UANI

“A Bloomberg Markets investigation has found that Koch Industries -- in addition to being involved in improper payments to win business in Africa, India and the Middle East -- has sold millions of dollars of petrochemical equipment to Iran, a country the U.S. identifies as a sponsor of global terrorism. Internal company documents show that the company made those sales through foreign subsidiaries, thwarting a U.S. trade ban… Cohlmia says Koch fired the employees and sales agents involved in the illicit payments and strengthened internal controls. Regarding sales to Iran, she wrote, ‘During the relevant time frame covered in your article, U.S. law allowed foreign subsidiaries of U.S. multinational companies to engage in trade involving countries subject to U.S. trade sanctions, including Iran, under certain conditions.’ Koch has since stopped all of its units from trading with Iran, she says… Internal company records show that Koch Industries used its foreign subsidiary to sidestep a U.S. trade ban barring American companies from selling materials to Iran. Koch-Glitsch offices in Germany and Italy continued selling to Iran until as recently as 2007, the records show. The company’s products helped build a methanol plant for Zagros Petrochemical Co., a unit of Iran’s state-owned National Iranian Petrochemical Co., the documents show.” (Bloomberg, "Koch Brothers Flout Law Getting Richer With Secret Iran Sales," 10/3/2011)

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"The trading with Iran involved Koch subsidiaries in Germany and Italy providing key components for a huge state-owned petro-chemical plant, despite a U.S. ban on trade with Iran since 1995."(ABC News,"Report: 'Secret Sins' of Koch Industries," 10/7/2011)

"The Persian Gulf country will buy two Ukrainian-made Antonov-158s, after a test flight of the aircraft earlier this month, Mohammad-Ali Sirati, managing director of the Iranian aircraft company, was cited as saying by the official Islamic Republic News Agency. The countries then will start to jointly build the aircraft next year, Sirati, whose company will be in charge of the project, said in Tehran yesterday. Some 30 percent of each plane will be made in Iran, state-run media reported." (Business Week, "Iran Says Antonov-158 Built With Ukraine May Fly in 2013," 10/6/2011)

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Antonov lists on its website that their AN-24 turboprop aircraft is serially produced at HESA plant in Isfahan, Iran. (Antonov website)

Over the last three presidential administrations, the United States government has granted Hercules U.S.A. Inc. 92 special licenses to do business in Iran. (New York Times, "Companies with Permission to Bypass Sanctions," 12/24/10)

"This license authorizes Union Carbide to enter into transactions necessary to dissolve its Iranian branch, which the company says has conducted no business since the imposition of sanctions." (New York Times, "Licenses Granted to U.S. Companies Run the Gamut," 12/24/10)

"Cabot received this license after it assisted in a sales transaction of silicon dioxidebetween two non-U.S. parties. The company applied for the exception after learning that the goods would be shipped via the Iranian government-owned shipping line known as Irisl. 'The items in question are already loaded onto containers at the dock and ready to be loaded onto the vessel, which is due to depart the port of Antwerp, Belgium, on Monday,' the company's lawyers, in the firm of Baker & McKenzie, wrote to OFAC on May 11, 2001. OFAC's director, Adam J. Szubin, stressed that the approval came seven years before Irisl was blacklisted by the United States for aiding Iran's nuclear and ballistic missile programs. Up until then, he said, the agency made case-by-case exceptions to a broad prohibition against dealing with Iranian companies in situations like this one in which the company had no prior knowledge that an Iranian entity was involved in the transaction and granting the license did not involve a direct payment from a United States person or company to an Iranian entity." (New York Times, "Licenses Granted to U.S. Companies Run the Gamut," 12/24/10)

The US Government granted Albemarle Corporation a license to sell ibuprofin in Iran. (New York Times, "Licenses Granted to U.S. Companies Run the Gamut," 12/24/10)

Transammonia actively does business in Iran via a Swiss subsidiary. (CNBC. "Transammonia:A Story of American Business in Iran," 12/7/10)

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Transammonia has performed business dealings with the Iran Petrochemical Commercial Company (IPCC), which is the subsidiary and international trading arm of the National Petrochemical Company (NPC). NPC is wholly owned by the Iranian government. It is responsible for the development and operation of the country's petrochemicals sector and is the second largest producer and exporter of petrochemicals in the Middle East after Saudi Arabia's Sabic.

On June 16, 2010, the U.S. Treasury Department added NPC and its subsidiary IPCC to the Iranian Transactions Regulations (ITR), which “prohibit transactions between U.S. persons and the Government of Iran. These identifications allow U.S. persons and others to identify Iranian Government entities and protect themselves against the risks posed by such entities.” (U.S. Department of Treasury, “Fact Sheet: U.S. Treasury Department Targets Iran’s Nuclear and Missile Programs,” 6/16/10)
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February 2010: “Transammonia purchased 23,000 tonnes from IPCC at $370/tonne FOB for late March loading from BIK [(Bandard Imam Khomeinei)].” (Chemical News & Intelligence, 2/24/10)

July 2009: “This price was $18/tonne lower than last done spot business in the Middle East, [1]which was concluded at $200/tonne FOB following a sale by Iran's Petrochemical Commercial Co (PCC) to trader Transammonia.” (Chemical News & Intelligence, 7/3/09)

May 2009: “Trader Transammonia confirmed it had purchased 23,400 tonnes from Iran Petrochemical Commercial Co (IPCC) at $200/tonne FOB (free on board) with 30 days' credit… Transammonia will ship 15,000 tonnes on 18-21 May on the Marycam Swan for shipment to the southeast Asia. The balance of the purchase will be lifted later, it said.” (Chemical News & Intelligence, 5/14/09).

May 2006: The Agricultural Support Services Company of Iran (ASSC) “received nine offers from traders and purchased urea from Transammonia at Euro212/tonne cost and freight (CFR) southern Iranian ports.” (Chemical news & Intelligence, 5/8/06)

SABIC signed a memorandum of understanding with Iran's PCCI in 2002 to export 500,000 tons of Methyl Tertiary Butyl Ether (MTBE) over five years. MTB is "a gasoline additive that replaces lead to raise the gasoline octane number and reduces harmful gas emissions from vehicles and engines." (European Fuel Oxygenates Association, "Sabic exports 500,000 tonnes of MTBE to Iran," 7/16/2002)

Helm AG is a Hamburg-based chemicals firm specializing in plastics, fertilizers, pharmaceuticals, and acids. The company has branches in over 30 countries and had a 2009 turnover of 5 million euros (Company Website). 

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Helm AG had previously been involved in the importation of Iranian petrochemicals to Europe, but announced in October of 2010 that they would be pulling out of the business. A company spokesman announced that "The company management decided there would be no more business with Iran - either directly or indirectly. The decision came into effect immediately and will not be revised in the immediate future" (Platts). 

In its May 2010 6-K report form, Braskem reports that operational problems in Iran may affect the company’s profitability:

"The outlook for the medium term is less favorable, as the industry expects the new capacity coming online in the Middle East and Asia to pressure profitability in the world petrochemical industry as of the second half of this year, since the additional capacity announced exceeds the expected growth in demand. However, various factors could minimize the impact from these new players and maintain industry profitability at levels above current expectations, such as: (i) continued operational problems in Iran, where crackers have operated at rates of around 50% since their start-up (2005); (ii) project and commissioning delays at these new capacities; (iii) the lack of qualified labor; (iv) problems with the supply of natural gas feedstock, such as in Qatar; and (v) stronger growth in world demand." (SEC, May 2010 6-K Report Form, 5/14/10)