According to its Annual Report filed with the SEC for fiscal year 2013: "From November 2012 to January 2013 one of our UK subsidiaries performed an assignment for Melli Bank PLC, a bank incorporated in the UK, consisting of assessing the refurbishment costs for two London properties leased by the bank. To carry out this assessment, our UK subsidiary inspected and measured the two properties and reported its assessments. Melli Bank PLC had been identified on the Specially Designated Nationals and Blocked Persons List (the “SDN List”) pursuant to Executive Order No. 13628. Our gross revenue attributable to this assignment was £7,500 (exclusive of VAT), which was paid to us in February 2013, and our net profits related thereto were approximately £3,375.
On November 6, 2013, one of our UK subsidiaries entered into a contract (the “Contract”) with Melli Bank PLC under which it agreed to provide advice on tax rates for leased commercial property in London. To our knowledge, our UK subsidiary did not perform any services under the Contract nor was it paid a fee. Under the Contract, our UK subsidiary had agreed to conduct inspections of the property, negotiate with UK authorities regarding the applicable rates, calculate tax rate liability, and advise on actions to reduce rate liability. Upon discovering through an internal review that Melli Bank PLC was on the SDN List, we placed a hold on all activity relating to Melli Bank PLC pending further guidance from the U.S. Treasury Department’s Office of Foreign Assets Control. We do not otherwise intend to enter into any Iran-related activity."