UK

Pearson PLC

Industry
Media
Symbol
NYSE: PSO
Country
UK
Sources

According to its Annual Report filed with the SEC for fiscal year 2014: "The US Iran Threat Reduction and Syria Human Rights Act of 2012 requires US-listed companies to disclose information relating to certain transactions with Iran, even when such transactions were in accordance with applicable laws. In 2014, certain non-US Group companies in compliance with applicable law provided subscriptions to the Financial Times newspaper to Iranian individuals, a subscription to an FT Group publication to an Iranian bank and accepted advertising in an FT Group publication from several Iranian banks. The gross revenues to the Group from these activities were approximately £54,000, and we estimate the net profit was approximately £6,000. In 2014, certain non-US Group companies in compliance with applicable law incurred approximately £65,000 of cost in relation to journalistic activities and the establishment of a news bureau. The Group may undertake similar activities in future periods in accordance with applicable law."

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According to its Annual Report filed with the SEC for fiscal year 2012: "The US Iran Threat Reduction and Syria Human Rights Act of 2012 requires US-listed companies to disclose information relating to certain transactions with Iran, even when such transactions were in accordance with applicable laws. In 2012, certain non-US Group companies in compliance with applicable law provided a subscription to the Financial Times to an Iranian individual, accepted advertising in an FT Group publication from several Iranian banks, and sold English language Penguin Group imprint books to Iranian wholesalers and retailers. The gross revenues to the Group from these activities were approximately £75,500, and we estimate the net profit was approximately £8,000. In addition, a non-US Group company in compliance with applicable law issued credits in the amount of £53,000 in respect of returns of educational materials from prior years. The Group may undertake similar activities in future periods in accordance with applicable law."

ITS Tubular Services

Industry
Energy
Country
UK
Sources

According to an Annual Report filed with the SEC in 2012: "In 2012, ITS  through its indirect non-U.S. subsidiaries International Tubulars FZE and International Tubular Services Kish Company may have engaged in transactions or dealings with an entity or entities owned or controlled, directly or indirectly, by the Government of Iran by providing equipment and related services pursuant to contracts in Iran.  Fund V is not aware of gross revenues and net profits, if any, attributable to that activity.  Fund V has been informed by ITS that ITS’ subsidiaries have stopped supplying equipment and related services into Iran and are winding down all operations related to Iran."

LivaNova PLC

Industry
Medical*
Country
UK
Sources

According to its Annual Report filed with the SEC for fiscal year 2019: "Two of our non-U.S. subsidiaries currently sell medical devices, including cardiac surgery and cardiopulmonary products, to privately held distributors in Iran.
We have limited visibility into the identity of these distributors’ customers in Iran. It is possible that their customers include entities, such as government-owned hospitals or sub-distributors, that are owned or controlled directly or indirectly by the Iranian government. To the best of our knowledge at this time, we do not have any contracts or commercial arrangements with the Iranian government.
Our gross revenues and net profits attributable to the above-mentioned Iranian activities were $1.6 million and $0.5 million for the three months ended December 31, 2019, respectively, and $10.3 million and $3.6 million for the twelve months ended December 31, 2019, respectively.
We believe our activities are consistent with applicable law, including U.S., EU, and other applicable sanctions laws, though such laws are complex and continue to evolve rapidly. We intend to continue our business in Iran."

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According to its Annual Report filed with the SEC for fiscal year 2018: "LivaNova has sold medical devices to Iran since we were formed in 2015. Two of our non-U.S. subsidiaries currently sell medical devices, including cardiac surgery and cardiopulmonary products, to privately held distributors in Iran.
We have limited visibility into the identity of these distributors’ customers in Iran. It is possible that their customers include entities, such as government-owned hospitals or sub-distributors, that are owned or controlled directly or indirectly by the Iranian government. To the best of our knowledge at this time, we do not have any contracts or commercial arrangements with the Iranian government.
For the year ended December 31, 2018, our gross revenues and net profits attributable to the above-mentioned Iranian activities were $10.3 million and $3.7 million, respectively.
We believe our activities are consistent with applicable law, including U.S., EU, and other applicable sanctions laws, though such laws are complex and continue to evolve rapidly. We intend to continue our business in Iran."

Delphi

Industry
Automotive
Country
UK
Sources

According to its Annual Report filed with the SEC for fiscal year 2012: "Prior to the enactment of ITRSHRA, we had a longstanding policy of reviewing and determining that any matter relating to possible transactions involving Iran did not violate applicable U.S. export controls and sanctions laws, and we do not believe that we have conducted any transactions that violated applicable laws. During 2012, certain of our non-U.S. affiliates engaged in transactions involving Iran in accordance with applicable law. Our non-U.S. affiliates have ceased transactions involving Iran as of October 9, 2012, as required by ITRSHRA.

Prior to October 9, 2012, some of our non-U.S. affiliates sold items out of general inventory to non-U.S. distributors outside of Iran, who sold those items to retail or automotive assembly, service, or repair establishments in Iran. The sales made to these non-U.S. distributors of items that were subsequently resold into Iran totaled approximately $3.7 million and generated operating income of approximately $0.7 million. In 2012, our non-U.S. affiliates received payments of approximately $2.7 million related to these sales. The items were all non-U.S. origin automotive components which, if exported from the United States, would not have required a U.S. export license (except for direct export to Iran and certain other very limited destinations or entities).

Our non-U.S. affiliates received payments from the distributors through banks outside of Iran. However, some of those transactions may have involved transfers of funds to the distributors through Iranian Government-owned banks, and we are not certain of the exact path of such transfers, and whether those transactions are therefore required to be disclosed under Section 13(r)(1)(D)(iii) or otherwise of the Securities Exchange Act of 1934. The transactions disclosed herein were not prohibited under any U.S. export controls and sanctions laws at the time the transactions were undertaken because they were not conducted by U.S. persons or entities, did not involve ten percent (10%) or more U.S.-origin content, and were not otherwise prohibited."

Travelport

Industry
Transportation
Country
UK
Sources

According to its Quarterly Report filed with the SEC in 2019: "As part of our global business in the travel industry, we provide certain passenger travel related Travel Commerce Platform and Technology Services to Iran Air. We also provide certain Technology Services to Iran Air Tours. All of these services are either exempt from applicable sanctions prohibitions pursuant to a statutory exemption permitting transactions ordinarily incident to travel or, to the extent not otherwise exempt, specifically licensed by the U.S. Office of Foreign Assets Control. Subject to any changes in the exempt/licensed status of such activities, we intend to continue these business activities, which are directly related to and promote the arrangement of travel for individuals".

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According to SEC disclosures filed by Travelport's affiliate La Qinta Holdings Inc, in 2014, 2015, 2016 and 2017: "As part of our global business in the travel industry, we --provide certain passenger travel related Travel Commerce Platform and Technology Services to Iran Air. We also provide certain Technology Services to Iran Air Tours. All of these services are either exempt from applicable sanctions prohibitions pursuant to a statutory exemption permitting transactions ordinarily incident to travel or, to the extent not otherwise exempt, specifically licensed by the U.S. Office of Foreign Assets Control. Subject to any changes in the exempt/licensed status of such activities, we intend to continue these business activities, which are directly related to and promote the arrangement of travel for individuals.

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According an SEC disclosure filed by Travelport affiliate Apria Healthcare Group, in 2013: "As part of our global business in the travel industry, we provide certain passenger travel related GDS and Airline IT Solutions services to Iran Air. We also provide certain Airline IT Solutions services to Iran Air Tours. All of these services are either exempt from applicable sanctions prohibitions pursuant to a statutory exemption in the International Emergency Economic Powers Act permitting transactions ordinarily incident to travel or, to the extent not otherwise exempt, specifically licensed by the U.S. Office of Foreign Assets Control (“OFAC”). Subject to any changes in the exempt/licensed status of such activities, we intend to continue these business activities, which are directly related to and promote the arrangement of travel for individuals.

The gross revenue and net profit attributable to these activities in the quarter ended September 30, 2013 were approximately $164,000 and $122,000, respectively.”

Clarivate Analytics Plc

Industry
Information Services
Country
UK
Sources

According to its Annual Report filed with the SEC for fiscal year 2019: "During the reporting period, the Company sold access to information and informational materials, which are generally exempt from U.S. economic sanctions, to 3 entities that are part of, or may be owned or controlled by, the Government of Iran.  We were advised by counsel that these transactions were permissible under U.S. sanctions pursuant to certain statutory and regulatory exemptions for the exportation of information and informational materials.  The Company terminated this activity in October 2019 and does not intend to resume it."

Metro Bank

Industry
Banking
Country
UK
Sources

"Embattled lender Metro Bank has been hit with a fresh lawsuit by a group of Iranian customers who say their accounts were unfairly suspended without notice or explanation. The group of 17 claimants, who are expected to seek at least £1.5m in damages, include dual British-Iranian citizens, Iranian citizens living in the UK and several UK-based businesses including an engineering firm and a consultancy. Law firm Ronald Fletcher Baker said its clients were blocked from accessing their accounts and cash between May and September 2019 without notice and without explanation. It first contacted Metro about the issue in July and served the bank with legal papers last week." (The Guardian, "Metro Bank hit with fresh lawsuit by Iranian customers," 3/17/2020). 

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"METRO Bank is undergoing a major review of its compliance controls after handling money from Cuba and Iran in breach of strict US and EU sanctions.

The review is being handled by a top level team of investigators at law firm DLA Piper, which was hired after the Iranian funds were received by the bank last year. 

Metro notified US officials of the Cuba offence in November 2017.

It is the latest in a series of problems for the bank which spent much of last year reeling from the impact of a major error in the way it accounted for its property loans." (Evening Standard, "Metro Bank in probe over Iran and Cuba sanctions breaches," 2/4/2020).