"Disclosures Under Iran Threat Reduction and Syria Human Rights Act of 2012
The Company is making the following disclosure under Section 13(r) of the Exchange Act because the Company’s management recently became aware that the ultimate customer in Iran, which meets the definition of the “Government of Iran” under Section 560.304 of 31 C.F.R. Part 560 (the “Iran Party”), was not eligible to receive non-U.S. origin products sold by our foreign subsidiary through a third-party distributor under General License H issued by the U.S. Department of the Treasury, Office of Foreign Assets Control (“OFAC”). Based upon currently known information, total revenues to our foreign subsidiary from indirect sales to the Iran Party, which took place from September 2016 through September 2018, were approximately $8.4 million, and the total net income attributable to those sales was approximately $1.6 million.
Upon expiration of OFAC’s authorization in November 2018, our foreign subsidiary stopped all shipments to the distributor for resale to the Iran Party, and, accordingly, the foreign subsidiary does not intend to continue sales to, or engage in other dealings with the Iran Party. On April 8, 2019, the Company submitted initial notifications of voluntary self-disclosures to OFAC regarding these historic activities, and the Company intends to cooperate fully with OFAC." (U.S. Securities and Exchange Commission, "Form 10-Q," 4/26/2019).
"Jacqueline Berry, a spokeswoman for 3M, said the company received this license to sell certain medical and dental products to civilian populations in Iran. It separately received another license to sell specialized window film to a United Nations building in Sudan." (New York Times, "Licenses Granted to U.S. Companies Run the Gamut," 12/24/10)