Archer Daniels Midland Company (ADM)
"Two sources said the increasing difficulties had prompted U.S. agribusiness company ADM (ADM.N) to halt trading with Iran since August. An ADM spokeswoman declined to comment." (Reuters, "Exclusive: Ships with one million tonnes of grain stuck outside Iran's ports in payment crisis," 10/2/2019).
Over the last three presidential administrations, the United States government has granted Archer Daniels Midland Company 48 special licenses to do business in Iran. (New York Times, "Companies with Permission to Bypass Sanctions," 12/24/10)
"After years of difficulty caused by economic sanctions, suppliers are hoping a nuclear deal will make it easier to win lucrative contracts to sell wheat, sugar and other food to Iran…Top global agribusiness groups such as Cargill and Archer Daniels Midland Co and others like Swiss commodities trader Glencore-Xstrata have been among the dominant players in Iran's food trade. Those three firms confirmed they sell agricultural products to Iran, and said the activity was in compliance with sanctions." (Reuters, "Food suppliers look to win Iran contracts after nuclear deal," 11/28/13)
According to its Annual Report filed with the SEC for fiscal year 2012: "On or about July 25, 2012, an 80% owned and controlled affiliate of the Company hired a vessel to transport a cargo of grain. The shipping arrangements and payment for $481,800 for the transportation were made directly with the charterer of the vessel. Neither the names of the vessel nor the charterer were listed on the United States Department of the Treasury’s Office of Foreign Assets Control’s (“OFAC”) List of Specially Designated Nationals (the “SDN List”). It was later determined by the Company and its bank that the vessel involved was beneficially owned by the Islamic Republic of Iran Shipping Lines (IRISL), a sanctioned party. The Company voluntarily disclosed the matter to OFAC. The involvement of a sanctioned party was inadvertent and unintentional and we believe the result of a concerted effort by Iran to hide its ownership of the vessel. Neither the Company nor its affiliate nor other of its subsidiaries have any intention of continuing such activity with a prohibited party. There was no profit that can be attributed to this specific transportation activity. This disclosure is made pursuant to Section 219 of the Iran Threat Reduction Act which requires that an issuer disclose in its annual or quarterly report filed with the Securities and Exchange Commission if any of its affiliates engaged in an OFAC reportable transaction."
"This license authorized Archer Daniels Midland Company to fulfill a contractual obligation it had in connection with a 'string transaction.' Companies enter into such transactions when they sell goods on a commodities market. Often, they have no way of knowing where the goods will end up. In this case, Archer Daniels Midland found out that its goods were destined for Iran after it entered into the transaction, according to its application. OFAC said it generally grants licenses in this type of situation because failing to do so could bring American commodities trading to a halt." (New York Times, "Licenses Granted to U.S. Companies Run the Gamut," 12/24/10)