Energy

Jereh Group

Industry
Energy
Symbol
SHE: 002353
Sources

According to a settlement with the US Treasury Department signed November 29, 2018, "The Jereh Group is an integrated oil and gas company specializing in oil and gas equipment manufacturing, engineering and construction, and oilfield technology services. The Jereh Group employs approximately 5,000 employees worldwide and is headquartered in the city of Yantai in China's northeastern Shandong province. 

From on or about October 2, 2014 to on or about March 4, 2016, the Jereh Group appears to have violated the Iranian Transactions and Sanctions Regulations, 31 C.F.R. part 560 (ITSR), on at least 11 occasions. Specifically, the Jereh Group appears to have violated §§ 560.203 and 560.204 of the ITSR when it exported or reexported, or attempted to export or reexport, U.S.-origin goods ultimately intended for Iran via China, in some cases after incorporation into other goods in China (referred to hereafter as the "Apparent Violations"). Two of the 11 transactions involved shipments that were seized by U.S. Customs and Border Protection (CPB). The Jereh Group did not cease its activities until the U.S. Department of Commerce's Bureau of Industry and Security (BIS) added Yantai Jereb Oilfield Services Group Co., Ltd. and four of its former employees, as well as other companies and individuals involved in the prohibited activities described below, to the Entity List.

[Jereh Group agreed to] pay or arrange for the payment to the U.S. Department of the Treasury the amount of $2,774,972."

CNOOC Ltd.

Industry
Energy
Country
Hong Kong
Sources

On June 16, 2011, CNOOC Ltd was added to the Florida State Board of Administration List of Prohibited Investments (Scrutinized Companies) due to its involvement in Iran. As of March 9, 2021, CNOOC Ltd remains on the SBA list of prohibited investments. 

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

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

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"Chinese oil companies such as Sinopec [SASADZ.UL], CNOOC Ltd and others have managed to reduce their shipments of Iranian oil but it is unclear which Chinese government parties might still be buying Iranian oil, a senior U.S. energy official said on Tuesday." (Reuters, 9/10/2019).

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According to CNOOC 20-F Filings, the company cites in its risk section the potential for U.S. sanctions related to its affiliates’ operations in Iran and Sudan. In particular, one of the company’s noncontrolled affiliates continued to provide certain drilling and other related services in Iran. In 2011, CalSTRS staff met with executives of the company in its offices in Beijing. The company confirmed its parent may have ties to Iran, but it does not, and will not, seek business in Iran as the company has and is looking to purchase more assets in the United States. CNOOC is listed on the December 31, 2018 CalSTRs Portfolio of companies identified as possibly having ties to Iran and from which CalSTRs has divested from and restricted in 2018. While CNOOC does not appear to have direct ties to Iran, CalSTRS is uncomfortable with its parent company’s relations to the country. In 2012, CalSTRS divested holdings of CNOOC and designated the company as “Divested and Restricted.” CalSTRS has maintained the “Divested and Restricted” designation in 2018.

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According to its Annual Report filed with the SEC for fiscal year 2018, 2017 : "To our knowledge, in 2018, China Oilfield Services Limited (COSL), one of our non-controlled affiliates, provided certain drilling services in Iran. We cannot predict at this time whether U.S. sanctions will be imposed on any of our affiliates."

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According to its Annual Report filed with the SEC for fiscal year 2016: "To our knowledge, in 2016, China Oilfield Services Limited (COSL), one of our non-controlled affiliates, provided certain drilling and other related services in Iran and another non-controlled affiliate of ours was engaged in submarine cable installation and trenching services in Iran. We cannot predict at this time whether U.S. sanctions will be imposed on any of our affiliates."

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According to its Annual Report filed with the SEC for fiscal year 2015: "To our knowledge, in 2015, China Oilfield Services Limited (COSL), one of our non-controlled affiliates, continued to provide certain drilling and other related services in Iran under renewed subcontracting agreements entered into in 2009, as it did in 2014. We cannot predict at this time whether U.S. sanctions will be imposed on any of our affiliates."

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According to its Annual Report filed with the SEC for fiscal year 2013: "To our knowledge, in 2013, China Oilfield Services Limited (COSL), one of our non-controlled affiliates, continued to provide certain drilling and other related services in Iran in relation to subcontracting agreements entered into in 2009, as it did in 2012. We cannot predict at this time whether U.S. sanctions will be imposed on any of our affiliates."

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Response

"We take the opportunity to clarify that, to the best of our knowledge, neither CNOOC Limited nor any of its subsidiaries has invested in any Iranian entity, or
has any business operations in Iran." (7/16/2020)

Sinopec Yizheng Chemical Fibre Co Ltd

Industry
Energy
Country
China
Sources

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

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

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

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As of December 31, 2019, the Alaska Retirement Management Board lists YCF as a company doing material business with Iran.

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As of May 28, 2020, the Florida State Board of Administration (“SBA”) continues to list YCF on its list of “Scrutinized companies with Activities in the Iran Petroleum Energy Sector.

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

ACS Trading LLC

Industry
Energy
Country
UAE
Sources

ACS Trading LLC is based in UAE and is part of the Avantgarde Group. ACS Trading facilitated the purchase of Grace 1, an IRGC-controlled vessel which was subject to a civil and criminal forfeiture complaint in the United States District Court for the District of Columbia. The IRGC publicly acknowledged that the vessel was operating on its behalf. (Pacer)