According to its Annual Report filed with the SEC for fiscal year 2019: "
The following information is disclosed pursuant to Section 13(r). None of these activities involved U.S. affiliates of Telefónica or the Company.
Roaming agreements with Iranian operators
Various subsidiaries of our controlling shareholder, Telefónica, have entered into roaming agreements with Iranian telecommunication companies. Pursuant to such roaming agreements these subsidiaries’ customers are able to roam in the particular Iranian network (outbound roaming) and customers of such Iranian operators are able to roam in the network of Telefónica’s relevant subsidiary (inbound roaming). For outbound roaming, these subsidiaries pay the relevant Iranian operator roaming fees for use of its network by our customers, and for inbound roaming, the Iranian operator pays the relevant subsidiary roaming fees for use of our network by its customers.
We have a roaming agreement with MTN Irancell. During 2019, we recorded US$0.68 in roaming revenues and US$169.11 (before taxes and US$184.32 after taxes) of expenses payable to MTN Irancell under this agreement.
In addition, as part of the Telefónica group, we adhere to the roaming agreements with Telefónica’s subsidiaries described below.
Telefónica’s subsidiaries were party to the following roaming agreements with Iranian telecommunication companies in 2019:
(1) Telefónica Móviles España (“TME”), Telefónica’s Spanish directly wholly-owned subsidiary, has respective roaming agreements with (i) Mobile Telecommunication Company of Iran (“MTCI”), (ii) MTN Irancell (“Irancell”), (iii) Taliya (“Taliya”) and (iv) Telecommunications Kish Co. (“TKC”). During 2019, TME recorded the following revenues related to these roaming agreements: (i) 67,273.13 euros from MTCI, (ii) 323.77 euros from Irancell, (iii) no revenues from Taliya, and (iv) no revenues from TKC.
TME also held a roaming hub through its 55% directly-owned subsidiary, Link2One, a.e.i.e. (“L2O”), until December 31, 2019. Under the related agreement, L2O provided a roaming hub service to Irancell enabling the latter to maintain a relationship with other members of the hub. Some members of the hub are also entities of the Telefónica Group. During 2019, L2O recorded revenues of 9,000.00 euros from Irancell. L2O closed its contractual relationship with Irancell on June 30, 2019. The roaming arrangement between TME and Irancell under the L2O framework was terminated on April 30, 2019.
(2) Telefónica Germany GmbH & Co. OHG (“TG”), Telefónica’s German 69.22% indirectly-owned subsidiary, has respective roaming agreements with (i) MTCI and (ii) Irancell. During 2019, TG recorded the following revenues related to these roaming agreements: (i) no revenues from MTCI and (ii) 7,441.13 euros from Irancell.
(3) Telefónica UK Ltd (“TUK”), Telefónica’s English directly wholly-owned subsidiary, has a roaming agreement Taliya. During 2019, TUK recorded no revenues from Taliya. TUK had also a roaming arrangement under the L2O framework with Irancell that was terminated on April 30, 2019. TUK recorded 314.54 euros in roaming revenues from the roaming arrangement with Irancell under the L2O framework.
(4) Telefónica Argentina, S.A. and Telefónica Móviles Argentina, S.A. (together “TA”), Telefónica’s Argentinean directly and indirectly wholly-owned subsidiaries, have a roaming agreement with Irancell. During 2019, TA recorded 1.27 euros in roaming revenues under this agreement.
(5) Pegaso Comunicaciones y Sistemas, S.A. de C.V. (“PCS”), Telefónica’s Mexican directly wholly-owned subsidiary, has a roaming agreement with Irancell. During 2019, PCS recorded 9.33 euros in roaming revenues under this agreement.
(6) Telefónica del Perú, S.A.A. (“TdP”), Telefónica’s Peruvian 98.57% indirectly-owned subsidiary, had a roaming arrangement with Irancell under the L2O framework that was terminated on April 30, 2019. During 2019 TdP recorded no revenues under this roaming arrangement with Irancell under the L2O framework.
(7) Colombia Telecomunicaciones, S.A. ESP (“ColTel”), Telefónica’s Colombian 67.50% directly and indirectly-owned subsidiary, had a roaming arrangement with Irancell under the L2O framework that was terminated on April 30, 2019. During 2019 ColTel recorded no revenues under this roaming arrangement with Irancell under the L2O framework.
(8) Telefonía Celular de Nicaragua S.A. (“TN”), Telefónica’s Nicaraguan 60% indirectly-owned subsidiary until its sale, had a roaming arrangement with Irancell under the L2O framework that was terminated on April 30, 2019. During 2019, TN recorder no revenues under this roaming arrangement with Irancell under the L2O framework. The sale of TN was completed on May 16, 2019.
(9) Telefonica Móviles del Uruguay S.A. (“TMU”), Telefónica’s Uruguayan directly wholly-owned subsidiary, had a roaming arrangement with Irancell under the L2O framework that was terminated on April 30, 2019. During 2019 TMU recorded 0.24 euros in roaming revenues under this roaming arrangement with Irancell under the L2O framework.
(10) Telefónica Móviles Chile S.A. (“TCH”), Telefónica’s Chilean directly wholly-owned subsidiary, had a roaming arrangement with Irancell under the L2O framework that was terminated on April 30, 2019. During 2019 TCH recorded 4.94 euros in roaming revenues roaming revenues under this roaming arrangement with Irancell under the L2O framework.
The net profit recorded by Telefónica’s subsidiaries pursuant to these agreements did not exceed the related revenues recorded thereunder.
The purpose of all of these agreements is to provide the Telefónica group’s customers with coverage in areas where the group does not own networks. For that purpose, Telefónica’s subsidiaries intend to continue maintaining these agreements.
The Telefónica group does not currently have any forthcoming plans to enter into new roaming arrangements with Iranian telecommunication companies. However, the group may consider entering into such arrangements in the future."