Department of Defense

"Hyundai Oilbank Co., a major South Korean refiner, plans to import 2 million barrels of Iranian condensate this month, a person familiar with the issue said Monday.

It would be Hyundai Oilbank’s first imports of ultralight crude since September, two months before the United States imposed the most biting sanctions ever on Iran. US President Donald Trump abandoned a landmark 2015 nuclear deal with Iran in May." (Korea Herald, 2/14/2019).

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In June 2016 Hyundai Oilbank markedly increased imports of Iranian oil. (Mehr News, “S Korea’s Iranian crude imports double in Jan-April period,” 6/7/2016).

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MOPCIO is the exclusive agent of Hyundai OIL BANK South Korea in IRAN.

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Hyundai Oil Bank is a subsidiary of Hyundai Heavy Industries.

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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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"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 SK Innovation Co. and Hyundai Oilbank Co. resumed shipments after Iran offered its own vessels." (Bloomberg, "South Korea’s Oil Imports From Iran Rise 24% From a Year Earlier," 1/14/2013)

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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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"Hyundai Oilbank Co. operates a 395,000 barrel-a-day refinery in Daesan." (Bloomberg, "Iran Oil Tanker Signals for Daesan as Korea Continues Importing," 11/6/2012)

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"An Iranian supertanker is heading to South Korea with a cargo of oil, according to shipping data, as the Islamic republic uses state-owned tankers to make deliveries in response to sanctions over its nuclear program. The Brawny, a very large crude carrier that can take on 2 million barrels of oil, left the Iranian port of Kharg Island yesterday and is provisionally scheduled to discharge its cargo at Daesan in South Korea, according to transmissions captured by IHS Inc. (IHS) on Bloomberg. National Iranian Tanker Co. owns the vessel. Hyundai Oilbank Co. operates a 395,000 barrel-a-day refinery in Daesan." (Bloomberg, "Iran Seen Sending Own Supertanker to Deliver Oil to South Korea," 10/5/12)

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"Another refiner, Hyundai Oilbank, will lift two million barrels in Iran by the end of the month, the government source said." (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." (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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"Iranian officials have offered accident insurance coverage worth a maximum of $1 billion for Iranian tankers shipping Iranian crude oil to South Korea, a Hyundai Oilbank official, who declined to be named, said Wednesday. Hyundai Oilbank and SK Innovation (096770.SE), which fully owns the nation's other refiner, SK Energy, are considering Iran's offer, officials from both companies said. Both companies imported crude oil from Iran until European Union sanctions that took effect July 1 effectively cut off insurance on Iranian crude shipments July 1 . . . The South Korean refiners are considering using the ships of NITC, or National Iranian Tanker Co., they said. Hyundai Oilbank is negotiating the details--including the offer of insurance and the number of monthly shipments--with Iranian officials, the Hyundai Oilbank official said. An agreement may be reached by the end of the month, he said. Meanwhile, Hyundai Oilbank is waiting for the government, which apparently finds the Iranian proposal 'acceptable,' to give it its official blessing, he said. A government official who asked not to be identified told Dow Jones Newswires earlier this week that government officials were leaning toward accepting the Iranian insurance proposal but that it was 'too early to say' whether it would be approved." (Nasdaq, "Iran Offers $1 Billion Insurance on Tankers to S Korea," 7/18/12)

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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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 "South Korean refiner Hyundai Oilbank, a heavy user of Iranian crude, postponed its planned $2 billion initial public offering on Friday due to the euro zone crisis, and ahead of a pending suspension of Iran crude imports on western sanctions…'The withdrawal has been widely expected in the market. Hyundai will be dealt the biggest blow should Iran oil imports be suspended because it has the highest portion of Iranian oil imports among local peers,' said Lee Jeong-heon, an analyst at Hana Daetoo Securities…Hyundai Oilbank is South Korea's biggest Iran oil buyer, sourcing around 20 percent of its total imports from Iran, higher than the country's 2011 average of 10 percent." (Reuters, "Iran crude buyer Hyundai Oilbank drops $2 billion IPO plan," 6/15/12)

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"Last month, industry sources said the only other South Korean refinery that buys Iranian crude, Hyundai Oil Bank, would stop imports from June... 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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"SEOUL, March 29 (Reuters) - South Korean refiner Hyundai Oilbank is delaying plans for an initial public offer worth up to $2 billion, partly on investor concerns over its links to Iran, sources said, the second big Asian IPO to be snagged by Western sanctions against Tehran.  Hyundai Oilbank, a heavy user of Iranian crude, is controlled by Hyundai Heavy Industries which initially aimed to list it in South Korea as early as May but is now looking at the second half of the year, three sources with knowledge of the matter told Reuters on Thursday.  The delay follows the postponement of another Iran-linked IPO planned for Hong Kong and reflects widening fallout from the U.S.-led sanctions against Iran." (Reuters, "Hyundai Oilbank to delay $2bln IPO amid Iran sanctions - sources" 3/29/12)
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"Hyundai Oilbank, the only other South Korean refiner that buys Iranian crude, will import 70,000 bpd in 2012, unchanged from 2011, a Hyundai spokesman said on Wednesday... Hyundai is making contingency plans for any disruption in the flow, the spokesman said." (Reuters, "S.Korea buys more Iran oil but eyes alternatives," 1/4/2012)
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"In 2009 Iran exported 81,446 bpd of crude to South Korea, 12 percent up versus the previous year, while maintaining its rank as South Korea's fourth-largest crude supplier after Saudi Arabia, the UAE and Kuwait, according to the data from Korea National Oil Corp.  South Korea's top refiners which buy Iranian crude include SK Energy (096770.KS) and Hyundai Oilbank." (Reuters, Iran's crude export and fuel import customers, 4/13/2010)

The representative of Japan's Isuzu Motors announced the expansion of its activities in Iran. The representative of Isuzu in the unveiling ceremony of Truck FVZ 26 tons said, “Iranian market is important for Isuzu Motors and because of this, the company wants to expand its activities in Iran”. (February 2018)

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Japan's iconic ISUZU brand has launched its latest vehicle in the Iranian market costing 1.18 billion rials ($33,700). (Financial Tribune, "ISUZU Pickup Launched," 5/29/2016). 

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In February 2016, Isuzu said that it was “considering expanding business in Iran following the recent removal of the Japanese government’s economic sanctions on Tehran.” (Bernama, “Japan’s Isuzu mulling biz expansion in Iran,” 2/10/2016).

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Isuzu 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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"Isuzu uses the Bahman Group as its distributor in Iran, according to Isuzu's Web site. The Sepah Cooperative Foundation, a large investment fund closely linked to the Iranian Revolutionary Guard Corps (IRGC), owns a 45 percent share of the Bahman Group, according to Iranian newspaper reports. (Among the links between the Sepah Cooperative Foundation and the IRGC: the general manager of the the Sepah Cooperative until this fall was IRGC commander Ahmad Vahid-Dastjerdi. Another former notable head of the Sepah Cooperative Foundation was Mohsen Rafiqdoost, who helped found the IRGC. The Sepah Cooperative Foundation's stake in the Bahman Group has also been reported by Rand Corporation, in a 2009 report prepared for the Office of the Secretary of Defense, as well as the think tanks the Washington Institute, and the Council on Foreign Relations reports.) Isuzu spokesman Kouichi Itou said in a statement that the company was not aware of those links and believed that a 'Retirement Insurance Organization' was a 45 percent shareholder in Bahman."
 
From 2000 through March 2010, Isuzu has been the recipient of $1.9 million in U.S. federal funds. (The New York Times, "Profiting from Iran, and the U.S.", 3/6/10)

A week after it was announced that French carmaker Peugeot-Citroen had left the Iranian market, Japan’s Mazda and South Korean Hyundai have also suspended contracts with Iran, according to a member of the parliamentary Industries and Mines Commission.

In an interview with the parliament-affiliated website, Valiyollah Maleki said June 12, “Mazda and Hyundai’s interests in the U.S. market are much more than in Iran, and they will not sacrifice their profit for the sake of Iran.” (June 13, 2018).

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Mazda 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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Mazda lists the Bahman Group, based in Tehran, Iran, on its Middle East & North Africa distributor list. (Company Website)

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"UANI (United Against Nuclear Iran) group calls on Japanese car manufacturer Mazda and French Peugeot to end their business in Iran, UANI (United Against Nuclear Iran U.S. group) Communications Director Nathan Carleton told Trend. While a lot of car manufacturing companies have left Iran due to sanctions imposed on the Islamic Republic, according to Carleton despite the threat of sanctions, there are still some world-known car brands that do their business in Iran. Among them are Mazda and Peugeot. 'Mazda's ongoing business in Iran is egregious given that its vehicles are produced in Iran in partnership with the Bahman Group, a manufacturing conglomerate that is 45.5 percent owned by the Islamic Revolutionary Guard Corps (IRGC),' Carleton said. He went on to note that if Mazda does not end its Iran business, it should be sanctioned under presidential Executive Order 13645, which authorizes sanctions on entities 'knowingly engaged in a significant transaction for the sale, supply, or transfer to Iran of significant goods or services used in connection with the automotive sector of Iran.'" (Trend, "UANI calls on Mazda, Peugeot to end their business in Iran," 9/16/13)

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"The report said that aside from Nissan and Peugeot, such car brands as Chinese Lifan, Mazda, Suzuki, and Hyundai are still being manufactured in Iran." (Trend, "Five reasons why Iran's car manufacturing suffers blow after blow," 11/27/2012)

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"Mazda has been operating in Iran at least since 1972. The Bahman Group assembles Mazda cars for the company. The Sepah Cooperative Foundation, a large investment fund closely linked to the Iranian Revolutionary Guard Corps (IRGC), owns a 45 percent share of the Bahman Group, according to Iranian newspaper reports. (Among the links between the Sepah Cooperative Foundation and the IRGC: the general manager of the the Sepah Cooperative until this fall was IRGC commander Ahmad Vahid-Dastjerdi. Another notable head of the Sepah Cooperative Foundation was Mohsen Rafiqdoost, who helped found the IRGC. The Sepah Cooperative Foundation's stake in the  Bahman Group has also been reported by Rand Corporation, in a 2009 report prepared for the Office of the Secretary of Defense, as well as the think tanks the Washington Institute, and the Council on Foreign Relations reports.) Mazda spokesman spokesman Chris Keeffe said that his company's business in Iran complies with all Japanese and international laws. Mr. Keefe said he was not aware of the reports linking the Iranian Revolutionary Gaurd to the Bahman Group and threfore could not comment. Contracts for Mazda and Ford Motor Company, which owned one-third of Mazda until 2008 and remains one of its largest shareholders, include selling trucks and cars to the United States military."  From 2000-2009, the company was the recipient of $2.4 billion US federal funds.  Their investments in Iran are currently active.  (The New York Times, "Profiting from Iran, and the US," 3/6/2010)

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“Khalaji, of the Washington Institute, lists the Bahman Group, which manufactures cars for Mazda, among [Iran Revolutionary] guard-owned companies.” (Council on Foreign Relations, “Iran’s Revolutionary Guard,” 10/3/07)

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“Japan's Mazda, one-third-owned by Ford, has a joint venture with Iran's private Bahman group to make a version of the Mazda 323, and Chrysler parent DaimlerChrysler has licensed assembly of an E-class Mercedes-Benz.” (Fortune, “Made in Iran,” 9/12/06)

"The CEO of SAIPA automaker group announced plans to resume the production of Nissan products in Iran. “Recently, we held negotiations with the officials of Japanese automobile manufacturer Nissan.” the CEO of SAIPA automaker group, Mohsen Qasem Jahroudi said. “According to the negotiations, a triple platform from Nissan will be introduced into the SAIPA automaker group,” he added. Nissan products were produced in Iran until a few years ago. One of the most famous of the products was Nissan Maxima whose production was stopped six years ago. Mr. Jahroudi stressed that Nissan will soon resume its activities in Iran." (March 14, 2018)

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"Jahan Novin Trading Company (JNA Nissan), the authorized representative of Japan’s Nissan in Iran, unveiled its latest Nissan X-Trail in Tehran on January 5. According to the local automotive website Asbe Bokhar, the trading company is a joint venture set up by an Omani company, Suhail Bahwan Group and the Iran’s Ariya Group. Suhail Bahwan Group has been representing the Japanese auto manufacturer since 2004 in the region and is one of the majority shareholders of Nissan. By forging a deal with the Omani company, JNA Group was able to meet government requirements on importing consumer goods with the parent company’s authorization." (January  8, 2017).

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"Iranian car manufacturing company Saipa is in talks with France's PSA Peugeot Citroen and Renault, Germany's Mercedes-Benz, and Sweden's Volvo to finalize deals on joint production of cars in Iran, Saipa officials announced on Tuesday.  Saipa CEO Saeid Madani announced that the company is in negotiations with PSA Peugeot Citroen to sign a deal, but at the same time noted that any deal would depend on the ongoing talks between Tehran and world powers over the country's peaceful nuclear energy program. He made the remarks on the sidelines of a ceremony held here in Tehran to unveil the production line of a new Volvo truck in Saipa Diesel factory… Japanese company Nissan has also declared its willingness to cooperate with Saipa and expand collabortions with the Iranian firm, he added." (Tasnim, Iran's Saipa Negotiating with European Automakers, 5/12/15)

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"The Trade Promotion Organization of Iran has announced the list of cars which are allowed to be imported in the current Iranian year, but renowned brands such as Porsche, Benz, BMW, Maserati, and Nissan are not in the list, ISNA news agency reported." (AzerNews, "Iran bans imports of renowned car brands," 5/27/2013) 

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"Such car brands as Nissan, Peugeot (sedan and hatchback), Toyota for several reasons, stopped their car manufacturing in Iran several months ago. Because French Peugeot Company and Iran Khodro stopped the co-operation, the manufacturing of Peugeot 206 in Iran has stopped. As for Nissan's Maxima brand, the giant car manufacturer from Japan halted its business in Iran after 11 years. However, in both cases with Nissan and Peugeot, several models are still being sold in Iran, such as Peugeot's 405 model, and Nissan's Teana. The report said that aside from Nissan and Peugeot, such car brands as Chinese Lifan, Mazda, Suzuki, and Hyundai are still being manufactured in Iran." (Trend, "Five reasons why Iran's car manufacturing suffers blow after blow," 11/27/2012)

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"A US activist group on Wednesday urged French automaker Renault and its Japanese partner Nissan to pull their business out of Iran because of its suspected program to develop nuclear weapons. In an open letter to Carlos Ghosn, the Renault-Nissan Alliance's chief executive officer, the advocacy group United Against Nuclear Iran (UANI) said, 'Renault's business dealings in Iran directly support the Iranian regime's ability to develop its illegal nuclear weapons program, support its terrorist proxies and puruse a brutal campaign of repression against the Iranian people.'... The UANI letter said it was 'disturbing' that Nissan was getting a contract valued at about $1 billion to manufacture a new fleet of New York City taxis while the automaker continues to do business in Iran. 'New York taxpayer dollars should not benefit a corporation, like Nissan, that partners with a regime that is the world's number one state sponsor of terror and has formed an alliance with al-Qaeda,' UANI said." (AFP, "US activists pressure Renault-Nissan to leave Iran," 4/5/2012)  

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"Nissan has a longtime relationship with the Iranian car company Pars Khodro Co., which has been producing Nissan cars and trucks for the Japanese company for sale in Iran since at least 1987. Nissan also does business with the United States government, selling the Department of Defense cars and trucks." From 2000-2009, the company was the recipient of $15.7 million US federal funds.  Their investments in Iran are currently active.  (The New York Times, "Profiting from Iran, and the US," 3/6/2010)

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Nissan has a production facility in Tehran with Pars Khodro, a major Iranian automobile manufacturer. In 2008, Pars Khodro manufactured the Nissan Pickup, Maxima and Paladin in this facility. In 2007, Pars Khodro produced 7,967 Nissan vehicles. (Nissan, “Profile 2008”)

Pars Khodro lists on its website that it sells and/or manufactures the Nissan Murano, Maxima, Pickup, Roniz [Paladin] and Teana car models. (Company Website)

Nissan Murano in Iran (Courtesy of IranSupercars)

"Has suspended activities in Iran "until further notice according to applicable sanctions"; had not resumed the production or sale of Mercedes cars or trucks in Iran." ("Daimler abandons its Iran plans over US sanctions," CNN, August 7, 2018.)

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Iran nears last steps to finalize deal with Daimler.

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"Daimler Trucks head Wolfgang Bernhard said on Saturday that "there is a huge demand for commercial vehicles in Iran" and that 'we plan to quickly resume our business activities in the market there,' AP reported. He added that the Stuttgart-based company has so far signed letters of intent with local partners Iran Khodro Diesel and Mammut Group to arrange a 'comprehensive re-entry' into the Islamic Republic where Daimler started doing business in the 1950s." (Tasnim News Agency, "Germany's Daimler Says to Resume Truck Business in Iran," 7/3/2016).

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"Daimler on Monday said its trucks division had signed letters of intent with joint venture partners in Iran as part of the German truck maker's re-entry into the Iranian market following the lifting of international sanctions…. Daimler said it would cooperate with Iran Khodro Diesel (IKD) and Iran's Mammut Group, establishing a joint venture for local production of Mercedes-Benz trucks and powertrain components, plus the establishment of a sales company for Mercedes-Benz trucks. Furthermore, there are plans for Daimler to return as a shareholder in the former engine joint venture Iranian Diesel Engine Manufacturing Co. (IDEM). Daimler Trucks intends to open a representative office in Tehran during the first quarter of 2016, the Stuttgart, Germany-based company said. The first Mercedes-Benz Actros and Axor trucks could be supplied to the country in the form of CKD (completely knocked down) kits - or fully disassembled - before the end of the year, Daimler said.In addition to the plans for Mercedes-Benz trucks, Daimler Trucks also sees great opportunities for its Mitsubishi FUSO brand – especially in the light-duty truck segment. To open up this market, Daimler and Mammut have signed a distribution agreement for the FUSO brand.” (Reuters, “Truck maker Daimler signs agreement to return to Iran,” 1/18/2016).

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"Daimler AG's Chief Executive Dieter Zetsche said Wednesday the German auto maker will divest its 30% stake in Iranian Diesel Engine Manufacturing as part of a wider review of its business relationships with the country. 'In view of the current political situation we have...extensively reassessed this business relationship,' Mr. Zetsche told shareholders at Daimler's annual general meeting." (The Wall Street Journal, "Daimler Downgrades Ties to Iran," 4/14/10)

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"Daimler has maintained a partnership with Iran car maker Iran Khodro since the 1960s, according to a company spokesperson, and it owns a 30 percent stake in an engine manufacturer owned by Iran Khodro. The company still ships cars to Iran, but new German export laws prohibit the sale of large trucks, and the spokesperson said that the sales are a small portion of worldwide revenue. Daimler and its subsidiaries have won contracts to supply cars and trucks to the U.S. government."  The company received $4.2 billion from the US government for their business investments in Iran during 2000-2009.  Their activities in Iran are currently active. (The New York Times, "Profiting from Iran, and the US," 3/6/2010)

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Germany's trade ties to Iran stretch back to the Middle Ages, and many of the companies currently there have been active in Iran for decades. Some 85 German companies have operations in Iran, from chemical maker BASF AG to Deutsche Lufthansa AG and Bayer AG, and others such as Linde AG and Mercedes-Benz parent Daimler AG are active there, according to the Hamburg-based German-Iranian Chamber of Commerce. More than 7,000 companies conduct business there through local representatives. Germany has become such a big trading partner for Iran because so many of its companies provide the machinery and engineering prowess Iran needs to improve its infrastructure.(The Wall Street Journal, "German Firms Feel Pressure Over Tehran Trade," 10/3/09)

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Several renowned German companies are involved in major Iranian infrastructure projects, especially in the petrochemical sector, like Linde, BASF, Lurgi, Krupp, Siemens, ZF Friedrichshafen, Mercedes, Volkswagen and MAN. (Payvand News, Iranian exports to Germany rose 50% last year, 1/9/08)

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Major Non-Oil Investments [In Iran]: Renault (France) and Mercedes (Germany)- automobile production in Karaj, Iran--valued at $370 million. (Congressional Research Service (CRS) Reports and Issue Briefs, Iran: U.S. concerns and policy responses, 12/1/07)

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German companies such as Siemens, BASF, Mercedes, and Volkswagen maintain strong business ties with Iran. (The New York Sun, Attack on Iran Said To Be Imminent, 9/28/07)

Chemicals giant Bayer and consumer goods producer Henkel said they are reviewing their Iran business. (Darrel Delamaide, “German firms bend to US sanctions, cutting ties to Iran,” Handelsblatt (Germany), August 9, 2018.)

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Works in Iran through its subsidiary Bayer Parsian AG. 

“Bayer looks back on a very long history in the Iranian market and has been present with an own entity in Iran for more than 50 years.”

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The Managing Director of "Bayer Middle East FZE", Mr. Harald Liedtke, serves as a board member of the German-Iranian Chamber of Commerce in Tehran. (AME Info, "Harald Liedtke new Managing Director of Bayer Middle East," 6/26/2011; German-Iranian Chamber of Commerce website, "Vorstand")

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Over the last three presidential administrations, the United States government has granted Bayer 13 special licenses to do business in Iran. (New York Times, "Companies with Permission to Bypass Sanctions," 12/24/10)

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"Bayer has been selling products in Iran since the 1880s, according to the company, and founded its first local subsidiary there in the 1960s. Bayer, which sells a variety of products, including medicine, soaps, car treatments and shoe soles, has also sold food, oils, X-Ray equipment and drugs to the American government." The company has $610 million in revenue and benefits from the US government for their investments in Iran during 2000-2009.  Their activities in Iran are currently active. (The New York Times, "Profiting from Iran, and the US," 3/6/2010)

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"Germany's trade ties to Iran stretch back to the Middle Ages, and many of the companies currently there have been active in Iran for decades. Some 85 German companies have operations in Iran, from chemical maker BASF AG to Deutsche Lufthansa AG and Bayer AG, and others such as Linde AG and Mercedes-Benz parent Daimler AG are active there, according to the Hamburg-based German-Iranian Chamber of Commerce. More than 7,000 companies conduct business there through local representatives. Germany has become such a big trading partner for Iran because so many of its companies provide the machinery and engineering prowess Iran needs to improve its infrastructure." (The Wall Street Journal, "German Firms Feel Pressure Over Tehran Trade," 10/3/09)

According to a 2021 financial statement, Alstom maintains full ownership over ALSTOM Khadamat S.A, which is located in Iran, and a 1% ownership of PARS SWITCH, also located in Iran. 

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According to its company website, Alstom has an office in Tehran, Iran. 

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In 2018, the U.S. state of Iowa, listed Alstom on its state lists of Companies Doing Business with the Iranian Petroleum/Natural Gas, Nuclear and Military Sectors, rendering Alstom ineligible for investment and/or state contracting.

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On August 17, 2018, Iowa Public Employee's Retirement System removed Alstom from its Iran prohibited companies list. 

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In 2017, the U.S. states of Iowa, listed Alstom on its state lists of Companies Doing Business with the Iranian Petroleum/Natural Gas, Nuclear and Military Sectors, rendering Alstom ineligible for investment and/or state contracting.

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September 2017 Alstom announced a cooperation agreement is expected to be inked by Iran’s Industrial Development Renovation Organization, Trans Russ Company and France’s Alstom in a bid to manufacture passenger wagons, metro carriages and spare parts in Arak Pars Wagon (APW) complex.

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 French multinational rail transport company Alstom signed a deal with the Industrial Development and Renovation Organization of Iran (IDRO) and Iran Khodro Rail Transport Industries Company (IRICO) in Tehran on Monday for establishing a joint company to cooperate on railway projects. (July 25, 2017).

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In June 2017 Alstom entered into a joint venture with the IDRO and Iranian Rail Industries Development Co to build metro and suburban rail carriages in Iran. Alstom will hold 60% of the project.

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“Iran [welcomes] the most senior French trade delegation in years on Monday, telling more than 100 executives that the farsighted among them stood to win the race for business following an easing of some economic sanctions…’A new chapter has begun in relations between Iran and Europe,’ Mohammad Nahavandian, President Hassan Rouhani's chief of staff, was quoted as saying by the official IRNA news agency. ‘You should carry the message back that potential for cooperation with Iran is real and not to be overlooked,’ he told the delegation. ‘Those with longer foresight stand to win this race.’ The delegation of more than 100 executives from Medef, the French employers' association, on a Feb 2-5 trip, met Nahavandian and members of Iran's Chamber of Commerce, Industries, Mines and Agriculture, IRNA said. A source close to the delegation told Reuters it was the most senior group of entrepreneurs and financiers to visit Iran since the 1979 revolution, representing the defence, aviation, petrochemicals, automotive, shipping and cosmetics sectors. Among companies represented were Safran, Airbus , Total, GDF-Suez, Renault, Alcatel, Alstom, Amundi and L'Oréal, the source said. ‘Many of these firms have worked in Iran before and their goal now is to restore links,’ the source said. ‘The very makeup of the delegation shows these people are here to evaluate potential for cooperation.’ A French embassy source in Tehran said the visit was merely exploratory and ‘nothing is to be signed this time around.’” (Reuters, “Iran welcomes French business chiefs after sanctions eased,” 2/3/14)

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"Executives from some of France's biggest companies, including energy giants GDF Suez SA and Alstom SA, are slated to fly to Tehran next month—signaling a fresh wave of corporate interest in Iran as the West eases sanctions. Details of the high-level business trip are emerging after Iran and Western powers completed the terms of an interim nuclear deal on Sunday, with Tehran agreeing to closer international monitoring of its nuclear program in exchange for limited, temporary sanctions relief. The deal specifically eases restrictions related to Iran's aviation, auto and petrochemicals industries……François Carpentier, Alstom's vice president for the Middle East, will take part in the delegation, a spokeswoman for the power and train company said, ‘to test the environment in the country.The embargo is still on, and we respect it,’ she said. ‘If it is eased, we will see.’ Alstom has continued to deliver spare parts to Iran related to a train contract signed 15 years ago, she said, while still abiding by laws and sanctions in place at the time. Alstom has previously said it hasn't discussed any new business with officials in Iran in recent years.” (Wall Street Journal, "French Companies Explore Return to Iran Amid Sanctions Thaw," 1/13/14)

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"Alstom has supplied gas turbine equipment and services that helped Iran meet a growing demand for electrical power. The company currently lists an office in Iran on its Web site, though spokesman Patrick Bessy said the company has not made any sales in Iran for several years."  The company received $226.3 million in benefits and revenue from the US government for their business investments in Iran between 2000-2009.  Their activities in Iran are currently active. (The New York Times, "Profiting from Iran, and the US," 3/6/2010)

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Alstom's World Wide Directory on its website lists an office in Tehran, Iran.

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New York State Comptroller Thomas P. DiNapoli also announced Tuesday the $110 billion fund would freeze an additional $300 million in seven other companies...The decision comes after two years of reviewing these companies, the potential risk of the investments and, in some cases, humanitarian efforts in these countries. "We don't expect our investments to benefit regimes that support genocide and terrorism," said DiNapoli...The fund also plans to monitor and prohibit further investment in ENI (E), Repsol YPF (REP), Royal Dutch Shell PLC (RDSA), Total SA (TOT), ABB Ltd. (ABB), Alstom (ALO.FR) and Snam Rete Gas (SNMRY). Additionally, it plans to focus on other industries including telecommunications. (Wall Street Journal, "NY Comptroller To Divest $86.2M In State Pension Fund Investments," 6/30/09)

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In a 2002 press release, Alstom reported it was "awarded a contract to supply gas turbine equipment and services to provide 900 MW of electric power to the Bandar Abase region. The Hormozgan power plant will be located approximately 50 km north of Bandar Abbas.

The contract, worth around 200 million euros, was placed by MAPNA Investment Co., Iran and Napna International Co., a company recently formed in the UAE to act as financier of and investor on IPP projects. As part of the government’s privatisation policy, IPP projects have been stipulated in the 2^nd Five-year Development Plan of Iran. MAPNA is a pioneer in this field, but already enjoys good business relationships with local and international companies who are acting as sub-contractors and suppliers in its contracts. 

ALSTOM will supply six GT13E2 gas turbines, including the generators, and will supervise the erection and commissioning work. In addition, ALSTOM will provide spare parts for a five-year operation period. The first GT13E2 unit will be delivered in March 2003 and the last unit in October 2003." ("ALSTOM awarded major contract to supply GT13E2 gas turbine technology to Iran," 8/29/02)

"The technology group Wärtsilä will supply engineering and equipment deliveries for two baseload power plants to Iranian energy companies Baran Niroo Beshel Co. and Tamin Niroo Saam Co. This is a breakthrough project as Wärtsilä is supplying the first decentralised power plants of its kind to Iran, showing results from our efforts to support the Iranian power generation market in its transition towards more flexible and smarter technologies." (July 2017)
 

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"Wärtsilä and Industrial Development & Renovation Organization of Iran (IDRO), the largest industrial corporation in Iran have signed a Memorandum of Understanding (MoU) on October 29th. The MoU was signed in connection to the President of Finland Mr. Sauli Niinistö’s recent visit to Iran. With this agreement, both parties agree to cooperate on the development of decentralized power generation in Iran, including power plant operations and maintenance services and related liquefied natural gas (LNG) infrastructure. Wärtsilä will provide relevant expertise and resources to support IDRO in its objective to improve the infrastructure and develop the Iranian industry. In a second phase this cooperation will be extended to the marine sector and the Iranian shipping industry... “With this agreement, Wärtsilä is showing its commitment to support the development of the Iranian industry and power generation sector, on the basis of a mutually beneficial relationship,” says Javier Cavada, President of Wärtsilä Energy Solutions." (Wärtsilä Website, "Wärtsilä and IDRO sign cooperation agreement to develop power generation in Iran | Wärtsilä Website" 11/14/2016).

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"UANI (United Against Nuclear Iran, a US-based organisation that seeks to prevent Iran acquiring a nuclear weapons capability) has called on Wärtsilä to end its, according to UANI, 'irresponsible' business activities. UANI says that Wärtsilä, through its agents and licensees, provides technology and marine diesel engines to Chinese shipbuilders that are currently building oil tankers for the Iranian regime. It says that: 'Wärtsilä’s activities are of particular concern given that the international community is attempting to isolate Iran via its shipping industry, and new tankers greatly assist the regime in attempting to overcome such efforts.' In a letter to Wärtsilä President & CEO, Björn Rosengren, UANI CEO, Ambassador Mark D. Wallace, wrote: 'Earlier this year, UANI launched its Shipping Campaign to compel international shippers, classification societies, P&I clubs and governments worldwide to cease their [Iran] business…In response to UANI’s campaign, members of the International Association of Classification Societies…ceased their classification of Iranian vessels... For example, Wärtsilä has reportedly supplied engines for IRISL vessels, and stated that it maintains an agent in Iran to handle future business with power plant and shipbuilding clients.' The letter mentions Wärtsilä’s involvement in 12 VLCCs being built in China for NITC. It says: 'Put simply, Wärtsilä is assisting the Iranian regime’s development of its most lucrative economic sector, the revenues from which go directly to fund the regime’s nefarious activities, including its nuclear program. In addition, Wärtsilä’s business in Iran includes a partnership with the Iran Heavy Diesel Engine Mfg Co... Wärtsilä’s apparent partnership with DESA is clearly unacceptable.' Wärtsilä has been requested to reply to the letter by 21 December, making its intentions clear with respect to its dealings with Iran." (The Motorship, "Wärtsilä under fire in US over Iran links," 12/19/2012) 

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"Wartsila Corporation, a Finnish manufacturer of ship engines, has built power plants in Iran and in 2002 supplied engines for Islamic Republic of Iran Shipping Line (IRISL) container ships. IRISL is a state-owned shipping company which was later blacklisted by the United States for facilitating the transfer of military cargo to Iran. Wartsila also has received federal contracts to provide, among others, engine parts to the Coast Guard. A Wartsila spokesman,  Atte Palomaki, said that the company operates in full compliance with sanctions, as it did when it supplied engines to a German shipyard building IRISL ships. "At that time IRISL was not on any blacklist," he said, adding that since then  the company has not supplied IRISL with any engines, nor would it because of the blacklisting. He said the company does have an agent in Iran who is paid on a commission basis to service other power plant and shipbuilding customers, but characterized the company's sales efforts there as a "minor activity." As the United States lobbies for tough new sanctions, Mr. Palomaki said Wartsila is keeping a watchful eye on the situation and its business in Iran: "We have concerns in the sense that the U.S. Navy is an important customer for us," he said. "We want to be very careful."

From 2000-2009, the company was the recipient of $95.4 million US federal funds.  Their business in Iran is currently active.  (The New York Times, "Profiting from Iran, and the US", 3/6/2010)

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The enormous New York State Common Retirement Fund plans to divest $86.2 million in investments from nine companies doing business in Sudan and Iran...The decision comes after two years of reviewing these companies, the potential risk of the investments and, in some cases, humanitarian efforts in these countries."We don't expect our investments to benefit regimes that support genocide and terrorism," said DiNapoli. The fund plans to divest out of $86 million in Gazprom (OGZPY), Inpex (1605.TO), Lukoil (LUKOY), Oil And Natural Gas Corp (500312.BY), OMV (OMVKY), Petroleo Brasilia (PBR), Statoil (STO), Wartsila OYJ and Sinopec Corp. DiNapoli said the firms were chosen because "they failed to respond or we were not satisfied with their responses" when asked to provide information to the fund on the investments and their risks. (Wall Street Journal, "NY Comptroller To Divest $86.2M In State Pension Fund Investments," 6/30/09)

Listed as an approved vendor in Iran by NIOEC, NPC, NIGCENG, NISOC and SADAF.

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The Toshiba website lists Badr Electric Company as the distributor in Iran. (Company Website)

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"A spokesperson for Toshiba said the company did sell its products in Iran, but decided in 2009 to stop doing business there except for existing contracts and some sales of medical products."  

From 2000-2009, the company was the recipient of $285.2 million US federal funds.  Their business in Iran is currently active but there are no further plans for new investments.  (The New York Times, "Profiting from Iran, and the US," 3/6/2010)

SonyIran has a website here. 

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According to its Annual Report filed with the SEC for fiscal year 2019: "Sony is aware that certain transactions during the fiscal year ended March 31, 2019, as described below, may be disclosable pursuant to Section 13(r) of the Exchange Act.

Sony does not customarily allocate net profit on a country-by-country or activity-by-activity basis, other than as set forth in Sony’s consolidated financial statements prepared in accordance with U.S. GAAP; thus, the net profit and loss described below are non-U.S. GAAP figures and are estimated solely for the purpose of preparing this disclosure pursuant to Section 13(r) of the Exchange Act. The information below is to the best of Sony’s knowledge, and in particular Sony may not be aware of all potentially reportable sales by third-party-owned dealers and distributors.

• During the fiscal year ended March 31, 2019, a non-U.S. subsidiary of Sony sold medical instruments, including medical printers, print media and monitors, to a third-party-owned dealer in Dubai, which, to the best of Sony’s knowledge, planned to resell those products to hospitals and health organizations in Iran, some of which are under the control of the Iranian Ministry of Health. Sony’s gross revenue from these sales was approximately 1.4 million U.S. dollars, and Sony has estimated that its net profit from such sales was 0.2 million U.S. dollars.
• Sony’s representative office in Tehran, Iran, which was established in 1992, has been closed and has been under liquidation processes since before the beginning of the fiscal year ended March 31, 2014. In the course of liquidation, Sony engages in certain incidental transactions (for example, permits, taxes, and similar matters incidental to the wind-down of the office in Iran) with Iranian government-owned entities. No material revenues or profits are associated with these transactions with the Iranian government-owned entities.

Sony is not aware of any other activity, transaction or dealing by Sony Corporation or any of its affiliates during the fiscal year ended March 31, 2019 that is disclosable in this report under Section 13(r) of the Exchange Act. As of the date of this report, Sony does not anticipate that any activity, transaction or dealing that may be disclosable will be conducted during the fiscal year ending March 31, 2020, except as described above in connection with the wind-down of its representative office in Iran. Nevertheless, Sony has continued to monitor developments in this area, especially in the light of the United States’ decision that was implemented in its entirety on November 5, 2018 to cease its participation in the Joint Comprehensive Plan of Action of July 14, 2015, among the United States, the United Kingdom, China, France, Russia, Germany, the European Union and Iran and re-impose certain secondary sanctions (i.e., laws and regulations that threaten to impose U.S. economic sanctions on non-U.S. companies engaging in specified transactions with Iran outside U.S. jurisdiction). Sony will determine whether and to what extent they affect Sony’s business with Iranian customers as currently conducted and may additionally be conducted. Such business activities may require disclosure pursuant to Section 13(r) of the Exchange Act. Sony intends to conduct any such business activities in accordance with applicable laws and regulations.

Sony believes, and maintains policies and procedures designed to ensure that, its transactions with Iran and elsewhere have been conducted in accordance with applicable economic sanctions laws and regulations and do not involve transactions likely to result in the imposition of sanctions or other penalties on Sony. However, there can be no assurance that Sony’s policies and procedures will be effective, and if the relevant authorities were to impose penalties or sanctions against Sony, the impact of such sanctions could be material."

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During the fiscal year ended March 31, 2017, a non-U.S. subsidiary of Sony sold medical instruments, including medical printers, print media and monitors, to a third-party-owned dealer in Dubai, which, to the best of Sony’s knowledge, planned to resell those products to hospitals and health organizations in Iran, some of which are under the control of the Iranian Ministry of Health. Sony’s gross revenue from these sales was approximately 5.7 million U.S. dollars, and Sony has estimated that its net profit from such sales was 0.4 million U.S. dollars.

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According to its Annual Report filed with the SEC for fiscal year 2016: "   

• During the fiscal year ended March 31, 2016, a non-U.S. subsidiary of Sony sold medical instruments, including medical printers, print media and monitors, to a third-party-owned dealer in Dubai, which, to the best of Sony’s knowledge, planned to resell those products to hospitals and health organizations in Iran, some of which are under the control of the Iranian Ministry of Health. Sony’s gross revenue from these sales was approximately 4.8 million U.S. dollars, and Sony has estimated that its net profit from such sales was 0.3 million U.S. dollars.
• Sony’s representative office in Tehran, Iran, which was established in 1992, has been closed and has been under liquidation processes since before the beginning of the fiscal year ended March 31, 2014. In the course of liquidation, Sony engages in certain incidental transactions (for example, permits, taxes, and similar matters incidental to the wind-down of the office in Iran) with Iranian government-owned entities. No material revenues or profits are associated with these transactions with the Iranian government-owned entities."

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According to its Annual Report filed with the SEC for fiscal year 2015: "Sony is aware that certain transactions during the fiscal year ended March 31, 2015, as described below, may be disclosable pursuant to Section 13(r) of the Exchange Act.

Sony does not customarily allocate net profit on a country-by-country or activity-by-activity basis, other than as set forth in Sony’s consolidated financial statements prepared in accordance with U.S. GAAP; thus, the net profit and loss described below are non-U.S. GAAP figures and are estimated solely for the purpose of preparing this disclosure pursuant to Section 13(r) of the Exchange Act. The information below is to the best of Sony’s knowledge, and in particular Sony may not be aware of all potentially reportable sales by third-party-owned dealers and distributors.

• During the fiscal year ended March 31, 2015, a non-U.S. subsidiary of Sony sold medical instruments, including medical printers and paper, to a third-party-owned dealer in Dubai, which, to the best of Sony’s knowledge, planned to resell those products to hospitals and health organizations in Iran, some of which are under the control of the Iranian Ministry of Health. Sony’s gross revenue from these sales was approximately 2.9 million U.S. dollars, and Sony has estimated that its net profit from such sales was 0.1 million U.S. dollars.       
• Sony’s representative office in Tehran, Iran, has been under liquidation processes and no longer engaged in any operation or activities other than the matters necessary for liquidation since before the beginning of the fiscal year ended March 31, 2014. In the course of liquidation, the office would engage in certain incidental transactions (for example, permits, taxes, and other similar matters incidental to the wind-down of the office in Iran) with Iranian government-owned entities. No material revenues or profits are associated with these transactions with the Iranian government.

Sony is not aware of any other activity, transaction or dealing by Sony Corporation or any of its affiliates during the fiscal year ended March 31, 2015 that is disclosable in this report under Section 13(r) of the Exchange Act. As of the date of this report, Sony does not anticipate that any activity, transaction or dealing that may be disclosable will be conducted during the fiscal year ending March 31, 2016, except as described above in connection with the wind-down of its representative office or for certain transactions through third-party-owned dealers that Sony believes to be intended for hospitals and health organizations in Iran. Nevertheless, in the future, Sony may conduct additional sales activities in Iran through third-party-owned dealers/distributors, which may require disclosure pursuant to Section 13(r) of the Exchange Act. Sony intends to conduct any such sales in accordance with applicable law."

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According to its Annual Report filed with the SEC for fiscal year 2014: "Sony is aware that certain transactions during the fiscal year ended March 31, 2014, as described below, may be disclosable pursuant to Section 13(r) of the Exchange Act.

Sony does not customarily allocate net profit on a country-by-country or activity-by-activity basis, other than as set forth in Sony’s consolidated financial statements prepared in accordance with U.S. GAAP; thus, the net profit and loss described below are non-U.S. GAAP figures and are estimated solely for the purpose of preparing this disclosure pursuant to Section 13(r) of the Exchange Act. The information below is to the best of Sony’s knowledge, and Sony in particular may not be aware of all potentially reportable sales by third-party-owned dealers and distributors.

• Before the beginning of the fiscal year ended March 31, 2014, Sony ceased its sales of professional equipment for use in television broadcasting to a third-party-owned dealer in Dubai, except for selling after-sales service parts and providing after-sales service training for such equipment, which were also ceased by the end of May 2013. The third-party-owned dealer in Dubai, to the best of Sony’s knowledge, may have resold such after-sales service parts and provided relevant after-sales services to the Islamic Republic of Iran Broadcasting, which we believe is a parent company of such dealer. During the fiscal year ended March 31, 2014, Sony’s gross revenue from these sales and training was approximately 14,000 U.S. dollars, and Sony has estimated that its net profit from such sales and training was approximately 11,000 U.S. dollars.
• During the fiscal year ended March 31, 2014, a non-U.S. subsidiary of Sony sold medical instruments, including medical printers, paper and monitors to a third-party-owned dealer in Dubai, which, to the best of Sony’s knowledge, planned to resell those products to the Iranian Ministry of Health. Sony’s gross revenue from these sales was approximately 2.5 million U.S. dollars, and Sony has estimated that its net profit from such sales was less than 0.5 million U.S. dollars.
• During the fiscal year ended March 31, 2014, a non-U.S. subsidiary of Sony closed a dormant bank account at Future Bank B.S.C. in Bahrain. Sony’s non-U.S. subsidiary closed the account in March 2014 and withdrew the remaining balance of the equivalent of 26,000 U.S. dollars, less de minimis fees.
• Sony’s representative office in Tehran, Iran, has been under liquidation processes and no longer engaged in any operation or activities other than the matters necessary for liquidation during the fiscal year ended March 31, 2014. In the course of liquidation, the office may engage in certain incidental transactions (for example, permits, taxes, and other similar matters incidental to the wind-down of the office in Iran) with Iranian government-owned entities. No material revenues or profits are associated with these transactions with the Iranian government.

Sony is not aware of any other activity, transaction or dealing by Sony Corporation or any of its affiliates during the fiscal year ended March 31, 2014 that is disclosable in this report under Section 13(r) of the Exchange Act. As of the date of this report, Sony does not anticipate that transactions that may be disclosable, as discussed above, will continue during the fiscal year ending March 31, 2015, except as described above in connection with the wind-down of its representative office or for certain transactions through third-party-owned dealers that Sony believes to be intended for the Iranian Ministry of Health. Nevertheless, in the future, Sony may conduct additional sales activities in Iran through third-party-owned dealers/distributors, which may require disclosure pursuant to Section 13(r) of the Exchange Act. Sony intends to conduct any such sales in accordance with applicable law.

Sony believes that, and maintains policies and procedures designed to ensure that, its transactions with Iran and elsewhere have been conducted in accordance with applicable economic sanctions laws and regulations and do not involve transactions likely to result in the imposition of sanctions or other penalties on Sony. However, there can be no assurance that Sony’s policies and procedures will be effective, and if the relevant authorities were to impose penalties or sanctions against Sony, the impact of such sanctions could be material."

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Company website lists numerous outlet and retail shops in Iran. (Company Website)

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“Sony Corp. (6758) sold almost $13 million in video and medical equipment to dealers in Dubai that resold the gear in Iran, the company said. The recipients included groups under U.S. sanctions. In a U.S. filing yesterday, Sony said it sold broadcast equipment, security cameras and video-conferencing gear to dealers who planned to resell or resold the products to groups including the Information Technology Department of the Iranian Police and the Islamic Republic of Iran Broadcasting… Sony ‘believes that, and maintains policies and procedures designed to ensure that, its transactions with Iran and elsewhere have been conducted in accordance with applicable economic sanctions laws and regulations,’ according to the filing. Penalties or sanctions taken against the company could be material if any government disagrees, Sony said... One dealer was a subsidiary of the Islamic Republic of Iran Broadcasting, Sony said in the filing. The company also reported sales of medical instruments -- including printers, paper and monitors -- it said were intended for the Ministry of Health.  Sony said it made the disclosure under the Iran Threat Reduction and Syria Human Rights Act of 2012 and related amendments to the Securities Exchange Act of 1934.  The company said it registered a profit of about $500,000 from the sale.” (Bloomberg, “Sony Reports Tech Sales to Iran that May Violate Sanctions,” 6/27/13)

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According to its Annual Report filed with the SEC for fiscal year 2013: "Sony is aware that certain transactions during the fiscal year ended March 31, 2013, as described below, may be disclosable pursuant to Section 13(r) of the Exchange Act.

Sony does not customarily allocate net profit on a country-by-country or activity-by-activity basis, other than as set forth in Sony’s consolidated financial statements prepared in accordance with U.S. GAAP; thus, the net profit and loss described below are non-U.S. GAAP figures and are estimated solely for the purpose of preparing this disclosure pursuant to Section 13(r) of the Exchange Act. The information below is to the best of Sony’s knowledge, and Sony in particular may not be aware of all potentially reportable sales by third-party-owned dealers and distributors.

• During the fiscal year ended March 31, 2013, Sony sold professional broadcast equipment, including cameras, switchers, VTRs, monitors and other associated broadcast equipment and media products for use in television broadcasting, to a third-party-owned dealer in Dubai, which, to the best of Sony’s knowledge, resold that equipment to the Islamic Republic of Iran Broadcasting, which we believe is a parent company of such dealer. Sony’s gross revenue from these sales was approximately 5.2 million U.S. dollars, and Sony has estimated that its net profit from such sales was less than 0.3 million U.S. dollars.
• During the fiscal year ended March 31, 2013, Sony sold medical instruments, including medical printers, paper and monitors to a third-party-owned dealer in Dubai, which, to the best of Sony’s knowledge, planned to resell those products to the Iranian Ministry of Health. Sony’s gross revenue from these sales was approximately 4.9 million U.S. dollars, and Sony has estimated that its net profit from such sales was less than 0.1 million U.S. dollars.
• During the fiscal year ended March 31, 2013, Sony sold video security cameras and hard disk products to a third-party-owned dealer in Dubai, which, to the best of Sony’s knowledge, planned to resell those products to the judiciary, Ferdowsi University, Iran Railway, Bank Sepah and Bank Melli in Iran. Such equipment is generally used by purchasers for the purposes of standard building/premises security in fixed locations. During the fiscal year ended March 31, 2013, Sony’s gross revenue from these sales was approximately 2.2 million U.S. dollars, and Sony has estimated that its net profit from such sales was less than 0.1 million U.S. dollars.
• During the fiscal year ended March 31, 2013, Sony sold video conference equipment to third-party-owned dealers in Dubai, which, to the best of Sony’s knowledge, planned to resell that equipment to the Information Technology Department of the Iranian Police. Sony’s gross revenue from these sales was approximately 0.5 million U.S. dollars, and Sony estimates that it recorded a net loss from such sales.

Sony’s small representative office in Tehran, Iran, may engage in certain incidental transactions (for example, permits, utilities, and other similar matters incidental to operating an office in Iran) with Iranian government-owned entities. No material revenues or profits are associated with these transactions with the Iranian government.

Sony is not aware of any other activity, transaction or dealing by Sony Corporation or any of its affiliates during the fiscal year ended March 31, 2013 that is disclosable in this report under Section 13(r) of the Exchange Act. As of the date of this report, Sony does not anticipate that transactions that may be disclosable, as discussed above, will continue during the fiscal year ending March 31, 2014, except for the operation of its representative office and certain transactions through third-party-owned dealers that Sony believes to be intended for the Islamic Republic of Iran Broadcasting and the Iranian Ministry of Health. Nevertheless, in the future, Sony may conduct additional sales activities in Iran through third-party-owned dealers/distributors, which may require disclosure pursuant to Section 13(r) of the Exchange Act. Sony intends to conduct any such sales in accordance with applicable law.

Sony believes that, and maintains policies and procedures designed to ensure that, its transactions with Iran and elsewhere have been conducted in accordance with applicable economic sanctions laws and regulations and do not involve transactions likely to result in the imposition of sanctions or other penalties on Sony. However, there can be no assurance that Sony’s policies and procedures will be effective, and if the relevant authorities were to impose penalties or sanctions against Sony, the impact of such sanctions could be material."

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"In the electronics and home appliances sections, sales of LG and Sony flat-screen televisions come with attractive service plans and free home installations. Local brands, such as Pars, go mostly ignored." (The Washington Post, "Iran hopes to resist sanctions by boosting production," 10/27/2012) 

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"But its population of about 75 million includes a sizeable urban middle class who have been avid consumers of foreign-made goods, including Samsung and Sony electronics and Peugeot cars." (Reuters, "Iran says it will cut imports of non-essential goods," 10/14/2012)

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"Sony has been in Iran since at least 2000 and currently has an office in the country."  From 2000-2009, the company was the recipient of $103.3 million US federal funds.  The company's business in Iran is currently active.  (The New York Times, "Profiting from Iran, and the US," 3/6/2010)