Promontory Financial Group LLC

"IBM Italia Servizi Finanziari S.p.A., a 100 percent owned subsidiary of IBM Italy, currently has an equipment financing lease with an Italian company called Irasco.  IBM’s original inspection of Irasco indicated it to be an Italian subsidiary of Ascotec Gmbh, a German company holding 51 percent of Irasco’s equity.  Upon further inspection of Ascotec (the German company), it was discovered to be wholly owned by Iranian Mines and Mining Industries Development and Renovation Organization (IMIDRO)." (CORRESP for INTERNATIONAL BUSINESS MACHINES CORP, 4/16/2009)

"IBM does not believe that the financing agreement between IBM Italy and Irasco constitutes a material risk to our investors, whether analyzed on a quantitative or qualitative basis.  From the perspective of quantitative materiality, at inception, the financing lease provided for total revenue to IBM of $106,652." (CORRESP for INTERNATIONAL BUSINESS MACHINES CORP, 6/8/2009)


IRASCO's main clients are in Iran, including the National Iranian Oil Company (controlled by the IRGC) (IRASCO client list)