According to its Annual Report filed with the SEC for fiscal year 2019: "Additionally, the U.S. Department of the Treasury’s Office of Foreign Control and the Bureau of Industry and Security at the U.S. Department of Commerce administer laws and regulations that restrict U.S. persons and, in some instances, non-U.S. persons, in conducting activities, transacting business or making investments in certain countries, or with governments, entities and individuals subject to U.S. economic sanctions. From time to time, certain of our subsidiaries have limited business dealings with countries subject to these sanctions, including Iran, Sudan, Syria, Russia and Cuba. These dealings represent an insignificant amount of our consolidated revenues and income but expose us to an increased risk of operating in these countries, including foreign exchange risks or restrictions or limitations on our ability to access funds generated in these jurisdictions, or the
risk of violating applicable sanctions or regulations, which are complex and subject to frequent change."
Baxter International acquired Gambro Middle East in Egypt to operate in Iran.
Over the last three presidential administrations, the United States government has granted Baxter International 22 special licenses to do business in Iran. (New York Times, "Companies with Permission to Bypass Sanctions," 12/24/10)
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