Conglomerate

On June 1, 2020, the Ohio Police & Fire Pension Fund (“OP&F”) listed Raizen on its scrutinized companies Iran/Sudan list.   On September 24, 2008, OP&F adopted an Iran and Sudan Divestment Policy, which notes, “[t]he purpose of this Policy is to divest and restrict the purchase of stocks and bonds (“direct holdings”) issued by a publicly traded Company… with “scrutinized active business operations” in Iran and Sudan.”  

According to a settlement with the US Treasury signed August 21, 2020, "From approximately December 2012 to Janumy 2016, Iscm Turkey [a Turkish subsidiary] appears to have violated§ 560.215 of the ITSR when it engaged in al least 144 transactions involving Iran valued at $383,443 that would have been prohibited by§§ 560.203, 560.204, 560.206, and 560.208 of the ITSR if engaged in by a U.S. person (the "Apparent Violations"). The Apprent Violations constitute an egregious case and were voluntarily self-disclosed.

[Berkshire Hathaway aggreed to] pay or arrange for the payment to the U.S. Department of the Treasury the amount of $4,144,651." 

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"Berkshire Hathaway Inc. has agreed to pay roughly $4.1 million to settle allegations that a Turkish subsidiary violated U.S. sanctions on Iran. The U.S. Treasury Department on Tuesday alleged that Berkshire’s indirect subsidiary—Iscar Kesici Takim Ticareti ve Imalati Limited Sirket—sold cutting tools and related inserts to two third-party Turkish distributors between 2012 and 2016, knowing that the goods would be shipped to a distributor in Iran for resale to end-users there." (Wall Street Journal, "Berkshire To Pay $4.1 Million To Settle Allegations Of Violating U.S. Sanctions On Iran," 10/21/2020). 

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According to its Quarterly report filed with the SEC for fiscal year 2016: "We are making the following disclosures under Section 13(r) of the Exchange Act because our management recently became aware that one of our foreign subsidiaries made sales through a third-party distributor to customers in Iran that include or may include parties (the "Iran Parties") that meet the definition of the "Government of Iran" under Section 560.304 of 31 C.F.R. Part 560. Based upon currently known information, total revenues to our subsidiary from sales to the Iran Parties, which took place from June 2013 through November 2015, were approximately $45,000, and the total net income attributable to those sales was approximately $2,500.

Our subsidiary has stopped all shipments to the Iran Parties, and the subsidiary does not intend to continue sales to, or engage in other dealings with, the Iran Parties. On May 6, 2016, we submitted initial notifications of voluntary self-disclosures to the U.S. Department of the Treasury, Office of Foreign Assets Control ("OFAC"), and the U.S. Department of Commerce, Bureau of Industry and Security ("BIS"). We will submit further information to OFAC and BIS after completing an internal investigation, which we are conducting with the assistance of outside counsel, and we intend to cooperate fully with both agencies."

The Iranian company HEPCO lists SANKO products under license on its company website. (HEPCO Website, “Under License”)

In 2017 the U.S. state of California listed MMC as a company under review for possibly providing consulting projects on Iranian energy projects.

"The company was reported as potentially having a subsidiary with ties to petrochemical production 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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According to its Annual Report filed with the SEC for fiscal year 2019: "As authorized by the U.S. Treasury’s Office of Foreign Assets Control (OFAC), a non-U.S. subsidiary of the Company completed sales of products used for process and water treatment applications in upstream oil and gas production related to the operation of and production from the Rhum gas field off the Scottish coast (Rhum) totaling $0.7 million during the subsidiary’s fiscal year ended November 30, 2019, and a nominal amount of sales of such products during December 2019. The net profit before taxes associated with these sales for each period were $0.1 million and nominal, respectively. Rhum is jointly owned by Serica Energy plc and Iranian Oil Company (U.K.) Limited. Our non-U.S. subsidiary intends to continue the Rhum-related activities, consistent with a specific license obtained from OFAC by its customers, and such activities may require additional disclosure pursuant to the abovementioned statute."

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According to its Annual report filed with the SEC for fiscal year 2018: "Our non-U.S. subsidiary timely completed the winding down of its business activities in Iran pursuant to the wind-down license. For its fiscal year 2018, through the completion of the wind-down period, our non-U.S. subsidiary completed the following sales related to businesses in our Energy operating segment to a distributor in Dubai and two distributors in Iran: sales of products used for process and water treatment applications in (i) upstream oil and gas production and (ii) petrochemical plants totaling $4.7 million. The net profit before taxes associated with these sales is estimated to be $0.9 million.

In addition to the foregoing, as authorized by OFAC, a non-U.S. subsidiary of the Company completed sales of products used for process and water treatment applications in upstream oil and gas production related to the operation of and production from the Rhum gas field off the Scottish coast (Rhum) totaling $0.6 million during the subsidiary’s fiscal year ended November 30, 2018, and additional sales of such products totaling $0.1 million were completed during December 2018. The net profit before taxes associated with these sales for each period were nominal. Rhum was previously jointly owned by BP Exploration Operating Company Limited (BP) and Iranian Oil Company (U.K.) Limited. BP completed the sale of its ownership stake in the Rhum joint arrangement and transferred its role as operator to Serica Energy plc on November 30, 2018. Our non-U.S. subsidiary intends to continue the Rhum-related activities, consistent with a specific license obtained from OFAC by its customers, and such activities may require additional disclosure pursuant to the abovementioned statute."

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Ecolab has reported that a subsidiary has sold products for upstream oil and gas production and petrochemical plants in Iran. In 2017, CalSTRS designated Ecolab as “Under Review” for potentially having ties to Iran. In 2018, CalSTRS removed Ecolab after confirming the company was winding down activities in Iran and reviewing the company’s business with Iran and internal controls to prevent sanction violations.

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In 2017 the U.S. state of California identified Ecolab as a company under review for Ecolab has reported that a subsidiary has sold products for upstream oil and gas production and petrochemical plants in Iran.

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According to its Annual Report filed with the SEC for fiscal year 2017: "a wholly-owned non-U.S. subsidiary of the Company completed the following sales related to businesses in our Energy operating segment pursuant to and in compliance with the terms and conditions of OFAC’s General License H: sales of products used for process and water treatment applications in (i) upstream oil and gas production and (ii) petrochemical plants totaling $5.9 million during the subsidiary’s fiscal year ended November 30, 2017, and additional sales of such products totaling $0.4 million during December 2017, were made to a distributor in Dubai and two distributors in Iran. The net profit before taxes associated with these sales is estimated to be $1.6 million and $0.1 million, respectively. Our non-U.S. subsidiary intends to continue doing business in Iran under General License H in compliance with U.S. economic sanctions and export control laws, which sales may require additional disclosure pursuant to the abovementioned statute."

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According to its Annual Report filed with the SEC for fiscal year 2016: "a wholly-owned non-U.S. subsidiary of the Company completed the following sales related to businesses in our Energy operating segment pursuant to and in compliance with the terms and conditions of OFAC’s General License H: sales of products used for process and water treatment applications in (i) upstream oil and gas production and (ii) petrochemical plants totaling $535,000 during the subsidiary’s fiscal year ended November 30, 2016, and additional sales of such products totaling $571,000 during December 2016, were made to a distributor in Dubai and two distributors in Iran. The net profit before taxes associated with these sales is estimated to be $117,180 and $351,192, respectively. Our non-U.S. subsidiary intends to continue doing business in Iran under General License H in compliance with U.S. economic sanctions and export control laws, which sales may require additional disclosure pursuant to the abovementioned statute."

On August 31, 2017 DuPont merged with Dow Chemicals to create DowDuPont.

As of July 1, 2021, ADKL is no longer listed on US state of Mississippi's list of Companies Doing Business with the Iranian Petroleum/Natural Gas, Nuclear and Military Sectors.

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

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In 2019, the U.S. state of Mississippi listed ADKL on its state lists of Companies Doing Business with the Iranian Petroleum/Natural Gas, Nuclear and Military Sectors, rendering ADKL ineligible for investment and/or state contracting.

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

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“Iran on Thursday awarded a major contract to a German company over the development of a petrochemical project in the country’s southwestern city of Masjed Soleyman. The contract has been awarded to Abels Decker Kuhfuß Lenzen (ADKL) and has an initial value of €2 billion which will be increased to as high as €10 billion in the future. Accordingly, the ADKL will cooperate with Masjed Soleyman Petrochemical Industries Company over providing the funds, transferring the technology and implementing contracts for the project within the framework of engineering, procurement, construction and finance (EPCF). The deal was signed during the visit to Iran by Garrelt Duin, the state minister for economic affairs and energy of Germany’s Nordrhein-Westfalen State. Yousef Davoodi, the managing director of Masjed Soleyman Petrochemical Industries Company, told reporters after signing the contract with ADKL that his company is interested in working with European enterprises. Davoodi also expressed hope that this would be the start of a mutually beneficial cooperation with ADKL. Also, ADKL’s Bernd Lenzen told reporters that €2 billion will be invested in the first phase of a petrochemical project in Masjed Soleyman. Lenzen added that this will be increased to €10 billion in further phases. Masjed Soleyman Petrochemical Industries Company says on its website that a petrochemical project – that it plans to develop in northern parts of Khouzestan province – will produce urea and ammonia as its key products. The daily production target of each in the first phase will be 3,250 tons of urea, 2,050 tons of ammonia.” (The Iran Project, “Iran awards major petchem deal to Germany’s ADKL,” 5/26/2016)

As of February 2022, Bouygues is not listed on Michigan's state list of companies Doing Business with the Iranian Petroleum/Natural Gas, Nuclear and Military Sectors, rendering Bouygues ineligible for investment and/or state contracting.

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

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May 2017 – “A preliminary deal signed by Bouygues (BOUY.PA) last year to build and run a new terminal at Tehran’s Khomeini airport has been canceled, a spokesman for the French construction group said on Friday.”

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"European companies are promising billions in new deals in Iran—€5.7 billion from Italian steelmaker Danieli and more than €300 million from French car builder PSA Peugeot Citroën, among others—as Iranian President Hassan Rouhani works to revive trade and political ties on the Continent this week. Mr. Rouhani landed in Rome on Monday on his first overseas trip since the European Union lifted sanctions on Jan. 16 in return for Tehran’s implementation of key restrictions on its nuclear program. The trip will take Mr. Rouhani from Vatican City—marking the first meeting between an Iranian president and a pope since 1999—to the gilded halls of Paris’s Élysée Palace. With a number of U.S. sanctions still in place, European countries are moving quickly to re-establish ties to sell everything from consumer goods to aircraft. Italian and Iranian companies signed deals valued at about €17 billion ($18.36 billion) late Monday ahead of a formal dinner between Mr. Rouhani and Italian Prime Minister Matteo Renzi. Earlier in the day, Italian steel firm Danieli said it would sign deals valued at about €5.7 billion during the visit. Other firms signing agreements on Monday included oil-field services company Saipem SpA, energy group Ansaldo Energia and ship maker Fincantieri SpA... In France, auto makers, airport operators and construction firms were primed for a raft of accords when Mr. Rouhani visits French President François Hollande on Thursday. French car maker Peugeot is expected to complete an agreement to manufacture cars in Iran as part of a 50-50 joint venture with auto maker Iran Khodro valued at more than €300 million, according to a person familiar with the matter... In opening its doors for business, however, Tehran is demanding European firms locate technological know-how and factories inside Iran to revive the country’s hobbled job market. Another key plank of Iran’s ambitions is the revamping of its creaky aviation industry. Iranian officials say they plan to buy more than 100 new jets from Airbus Group SE to replenish the country’s small and poorly maintained commercial passenger fleet. Mr. Rouhani’s meeting with Mr. Hollande in Paris on Thursday is timed to the unveiling of about €400 million in contracts to expand Iran’s aging airports for increased tourism and business traffic, one of the people familiar with the matter said. Tehran is expected to tap French airport operator Aéroports de Paris and construction-and-media conglomerate Bouygues SA to design and build a new terminal at Tehran’s Imam Khomeini International Airport, according to the people. French construction firm Vinci SA will develop and operate airports in Mashhad and another Iranian city, the people said... Just minutes after Mr. Rouhani landed in Rome, Italian airline Alitalia SpA said it would boost the number of flights between Rome and Tehran from four times a week to daily, starting March 27." (Wall Street Journal, “Iran President Visits Europe to Seal Post-Sanctions Deals Worth Billions,” 1/25/2016)

“May 27 Liaoning Wellhope Agri-tech Joint Stock Co Ltd… Says it signs MOU with Iran's Abzi Gostar Mobtakeran Teheran feed to set up JV in Iran” (Reuters, “BRIEF-Liaoning Wellhope Agri-Tech signs mou with Iran's Abzi Gostar to set up JV,” 5/27/2016)

On August 14, 2020, SK Holdings was removed from the Iowa Public Employees' Retirement System Iran Prohibited Companies List. 

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

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“A group of top Korean business tycoons -- including SK Group chairman Chey Tae-won, GS Group chairman Huh Chang-soo and LS Group chairman Koo Cha-yol -- flocked to the promising Iran market Monday in an attempt to explore new business opportunities in many sectors ranging from energy to infrastructure construction... SK Group, the nation’s third largest conglomerate, is one of the most proactive in scouting for business opportunities in Iran, which has an enormous pent-up demand for resumption of oil exports and modernization of its infrastructure after the recent lifting of international sanctions.'During his visit, the group chairman will seek deals in areas such as energy, trading and infrastructure restoration with five CEOs from affiliates including SK E&S, SK Energy and SK Telecom,’ a company spokesperson said. Industry watchers forecast SK which has imported crude oil from Iran for years could clinch possible lucrative business deals in Iran ahead of other Korean conglomerates. According to the group, SK Innovation, the holding company of SK’s energy businesses, has already increased imports of crude oil and natural gas condensate from Iran in the first quarter this year... In contrast with the cautious approach of corporates about striking business deals in a new market full of uncertainties, the Korean government was confident that trade and investment with Iran will be lifted to the pre-sanction levels. 'The two heads of state agreed on cooperation and exchanges both in economic and noneconomic areas,' Cheong Wa Dae said in a statement released after the historic summit meeting between President Park and her Iranian counterpart Hassan Rouhani. In the economic sector, private and public corporate delegation members are expected to sign memoranda of understanding for 66 infrastructure-related construction projects ranging from rails to power plants to hospitals. In return for hiring Korean contactors, Seoul has a plan to increase its daily crude imports from Iran to around 280,000 barrels from 115,000 barrels last year.” (The Korea Herald, “Tycoons in search of growth in Iran,” 5/2/2016)

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"An economic mission consisting of representatives from 236 of the nation’s businesses are heading to Iran with President Park Geun-hye next month now that the sanctions against Iran have been lifted… The nation’s No. 3 conglomerate, SK Group, will send its chairman, Chey Tae-won, as well as executives from its oil refiners SK Innovation, SK Networks and SK Energy.” (Korea JoongAng Daily, “More than 230 Korean businessmen join entourage to Tehran,” 4/28/2016)