Retail

On June 1, 2020, the Ohio Police & Fire Pension Fund (“OP&F”) listed Suria KLCC 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 its Annual Report filed with the SEC for fiscal year 2014: "Near the conclusion of the second quarter, our United Kingdom subsidiary inadvertently permitted one individual to open a business membership in the name of Iran Air.  The transaction has been reversed and the membership was canceled on March 12, 2014.  Because of the cancellation the Company has recognized no revenue associated with the transaction."  

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According to its Annual Report filed with the SEC for fiscal year 2013: "During the second and third fiscal quarters of 2013, we had as cardholders at our subsidiary in Japan four individuals under two business memberships in the name of the Embassy of the Islamic Republic of Iran (“Embassy”).  In the same time period, we had as cardholders in our United Kingdom subsidiary two individuals under one business membership in the name of Iran Air.  Gross revenue in the second and third quarters of 2013 attributable to the memberships associated with the Iran Embassy was approximately $5,178, and our estimated profit on these transactions was less than $160.  The Company recognized no revenue or profit attributable to the Iran Air membership in the second and third quarters of 2013.  The Iran Air membership and one of the Iran Embassy memberships were canceled during the second quarter of 2013, and the remaining Iran Embassy membership was canceled in June 2013, prior to which time an additional $319 in revenue and less than $8 in estimated net profits were earned in the fourth quarter of 2013.  The Company does not intend to continue these activities."

"Adidas Follows Nike's lead and stops service to Iran's soccer team." ("Adidas Follows Nike's Lead and Stops Service To Iran's Soccer Team," Jpost, 7/30/2018)

“The sanctions mean that, as a U.S. company, we cannot provide shoes to players in the Iran national team at this time,” Nike said in a statement on Friday to NBC News....The reason Nike won't be providing the shoes is that there is "no general license permitting the transfer of U.S.-origin / owned clothing to Iran," Richard Nephew, a former director for Iran at the National Security Council and a sanctions expert, told NBC News via email. "We have such licenses for humanitarian goods and shoes usually don't count," Nephew said. The Treasury issues some licenses in order to authorize activities that would otherwise be prohibited with regard to Iran, but Nephew said that Nike's shoes are likely not covered by these licenses." (6/10/2018).

"Food retailer Royal Ahold Delhaize (a Dutch company) disclosed that in 2016 its subsidiary bol.com sold to two separate individuals a book on the Dutch language. The books were delivered to the Iranian Embassy in the Netherlands, for a net revenue of just €67."

"Iran and Italy have signed an MoU for transfer of new technologies in the field of leather and modernization of the relevant industry in Iran. A memorandum of cooperation in the field of leather industry was signed between Iran’s Leather Industry Association and Italy's Leather Union during a session attended by Textile Director General of the Ministry of Industry, Mines and Trade Golnaz Nasrollahi." (November 30, 2015).

In 2017 the U.S. state of Michigan listed Lawson Inc. on its Iran restricted companies list rendering Lawson Inc. ineligible for investment and/or state contracting.

"A memorandum of understanding on electronic trade and joint investments in hypermarkets and small chain stores was signed between South Korea’s largest retailer Emart and Iran’s Refah Chain Stores Company on Wednesday. “Among the aims pursued is developing production of Korean items in Iran with a focus on technology transfer and raising the quality of domestic products,” ISNA quoted Refah’s CEO, Farshid Golzadeh Kermani, as saying. According to Golzadeh, the two sides plan to invest in joint-brand hypermarkets and stores. The size of investment has yet to be disclosed." (June 16, 2016)

According to the EXPOOL website and Facebook page, EXPOOL attended the “Marche Region Mission In Iran” from July 11-15, 2016.  (EXPOOL Consortium, “Fairs and events”).  The Italian Ministry of Foreign Affairs released a statement describing the mission as follows:  “In Tehran, President Ceriscioli and the delegation of businessmen was received by the Italian Ambassador in Tehran Mauro Conciatori and by business and trade representatives who held a long discussion on the problems and perspectives of Iran and of the whole Western Asian region.”  (Farnesia Press Archives, “Tehran – The Marche Region on the lookout for new investments in Iran,” 7/13/2016).  The EXPOOL Facebook page posted five photos from the event on July 12, 2016, stating “Live from #Tehran where our President Mauro Guerrini is attending #b2b meetings to promote #ExpoolConsortium shoe companies!”  (Facebook, “EXPOOL Consortium”).  In addition, EXPOOL posted numerous posts to its Facebook in Italian discussing its participation at the conference.  (Id.).

ColisExpat is a French company that connects Iranians with Amazon services, potentially allowing Amazon to circumvent US sanctions. According to its website, "ColisExpat receives your Amazon purchases and forwards them at your house in Iran."

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The sanctioned entities reportedly got around Amazon’s screening process by using common alternative spellings of a sanctioned region like spelling Crimea as Krimea or by shipping items to the foreign missions of the sanctioned nations like Iran. Last year Apple paid around $467,000 to settle similar allegations that it violated U.S. sanctions by doing business with a blacklisted entity for more than two years because the company’s screening tool failed to account for differences in punctuation and letter cases. (Forbes, "Amazon Agrees To Pay $135,000 In Settlement For Violating U.S. Sanctions," 7/10/2020).

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"In early August, Iranians took to Twitter to report that they had received emails from Amazon Web Services (AWS) informing them that their accounts had been disabled in compliance with United States government sanctions and export control regulations." (Al Jazeera, "Locked Out: Why is Amazon blocking Iranians from its services?" 10/2/2019). 

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"Amazon has become the latest major American technology company to block Iranians from accessing its products and services due to U.S. government sanctions that prohibit companies from providing products or services to people based in Iran. Iranian developers who are now banned from using Amazon Web Service (AWS), which offers the worlds most extensive cloud computing platforms, will feel the greatest impact, as well as those who use those developers’ websites, services and products including virtual private networks (VPNs) that enable users to circumvent online censorship." (Center for Human Rights in Iran, "More Iranians Forced to Rely on Unsafe Online Hosting After Amazon Ban," 8/7/2019).

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In July 2017 Amazon disclosed the government probe in documents filed with the SEC. The company said that between Jan 2012 and June 2017 it sold and delivered nearly $25,000 worth of merchandise to an Iranian embassy outside of Iran, and another $8,100 to other individuals with ties to the Iranian government, according to the filing.

The products it sold included books, jewelry, toys, health and beauty products, electronics, lawn and patio equipment, and musical instruments

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"Amazon.com Inc. on Friday disclosed Iranian business ties that may have violated U.S. sanctions, warning that it may be penalized after a regulatory review of the activities. The company said in a regulatory filing that from 2012 to 2016 it "processed and delivered orders of consumer products for certain individuals and entities located outside Iran covered by the Iran Threat Reduction and Syria Human Rights Act (ITRA)"... Amazon said Friday it sold a variety of consumer products to individuals and unspecified groups controlled or owned by the Iranian government. The goods ranged from apparel to software to pet products and cost $50 to about $2,400, according to the filing. Amazon said it doesn't plan to sell to these accounts in the future." (Bloomberg,  "Amazon Discloses Iranian Business Ties, Warms of Penalities," 2/10/2017).