Luxembourg

According to its Annual Report filed with the SEC for fiscal year 2019: "As previously reported, Tenaris ceased all deliveries of products and services to Iran by the end of October 2018, that is, during the wind-down period and before the full reinstatement of U.S. secondary sanctions on November 5, 2018. Tenaris has not, directly or indirectly, delivered any goods or services to Iran or Iranian companies during 2019 and does not intend to explore any commercial opportunities in Iran, nor does it intend to participate in tender offers by, or issue offers to provide products or services to, Iranian companies or their subsidiaries.
During 2019 Tenaris collected certain payments for sales of goods or services in connection with past commercial activities relating to Iran, as further described below. Tenaris believes that such activities do not violate any U.S. or foreign law. In addition, in all cases, Tenaris collected amounts owed for sales of goods or performance of services in accordance with OFAC regulations. Tenaris has procedures in place designed to ensure that such activities comply with all applicable U.S. and other international export control and economic sanctions laws and regulations."

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According to its Annual Report filed with the SEC for fiscal year 2018: "In the cases described below, all deliveries of products and services and any other relevant activities by Tenaris ceased by the end of October 2018, that is, during the wind-down period and before the reimposing of the U.S. secondary sanctions. In addition, in all cases, Tenaris collected amounts owed for sales of goods or performance of services in accordance with OFAC regulations. Tenaris has procedures in place designed to ensure that such activities comply with all applicable U.S. and other international export control and economic sanctions laws and regulations.

Currently, Tenaris does not intend to continue exploring commercial opportunities with potential Iranian business partners nor does it intend to participate in tender offers by, or issue offers to provide products or services to, Iranian companies or their subsidiaries."

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According to its Annual Report filed with the SEC for fiscal year 2017: 

• In 2017, TGS participated in several tenders issued by the National Iranian Oil Company, or NIOC, and its subsidiaries for the supply of OCTG Casing, Tubing, Line Pipe and Accessories for oil and gas projects in Iran. Moreover, during 2017 TGS and other non-U.S. affiliates of Tenaris have issued offers to NIOC and other Iranian companies for the provision of goods and/or services. Except as otherwise specified below, none of such tenders or offers were accepted as of December 31, 2017. Tenaris intends to continue participating in tenders and issuing offers to NIOC, its subsidiaries or other Iranian companies through TGS or other of its non-U.S. affiliates, in compliance with applicable law.
• In November 2017, Dalmine booked a purchase order with Buhlmann RFS Gmbh (a distributor located in Germany) for the provision of Line Pipes for use in downstream activities in Iran for Esfahan Oil Refinery Project (end user NIOC), for a total value of EUR0.6 million (approximately $0.7 million). No invoices were issued during 2017 and, therefore, no revenues were recorded for such order as of December 31, 2017. The requested material is under production and delivery is expected for 2018. Dalmine intends to perform its undischarged obligations and collect all or part of the outstanding amounts during 2018.
• During 2017, Dalmine booked four orders with Commerciale Tubi Acciaio (a distributor located in Italy) for the provision of line pipes for use in downstream activities in Iran, Kangan Project, for a total value of EUR0.9 million (approximately $1.1 million). As of December 31, 2017, a portion of these orders was delivered and payment thereof collected, with EUR0.5 million (approximately $0.6 million) outstanding as of December 31, 2017. Materials not invoiced during 2017 are under production and delivery is expected for 2018. Dalmine intends to perform its undischarged obligations and collect all or part of the outstanding amounts during 2018.
• In July 2017, TGS was awarded a spot order from Azar Ab Industries Co., for seamless tubes for manufacturing of Industrial Boiler for Esfahan Refinery in Iran, for a total value of approximately EUR1.2 million (approximately $1.4 million), of which EUR0.2 million (approximately $0.2 million) were collected as of December 31, 2017. TGS expects to continue performing its undischarged obligations and to collect all or part of the outstanding amounts under the above order during 2018.
• During 2017, Dalmine was awarded some spot orders from Mapna International FZE, for carbon steel and low alloyed pipes and tubes delivered to Mapna Boiler and Equipment Engineering and Manufacturing Co., or Mapna, for the manufacturing of boilers for conventional power plants in Iran for a total value of approximately EUR2 million (approximately $2.4 million), of which EUR0.3 million (approximately $0.4 million) were collected as of December 31, 2017. Moreover, during 2017 certain employees of Mapna visited the manufacturing mills of Dalmine and Silcotub (located in Italy and Romania, respectively) for the purposes of inspecting the material under production for the above-referred orders. Dalmine expects to continue performing its undischarged obligations and to collect all or part of the outstanding amounts under the above orders during 2018.
• During the course of the year ended December 31, 2017, TGS entered into several confidentiality agreements for the purpose of sharing information with potential Iranian business partners, some of which were companies controlled by the Government of Iran, with the aim of exploring commercial opportunities relating to the supply of goods and services to NIOC or its subsidiaries. No revenues were attributable to these activities. TGS, as well as other Tenaris non-U.S. subsidiaries, intend to continue to explore commercial opportunities with such potential Iranian business partners in compliance with applicable law.
• In June 2017, TGS renewed its Agency Agreement (initially entered into in June 2016) with Industrials SGC Ltd., or SGC, (a U.K.-based company) for an additional one-year period (i.e. now expiring on June 12, 2018). The purpose of such agreement is to promote and market certain products manufactured by non-U.S. affiliates of Tenaris in the territory of Iran. As of December 31, 2017, no revenues or net profits were attributable to the Agency Agreement. TGS intends to continue promoting and marketing Tenaris products in Iran under the Agency Agreement with SGC.
• During 2017, certain non-U.S. employees of some non-U.S. affiliates of Tenaris visited Iran in order to discuss potential commercial opportunities with Iranian public and private entities. Moreover, during May 2017, certain of the above-referred employees attended trade shows in Iran. These included an oil & gas industry trade show (the Iran Oil Show) organized by NIOC. No fees were paid to NIOC or other Iranian state-owned companies in connection with such activities, other than routine amounts such as travel-related taxes and fees. No revenues were attributable to the above-referred activities. Certain of Tenaris’s non-U.S. affiliates intend to continue visiting Iran in order to develop further commercial opportunities in the country in compliance with applicable law.

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According to its Annual Report filed with the SEC in 2017: 

"Following the partial lifting and suspension of several international sanctions and restrictions against Iran in mid-January 2016 (in particular, the lifting of most U.S. secondary sanctions against such country under the Joint Comprehensive Plan of Action or ‘JCPOA’ entered into by the P5+1 and the Islamic Republic of Iran), Tenaris’s non-U.S. affiliates considered commercial opportunities in Iran during the year ended December 31, 2016 and engaged in certain transactions or dealings involving Iran or nationals of such country (as more particularly described below). Tenaris intends to continue exploring commercial opportunities in Iran in compliance with applicable U.S. and other international export control and economic sanctions laws and regulations.

• In 2016, TGS participated in several tenders issued by the National Iranian Oil Company, or NIOC, and its subsidiaries for the supply of OCTG Casing, Tubing and Accessories for oil and gas projects in Iran. Moreover, during 2016 TGS and other non-U.S. affiliates of Tenaris have issued offers to NIOC and other Iranian companies for the provision of goods and/or services. Except as otherwise specified below, none of such tenders or offers were accepted as of December 31, 2016. Tenaris intends to continue participating in tenders and issuing offers to NIOC, its subsidiaries or other Iranian companies through TGS or other of its non-U.S. affiliates, in compliance with applicable law.

• In October 2016, TGS entered into an agreement for the provision of technical field service assistance to Petropars Ltd, or Petropars, for its project located in the Salman gas field in Iran, for a total value of EUR0.039 million (approximately $0.041 million). Tenaris has been informed that Petropars operates the Salman project pursuant to a service contract with Iranian Offshore Oil Company, a subsidiary of NIOC. All services required to be performed by Tenaris for the benefit of Petropars were completed during October 2016. As of December 31, 2016, the payment amount has not yet been collected. TGS intends to collect all or part of the outstanding amounts during 2017.

• In May 2016, TGS was awarded by Toos Payvand Co., a Tehran-based company, a spot purchase order for carbon steel pipes for the Isfahan Refinery project, for a total value of EUR3.5 million (approximately $3.71 million). As of December 31, 2016, certain amounts were pending collection. TGS intends to collect all or part of the outstanding amounts and to continue performing its obligations under this contract during 2017.

• In December 2016, TGS entered into a distribution agreement with Petrochemical Transportation Engineering Company, or PTEC, a private Iranian company, for pipes used in downstream activities, such as refineries, petrochemical and gas processing. On December 21, 2016, PTEC placed one purchase order for a total value of EUR2.2 million (approximately $2.3 million). Tenaris made no shipments and recorded no revenues in connection with this agreement for the year ended December 31, 2016. TGS intends to fulfill its obligations and collect all or part of the outstanding amounts during 2017.

• During the course of the year ended December 31, 2016, TGS entered into several confidentiality agreements for the purpose of sharing information with potential Iranian business partners, some of which were companies controlled by the Government of Iran, with the aim of exploring commercial opportunities relating to the supply of goods and services to NIOC or its subsidiaries. No revenues were attributable to these activities. TGS intends to continue to explore commercial opportunities with such potential Iranian business partners in compliance with applicable law.

• In June 2016, TGS entered into an Agency Agreement, expiring on June 12, 2017, with Industrials SGC Ltd., or SGC, (a U.K.-based company) for the purposes of promoting and marketing certain products manufactured by non-U.S. affiliates of Tenaris in the territory of Iran. As of December 31, 2016, no revenues or net profits were attributable to the Agency Agreement. TGS intends to continue promoting and marketing Tenaris products in Iran under the Agency Agreement with SGC.

•  During 2016, certain non-U.S. employees of some non-U.S. affiliates of Tenaris visited Iran in order to discuss potential commercial opportunities with Iranian public and private entities. Moreover, during May 2016, certain of the above-referred employees attended trade shows in Iran. These included an oil & gas industry trade show (the Iran Oil Show) organized by NIOC and a conference (“Iran Pipe & Tube”) organized by Metal Bulletin, at which a technical presentation was given on behalf of a non-U.S. affiliate of Tenaris. No fees were paid to NIOC or other Iranian state-owned companies in connection with such activities, other than routine amounts such as travel-related taxes and fees. No revenues were attributable to the above-referred activities. Certain of Tenaris’s non-U.S. affiliates intend to continue visiting Iran in order to develop further commercial opportunities in the country in compliance with applicable law.

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According to its Annual Report filed with the SEC in 2016:

• "During 2015, Tenaris’s employees attended an exhibition of the oil & gas industry in Iran named Iran Oil Show, for which no fee was paid to the National Iranian Oil Company."

•  Tenaris’s policy in 2015, based on the sanctions against Iran, was not to engage in future sales or deliveries. In January 2016, many of the international sanctions restrictions were lifted or suspended, thus enabling certain oil and gas related business with Iran under specified circumstances. Tenaris may consider opportunities in Iran and engage in transactions to the extent any such transactions are not prohibited under applicable remaining sanctions restrictions.

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According to its Annual Report filed with the SEC in 2014 and 2015: "While the Tenaris subsidiaries identified above intend to perform their pending obligations under such pre-existing agreements, Tenaris and its subsidiaries ceased prior to the end of 2012 all sales and deliveries of goods and services to Iran. Tenaris’s current policy, based on the sanctions against Iran, is not to engage in future sales or deliveries."

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According to its Annual Report filed with the SEC in 2013: "In January 2010, Tenaris Global Services S.A., or TGS, a Tenaris subsidiary, entered into an agreement with the National Iranian Drilling Company, or NIDC, a company controlled by the Government of Iran, for a total value of EUR 9.4 million (approximately $ 12.6 million). TGS made all deliveries and collected most of its account receivables under the NIDC agreement prior to 2012. In 2012, TGS collected an amount of EUR 750 thousand (approximately $ 1.0 million) for products delivered to NIDC in prior years. An outstanding balance of EUR 172 thousand (approximately $ 0.2 million) is still due to TGS. In addition, TGS has not yet fully performed its obligation to allow technical visits to Tenaris’s mills by twenty NIDC experts at TGS’s cost.

TGS is also a party to an April 2011 agreement with Global Procurement General Trading FZE, or Global FZE, a company incorporated in United Arab Emirates, for the provision of OCTG for an amount of AED 16.5 million (approximately $ 4.5 million). TGS has been informed by Global FZE that the end users of the products delivered under this agreement are Oil Industries Engineering and Construction Group, or OIEC, and Pars Oil and Gas Company, or POGC, which are controlled by the Government of Iran. In 2012, TGS delivered products under the Global FZE agreement for a total value of AED 16.3 million (approximately $ 4.4 million), and collected a total amount of AED 15.4 million (approximately $ 4.2 million).

As of December 31, 2012, a balance of AED 862 thousand (approximately $ 0.2 million) was outstanding, and will only become due after the end of the warranty period.

In March 2011, TGS entered into an agreement for the provision of technical field service assistance to ENI Iran B.V. for its project in Darquain, Iran, for a value of EUR 246 thousand (approximately $ 0.3 million). As of December 31, 2012, the entire contract amount was still outstanding. Tenaris has been informed that ENI Iran operates the Darquain project pursuant to a service contract with the National Iranian Oil Company, or NIOC.

In May 2011, our subsidiary Dalmine entered into an agreement with Edison International S.p.A., or Edison, an Italian company, for the supply of OCTG casing for a development project in Iran, for a value of EUR 926 thousand (approximately $ 1.2 million). In 2012, Dalmine collected EUR 1.1 million (approximately $ 1.4 million) on account of material delivered to Edison during 2011. Dalmine has been informed that Edison operates such project under an exploration and development service contract with NIOC.

Except as otherwise stated above, there are no pending obligations of Tenaris or its subsidiaries under the agreements described above. While the Tenaris subsidiaries identified above intend to perform their pending obligations under existing agreements, neither Tenaris nor any of its subsidiaries has plans to make new sales of products or services to Iran.

Tenaris estimates that the sales of products and services to, or for use by, customers controlled by the Government of Iran in 2012 by its subsidiaries as indicated above generated a profit before tax of approximately $0.8 million."

According to its Form 20-F filed for the year 2019 on April 8, 2020 with the SEC:

During 2019, we conducted limited Iran-related activities and transactions that can be qualified as dealings with the government of Iran, or with persons or entities designated under certain executive orders, as defined by Section 13(r) of the Exchange Act. 

These dealings all relate to the operation of the Zvartnots Airport by AIA, our Armenian subsidiary, and in particular in connection with certain international flights that Mahan Air operated from Iran to Armenia. Mahan Air is a private airline based in Teheran, Iran, which operated 123 flights to and from the Zvartnots Airport during 2019. In 2011, pursuant to Executive Order No. 13224, Mahan Air was designated as a Specially Designated National (SDN). Despite this designation, based on information available on its website, Mahan Air continues to have operations in several cities around the world, such as, Barcelona, Milan and Moscow. 

Under the Armenian Concession Agreement, AIA is required and cannot refuse to operate all commercial flights and deal with all airlines authorized by the Armenian Government to fly from or to the Zvartnots Airport. 

In August 2019, Mahan Air stopped operating flights at the Zvartnots Airport. Since then, no Mahan Air flights have been handled by AIA.

While in operation, in connection with flights to and from the Zvartnots Airport, AIA collected aeronautical, fueling and cargo fees from Mahan Air as authorized under the Armenian Concession Agreement. During 2019, and until such flights were discontinued, the total revenue derived from aeronautical and fueling fees charged to Mahan Air amounted to approximately €0.5 million. Revenue derived from other fees charged to Mahan Air, such as cargo fees, cannot be determined because they are impacted by general cost and expenses not allocable to a particular airline or customer. Overall, the revenue derived from the operation of Mahan Air’s flights is not material.     

In response to our inquiry, Zvartnots Handling informed us that until August 2019, Zvartnots Handling supplied handling services to Mahan Air, as agreed under a Standard Ground Handling Agreement, in connection with the flights from Teheran, Iran to the Zvartnot Airport. Moreover, Zvartnots Handling entered into a Standard Ground Handling Agreement for the provision of these handling services with Mahan Air. We were informed that during 2019, and until such services were discontinued, Zvartnots Handling collected an aggregate amount of approximately €0.3 million for services under this agreement.

According to its Form 20-F for the year 2019, filed with the SEC on April 9, 2020:

As previously reported, Tenaris ceased all deliveries of products and services to Iran by the end of October 2018, that is, during the wind-down period and before the full reinstatement of U.S. secondary sanctions on November 5, 2018. Tenaris has not, directly or indirectly, delivered any goods or services to Iran or Iranian companies during 2019 and does not intend to explore any commercial opportunities in Iran, nor does it intend to participate in tender offers by, or issue offers to provide products or services to, Iranian companies or their subsidiaries.

In May 2016, TGS was awarded by Toos Payvand Co., a Tehran-based company, a spot purchase order for carbon steel pipes for the Esfahan Oil Refinery Project (end user National Iranian Oil Company or “NIOC”), for a total value of EUR3.5 million (approximately $4.0 million). TGS delivered most of the items requested under such purchase order, for which the customer made advance payments, during 2017 and during the wind-down period associated with the reinstatement of U.S. secondary sanctions. Shipments under this purchase order were suspended as of October 2018. As of December 31, 2019, TGS recorded an advance payment from Toos Payvand Co. for undelivered goods for approximately EUR 0.04 million (approximately $0.04 million).

During 2018, Dalmine was awarded spot orders from Mapna International FZE for a total value of EUR4.1 million (approximately $4.7 million) of which EUR 4.0 million (approximately $4.5 million) were collected as of December 31, 2018. By October 2018, Dalmine had delivered all ordered items. On April 18, 2019, Dalmine collected the outstanding balance of approximately EUR0.1 million (approximately $0.1 million) in compliance with OFAC regulations. No obligations are outstanding, and no amounts are due to Dalmine in connection with these purchase orders.

During 2018, Dalmine received an order from U.K.-based company BP Exploration Operating Co. Ltd. for EUR0.2 million (approximately $0.2 million) for the provision of casing and coupling to be used in the Rhum Gas Oilfield (located in the U.K.). At the time of the order, the partners in the Rhum Gas Oilfield are BP Exploration Operating Co Ltd. (50%) and Iranian Oil Co UK Ltd (50%), a subsidiary of NIOC. All items were delivered by October 2018. On May 21, 2019, Dalmine collected the outstanding balance of approximately EUR0.2 million (approximately $0.2 million) from BP Exploration Operating Co. Ltd. in compliance with OFAC regulations. No obligations are outstanding, and no amounts are due to Dalmine in connection with this purchase order.

Azimut will buy the stake through AZ International Holdings, its Luxembourg-based unit.  Azimut and Mofid also plan to establish a fund, domiciled in Luxembourg, for foreign investors to invest in Iran.”  (Financial Times, “Italian asset manager buys stake in Iranian rival,” 10/10/2017).

"Cargolux (CV, Luxembourg) is in talks with Iran Air (IR, Tehran Mehrabad) over possible cooperation in the future an airline spokeswoman has confirmed to ch-aviation. The cargo specialist sent several representatives to Iran last week as part of a forty-strong business delegation led by Luxembourg's Economy Minister and Deputy Prime Minister Etienne Schneider to explore possible investment opportunities. "We are in discussions with them to explore if there [are] business opportunities," Cargolux's Head of Corporate Communications, Moa Sigurdardottir, said in an emailed statement. "At this stage nothing has been signed." Local press reports have indicated Cargolux will likely resume its Iranian operations with charter flights which, if successful, could lead to scheduled services. The carrier withdrew from the Iranian market in 2007." (ch-aviation, "Luxembourg's Cargolux is in talks with Iran Air," 10/27/2016).

Paul Wurth lists numerous speakers at the 2nd Iranian Iron & Steel Conference that took place from September 26-28, 2016 in Isfahan, Iran. (Metal Bulletin, "2nd Iranian Iron & Steel Conference"). 

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"From 5 – 8 May, the Paul Wurth Oil & Gas Division participated in this “Iran Oil Show 2016” in Tehran to introduce the new Paul Wurth market segment - specialised valve solutions for oil & gas downstream processes - to this region. Due to the long-lasting sanctions there is a huge demand also on new and serviced/repaired equipment like special process valves for this industrial sector. For Paul Wurth as a newcomer in this business field it was observable and consequentially helpful that SMS group is very well known and recognised in this country as a reliable business partner since many years. The major challenge in the near future will be the financing of projects in Iran, as the banking system is not yet up and running, and to find the correct partners for local supplies and service activities." (Paul Wurth At Iran Oil Show 2016, 9/6/2016).

"Three foreign currency printing companies have decided to discontinue their businesses in Iran, UANI (United Against Nuclear Iran U.S. group) Communications Director Nathan Carleton told Trend. Earlier this month, UANI has launched a 'Iran Rial Currency Printing Campaign', which targeted companies that print Rial for the Islamic Republic.According to Nathan Carleton, three such companies have stopped their businesses there, as a result of UANI's campaign.'All three of the firms we contacted, 'KBA', 'Flint', and 'DLR', have informed us that they are no longer involved in currency printing in Iran,' Carleton said, noting that UANI applauds the companies for their decisions . . . Flint, an ink and chemical supplier based in Luxemburg, worked in Iran through SunColor Inks Co., and held the patent for a trademarked family of banknote printing products repeatedly requested by the Central Bank of Iran . . . Nathan Carleton noted that no one should be helping the Iranian regime print more currency during this critical time.'We will continue to observe the rial's value, but we do not expect it to improve unless the regime changes course.'" (Bloomberg, "Three currency printing companies stop their businesses in Iran," 10/20/12)

Jan 2018 - Deutsche Borse said Friday the CBI had filed a complaint against Clearstream at a court in Luxembourg where the post-trade services provider is based. Deutsche Borse said Iran’s central bank wants Clearstream and Italian bank Banca UBAE SpA to return its assets plus interest in addition to damages worth the same amount. The assets sought reportedly include about $1.9 billion which Clearstream has turned over to the US to “compensate” around 1,000 Americans claiming damage from Iran over a 1983 bombing in Beirut and another attack in 1996 in Saudi Arabia. The CBI further seeks around $2 billion in customer assets which are held at Clearstream and are subject to similar appropriation in the US and Luxembourg.

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“Deutsche Börse said on Wednesday that its Clearstream unit was the subject of a criminal investigation into potential violations of United States money laundering laws and sanctions against Iran. The German stock exchange said the unit was cooperating with an investigation by the office of Preet Bharara, the United States attorney for the Southern District of New York. ‘The investigation is in a very early stage and our U.S. counsels are currently analyzing the situation,’ Clearstream said in a statement on Wednesday. ‘Investigation is a search process in a criminal proceeding. It is not a prosecution. Clearstream is currently not subject to prosecution’…Clearstream, based in Luxembourg, provides post-trading and settlement services – namely delivering cash and securities between trading parties. It settles more than 250,000 transactions a day. On Wednesday, Clearstream said Mr. Bharara’s office had recently issued a grand jury subpoena seeking data on any property belonging to Iran or its central bank that was possibly being held by Clearstream, as well as services or acts undertaken by the unit for Iran’s benefit. Clearstream said it would comply with the laws of all relevant jurisdictions…In January, Clearstream agreed to pay $152 million to settle civil claims by the Treasury Department that its United States account was used as a conduit to hold about $2.8 billion in securities for Iran’s central bank between December 2007 and June 2008.” (New York Times, “Deutsche Börse Unit Is Subject of U.S. Criminal Investigation,” 4/2/14)

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“A U.S. grand jury is probing whether Deutsche Boerse AG's Clearstream Banking SA unit took any steps to benefit Iran and its central bank, according to a court filing in a case that stems from the 1983 bombing of the U.S. Marine barracks in Beirut. The grand jury subpoena issued in New York seeks documents related to any property held or any services rendered by Clearstream for the benefit of Iran or its central bank, Bank Markazi. The grand jury is looking at possible violations of money laundering and Iran sanctions laws, according to the subpoena. A spokesman for Luxembourg-based Clearstream said the bank was aware of the subpoena but had no further information on the investigation. The filing on Monday came as part of a lawsuit brought by family members of the victims of the Beirut bombing, who won a $2.7 billion judgment against Iran in 2007. The families have accused Iran of providing material support to Hezbollah, which carried out the attack, killing 241 U.S. servicemen. The lawsuit was filed in 2010 after the U.S. Treasury Department uncovered $1.8 billion in Iranian funds held at Citibank in New York, part of Citigroup Inc. The complaint named Iran and a number of banks, including Citi, Bank Markazi, Clearstream and Rome-based Banca UBAE, as defendants and sought to have the funds turned over to help satisfy the judgment. The other banks were alleged to have helped Iran hide its control of the accounts and transfer money out of the bank after it was ordered frozen…Citi did not oppose the plaintiffs' request to have the funds handed over, but Clearstream, Banca UBAE and Bank Markazi all moved to dismiss the lawsuit…In January, in a separate case, Clearstream agreed to pay $152 million to settle U.S. government claims that the banking unit held some $2.8 billion in securities in the United States for Bank Markazi. The bank said in January that the settlement ended the probe without a formal finding that Clearstream had violated U.S. sanctions laws prohibiting Iran's central bank from any financial dealings with the United States. The case is Peterson v Islamic Republic of Iran, U.S. District Court for the Southern District of New York, No. 10-4518.” (Reuters, “U.S. grand jury probing Deutsche Borse unit's ties to Iran bank,” 4/1/14)

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“A Deutsche Boerse unit agreed to pay $152 million to settle allegations that it held some $2.8 billion in securities in the United States for the central bank of Iran, the U.S. Treasury said on Thursday. The unit, Clearstream Banking of Luxembourg, had an account with a U.S. financial institution in New York from December 2007 to June 2008 through which Iran's central bank held interest in 26 corporate and sovereign bonds, the Treasury Department said. It did not name the U.S. financial institution involved. ‘Clearstream provided the government of Iran with substantial and unauthorized access to the U.S. financial system,’ Adam Szubin, who leads the Treasury office that enforces U.S. sanctions, the Office of Foreign Assets Control, said in a statement. Deutsche Boerse, which had already disclosed the settlement amount in November, said on Thursday the settlement closed the probe without a formal finding that Clearstream had violated U.S. sanctions laws…Clearstream met with U.S. officials about the account in 2007 and 2008, and decided to end its business with Iranian clients, Treasury said. According to the settlement, in February 2008 Clearstream transferred the rights to the Iranian central bank's securities to a custody account of a European commercial bank held by Clearstream. But Iran continued to own those securities, and the securities continued to sit in Clearstream's New York account, the Treasury Department said. Emails also showed that several Clearstream employees, including at least one supervisor and one senior executive, recognized that transferring the securities to a custody account still meant Iran's central bank owned them, according to the settlement. Clearstream neither admitted nor denied the Treasury Department's allegations. Clearstream eventually cooperated with OFAC and stopped dealing with Iran, according to the Treasury Department, which said it agreed to reduce the ultimate size of the fine. Under the settlement, Clearstream is required to maintain policies that ensure similar actions do not happen again.” (Reuters, “Deutsche Boerse to pay $152 million in U.S. sanctions probe,” 1/23/14)

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“The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) today announced a $152 million agreement with Clearstream Banking, S.A. (Clearstream), of Luxembourg, to settle its potential civil liability for apparent violations surrounding Clearstream’s use of its omnibus account with a U.S. financial institution as a conduit to hold securities on behalf of the Central Bank of Iran (CBI). ’Clearstream provided the Government of Iran with substantial and unauthorized access to the U.S. financial system,’ said OFAC Director Adam J. Szubin. ‘Today’s action should serve as a clear alert to firms operating in the securities industry that they need to be vigilant with respect to dealings with sanctioned parties, and that omnibus and custody accounts require scrutiny to ensure compliance with relevant sanctions laws.’ From at least December 2007 through June 2008, Clearstream held an account at a U.S. financial institution in New York through which the CBI maintained a beneficial ownership interest in 26 securities, with a nominal value of $2.813 billion, and exported certain associated securities-related services to the CBI.  Clearstream, as intermediary, served as the channel through which the CBI held interests in these securities and transferred those interests at a later date, thereby exporting custody and related services from the United States to the CBI in apparent violation of the Iranian Transactions and Sanctions Regulations (ITSR), 31 C.F.R. part 560.  Following meetings with OFAC officials in late 2007 and early 2008, in which Clearstream conveyed its decision to terminate its business with Iranian clients, Clearstream transferred the above-mentioned securities entitlements free-of-payment (FOP) from the CBI’s account at Clearstream to a European bank’s newly-opened custody account at Clearstream.   This new custody account allowed the CBI to continue holding its interests in the securities through Clearstream’s omnibus account in the United States.  Given the totality of facts and circumstances surrounding the transfers, Clearstream had reason to know that the CBI was retaining beneficial ownership of the securities following the FOP transfers.  As a result of the FOP transfers, the record ownership of the securities entitlements on Clearstream’s books changed, but the beneficial ownership did not, resulting in the CBI’s interest being buried one layer deeper in the custodial chain.  Clearstream’s exportation of services from the United States to the CBI then continued after the securities entitlements were moved to the European bank’s custody account…learstream’s strong remedial response to subsequently enhance its sanctions compliance policies and procedures was a major factor in OFAC’s mitigation of the size of the settlement amount.” (U.S. Department of Treasury, “Treasury Department Reaches Landmark $152 Million Settlement with Clearstream Banking, S.A.,” 1/23/14)  

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"Deutsche Boerse agreed on Thursday to pay $152 million to settle allegations by the U.S. Office of Foreign Assets Control (OFAC) that the company's Clearstream unit may have violated U.S. economic sanctions tied to Iran. The German exchange operator received an offer from the United States in October after OFAC closed the investigation." (Reuters, "Deutsche Boerse settles Iran suit with U.S.," 11/7/13)

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"Deutsche Boerse AG (DB1) said the fine its Clearstream unit faces from U.S. government allegations that it violated sanctions against Iran may be half the previously disclosed amount. The penalty totals $169 million, or only $152 million if the Frankfurt-based company settles with the U.S. Treasury Department’s Office of Foreign Assets Control, Deutsche Boerse said in a statement yesterday. In January, Deutsche Boerse said it might have to pay $340 million. The Treasury investigation, which Deutsche Boerse said has concluded, centered on securities transfers within the Clearstream system in 2008, following the company’s decision in 2007 to close Iranian customers’ accounts. The company started talks on a deal with the U.S. Treasury in 2008, the Frankfurt-based exchange said earlier this year…'A settlement with OFAC would not constitute a final determination that a violation has occurred,' Deutsche Boerse said in yesterday’s statement. The exchange operator will now decide whether to settle with U.S. regulators, it said. The fine will be included as a provision in the company’s third-quarter filing. Deutsche Boerse shares slid 1.83 euros, or 3.2 percent, to 55.57 euros at 9:22 a.m. in Frankfurt today, the biggest drop in 11 weeks." (Bloomberg, "Deutsche Boerse’s Iran Fine From U.S. Is Half Estimate," 10/29/13)

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"Deutsche Boerse on Thursday said it would ask a U.S. court to dismiss claims against its Clearstream unit from relatives of a 1983 bombing of the U.S. Marine Corps barracks in Beirut. For a settlement to go through, Deutsche Boerse needed the approval of a certain amount of plaintiffs. 'The requisite number of signatures has been obtained,' Boerse said in a regulatory statement. Through its Clearstream unit, Deutsche Boerse has been embroiled in a legal dispute with U.S. plaintiffs seeking damages from Iran for Clearstream's alleged role in helping Hezbollah carry out the barracks attack during the civil war in Lebanon. As part of this action, U.S. plaintiffs sought in 2008 to freeze Iranian funds held in Luxembourg-based Clearstream's securities account. The U.S. amended a sanctions bill against Iran in August 2012 which opened the door to further damages claims against foreign lenders including Clearstream." (Reuters, "Deutsche Boerse to seek dismissal of Clearstream case in U.S.," 10/24/13)

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"Deutsche Boerse AG said U.S. regulators may fine its Clearstream settlement unit as much as $340 million over possible violations of sanctions against Iran.  Clearstream has started talks on a deal with the U.S. Treasury Department's Office of Foreign Assets Control related to securities transfers within its settlement system in 2008, the Frankfurt-based exchange said in a statement today. Deutsche Boerse shares rose 0.2 percent to 47.03 euros at the close of trading in Frankfurt. Standard Chartered Plc agreed to pay $327 million in fines last month, including $132 million to OFAC, after regulators said it violated U.S. sanctions with Iran. Britain's second- largest bank by market value was accused of helping Iran launder about $250 billion in violation of federal laws, keeping false records and handling wire transfers for Iranian clients." (Bloomberg, "Deutsche Boerse Faces $340 Million Fine Over Iran," 01/09/13)

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"The Senate and the House of Representatives are drafting bills that would seek to blacklist essentially every Iranian bank. The U.S. Treasury has blacklisted 18 Iranian banks, but lawmakers say Tehran is using more than 20 other banks to finance its nuclear program and its support for militant groups, such as Hamas in the Palestinian territories and Hezbollah in Lebanon. Treasury Department officials said Wednesday that they have blacklisted 23 Iranian financial institutions in actions taken against banks and other firms. Congressional officials said the new legislation will also target communications, software and technology companies that continue to do business with Iranian banks. Possible targets include Deutsche Börse AG's Clearstream unit and Belgium-based Euroclear Group, which are believed to facilitate financial transactions for Iran's central bank. Clearstream didn't respond to requests to comment." (The Wall Street Journal, "U.S. to Probe Iran's Commitment to Talk," 3/7/2012)

"The U.S. gave European satellite companies Intelsat SA and Eutelsat Communications SA another six months to win back Iran's business lost after lawmakers barred them from transmitting Iranian programming... The companies say they have had to push hard, and have regained some of the business they lost. Both companies said the amount of revenue lost was immaterial. 'Our business level there has not returned to its previous state,' said Dianne VanBeber, an Intelsat spokeswoman."  (The Wall Street Journal, "Intelsat, Eutelsat Granted New U.S. Waivers," 8/28/2014)

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"The International Telecommunications Satellite Organization (Intelsat) has taken a number of Iranian channels off the air in Europe based on an order by the U.S., Press TV reported." (Trend, "Intelsat takes Iranian channels off air," 10/22/2012) 

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"Other Western satellite companies, including Intelsat SA and Telesat Holdings Inc., still carry IRIB's channels." (The Wall Street Journal, "A Top Satellite Provider Cuts Off Iran State Broadcaster," 10/15/2012) 

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"IRIB broadcasts not only in Persian but in Arabic—on its Al Alam channel—and in English on its Press TV. Besides Eutelsat, companies it uses include Intelsat SA, Telesat Holdings Inc. and AsiaSat, a Hong Kong-based operator in which General Electric Co. has a stake... Iran has little reason to jam Intelsat and AsiaSat, which don't carry BBC Persian or other typically targeted channels, and those companies said they weren't aware of their satellites being jammed... Intelsat, based in Luxembourg but with main offices in Washington, is able to do business with Iran despite the U.S. embargo because of a license from the Treasury's Office of Foreign Assets Control. Intelsat was once an intergovernmental organization and was obliged to provide service to the group's former members, including Iran, when it changed to a private company a decade ago. 'Satellite operators like Intelsat do not censor the content that is broadcast over their satellites,' said Dianne Van Beber, a vice president and spokeswoman." (The Wall Street Journal, "In Skies Over Iran, a Battle for Control of Satellite TV," 12/27/2011)

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"European satellite companies like Eutelsat, Intelsat and Arqiva provide extensive services to the Iranian state-owned Islamic Republic of Iran Broadcasting (IRIB), including for domestic Iranian radio and television broadcasts, and for Iran's growing list of foreign-language channels, like the English-language PressTV and the Arabic Al-Alam."(The Wall Street Journal, "Broadcasting Tehran's Repression," 12/9/2011)

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"This license application is so heavily redacted by OFAC that one cannot say what type of activity it authorized. In records released by the State Department, however, it says that the license would allow Intelsat to respond to a request for a proposal for the provision of public international telecommunications service to Iran, and that granting such a license would be consistent with the United States policy goal of promoting the free flow of information to and from Iran." (New York Times, "Licenses Granted to U.S. Companies Run the Gamut," 12/24/10)

"Luxembourg-based software company Skype, which is in registration for an initial public offering, has answered a subpoena from the Treasury Department seeking information about transactions involving Iran.

Silver Lake Partners, the tech-centric private equity firm that bought the majority share in Skype in 2009, was served an administrative subpoena in July, Skype said in a Nov. 2 filing with the Securities and Exchange commission. The little-noticed subpoena was first disclosed by the company in its August registration statement.

The Treasury’s Office of Foreign Assets Control, which enforces U.S. sanctions, requested information on transactions since 2005, including those related to call termination fees to an unnamed Iranian telecommunications provider, the company said." (Wall Street Journal, "Skype Answers Subpoena On Sanctions Investigation," 11/3/2010)