Department of Defense

Hyundai Engineering and Construction is listed on the March 1, 2022 Report to the New Jersey Legislature Iran Divestment as a prohibited company.

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On February 16, 2021, Iowa Public Employees' Retirement System removed Hyundai E&C from its Iran Prohibited Companies List. 

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As of December 2020, Rhode Island continues to list Hyundai E&C as an Iran scrutinized company for active involvement of at least $50 million in Iran's energy sector.

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As of July 2020, Hyundai E&C remains on the Pennsylvania Treasury's List of Scrutinized Companies Determined as Having Involvement In Iran because of oil-related investment of US $20 million since 1996. 

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Hyundai E&C is listed on the 4Q 2020 Minnesota State Board of Investment List of Unauthorized (Scrutinized) Iran Companies.

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On May 15, 2020, the IPERS identified Hyundai E&C on its Iran Prohibited Companies List.

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On January 20, 2020, Minnesota SBI listed Hyundai E&C as a scrutinized investment. The managers are explicitly instructed to refrain from purchasing securities on this list.

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As of October 2019, Hyundai Engineering & Construction remains on the Pennsylvania Treasury's List of Scrutinized Companies Determined as Having Involvement In Iran because of oil-related investment of US $20 million since 1996. 

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As of August 15, 2019, the state of Iowa listed Hyundai Engineering & Construction on its Iran scrutinized companies list.

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"South Korea’s Hyundai Engineering & Construction said on Monday that it scrapped a 595 billion won ($521 million) deal to build a petrochemicals complex in Iran, saying the Iranian customer’s ability to fund it had been hit by the prospect of U.S. economic sanctions against Tehran." (Reuters, 10/29/2018)

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In 2018 the U.S. state of Iowa listed Hyundai Engineering & Construction on its Iran prohibited companies list rendering Hyundai Engineering & Construction ineligible for investment and/or state contracting.

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In 2017 the U.S. state of Pennsylvania, Rhode Island and South Carolina listed Hyundai Engineering & Construction Co., on its Iran scrutinized list for an oil related involvement of at least US $20 million since 1996, rendering Hyundai Engineering & Construction ineligible for investment and/or state contracting.

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In 2016, Hyundai Engineering & Construction was added to the Pennsylvania Treasury's List of Scrutinized Companies Determined as Having Involvement in Iran because of oil-related investment of US $20 million since 1996 and new involvement was identified.

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“Korean construction firms are paying attention to Iran, the fourth largest client in the global construction market. Responding to the lifting of sanctions against Iran, they are taking swift actions, such as strengthening market survey and preparing to enter the market…Korean construction firms are taking actions behind the curtains while watching international political situations. Hyundai E&C and Daelim, two major constructors in Korea, have operated a local office in Tehran where Korean and Iranian employees work together in order to re-enter the Iranian market at some point. An official from a large construction firm said, ‘Since gaining trust from a client is very important in the Middle East, Korean construction firms have maintained relationships (with Iranian clients) even after sanctions.’ Kwon Myeong-gwang, an ICAK manager in charge of Iran and Kuwait markets, said, ‘Iran is a big market, and projects that couldn’t be embarked on due to economic sanctions may come to the market all at once,’ adding, ‘Construction of oil and gas facilities is promising.’” (The Dong-A Ilbo, “Will thawing sanctions against Iran boost construction business?” 2/2/14)

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“Construction shares are showing strength on the news of the Iranian government reaching an agreement with six world powers to curb its nuclear activities in return for about $7 billion in sanctions relief, after days of intense talks in Geneva. At 9:18 am on November 25, the shares of Daelim Industrial were traded at 98,000 won, up 4.59 percent from the previous day's 93,700 won. Other construction shares such as Byucksan Engineering & Construction (14.92%), Namkwang Engineering & Construction (12.27%), Daewoo Engineering & Construction (3.23%), Sungjee Co. (3.13%), and Hyundai Engineering & Construction (1.47%) also increased by a large clip. The KOSPI construction industry index rose 2.99 percent, the highest among all other industrial sectors.” (The Korean Economic Daily, “Construction Shares Rise on the Back of Iran Nuclear Deal,” 11/26/13)

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“Hyundai Engineering & Construction (Hyundai E&C), the nation’s largest construction firm, has successfully diversified its business portfolio to maintain steady growth in the ever-uncertain global market. Hyundai traditionally focused on civil engineering, but has added power plants and electricity supply networks in recent years. Its diversified business areas ensure that they will complement each other, said the company…Hyundai’s big break in plant making came in 2005, when it completed a gas processor near the South Pars Gas Field in Iran. Worth $1.6 billion, and utilizing 18,300 workers daily, the construction giant finished the project in 35 months, a record for a project that size, according to the company. ‘We became the contractor that many sought for gas processors after the success of the project,’ said the Hyundai spokesman.” (Korea Times, “Hyundai E&C diversifies portfolio,” 4/25/13)

According to the Tuvpr website, Tuvpr is the exclusive representative for AVL in Iran.

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“Iran’s TUVPR and Austria’s automotive consulting firm AVL have signed a deal worth 110 million euros for the production of low-consumption Euro 6 engines, ….  The agreement was signed by a consortium of four Iranian and foreign companies on the sidelines of an Iran-EU trade and investment conference which opened in Vienna on Thursday, TUVPR Managing Director Seyyed Mojtaba Mirsoheil said.” (Press TV, “Iran, Austria firms sign auto engine deal,” 7/23/2015).

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AVL has two U.S. subsidiaries,  AVL North America, Inc. and AVL Powertrain Engineering, Inc. AVL North America has received over $12 million in U.S. government contracts, and AVL Powertrain Engineering has received over $6 million in U.S. government contracts.

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“The research department of Iran's Oil Ministry has signed a deal with Austrian AVL to develop energy saving projects in the Iranian oil industry, IRNA quoted the research department's head, Amir Abbas Hosseini as saying on March 1. The main part of the research department's activities is related to the export of technical and engineering services in the oil industry's upstream sector, he added. Iran is currently providing Iraq and Sudan with educational and operational services, IRNA quoted director of the Iranian Oil Research Center Hamidreza Katouzian as saying on January 3. A number of Iraqi oil engineers have passed educational courses in Iran in cooperation with the Iranian Oil Research Center, he said. Most of the services to Iraq and Sudan are related to the upstream sector of the oil industry, he noted. Iran will also export oil industry technology to Indonesia for revival of 'dead' oil wells, he further said.” (Trend, “Iran signs deal with Austrian firm for energy saving project,” 3/1/14)

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“Multiple companies currently exploring new business ventures in Iran are also cashing in on highly lucrative contracts with the U.S. Defense Department, raising questions about whether their dealings with Iran could run afoul of U.S. law. At least 13 major international companies have said in recent weeks that they aim to reenter the Iranian marketplace over the next several months. The companies have received Pentagon contracts totaling well over $107 billion, according to a Washington Free Beacon analysis that tracked DoD contracts awarded since fiscal year 2009. Many of the companies, which include carmaker Renault and oil giants such as BP, have already sent high-level trade delegations to Tehran to meet with Iranian officials about striking new business deals…These companies include Boeing and General Electric—which have DoD contracts worth $87 and $12 billion respectively—as well as the Italian oil company Eni, Merck, Safran, Vitol, Bosch Rexroth, Sanofi Pastuer, and AVL.” (Washington Free Beacon, “Pentagon Contractors Exploring Business with Iran,” 2/25/14)

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“A delegation of about 10 Austrian companies hoping to win post-sanctions business in Iran following its nuclear deal with world powers will visit Tehran this weekend, the Austrian Chamber of Commerce said…A spokesman for the Austrian Chamber of Commerce said its vice president would go with representatives of the 10 companies on the trip to Tehran, which has had good relations for decades with neutral Austria. The chamber did not want to name the firms but Austrian newspaper Die Presse said that rail technology firms Plasser & Theurer and AVL, high-rise engineering firm Doka, engineering consultants ILF and cable car maker Doppelmayr were among them…Doppelmayr said it would have regional representatives at the talks organised by an Austrian trade representative in Tehran, and AVL said it was sending a delegate. The other companies named had no immediate comment.” (Reuters, “Austrian trade delegation to visit Iran after nuclear deal,” 12/4/13)

"Iranian electronics manufacturer Entekhab plans to acquire Dongbu Daewoo Electronics by purchasing a 100 percent stake in the smaller Korean consumer electronics firm, local financial sources said Sunday." (January 2018).

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According to Korean and Iranian media sources, Korea Development Bank (“KDB”), as a creditor for Dongbu Steel, is considering “putting off the plan … to sell off the cash-strapped company’s [Dongbu Steel] electric furnace used for hot-rolled steel production [at the Dangjin plant] to an Iranian steelmaker amid concerns that the U.S. could walk out a nuclear deal with the Middle Eastern country.”  (Pulse News, “S. Korea’s creditors may call off Dongbu Steel furnace sale to Iranian steelmaker,” 10/23/2017; Financial Tribune, “S. Korean Firm May Call Off Furnace Sale to Iranian Steelmaker,” 10/26/2017).

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Dongbu Group is a “Global conglomerate corporation which operates through seven business segments with 59 subsidiaries and 40,000 employees.” These segments include steel, chemicals, construction and electronics. Dongbu CNI, a Dongbu Group subsidiary specializing in IT and electronics, lists an office in Tehran. Other Dongbu subsidiaries and major affiliates, including Dongbu Corporation, hold $40 million in contracts with the U.S. government. 

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

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In May 2016, ZF announced that it “is intensifying its business commitments in Iran. To this end, the company has opened up the ZF Pars SSK subsidiary, which will start to combine ZF’s business activities in the region.”  Matthias Benz, Senior Vice President for Corporate Market at ZF, stated “‘[t]he Iranian market offers a great deal of potential.…The new Iranian subsidiary will enable us to concentrate our existing business activities, while also tapping into new business areas and acquiring new customers.’”   Further, “[t]he business activities of this joint venture, which will continue to exist alongside the new ZF Pars SSK subsidiary, will be intensified; the production facility is also scheduled to be modernized and updated.” (ZF Website, “ZF Opens Subsidiary in Iran,” 6/15/2016).   

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In 2008 and 2014, ZF was reported as one of the “renowned German companies [ ] involved in major Iranian infrastructure projects, especially in the petrochemical sector.” (Payvand Iran News, “German-Iranian trade up 7.8 percent,”12/2/2008; Iran Daily, “Iran-Germany trade up 19%,” 7/10/2014).  

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Automotive industry supplier, specializing in engines and parts. Has presence in Iran. (Matthias Kuntzel, "Who is Who in German Trade With Iran") 

"The company was reported as potentially selling pump products in Iran. In 2018 CalPERS designated the company as under review. In 2019 CalPERS changed the designation to “being monitored” because CalPERS’ initial screening has not identified the company as having involvement in the regions and/or activities targeted by the Act. CalPERS has maintained the company in “monitor” status for 2020. CalPERS continues to monitor the company for possible changes in status relevant to the Act."

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In 2015, CalSTRS designated Sulzer AG as “Under Review” for potentially having ties to Iran. In 2016, CalSTRS designated Sulzer AG as “Being Monitored” while conducting further review of the company’s internal controls and compliance programs and maintained that designation in 2017. In 2018, CalSTRS removed Sulzer AG from the “Being Monitored“list after reviewing internal controls and receiving confirmation the company ceased doing business in Iran. In 2019 CalPERS changed the designation to “being monitored” because CalPERS’ initial screening has not identified the company as having involvement in the activities targeted by the Act. CalPERS will continue to assess and/or monitor the company for possible changes in status relevant to the Act.

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Sulzer's Middle East contact is listed as an attendee at the Focus Iran Summit & Exhibition that took place from September 26-27, 2016, in Tehran, Iran. (Participating Companies)

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"The Swiss newspaper Sonntag reported that engineering group Sulzer (SUN.S) had since 2009 conducted much less business there than in previous years, citing a company spokeswoman. Sulzer was not immediately available for comment." (Reuters, "ABB, other Swiss firms halting Iran business," 1/31/10)

As of May 17, 2021, Iowa's Public Employee's Retirement System lists POSCO on its Iran Scrutinized Companies List.

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As of August 15, 2019, the state of Iowa listed POSCO on its Iran scrutinized companies list.

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"The latest development in the tug-of-war between Iran and Saudi Arabia has manifested in the kingdom blocking an investment deal by South Korea in Iran’s steel industry. South Korea’s POSCO Engineering & Construction had signed a $1.6 billion memorandum of agreement with the Iranian steelmaker, Pars Kohan Diar Parsian Steel (PKP), in May 2016, to build a steel mill incorporating POSCO’s proprietary technology in Iran’s Chabahar Free Trade-Industrial Zone." (January 23, 2018).

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POSCO is the parent company of Sungjin Geotec Co., LtdPOSCO, and Daewoo Internationalbsp;POSCO has an extensive American presence through its subsidiaries and joint ventures including POSCO America Corp., United Spiral Pipe LLCUSS-POSCO Industries

POSCO reportedly participating in the Iran Mines & Mining Industries Summit, being held in Tehran May 31-June 1, 2015. (IMIS Website, “List of companies participating in IMIS”)

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"Iranian Mines and Mining Industries Development and Renovation Organization (IMIDRO) welcome cooperation with South Korean POSCO (Pohang Iron and Steel Company) in implementing new steel projects in southern Iran, deputy minister said Saturday... Deputy Industries, Mines and Commerce Minister and head of IMIDRO Mehdi Karbasian made the comment in a meeting with the visiting top manger of POSCO Jin Sik Choi, further elaborating that Iran-Korea cooperation in steel field will be along the southern coasts of Iran, including in Chabahar, Bandar Abbas and Asaluyeh... The top POSCO manager said that his multinational firm is ready to assist Iran in implementing its steep plants using the modern 'Finex' technology. Jin Sik Choi said that POSCO has recently assembled a steel plant with nominal annual production capacity of two million tons and before that a steel factory with annual 1.5 million ton production, both using the Finex technology." (IRNA, "Iran welcomes South Korean cooperation in steel projects," 1/31/15)

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"South Korea's POSCO has announced readiness to invest in Iran's steel projects, the Fars News Agency reported on March 15. A number of officials from POSCO met with officials from Iran's Mobarakeh Steel Company in the Iranian city of Isfahan. Korea's export-import companies are expected to benefit as the Obama administration issued a statement on January 20 that it would temporarily lift sanctions against Iran, according to Businesskorea website. South Korea regained the right to resume the export of automobile parts and steel and import of oil from Iran, which has historically been its major supplier…The steel industry is among the beneficiaries of the ease of sanctions. Sales of steel products totaled $373 million. The market share of steel products is also 24.3 percent, nearly a quarter of the whole market. Particularly, the demand for steel plates for automobiles is expected to rise, and overall, Iran's focus on manufacturing is expected to help to increase the general demand for steel as a whole.” (Trend, “South Korea’s POSCO ready to participate in Iran’s steel projects,” 3/15/14)

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"South Korean steelmaker POSCO , minority-owned by Warren Buffett's Berkshire Hathaway, has cut ties with government entities and sensitive industries in Iran such as energy and continues to trade with private firms, a letter showed... In a letter sent to U.S. pressure group United Against Nuclear Iran (UANI) dated Feb. 28 and seen by Reuters, POSCO, a top global steelmaker, said it had scaled down business  with Iran. 'Certain of POSCO's subsidiaries continue to engage in transactions in Iran,' POSCO's chief legal officer Song Se-Bin wrote in the letter. 'However, these transactions involve only the civil market. Moreover, these POSCO entities engage in transactions only with Iranian entities that POSCO believes, based on its best due diligence efforts, are not owned or controlled by the Iranian government.' Song said POSCO entities had 'completed, terminated or assigned all of their activities related to the sensitive sectors of the Iranian economy - the energy, defence and nuclear sectors.' 'Although these efforts have resulted in the loss of certain projects and substantial financial losses to the POSCO entities, POSCO believes it important that it be regarded as a responsible corporate citizen.' A targeted campaign by UANI, which includes former U.S. ambassadors as well as former CIA and British intelligence chiefs on its board, has led to several foreign companies in sectors including shipping to exit Iran. UANI, which is funded by private donations and backs tougher sanctions on Tehran, had called on POSCO to cease its Iran trade. UANI chief executive Mark Wallace said it appreciated the company had taken multiple steps to reduce its Iran business. 'We continue to call, however, for POSCO to fully end its business in Iran,' said Wallace, a former U.S. ambassador to the United Nations.  'Given the nature of the business, the only way for POSCO to eliminate its exposure to the Iranian regime and IRGC-controlled entities is to completely pull out of the country,' he said, referring to the Revolutionary Guards, which reports directly to Iran's Supreme Leader. POSCO, which is 5.1 percent owned by Berkshire Hathaway , is the world's No.5 steelmaker by output. Buffett's business partner Charlie Munger has frequently praised POSCO as being, in his opinion, the best-run steelmaker in the world. Buffett, via his assistant, could not be immediately reached for comment. When contacted about its Iran deals, POSCO spokeswoman Jiyoung Kim said: 'POSCO and its subsidiaries stopped trades with Iranian government and state-run Iranian companies.'POSCO will abide by the law regarding U.S. sanctions on Iran, and plans to actively cooperate with U.S. policies.'... POSCO's Song said in the letter it followed strict guidelines on trading with Iran which required written confirmation from the Korea Strategic Trade Institute, which is under Seoul's economy ministry, that any investment or trading did not directly or significantly contribute to enhancing Iran's oil capabilities or involve blacklisted entities or individuals. Song said POSCO personnel would 'face disciplinary action for non-compliance' if they did not adhere to its trading policies in Iran.  'POSCO shares UANI's goal of thwarting Iran's nuclear programme,' Song said." (Reuters, "S.Korean POSCO cuts back on Iran steel business," 3/12/2013)
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"We engage in limited business activities and investments relating to Sanctions Targets, including Iran, Myanmar and Sudan . . . Our subsidiaries also engage in limited business activities and investments relating to Sanctions Targets . . . We expect to continue operations and investments relating to countries targeted by United States and European Union economic sanctions." (SEC, "Form 20-F," 4/30/12)

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"We acquired a controlling interest in Sungjin Geotec Co., Ltd. (“Sungjin Geotec”), a manufacturer of specialized equipment used in the power and energy industries in May 2010, and we currently hold a 36.7% interest in the company. In recent years, Sungjin Geotec entered into contracts with various suppliers to supply equipment for the development of natural gas fields in Iran, including natural gas fields located in South Pars that is led by Pars Oil and Gas Company, a subsidiary of National Iranian Oil Company." (SEC, "Form 20-F," 4/30/12)

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"POSCO, a construction company in which we hold an 89.5% interest, engages in the planning, design and construction of industrial facilities in Iran."(SEC, "Form 20-F," 4/30/12)

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"Daewoo International, a global trading company in which we hold a 66.6% interest, engages in the trading of steel, raw materials and other items with Sanctions Targets, including Iran and Sudan."  (SEC, "Form 20-F," 4/30/12)

FEV partnered with Iran Khodro to produce EF7 engines. 

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FEV is a Germany-based global supplier of engine, powertrain, and instrumentation systems. 

According to an industry publication, FEV designed and developed a new dual-fuel compressed natural gas engine in Iran. FEV Motorentechnik GmbH lists a representative office in Tehran on its website.

FEV has received $130 million in US government contracts over the past decade, including $16 million from the Department of Defense.

According to its company website, Toyota Motor has an oversea distributor in Iran that is named Irtoya Co. 

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On January 20, 2020, Minnesota SBI listed Toyota Motor as a scrutinized investment. The managers are explicitly instructed to refrain from purchasing securities on this list

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According to its Annual Report filed with the SEC for fiscal year 2018: Toyota Kirloskar Motor Private Limited, a majority-owned subsidiary of Toyota, sold one Toyota vehicle to the Iranian embassy in India. 

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"The world's largest carmaker selling a single vehicle to a country of 82 million people is not usually a recipe for controversy. But that's what Toyota is facing after it issued an apology and revealed on October 24 that the Japanese car manufacturer's Indian subsidiary, Toyota Kirloskar Motor Private, sold one vehicle to the Iranian Embassy in New Delhi in early 2017. (October 25, 2017)

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According to its Annual Report filed with the SEC for fiscal year 2015: "During the fiscal year ended March 31, 2015:      

• Toyota Tourist International, Inc., a majority-owned subsidiary of Toyota, obtained three visas from the Iranian embassy in Japan in connection with certain travel arrangements.
• Tokyo Toyota Motor Co., Ltd., a wholly-owned indirect subsidiary of Toyota, performed maintenance services for Toyota vehicles owned by the Iranian embassy in Japan.

Altogether, the above activities contributed an insignificant amount in gross revenues and net profit to Toyota. Toyota believes that none of the above transactions subject it or its affiliates to U.S. sanctions. Toyota Tourist International intends to cease conducting the activities described above. Tokyo Toyota Motor may, if requested by the Iranian embassy in Japan, continue to perform maintenance services relating to vehicles owned by such embassy, in accordance with applicable laws and regulations, in order to honor Toyota’s commitment to the safety and reliability of its vehicles."

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According to its Annual Report filed with the SEC for fiscal year 2014: "During the fiscal year ended March 31, 2014:

• Toyota Tourist International, Inc., a majority-owned subsidiary of Toyota, obtained eight visas from the Iranian embassy in Japan in connection with certain travel arrangements.
• Tokyo Toyota Motor Co., Ltd., a wholly-owned indirect subsidiary of Toyota, performed maintenance services for Toyota vehicles owned by the Iranian embassy in Japan.

Altogether, the above activities contributed an insignificant amount in gross revenues and net profit to Toyota. Toyota believes that none of the above transactions subject it or its affiliates to U.S. sanctions. Toyota Tourist International intends to cease conducting the activities described above. Tokyo Toyota Motor may, if requested by the Iranian embassy in Japan, continue to perform maintenance services relating to vehicles owned by such embassy, in accordance with applicable laws and regulations, in order to honor Toyota’s commitment to the safety and reliability of its vehicles."

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"[T]he auto sanctions were lifted earlier this year after an interim nuclear agreement was reached between Iran and world powers and a final accord is still on the horizon, raising the prospect of better times for the industry. That will draw international suitors to Tehran on Monday for the second consecutive Iran Auto Show. Mercedes Benz, Volkswagen, Renault, Peugeot, Kia and Toyota have confirmed [they will attend]." (Agence France-Presse, "Foreign automakers find Iranian market has gone local," 11/30/14)

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"Iran totally imported 51,967 cars in the first half of the current Iranian calendar year (March 21 - September 22). Hyundai with 24,991 cars was the main exporter of cars to Iran in the mentioned period, Peykhabar News Website reported on Nov. 15. Kia Motors with 9,339 cars, Geely with 5,783 cars, Toyota with 4,528 cars..."(Trend, "Korea’s Hyundai gains lion share of Iran’s car imports market," 11/16/14)

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"Last week, Qorbani announced that Benz, Volkswagen, Volvo, Fiat, Rover, Skoda, Renault, Peugeot, Kia and Toyota would take part in the Iranian auto expo, adding that the US car-manufacturers would also join the event. 'In case of desirable conditions, General Motors and Ford companies will also attend the event.' He continued that some leading car parts makers, including Siemens, FORD Mendo, Busch, FRW and ACI would attend the gathering. The event will start work on December 10." (Fars News, "55 Giant Int'l Carmakers, Part-Makers to Participate in Iranian Auto Expo," 11/2/14)

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"Indonesian ambassador to Tehran Dian Wirengjurit announced that his country plans to help Iran to set up assembly-line of Toyota cars in Aras Free Zone in the Northwestern parts of the country. 'Negotiations with the head of the Indonesian plant of Toyota Company have been held and he has agreed with launching assembly-line of Toyota cars in Aras Free Zone,' the Indonesian ambassador said in a meeting with Managing Director of Aras Free Zone Mohsen Khadem on Wednesday. The Indonesian ambassador pointed to the production of 1.5 million cars in Iran, and said, 'This is a valuable time to import raw materials and tires to Iran with no third party involved.'" (Fars News, "Envoy: Indonesia Agrees with Setting Up Assembly-Line of Toyota Cars in Iran," 8/20/2014)

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"According to the report, 17 car brands have been permitted to be imported in the current year. The cars include Hyundai (2 models), ABT, Alfa Romeo (2 models), MG, SsangYong, Toyota, Renault (6 models), and Kia (2 models)." (Azer News, "Iran bans imports of renowned car brands," 5/27/2013) 

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According to its Annual Report filed with the SEC for fiscal year 2013: "During the fiscal year ended March 31, 2013:

• P.T. Toyota-Astra Motor (“TAM”), an Indonesian company, sold three Toyota vehicles to the Iranian embassy in Indonesia. P.T. Toyota Motor Manufacturing Indonesia, an Indonesian company and subsidiary of Toyota, manufactured and sold the vehicles to TAM. TAM is the sole distributor of Toyota vehicles in Indonesia. As of March 31, 2013, Toyota held 49 percent of the shares of common stock of TAM, and PT Astra International Tbk, an Indonesian company, held the remaining 51 percent of the shares of common stock of TAM.
• Tokyo Toyota Motor Co., Ltd., a wholly-owned indirect subsidiary of Toyota, performed maintenance services for Toyota vehicles owned by the Iranian embassy in Japan.     
• Toyota Tourist International, Inc., a majority-owned subsidiary of Toyota, obtained two visas from the Iranian embassy in Japan in connection with certain travel arrangements."

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"Toyota Motor Corp (7203.T) said on Wednesday it had suspended auto exports to Iran indefinitely since June, amid growing international scrutiny of companies dealing with the country." (Reuters, "Toyota says halted exports to Iran since June," 8/11/2010)

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"Sales of Toyota vehicles in Iran are handled by an independent Iranian company, and over the last five years, Toyota’s sales there represented less than a 1 percent share of the Iranian market, said a company spokesperson, Mira Sleilati." Toyota was the recipient of $154.4 million in US funds and revenues to conduct business in Iran.  Their business activities in Iran are active.  (The New York Times, "Profiting from Iran, and the U.S.", 3/6/2010)

Reuters article dated June 9, 2017, specifically citing Cargotec, which reports, “Western manufacturers are shying away from supplying equipment for an Iranian port that India is developing for fear the United States may reimpose sanctions on Tehran, Indian officials say…”  (Reuters, “India’s plan to develop key Iranian port faces U.S. headwinds,” 6/9/2017). According to the article, “Konecranes (KCRA.HE) and Cargotec (CGCBV:HE) have told India Ports Global Pvt Ltd, which is developing the deepwater port in [Chabahar, Iran], they were unable to take part in the bids as their banks were not ready to facilitate transactions involving Iran due to uncertainty over U.S. policy…”  (Id.).

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Cargotec is a cargo handling company that provides services for industrial, marine, harbor, and on-road cargo. Cargotec is based in Helsinki and had 2.6 billion euros in total sales in 2009. As of 2007 it is the world’s second largest crane manufacturer.

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"A European machinery company that has received more than $1 billion in U.S. government contracts is coming under scrutiny after pictures emerged this week of its cranes being used to publicly execute individuals in Iran. The company, Cargotec, acknowledged to the Washington Free Beacon on Wednesday that its equipment is being used to publicly hang Iranian prisoners, but maintained that it is not responsible for directly selling the equipment to the Islamic Republic... Cargotec, via a Texas-based subsidiary called Kalmar, has long partnered with the U.S. government to provide equipment mainly to the Pentagon. These contracts have totaled around $1.21 billion as of November 2015, according to records compiled by the Federal Procurement Data System. Photographs of a Cargotec crane being used for an execution earlier this week were first published by Iranian-controlled websites and prompted criticism from groups such as United Against a Nuclear Iran, which has been waging a pressure campaign to stop companies from providing this type of equipment to Iran... 'We have seen numerous examples over the years of the Iranian regime using the cranes of brand-name companies to publicly execute people,' said Matan Shamir, UANI's executive director. 'Cargotec should follow the lead of other responsible companies and end its Iran business given the exploitation of its products to commit such egregious abuses.' A spokesman for Cargotec said that the company is 'sad' to see its products being used to help the Iranian regime execute its citizens. 'We are aware of the unfortunate situation where cranes have been used in public executions in Iran,' the spokesman said via email. 'We are naturally extremely sad to see these pictures and strongly judge this kind of action and behavior.' ... Criticism from groups such as United Against a Nuclear Iran has focused on companies such as Cargotec that also hold U.S. government contracts. These critics maintain that both the U.S. government and these companies should work harder to prevent Iranian human rights abuses. 'Given its lucrative business with the U.S. military, Cargotec should be even more sensitive to doing business with an avowed enemy of the United States that is responsible for killing hundreds of American soldiers,' said Shamir." (Free Beacon, "U.S. Contractor’s Cranes Being Used to Hang Iranians," 11/12/15) 

In January 2021, the State of New Jersey Department of the Treasury listed SK Energy as a company engaged in prohibited activities in Iran pursuant to P.L. 2012, c. 25 ("Chapter 25"). 

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On October 14, 2020, SK Energy remained on the Tennesse Department of General Services list of persons it determines engage in investment activities in Iran, as described in 12-12-105.

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As of July 1, 2020, SK Energy is listed as an entity “determined, based on credible information available to the public, to be engaged in prohibited activities in Iran pursuant to New Jersey P.L. 2012, c.25 (“Chapter 25”). 

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In 2020, the U.S. state of Mississippi listed SK Energy on its state lists of Companies Doing Business with the Iranian Petroleum/Natural Gas, Nuclear and Military Sectors, rendering it ineligible for investment and/or state contracting.

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As of June 8, 2020, SK Energy is listed on the Pennsylvania Department of General Services Iran Free Procurement List. Entities included on this list are ineligible to enter into a contract with the Commonwealth of Pennsylvania for goods and services worth at least $1,000,000 per sections 3501-3506 of the Commonwealth Procurement Code, 62 Pa. C.S. §§ 3501-3506.  

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As of April 15, 2020, SK Energy is included as an entity determined to be non-responsive bidders/offerers pursuant to The New York State Iran Divestment Act of 2012.  

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As of April 15, 2020, SK Energy is included on the Tennessee list of persons it determines engage in investment activities in Iran, as described in § 12-12-105. 

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On March 13, 2019, the Mississippi Department of Finance & Administration identified SK Energy as a company “engaged in investment activities in Iran, providing funds, goods or services valued at $20,000,000 or more in the energy sector of Iran.”  

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In 2018 and 2019 Tennessee used the New York list of “Entities determined to be non-responsive bidders/offerers pursuant to the New York State Iran Divestment Act of 2012.” SK Energy was included on this list in 2018 and 2019. Tennessee states "Inclusion on this list would make a person ineligible to contract with the state of Tennessee, if a person ceases its engagement in investment activities in Iran, it may be removed from the list."

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“South Korea's crude imports from Iran surged 104 percent in February from a year earlier as refiners hiked purchases ahead of maintenance shutdown starting from March, according to the country's customs data and a refining source. South Korea imported 1.1 million tonnes of Iranian crude last month, or 294,069 barrels per day (bpd), up 4.5 times from January and double from a year earlier, preliminary customs data showed on Saturday…’The two refiners had to hike the imports ahead of maintenance shutdown starting from March. Before and after the maintenance, refiners usually import more to meet annual import contracts,’ a Seoul-based refining source told Reuters. Of four South Korean refiners, SK Energy and Hyundai Oilbank are the only ones that buy Iranian oil on a regular basis. Their Iranian crude imports can vary from month to month as one of the two refiners that buy from the OPEC receives the oil only every other month. SK Energy will shut a 260,000 bpd No. 5 crude distillation unit (CDU) and a 57,000-bpd No.1 gasoline-making unit in the second quarter for maintenance, a spokesman at parent SK Innovation Co Ltd said. Hyundai Oilbank will shut its No.1 110,000-bpd CDU in April for maintenance, it said last month.” (Reuters, “S.Korea Feb Iran oil imports soar ahead of shutdown," 3/15/14)

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"South Korea's Iranian crude imports fell in October from September, meeting a targetted 15 percent cut in its shipments from the OPEC member for the June-November period to secure an extension of its six-month U.S. sanctions waiver…outh Korea imported 420,402 tonnes of Iranian crude last month, or 99,405 barrels per day (bpd), down more than a quarter compared with September and down nearly a half from a year earlier, preliminary customs data showed on Friday…The total means South Korea met the 125,814 bpd it aims to achieve in its imports from Iran in the six months through November…South Korea's Iranian crude imports vary from month to month as one of the two Korean refiners that buys from Iran receives oil only every other month, according to industry sources. The imports unexpectedly jumped in July from the year-earlier period before dropping off again in August. SK Energy and Hyundai Oilbank are the only South Korean refiners that take Iranian oil on a regular basis. South Korea, the world's fifth-largest crude buyer, imported a total of 10.7 million tonnes of crude last month against 11.1 million tonnes in October 2012, data from the Korea Customs Service also showed on Friday." (Reuters, "S.Korea's Oct Iran oil imports drop, meet target," 11/15/13)

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"South Korean refiners SK Energy and Hyundai Oilbank are the only two in the country to import Iranian crude. Spokesmen at both refiners declined to comment." (Reuters, "South Korea Pledges 15 Percent Cut to Iran Oil Imports," 06/24/13)

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"South Korea's imports of Iranian crude in March fell 16.2 percent from a year ago to 4.02 million barrels, data from the state-run Korea National Oil Corp showed on Monday, after its biggest refiner SK Energy shut a crude unit for maintenance... But imports from sanctions-hit Iran should surge month-on-month to 190,000 bpd in April as SK Energy's 110,000-bpd crude distillation unit returned to operation on April 16 after 30 days of maintenance... Its two buyers of Iranian crude, refiners SK Energy and Hyundai Oilbank, are shutting a combined 560,000 bpd of refinery capacity for planned maintenance between March and June." (Reuters, "Update 1 - S.Korea's Iran Crude Imports for March Down 16.2 pct Y/Y," 4/22/2013)

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"South Korean refiners will cut imports of Iranian crude during the six months to May by about a fifth from a year earlier, to avoid sanctions by Washington, government and industry sources told Reuters on Monday. Last week the United States granted 180-day waivers on Iran sanctions to China, India, South Korea and some other countries after they cut oil purchases from the Islamic Republic... South Korea, the world's fifth largest importer of crude, and one of Iran's biggest oil customers, gave the assurance on the size of the cuts in talks with the United States following discussions with Korean refiners, the sources said. Such a cut would imply South Korean imports of about 147,814 barrels per day (bpd) over the period to next May, since the country imported 184,767 bpd of Iranian crude from December 2011 to May 2012. Two refiners, SK Energy and Hyundai Oilbank, now import about 200,000 barrels per day of crude from Iran." (Reuters, "South Korea to Cut Iran Crude Imports 20 Percent," 12/10/12)

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"South Korea's biggest oil refiner SK Energy loaded a second cargo of crude in Iran last week, a government source said on Wednesday, as Seoul resumes Iranian oil shipments after a near two-month gap caused by a European Union ban on insurance cover... A spokesman for SK Energy's parent firm confirmed last week that another Iranian cargo of the same volume was already on its way to South Korea. 'SK Energy lifted its second cargo in Iran last week,' said the source at South Korea's economy ministry, adding that SK Energy's first cargo had not arrived yet in Korea. SK Energy and its parent SK Innovation declined to comment... Of South Korea's four refiners, only SK Energy and Hyundai Oilbank import Iranian crude. SK Energy's term contracts with Iran this year provide for imports of two Very Large Crude Carriers (VLCCs) of crude per month, or 4 million barrels, and Hyundai Oilbank imports one VLCC per month, or 2 million barrels, according to the economy ministry source." (Reuters, "S.Korea's SK Energy lifts 2nd Iran crude cargo-source," 9/26/2012)

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"South Korean refiners will resume imports of up to 200,000 barrels per day of Iranian crude from September, economy ministry sources said on Monday, ending a two-month gap due to a European Union ban on insurance cover for Iranian oil... Total imports envisaged at resumption will be six million barrels per month, or 200,000 bpd. SK Energy will import four million barrels per month and Hyundai Oilbank will import two million barrels per month, the economy ministry source added. This is the volume refiners agreed in term contracts with Iran for this year... A spokesman at SK Innovation, which owns SK Energy, told Reuters last Friday that the talks with Iran were progressing well, and the refiner expected to resume the imports around September loading." (Reuters, "S.Korea to resume Iran oil imports from Sept -econ min sources," 8/20/12)

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"South Korean refiners plan to resume buying crude from Iran in September after a two-month hiatus due to a European Union embargo that made shipping the oil difficult, government and refining sources said on Wednesday. The refiners have, like their Chinese and Indian counterparts, asked Iran to deliver crude on Iranian tankers, government and industry sources said. This shifts the responsibility to Iran for insurance, sidestepping a ban in the EU on insurers from covering Iranian shipments... South Korean refiners and the National Iranian Tanker Company (NITC) are close to finalising a deal that would allow loading to resume from September, sources said.'Refiners have requested Iran to deliver crude, and the deal is almost reached,' a government source with direct knowledge of the matter said... Two refining sources confirmed the request had been made to NITC. SK Energy and Hyundai Oilbank are the only two South Korean refiners that import Iranian crude. The refiners would buy a similar quantity of oil as they had prior to the July stoppage, sources said. There may be some variance month by month due to the size of vessels available for imports from NITC, one refining source said." (Reuters, "S.Korea to resume buying Iranian crude in Sept," 8/8/12)

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"There's a 'high chance' that South Korea will resume importing Iranian crude oil in the near future, Minister of Knowledge Economy Hong Sukwoo said Thursday… Iranian officials have since offered accident insurance coverage worth a maximum of $1 billion on Iranian tankers shipping crude oil to South Korea, a Hyundai Oilbank official said earlier this month. Hyundai Oilbank and SK Energy, the two South Korean refiners that imported Iranian crude, are considering Iran's offer to provide shipping services, officials from both companies have said… South Korea usually imports around 10% of its crude-oil requirements from Iran, but that percentage declined to 7.4% in the first six months of this year." (Dow Jones, "S Korea Oil Imports to Iran Seen Restarting," 7/26/12)

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"South Korea became the first major Asian consumer of Iranian crude to announce a halt to imports after the government said they would be suspended from July 1 due to a European Union ban on insuring tankers carrying Iranian oil... Of South Korea's four refiners, only SK Energy and Hyundai Oilbank import Iranian crude. Sources said both refiners will stop importing from Iran when the EU insurance embargo takes effect from July 1." (Reuters, "South Korea to halt Iran oil imports as EU ban bites," 6/25/12)

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"Earlier this month, two South Korean shipping companies said they had suspended importing Iranian crude due to a separate EU embargo set to come into force from July. SK Shipping, which handles the needs of refiner SK Energy, said it shipped its last cargo from Iran early this month and it would arrive by the end of June... SK Energy and Hyundai Oilbank are the only Korean refiners still importing Iranian oil. They said the suspension was temporary as Seoul seeks an exemption from the EU measures." (France 24, "S.Korea reports sharp fall in Iran oil imports,"6/25/12)

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"SK Innovation fully owns SK Energy, the country's largest oil refiner, which relies on Iran for around 10%-15% of its crude-oil imports." (The Wall Street Journal, "Official: South Korea Has No Plans To Halt Iran Crude," 5/22/2012)

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"South Korea's largest oil refiner SK Energy <096770.KS> will stop Iranian oil imports after the ban takes effect, two sources with direct knowledge of the matter said on Monday... 'SK Energy won't lift Iranian crude oil after lifting a 2 million barrel cargo in early June,' one of the two sources said. SK Energy will not import Iranian oil for July arrival.'... SK Energy had agreed to import 130,000 barrels per day (bpd) of Iranian crude this year under a long-term supply deal, while Hyundai Oilbank had agreed to import 70,000 bpd." (Reuters, "Exclusive: South Korea poised to halt Iran oil imports from July: sources," 5/21/2012)
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"South Korea will make sharp cuts in imports of Iranian crude from June as tightening Western sanctions make it impossible to secure insurance cover for tankers to ship the crude, industry and company sources said... With no resolution in sight, Hyundai Oilbank, one of two buyers of Iranian oil in South Korea, has decided to stop lifting cargoes from June, industry sources told Reuters. But bigger counterpart SK Energy is sticking with its plan to lift annual committed volumes at least until June. For July onwards, SK Energy, the country's largest refiner, is in talks with the government to secure insurance cover for tankers shipping the oil. If the government disagrees, the company will have little option but to halt purchases, said the sources, who declined to be identified as they are not authorized to talk to the media." (Chicago Tribune, "South Korea's Iran crude imports to plunge from June: sources," 4/26/12)

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"SK Energy will buy the additional crude, taking 130,000 bpd in 2012, up 10,000 bpd on the year, a government source said. An SK Energy spokesman declined to comment when asked about the deal... SK Energy could replace Iranian oil with imports from elsewhere in the Middle East if it needed to, although that might cost more money, an SK Energy source said." (Reuters, "S.Korea buys more Iran oil but eyes alternatives," 1/4/2012)

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"'We don't see any impact on crude imports from Iran,' a source at South Korea's largest refiner SK Energy said. 'While we cannot disclose the term import barrels for 2011, I can tell next year's oil import from Iran will continue as much as this year's.'

 An official at Hyundai Oilbank also said the term volume for 2011 will be stable from 2010. SK Energy and Hyundai Oilbank are the only buyers of Iranian crude in the country among four refiners.    Trade with Iran accounts for less than 1.5 percent of South Korea's overall trade but Iran is an important supplier of crude oil to South Korea, which imports all of its crude needs.

 Iran is South Korea's fourth-largest crude supplier. South Korea imported 67.1 million barrels of Iranian crude between January and November this year, accounting for 8 percent of the country's total crude imports, down about 10 percent from a year earlier." (Reuters, "Iran's Asian crude buyers see flow steady despite financial sanctions," 12/30/10)