China

According to a settlement with the US Treasury Department signed November 29, 2018, "The Jereh Group is an integrated oil and gas company specializing in oil and gas equipment manufacturing, engineering and construction, and oilfield technology services. The Jereh Group employs approximately 5,000 employees worldwide and is headquartered in the city of Yantai in China's northeastern Shandong province. 

From on or about October 2, 2014 to on or about March 4, 2016, the Jereh Group appears to have violated the Iranian Transactions and Sanctions Regulations, 31 C.F.R. part 560 (ITSR), on at least 11 occasions. Specifically, the Jereh Group appears to have violated §§ 560.203 and 560.204 of the ITSR when it exported or reexported, or attempted to export or reexport, U.S.-origin goods ultimately intended for Iran via China, in some cases after incorporation into other goods in China (referred to hereafter as the "Apparent Violations"). Two of the 11 transactions involved shipments that were seized by U.S. Customs and Border Protection (CPB). The Jereh Group did not cease its activities until the U.S. Department of Commerce's Bureau of Industry and Security (BIS) added Yantai Jereb Oilfield Services Group Co., Ltd. and four of its former employees, as well as other companies and individuals involved in the prohibited activities described below, to the Entity List.

[Jereh Group agreed to] pay or arrange for the payment to the U.S. Department of the Treasury the amount of $2,774,972."

YS Control Valve is featured on the website of the Iranian firm, DIBAGARAN FARAYAND (DIFACO).

Zhenhai Refining & Chemical Co., Ltd. is listed on the 4Q 2020 Minnesota State Board of Investment List of Unauthorized (Scrutinized) Iran Companies.

Addax Petroleum Corp. is listed on the 4Q 2020 Minnesota State Board of Investment List of Unauthorized (Scrutinized) Iran Companies.

"China National Chemical reportedly has construction projects in Iran. In 2020, CalSTRS identified China National Chemical as potentially having ties to Iran and began the review process."

"BYD Company reportedly has a contract to distribute automobiles and the transfer of energy technology into Iran. In 2020, CalSTRS identified BYD Electronic as potentially having ties to Iran and began the review process."

"Triliance used Dynapex Energy – Chinese entity based in Hong Kong, to facilitate the shipment and resale of tens of thousands of metric tons of petrochemical products worth millions of dollars to an Asian country;

In January 2020, OFAC sanctioned Triliance and three other petrochemical and petroleum companies that have collectively transferred the equivalent of hundreds of millions of dollars’ worth of exports from the National Iranian Oil Company (NIOC), which helps to finance Iran’s Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF) and its terrorist proxies. Iran’s petroleum and petrochemical industries are major sources of revenue for the Iranian regime and fund its malign activities throughout the Middle East. Triliance has used various front companies to purchase, or facilitate the purchase and movement of, petrochemical products from Iran, and the entities targeted today help facilitate Iran’s petrochemical and petroleum exports in contravention of U.S. economic sanctions;" (U.S. Treasury, "Treasury Sanctions Companies for Enabling the Shipment and Sale of Iranian Petrochemicals," 9/3/2020).

"Triliance used Jingho Technology Co. Limited Chinese entity based in Hong Kong, to facilitate the shipment and resale of tens of thousands of metric tons of petrochemical products worth millions of dollars to an Asian country;

In January 2020, OFAC sanctioned Triliance and three other petrochemical and petroleum companies that have collectively transferred the equivalent of hundreds of millions of dollars’ worth of exports from the National Iranian Oil Company (NIOC), which helps to finance Iran’s Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF) and its terrorist proxies. Iran’s petroleum and petrochemical industries are major sources of revenue for the Iranian regime and fund its malign activities throughout the Middle East. Triliance has used various front companies to purchase, or facilitate the purchase and movement of, petrochemical products from Iran, and the entities targeted today help facilitate Iran’s petrochemical and petroleum exports in contravention of U.S. economic sanctions." ( (U.S. Treasury, "Treasury Sanctions Companies for Enabling the Shipment and Sale of Iranian Petrochemicals," 9/3/2020).

YCF is listed on the 4Q 2020 Minnesota State Board of Investment List of Unauthorized (Scrutinized) Iran Companies.

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In 2020, the U.S. state of Mississippi listed YCF on its state lists of Companies Doing Business with the Iranian Petroleum/Natural Gas, Nuclear and Military Sectors, rendering it ineligible for investment and/or state contracting.

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On January 20, 2020, Minnesota SBI listed YCF as a scrutinized investment. The managers are explicitly instructed to refrain from purchasing securities on this list.

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As of December 31, 2019, the Alaska Retirement Management Board lists YCF as a company doing material business with Iran.

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As of May 28, 2020, the Florida State Board of Administration (“SBA”) continues to list YCF on its list of “Scrutinized companies with Activities in the Iran Petroleum Energy Sector.

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On March 13, 2019, the Mississippi Department of Finance & Administration identified YCF as a company “engaged in investment activities in Iran, providing funds, goods or services valued at $20,000,000 or more in the energy sector of Iran.

According to its Annual Report filed with the SEC for fiscal year 2018: "In June 2017, CLPCIC, a casualty and property insurance company in which we own 40% interest, provided marine hull insurance for a fleet of vessels managed by the National Iranian Tanker Company (“NITC”) as a co-insurer for the period from July 1, 2017 to June 30, 2018, and the lead insurer is Assuranceforeningen Skuld. These transactions were entered into in compliance with laws and regulations applicable to CLPCIC. We understand that NITC is affiliated with the Government of Iran and it was, at the time the insurance was in force, on the List of Persons Identified as Blocked Solely Pursuant to Executive Order 13599. The total premiums that CLPCIC received from these transactions are approximately RMB 530,000. The insurance coverage under these transactions expired on June 30, 2018. CLPCIC does not intend to continue providing insurance coverage to NITC upon the expiration of the insurance coverage."