Canada

Galvanic is featured on the website of the Iranian energy services firm Sima Mehr.

According to its Annual Report filed with the SEC for fiscal year 2012: "During the period from January to September, 2012, the company made several fleet sales of motor fuel with an aggregate total sales price of approximately $11,000 to the Iranian Embassy in Canada. The net earnings attributable to these sales were less than $500. These sales were made without the involvement of any U.S. person and were permitted by U.S. laws in effect at the time. No sales occurred after the October 10, 2012, effective date and the company does not expect any such sales to occur in the future."

According to its Annual report filed with the SEC for fiscal year 2018: "From February 2018, EXFO Solutions (formerly Astellia), a recently acquired subsidiary of EXFO organized and existing under the laws of France, engaged in transactions involving the sale of passive monitoring and troubleshooting solutions and associated services to end users in Iran. EXFO Solutions (formerly Astellia) sold the equipment for end use by Iranian mobile network operators, Mobile Communications Company of Iran ("MCCI") and MTN Irancell. Although it is difficult to evaluate with any reasonable degree of certainty, we have concluded that we cannot exclude the possibility that MCCI or MTN Irancell is owned or controlled, directly or indirectly, by the government of Iran.

Prior to its acquisition by EXFO, EXFO Solutions (formerly Astellia), through a subsidiary located in Lebanon, employed four (4) employees delivering services in Iran, a practice that was continued after the acquisition through the end of October 2018. These activities complied in all material respects with applicable sanction laws and regulations; however, they were inconsistent with EXFO's internal policies. EXFO discovered this activity during the pre-acquisition due diligence of EXFO Solutions (formerly Astellia) and has conducted a comprehensive internal investigation and review. As a result of this investigation and review, EXFO has implemented additional compliance procedures designed to prevent future violations of its internal policy and is currently in the process of withdrawing from any direct activities, transactions, or dealings relating to Iran or certain designated individuals or entities and will no longer have employees providing services in Iran. In addition, EXFO revised its internal policies to allow indirect support and maintenance of EXFO Solutions' systems deployed at MCCI and MTN Irancell through a non-related third-party based outside Iran to honor EXFO Solutions' (formerly Astellia) prior engagement with existing customers in compliance with applicable export controls, sanctions and other laws, rules and regulation. The withdrawal process was completed on November 4, 2018 and support services through a non-related third party was established at that date."

According to its Annual Report filed with the SEC for fiscal year 2017: "During the year ended October 31, 2017, the Bank received certain incoming and outgoing wire transfer messages on behalf of or for credit to customers of the Bank that, after review and investigation, appear to have involved a party in Iran or related to an underlying transaction with a party in Iran. In one case, the Bank identified that the receiving financial institution was an Iranian state-owned entity. The Bank rejected this Euro payment. In another case, the Bank’s investigation identified that an outgoing Euro payment to a private company in Iran related to work performed by that party at a facility affiliated with the Government of Iran. In addition, during the year ended October 31, 2017, the Bank processed a number of USD bank drafts drawn on a U.S. financial institution and issued to Bank customers payable to the Iranian Interest Section of the Pakistan Embassy, located in Washington, D.C., for official business of the Iranian Interests Section, including payment of Iranian passport fees and visas. The Bank believes that its activity in connection with these wire transfers and bank drafts did not violate any applicable sanctions. As the wire transfers involved interests of the Government of Iran or parties affiliated with the Government of Iran, the Bank is including disclosure in this report because it potentially could be required to be disclosed under Section 13(r).

In addition, in February 2017, the Bank processed an incoming US dollar wire transfer for one of its customers in Canada that originated from a bank in the UAE. After review, the Bank discovered that the wire transfer represented payment for oil and gas services equipment on behalf of a private company based in Iran that is not named on an OFAC sanctions list. The Bank believes that its activity in processing the incoming payment is not required to be disclosed under Section 13(r), but the Bank is providing disclosure because the underlying transaction appears to have related to Iran’s oil and gas sector and thus potentially could be an activity described in subsection (a) or (b) of Section 5 of the Iran Sanctions Act of 1996 that would be required to be disclosed under Section 13(r) for any person who knowingly engages in such activity.

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According to its Annual Report filed with the SEC for fiscal year 2016: "In February 2016, the Bank processed an incoming Canadian dollar wire transfer for one of its customers in Canada that originated from a bank in Kuwait. The Bank has learned that the wire transfer represented payment from a private company based in Iran that is not named on the OFAC sanctions lists, for oil and gas exploration and extraction equipment that the customer supplied to that entity. After review of the underlying transaction, the Bank has no reason to believe that the wire transfer or the transaction violated any applicable sanctions. Although the Bank believes that its activity in processing the incoming payment is not required to be disclosed under Section 13(r), the underlying transaction, which involved the supply of oil and gas exploration and extraction equipment, potentially could be required to be disclosed under Section 13(r); accordingly, the Bank is including disclosure of this activity in this report. This customer’s banking accounts were closed in August 2016. It is not possible to accurately determine the precise net profit attributable to such wire transfer, and even if revenues and profits from these were calculated, they would be negligible."

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According to its Annual Report filed with the SEC for fiscal year 2015: "The Bank held one Canadian dollar account for the Embassy of Iran in Canada. This account, used for the purpose of official embassy business, has been frozen since 2013 and was closed on June 1, 2015. In addition, the Bank issued a bank draft payable to the “Interest Section of the Islamic Republic of Iran” (the “Iran Section”) for a visa fee. The Iran Section is part of the Pakistani Embassy in Washington, D.C. The Bank has complied with all applicable laws in connection with this account and bank draft."

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According to its Annual Report filed with the SEC for fiscal year 2014: "The Bank holds one Canadian dollar account for the Embassy of Iran in Canada. This account, used for the purpose of official embassy business, has been frozen since 2013. A second Canadian dollar account for the Embassy of Iran, used to fund scholarship payments to Iranian students studying in North America, was the subject of a court order requiring the Bank to pay the balance to the judgment creditor as a result of a requirement from the Sherriff’s Office (civil restitution office). This was done in April 2014 and the account was then closed. The Bank has complied with and will continue to comply with all applicable laws in relation to these accounts."

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According to its Annual Report filed with the SEC for fiscal year 2013: "The Bank holds two Canadian dollar accounts for the Embassy of Iran in Canada. These are for the purpose of official embassy business, including scholarship payments to Iranian students studying in North America. These accounts have been frozen since 2013. The Bank has complied with and will continue to comply with all applicable laws in relation to these accounts.

The Bank holds a Canadian dollar deposit account for a business that received a wire transfer from an entity that is owned or controlled by a person designated on the SDN List with respect to sanctions pertaining to Iran. The wire transfer funds were received and frozen in 2007. The freeze on these funds was released in October 2013 as a result of the issuance of a certificate by Canada’s Minister of Foreign Affairs pursuant to Section 19 of Canada’s Regulations Implementing the United Nations Resolutions on Iran. The Bank has complied with and will continue to comply with all applicable laws in relation to this account."

According to its 2019 Annual Report filed with the SEC: "During January 1, 2019 until December 31, 2019, a non-U.S. affiliate of the largest shareholder of the Company (“the non-U.S. Shareholder Affiliate”) entered into sales contracts for agricultural products with, or for delivery to or from Iranian entities wholly or majority owned by the GOI.  The non-U.S. Shareholder Affiliate performed its obligations under the contracts in compliance with applicable sanctions laws and, where required, with the necessary prior approvals by the relevant governmental authorities. The non-U.S. Stockholder Affiliates expect to continue to engage in similar activities in the future in compliance with applicable economic sanctions and in conformity with U.S. secondary sanctions."

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According to its Annual Report filed with the SEC for fiscal year 2018: "During January 1, 2018 until December 31, 2018, a non-U.S. affiliate of the largest shareholder of the Company (“the non-U.S. Shareholder Affiliate”) entered into sales and purchase contracts for agricultural products, metals, minerals and energy products with, or for delivery to or from Iranian entities wholly or majority owned by the GOI.  The non-U.S. Shareholder Affiliate performed its obligations under the contracts in compliance with applicable sanctions laws and, where required, with the necessary prior approvals by the relevant governmental authorities.
  
The gross revenue of the non-U.S Shareholder Affiliate related to these contracts did not exceed the value of USD $1.049 billion for the twelve months ended December 31, 2018.

The non-U.S. Shareholder Affiliate does not allocate net profit on a country-by-country or activity-by-activity basis, but estimates that the net profit attributable to the contracts would not exceed a small fraction of the gross revenue from such contracts. It is not possible to determine accurately the precise net profit attributable to such contracts.

The contracts disclosed above do not violate applicable sanctions laws administered by the U.S. Department of the Treasury, Office of Foreign Assets Control, and are not the subject of any enforcement action under Iran sanction laws.

In response to the re-imposition of certain US secondary sanctions, the non-U.S. Shareholder Affiliate wound down such activities to the extent necessary to avoid any sanctionable activity after such sanctions took effect."

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According to its Annual Report filed with the SEC for fiscal year 2015: "Because the SEC defines the term “affiliate” broadly, our largest shareholder may be considered an affiliate of the Company despite the fact that the Company has no control over our largest shareholder’s actions or the actions of its affiliates. As such, pursuant to Section 13(r)(1)(D)(iii) of the Exchange Act, the Company hereby discloses the following information provided by our largest shareholder regarding transactions or dealings with entities controlled by the Government of Iran (the “GOI”):

During the period from February 1, 2014 until January 31, 2015, a non-U.S. affiliate of the largest shareholder of the Company (the “non-U.S. Shareholder Affiliate”) entered into sales contracts for agricultural products for delivery to Iranian entities wholly or majority owned by the GOI. The non-U.S. Shareholder Affiliate performed its obligations under the contracts in compliance with applicable sanction laws and, where required, with the necessary prior approvals by the relevant governmental authorities.

The gross revenue of the non-U.S Shareholder Affiliate related to these contracts did not exceed the value of $119 million for the twelve months ended January 31, 2015. The non-U.S. Shareholder Affiliate does not allocate net profit on a country-by-country or activity-by-activity basis, but estimates that the net profit attributable to the contracts would not exceed a small fraction of the gross revenue from such contracts. It is not possible to determine accurately the precise net profit attributable to such contracts.

The contracts disclosed above do not violate applicable sanctions laws administered by the U.S. Department of the Treasury, Office of Foreign Assets Control, and are not the subject of any enforcement action under Iran sanction laws.

In compliance with applicable economic sanctions and in conformity with U.S. secondary sanctions, the non-U.S. Shareholder Affiliate expects to continue to engage in similar activities in the future.

Neither the Company nor any of its subsidiaries (i) engaged in any transactions or activities requiring disclosure under ITRA nor (ii) were involved in the transactions described in this section. As of the date of this report, the Company is not aware of any other activity, transaction or dealing by us or any of its affiliates during the fiscal year ended January 31, 2015 that requires disclosure in this report under Section 13(r) of the Exchange Act."

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According to its Annual Report filed with the SEC for fiscal year 2014: "Because the SEC defines the term “affiliate” broadly, our largest shareholder may be considered an affiliate of the Company despite the fact that the Company has no control over our largest shareholder’s actions or the actions of its affiliates. As such, pursuant to Section 13(r)(1)(D)(iii) of the Exchange Act, the Company hereby discloses the following information provided by our largest shareholder regarding transactions or dealings with entities controlled by the Government of Iran (“GOI”):

During the period from February 1, 2013 until January 31, 2014, non-U.S. affiliates of the largest shareholder of the Company (“non-U.S. Shareholder Affiliates”) entered into sales contracts for agricultural products as well as sale and purchase contracts for metal oxides and metals with Iranian entities, wholly or majority owned by the GOI. All contracts were conducted in compliance with applicable sanction laws and, where required, with the necessary prior approvals by the relevant governmental authorities.

The gross revenue of the non-U.S Shareholder Affiliates related to these contracts did not exceed the value of $206 million for the twelve months ended January 31, 2014. This figure includes the gross revenue of goods sold in the period but purchased in previous periods. The non-U.S. Shareholder Affiliates do not allocate net profit on a country-by-country or activity-by-activity basis, but estimate the net profit attributable to the contracts with the GOI would not exceed a small fraction of the gross revenue from such contracts. It is not possible to determine accurately the precise net profit attributable to these contracts.

These contracts disclosed above do not violate applicable sanctions laws administered by the U.S. Department of the Treasury, Office of Foreign Assets Control, and are not the subject of any enforcement action under Iran sanction laws.

In compliance with applicable economic sanctions and in conformity with U.S. secondary sanctions, the non-U.S. Shareholder Affiliates expect to continue to engage in similar activities in the future relating to agricultural products.

Neither the Company nor any of its subsidiaries (i) engaged in any transactions or activities requiring disclosure under ITRA nor (ii) were involved in the transactions described in this section. As of the date of this report, the Company is not aware of any other activity, transaction or dealing by us or any of its affiliates during the fiscal year ended January 31, 2014 that requires disclosure in this report under Section 13(r) of the Exchange Act."

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According to its Annual Report filed with the SEC for fiscal year 2013: "Because the SEC defines the term “affiliate” broadly, our largest shareholder may be considered an affiliate of the Company despite the fact that the Company has no control over its actions or the actions of its affiliates. As such, pursuant to Section 13(r)(1)(D)(iii) of the Exchange Act, the Company hereby discloses the following information provided by our largest shareholder regarding transactions or dealings with entities controlled by the Government of Iran (“GOI”):

"During the year ended January 31, 2013, non-U.S. affiliates of the largest shareholder of the Company ("Shareholder Affiliates") entered into sales contracts for wheat and coal as well as sale and purchase contracts for metal oxides and metals with Iranian entities, which are either fully or majority owned by the GOI. The GOI is in the process of privatizing some of these entities. All transactions were conducted in compliance with applicable sanction laws and, where required, with the necessary prior approvals by the relevant governmental authorities.

The gross revenue of the non-U.S Shareholder Affiliates related to these transactions did not exceed the value of $645 million for the twelve months ended January 31, 2013. This figure includes the gross revenue of goods sold in the period but purchased in previous periods. The non-U.S. Shareholder Affiliates do not allocate net profit on a country-by-country or activity-by-activity basis, but estimate that the net profit attributable to the transactions with the GOI would not exceed a small fraction of the gross revenue from such transactions. It is not possible to determine accurately the precise net profit attributable to these transactions.

The non-U.S. Shareholder Affiliates believe that these transactions disclosed above do not constitute violations of applicable sanctions laws administered by the U.S. Department of the Treasury, Office of Foreign Assets Control, and are not the subject of any enforcement actions under Iran sanction laws.

In accordance with applicable U.S. and foreign sanctions laws, the non-U.S. Shareholder Affiliates expect to continue to engage in similar activities in the future."

Neither the Company nor any of its subsidiaries (i) engaged in any transactions or activities requiring disclosure under ITRA nor (ii) were involved in the transactions described in this section. As of the date of this report, the Company is not aware of any other activity, transaction or dealing by us or any of its affiliates during the fiscal year ended January 31, 2013 that requires disclosure in this report under Section 13(r) of the Exchange Act."

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

RST is exclusively represented by the Iranian firm, Abzar-E-Khak in Iran, according to the Abzar-E-Khak company website.  (Abzar-E-Khak Website, “RST”)

Instantel is exclusively represented by the Iranian firm, Abzar-E-Khak in Iran, according to the Abzar-E-Khak company website.  (Abzar-E-Khak Website, “Instantel”). 

An acquisition of Fiera Capital reportedly has a fund that invests exclusively in Iranian securities In 2017, CalSTRS designated Fiera Capital as “Under Review” for potentially having ties to Iran. In 2018, CalSTRS removed Fiera Capital after 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 listed Fiera Capital as a company under review for reportedly having a fund that invests exclusively in Iranian securities.

Air Canada's website lists flights from Canada to Iran.

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In October 2016, the Financial Tribute reported, “Negotiations are underway with Air India, Korean Airline and Air Canada to establish new flights to Imam Khomeini Airport.” (Financial Tribute, “Iran in Talks to Establish Direct Canada Flights,” 10/3/2016).