Withdrawn

Dole Food Company

Industry
Food and Beverage
States
CA
Country
USA
Sources

“Dole Food Company has previously engaged in the exportation of agricultural commodities to distributors located in Iran and in other countries for onward shipment to Iran in reliance on an OFAC general license that authorizes such activities…In January 2020, due to difficulties in receiving payment and importing the agricultural commodities into Iran following the reimposition of U.S. sanctions against Iran that had been lifted under the Joint Comprehensive Plan of Action, Dole Food Company ceased all direct exports of agricultural commodities to Iran and all exports to other countries for the purpose of onward distribution to Iranian consignees or end users.” (SEC Filing, 2020)

Aalborg

Industry
Manufacturing
States
NY
Country
USA
Response

"We observe the strictest boycott of all Iran related businesses, and I am instructing our Export Manger to take immediate action tracing any third party suppliers that have breached the sanction regulations. Rest assured of our unqualified support for boycotting Iran. Please continue the good work of monitoring breaches of the Iran boycott..." (August 13, 2021).

Fluenta

Industry
Technology
Country
Norway
Sources

Fluenta features on the official Iranian vendor website, “VList” – the ‘petroleum and energy vendor source search engine of I.R. Iran’.”

Response

“Thanks for your letter dated 23rd of September which has been forwarded to me. Our position regarding Iran is currently very simple. We do not do business on projects in Iran or with any companies in Iran, and we seek to comply with all sanctions in place. I expect our position on the approved vendor list is as a result of work undertaken before the current sanctions were imposed. I hope this clarifies the matter.” (September 24, 2021)

MCT Brattberg AB

Industry
Manufacturing
Country
Sweden
Sources

MCT Brattberg features on the official Iranian vendor website, “VList” – the ‘petroleum and energy vendor source search engine of I.R. Iran’.”

Response

"As stated in my email to you on the 29th of September 2021, MCT Brattberg is following the development in Iran, and we can confirm that we have had NO and will NOT have any trades with Iran as long as the sanctions still are ongoing. The below explanation was also provided to you in my email from the 29th of September 2021 and is still valid. Why MCT Brattberg is on Iranian companies “approved vendor” list can only depend on previous trades made before the sanctions was established. These trades were made by at that time a MCT Brattberg representative, ESPAK. We reminded ESPAK in 2019 that they were no longer a representative of MCT Brattberg, and this information was at that time shared with you, as per attached PDF, two pages." (September 12, 2023)

Servomex Group

Industry
Engineering
Country
UK
Sources

Servomex is featured on the website of the Iranian energy services firm Sima Mehr.

Response

"Servomex has not done business in Iran, directly or indirectly, since the US withdrew from the JCPOA in 2018. With regards to Sima Mehr, Servomex have had no business transactions with them since 2018…In the circumstances, we will attempt to have Sima Mehr remove references to Servomex from their website." (6/29/2021)

ICICI Bank

Industry
Banking
Country
India
Sources

"ICICI Bank reportedly facilitates banking services with Iran. In 2020, CalSTRS identified and subsequently removed ICICI Bank after reviewing the company’s internal controls to prevent sanction violations."

CNOOC Ltd.

Industry
Energy
Country
Hong Kong
Sources

On June 16, 2011, CNOOC Ltd was added to the Florida State Board of Administration List of Prohibited Investments (Scrutinized Companies) due to its involvement in Iran. As of March 9, 2021, CNOOC Ltd remains on the SBA list of prohibited investments. 

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As of July 2020, China Oilfield remains on the Pennsylvania Treasury's List of Scrutinized Companies Determined as Having Involvement In Iran because of oil-related investment of US $20 million since 1996. 

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In 2020, the U.S. state of Mississippi listed CNOOC on its state lists of Companies Doing Business with the Iranian Petroleum/Natural Gas, Nuclear and Military Sectors, rendering it ineligible for investment and/or state contracting.

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"Chinese oil companies such as Sinopec [SASADZ.UL], CNOOC Ltd and others have managed to reduce their shipments of Iranian oil but it is unclear which Chinese government parties might still be buying Iranian oil, a senior U.S. energy official said on Tuesday." (Reuters, 9/10/2019).

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According to CNOOC 20-F Filings, the company cites in its risk section the potential for U.S. sanctions related to its affiliates’ operations in Iran and Sudan. In particular, one of the company’s noncontrolled affiliates continued to provide certain drilling and other related services in Iran. In 2011, CalSTRS staff met with executives of the company in its offices in Beijing. The company confirmed its parent may have ties to Iran, but it does not, and will not, seek business in Iran as the company has and is looking to purchase more assets in the United States. CNOOC is listed on the December 31, 2018 CalSTRs Portfolio of companies identified as possibly having ties to Iran and from which CalSTRs has divested from and restricted in 2018. While CNOOC does not appear to have direct ties to Iran, CalSTRS is uncomfortable with its parent company’s relations to the country. In 2012, CalSTRS divested holdings of CNOOC and designated the company as “Divested and Restricted.” CalSTRS has maintained the “Divested and Restricted” designation in 2018.

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According to its Annual Report filed with the SEC for fiscal year 2018, 2017 : "To our knowledge, in 2018, China Oilfield Services Limited (COSL), one of our non-controlled affiliates, provided certain drilling services in Iran. We cannot predict at this time whether U.S. sanctions will be imposed on any of our affiliates."

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According to its Annual Report filed with the SEC for fiscal year 2016: "To our knowledge, in 2016, China Oilfield Services Limited (COSL), one of our non-controlled affiliates, provided certain drilling and other related services in Iran and another non-controlled affiliate of ours was engaged in submarine cable installation and trenching services in Iran. We cannot predict at this time whether U.S. sanctions will be imposed on any of our affiliates."

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According to its Annual Report filed with the SEC for fiscal year 2015: "To our knowledge, in 2015, China Oilfield Services Limited (COSL), one of our non-controlled affiliates, continued to provide certain drilling and other related services in Iran under renewed subcontracting agreements entered into in 2009, as it did in 2014. We cannot predict at this time whether U.S. sanctions will be imposed on any of our affiliates."

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According to its Annual Report filed with the SEC for fiscal year 2013: "To our knowledge, in 2013, China Oilfield Services Limited (COSL), one of our non-controlled affiliates, continued to provide certain drilling and other related services in Iran in relation to subcontracting agreements entered into in 2009, as it did in 2012. We cannot predict at this time whether U.S. sanctions will be imposed on any of our affiliates."

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Response

"We take the opportunity to clarify that, to the best of our knowledge, neither CNOOC Limited nor any of its subsidiaries has invested in any Iranian entity, or
has any business operations in Iran." (7/16/2020)

DSV Panalpina A/S

Industry
Transportation
Country
Denmark
Sources

"DSV A/S merged with Panalpina Welttransport Holding AG, which had previously been identified as possibly providing shipping services to Iran. In 2019, CalSTRS identified DSV A/S as potentially having ties to Iran with the merger with Panalpina Welttransport Holding AG and began the review process. In 2020, CalSTRS removed DSV Panalpina A/S after reviewing the company’s internal controls to prevent sanction violations."

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In 2019, CalSTRS identified DSV A/S as potentially having ties to Iran with the merger with Panalpina Welttransport Holding AG and began the review process. DSV A/S merged with Panalpina Welttransport Holding AG, which had previously been identified as possibly providing shipping services to Iran. 

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"Iran is a highly attractive market – one where Panalpina wants to grow its business now that the international embargoes have been lifted. Opportunities lie, first and foremost, in oil and gas.

Panalpina has cooperated with its Iranian agent Chain International Transport Co. since 2000. Chain International with its head office in Teheran and numerous other offices throughout the country employs over 110 very well educated and trained staff. They provide all modes of transport also for heavy-lift and oversized cargo. Furthermore they provide customs clearance and logistics services.

If extra expertise is needed in Iran, Panalpina is ready to send its project managers to the country for supervision on the ground." (My News Desk, "Ready for Iran," 1/18/2016). 

Response

Response 6/26/2020