Technology

According to its Annual Report filed with the SEC for fiscal year 2019: "Section 219 of the Iran Threat Reduction and Syria Human Rights Act of 2012 and Section 13(r) of the Exchange Act require an issuer to disclose in its annual and quarterly reports whether it or any of its affiliates have knowingly engaged in certain activities, including specified activities or transactions relating to the Government of Iran (as defined in section 560.304 of title 31 of the Code of Federal Regulations) and to persons designated under Executive Order No. 13382 (70 Fed. Reg. 38567). In the quarter ended March 31, 2020, we determined that one of our non-U.S. subsidiaries provided limited hard copy record, electronic media (e.g., CD), box and container storage and handling services during such quarter, and in prior periods since the reporting requirement took effect, to at least one Government of Iran entity and one entity designated under Executive Order No. 13382 - both located outside of Iran.   

In each case, the customer relationship commenced at a time when U.S. sanctions law did not limit dealings with entities determined to be part of the Government of Iran or designated under Executive Order No. 13382 by non-U.S. entities owned or controlled by U.S. persons. Each relationship automatically continued from year to year without any affirmative step being taken by either party."

According to its Annual Report filed with the SEC in 2018: "We determined that, between November 2012 and September 2018, our subsidiary iWeb provided information technology services to Pioneer Logistics Havacilik Turizm Yonetim Danismanlik Ithalat Ihracat San. Tic. Ltd. Sti, a Turkish company (“Pioneer Logistics”). On August 29, 2014, the Department of Commerce, Bureau of Industry and Security (“BIS”) determined that Pioneer Logistics was part of a procurement ring which directly supported the operation of Mahan Airlines, an Iranian airline and entity on BIS’s denied persons list.

From August 2014 to September 2018, iWeb received approximately $8,855 in fees from Pioneer Logistics. We are unable to accurately calculate the net profit attributable to these transactions. We promptly terminated Pioneer Logistics as a customer upon learning of its designation and do not plan to provide services to Pioneer Logistics in the future."

According to its Annual Report filed with the SEC for fiscal year 2015: "During the year ended January 3, 2015, we learned that Ingram Micro Germany, one of our wholly-owned non-U.S. subsidiaries, made one sale during the year ended January 3, 2015, to an individual who received delivery of the sale at a German subsidiary of an Iranian company. The individual is not included on the Specially Designated Nationals and Blocked Persons List maintained by the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) with the identifier “[IRAN]”, however, the German company is included on that list. This sale consisted of a single graphics card resulting in revenue to us of approximately $.045, with net profits of substantially less than that. The sale appears to be the result of human error and was not made with any intent to violate our policies and procedures or any applicable laws. However, the sale was conducted in contravention of Ingram Micro’s export control and sanctions policies, which prohibit Ingram Micro and its affiliates from conducting any activities, transactions or dealings with Iran or Iranian counterparties, including the Government of Iran. In connection with our discovery of the above-described sale, we have increased compliance resources and training intended to prevent such activity from recurring. We have voluntarily notified OFAC of the sale and intend to cooperate fully with OFAC."

Avaya disclosed in its Annual Report filed with the SEC for fiscal year 2018: "During Avaya’s recent review of its compliance practices in regards to sanctions regulations administered by the Office of Foreign Assets Control (“OFAC”) of the U.S. Department of the Treasury, Avaya determined that AISL processed a sales order received through HKT for an end user identified as MelliBank PLc Hong Kong Branch (“MBHK”). Though this entity is not specifically identified on OFAC’s Specially Designated Nationals and Blocked Persons List, it is designated as a Specially Designated National and Blocked Persons (“SDN”) as a result of the SDN designation of its ultimate parent company in 2016 pursuant to Executive Order 13599. The gross revenues Avaya received from the sale were $4,954.01 and the net profits from the sale were $2,031.15. Once the sale to MBHK was discovered, Avaya terminated all agreements and dealings with MBHK, including a sales and maintenance agreement. Avaya does not intend to engage in any future activities, transactions or dealings with MBHK.

Avaya filed a voluntary disclosure with OFAC on April 4, 2018 regarding the matter described above. Avaya remains committed to complying fully with U.S. sanctions laws and regulations and has devoted significant resources to its global trade compliance program. Avaya is in the process of implementing various enhancements to strengthen its existing global trade compliance procedures and plans to work with HKT on implementation of other remedial measures, including an improvement plan designed to prevent future exposure to persons targeted under U.S. sanctions."

According to its Annual Report filed with the SEC for fiscal year 2019: "For a portion of the reporting period, our travel business allowed consumers to book hotels in and flights serving Iran. The revenue from these offers was immaterial. We believe that these activities have been conducted in accordance with applicable laws and regulations and that they are not sanctionable under U.S. law. In late 2019, we entered into a distribution and commercial agreement in relation to Jumia Travel’s flight and hotel booking portals. As part of this agreement, we will continue promoting flight and hotel booking services on our platform, redirecting the relevant traffic to our partner Travelstart, who will manage the sales, fulfilment and customer service aspects of the business.

Our indirect shareholder, MTN Group Limited, holds a 49% indirect, non-controlling interest in Irancell, which operates Iran’s second largest mobile network and offers international voice, interconnect and roaming services. MTN Group Limited also has a beneficial interest of about 44% in Iranian e-commerce business Snapp (also known as Iran Internet Group), which includes retail marketplace, ride hailing, travel, delivery and food delivery businesses. We have been informed that these investments were made in accordance with applicable laws and regulations, and these entities are not sanctioned under U.S. law."

In its report, “Evolution of UAVs Employed By Houthi Forces In Yemen,” CAR concludes, “A significant number of Houthi UAV components either originated in Iran, or match those used by factions in the region that are linked to Iran.” The report contains the following notable excerpt: "All of the Qasef-1s documented by CAR employed circuit boards attached with microcontrollers bearing an Atmel label. A CAR field investigation team also documented an identical Microchip Atmel microcontroller in a receiver for an RCIED which Bahraini security forces had seized in March 2015 from a passenger bus that had travelled from Iraq, through Saudi Arabia, and into Bahrain." CAR, “Evolution Of UAVs Employed By Houthi Forces In Yemen,” February 2020.

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According to its website, Iranian company Fatehin Sanat supplies various products made by Microchip.

Yokogawa is featured on the website of the Iranian firm, DIBAGARAN FARAYAND (DIFACO).”

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Iranian oil, gas, petrochemical and power industries services company Petrokalooj cites Yokagawa as a supplier on its website.

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The Yokogawa logo appears on the webpage of the Iranian firm, Pars Akam Energy (“Pars Akam”).  (Pars Akam Website, “Home”). 

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According to its website, Amitis is an authorized representative for Yokogawa in Iran.

Jasco is featured on the website of the Iranian firm, Farasar Chimie, according to Farasar Chimie’s website.

Intertec is featured in the brochure for the Iranian firm International West Technology Transfer Co (“IWTT”).

Iranian oil and gas firm, Espak Company, which attended the 24th Iran Oil Show of 2019 that took place May 1-4 in Tehran, Iran, features Intelli on the Espak website.