As stated in its 2017 20-F SEC disclosure: "To help us fulfill this mission, we have representative offices located in Iran. In the second quarter of 2016, a non-US affiliate within our Innovative Medicines Division submitted a non-binding written proposal for potential collaboration related to local manufacturing, scientific and medical activities between the Iranian Ministry of Health and certain non-US affiliates within our Innovative Medicines and Sandoz Divisions. In the third quarter of 2016, a non-US affiliate within our Innovative Medicines Division submitted a draft of a proposed binding Memorandum of Understanding (MoU), based on the proposal submitted during the second quarter of 2016, to the Embassy of the Islamic Republic of Iran in Bern, Switzerland, to seek support for a meeting with representatives of the Iranian Ministry of Health to negotiate and finalize the MoU. A draft of the proposed binding MoU was submitted to the Iranian Ministry of Health and the Ministry of Foreign Affairs of Iran in the fourth quarter of 2016.
In 2017, non-US affiliates relating to our Innovative Medicines and Sandoz Divisions made payments to government entities in Iran related to exit fees and other transactions ordinarily incident to travel by doctors and other medical professionals resident in Iran to attend conferences or other events outside Iran.
From time to time, including in 2017, non-US affiliates relating to our Innovative Medicines and Sandoz Divisions enter into agreements with hospitals, research institutes, medical associations and universities in Iran to provide grants, sponsor congresses, seminars and symposia, and with doctors and other healthcare professionals for consulting services, including participation in advisory boards and investigator services for observational (non-interventional) studies. Some of these hospitals and research institutes are owned or controlled by the government of Iran, and some of these doctors and healthcare professionals are employed by hospitals that may be public or government-owned.
Because our Innovative Medicines and Sandoz Divisions have operations in Iran, including employees, they obtain services and have other dealings incidental to their activities in that country, including paying taxes and salaries either directly or indirectly through a service provider, and obtaining office rentals, insurance, electricity, water and telecommunications services, office and similar supplies and customs-related services from Iranian companies that may be owned or controlled by the government of Iran."
"Novartis AG, Europe's biggest drugmaker by sales, said its Alcon eye-care unit is under U.S. government investigation related to the export of products to Iran and other countries subject to trade sanctions. Alcon was notified last year that the U.S. Attorney's office for the Northern District of Texas is conducting an investigation into its sales, Novartis said in a regulatory filing today. The unit, run from Fort Worth, Texas, received a grand jury subpoena for documents dating back to 2005. Alcon is cooperating with the investigation, according to the filing. The U.S. government has programs that prohibit or limit products made or held in the U.S. from being sold to certain countries, including Iran, Syria and North Korea. Novartis, based in Basel, Switzerland, took full control of Alcon in 2010 after an 11 month dispute with minority shareholders. Alcon was based in Huenenberg, Switzerland, with U.S. headquarters in Texas. It generated $2.6 billion in sales during the fourth quarter, Novartis said today." (Bloomberg, "Novartis Draws U.S. Investigation Into Sales to Iran," 1/23/12)