eligible for an OFAC general license. The Company subsequently obtained the specific licenses required for these continued sales. The Company has also submitted an initial notification of voluntary self-disclosure regarding this matter to OFAC."

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According to its Annual Report filed with the SEC in 2013: "As of October 9, 2012, all of Medtronic's business dealings with Iran (including business conducted by non-U.S. affiliates) have been conducted pursuant to general or specific licenses issued by the U.S. Treasury Department's Office of Foreign Assets Controls (OFAC). Medtronic and its affiliates plan to continue their existing activities and operations with Iran in accordance with such general or specific licenses.

In October 2012, the U.S. sanctions against Iran were extended to entities owned or controlled by U.S. persons. Prior to such time, it was permissible under U.S. law for independent non-U.S. subsidiaries of U.S. companies to engage in sales to Iranian customers under certain limited circumstances without the need for OFAC authorization. In accordance with these requirements, and without the involvement of U.S. persons, certain of Medtronic's non‑U.S. subsidiaries engaged in lawful sales to Iran during the first two quarters of fiscal year 2013 from its CRDM, Coronary, Structural Heart, Endovascular, Spine, Neuromodulation, Diabetes, and Surgical Technologies businesses. Other sales to or for Iranian customers during the first two quarters of fiscal year 2013 wereundertaken pursuant to specific licenses issued by OFAC. The Iranian sales were generally conducted through distributors, some of whose customers included public hospitals which may be owned or controlled directly or indirectly by the Iranian government. Certain of these sales were also made to a non-governmental entity which sells to the Iranian Ministry of Health. All activities by the Company and its non-U.S. subsidiaries with entities in Iran, including certain governmental entities, in the first two quarters of fiscal year 2013 resulted in approximately $25 million in gross revenue and approximately $16 million in net profits (excluding selling, general, and administrative expenses and allocations)."

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Over the last three presidential administrations, the United States government has granted Medtronic Inc. 28 special licenses to do business in Iran. (New York Times, "Companies with Permission to Bypass Sanctions," 12/24/10)

Ingersoll Rand

Industry
Construction, Industrial Services, Manufacturing
Value of USG Contracts
422
Value of USG Contract Source
http://www.nytimes.com/interactive/2010/03/06/world/iran-sanctions.html
Symbol
NYSE:IR
States
NC
Country
Ireland
Contact Information


Sources

The Iranian firm, Raya Tosee Tajhiz Paya (“Raya Tosee”), claims to be an authorized agent of Ingersoll Rand in Iran.  (Raya Tosee Website, “Home.”). 

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Ingersoll-rand is listed as a participating company at the 14th International Exhibition of Transportation & Urban Services & Related Industries which takes place October 27-30th, 2016 in Tehran Iran. (Participating International Companies)  

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"New Jersey-based Ingersoll Rand, which has won lucrative contracts from the U.S. military, has been selling industrial air condition and air compression systems to Iran through foreign subsidiaries since at least 2000, according to the company. The National Iranian Drilling Company states on its Web site that it uses Ingersoll Rand compressors in its work. Spokesman Paul Dickard said that compressed air systems have a wide variety of applications,  and "it wouldn't be outside the range of possibility" that Ingersoll Rand systems would be used in the oil and gas sectors or even a nuclear plant, where such equipment is commonly found. Mr. Dickard said the company is evaluating what he called its "minor" business in Iran in light of the current political climate, adding: "We will want to think very seriously about whether we want to continue participating in Iran if it puts at risk other business that might be more lucrative for us."  From 2000-2009, the company was the recipient of $422.1 million US federal funds.  They have withdrawn their investments in Iran.  (The New York Times, "Profiting from Iran, and the US," 3/6/2010)

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“Havacaran Industrial Technologies is the distributor of Ingersoll Rand Air Compressors in Iran” (Havacaran website). On its website, Havacaran has posted a certificate from Ingersoll Rand, which formally certifies that it is a distributor "for performing sales & after sales service for Centrifugal (CENTAC), Oil Free Dry Rotary Screw (SIERRA), Oil Injected Rotary Screw (SSR) and Reciprocating (T-30, ESH, PHE) Air Compressors and down stream accessories like air dry & filters" (Havacaran Website, "Certificate"). Ingersoll-Rand, in consortium with Havacaran, participated in Iran’s 12th international oil show in 2007 (Iran's 12th Oil Show, "Exhibitors List").

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The National Iranian Drilling Company (NIDC), a subsidiary of the state-owned National Iranian Oil Company (NIOC), states on its website that the company uses Ingersoll Rand compression systems (NIDC website).

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SATCO (Sameh Afzar Tajak Co.) is a private commercial company in Iran "working in the operation, maintenance, procurement and planning of power stations, automotive industries, steel industries and oil fields" (SATCO website, "About Us"). Ingersoll Rand is one of seven "Principals" affiliated with SATCO, selling assembly and industrial tools as well as material handling products (SATCO website, "Principals"). SATCO has sold products to several oil, gas and petrochemical companies, such as the state-owned National Iranian Drilling Company, as well as numerous light and heavy industries, power stations, the steel industry and automotive industry (SATCO website, "Sales").

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Ingersoll Rand, in consortium with SATCO, participated in Iran’s 12th international oil show in 2007 (Iran's 12th Oil Show, "Exhibitor List"). SATCO was also an exhibitor at Iran's13th annual oil show in 2008 (Iran's 13th Oil Show, "Exhibitors").

Ingersoll Rand's Distributor Certificate to Havacaran
Ingersoll Rand's Distributor Certificate to Havacaran (Havacaran Website, "Certificate")

Response

Response: "Since the date of my 2010 letter, I can assure you that Ingersoll Rand has not sought to revisit our Iran policy…" (November 2016)

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At the urging of UANI supporters, Ingersoll Rand has stated that it will prohibit all further sales into Iran.