Withdrawn

Illinois-based Dover, a manufacturing conglomerate, said the revocation of License H would end its business in Iran. Dover had been selling spare parts for pumps used in Iran’s energy infrastructure and was set to earn more than $16 million in revenue from contracts signed there since the beginning of 2017, according to regulatory filings. (June 5, 2018).

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In its 2017 SEC 10:K filing Dover notes: “In connection with the easing of certain sanctions by the U.S. against Iran in January 2016 and in compliance with the economic sanctions regulations administered by U.S. Treasury’s Office of Foreign Assets Control (“OFAC”), a wholly-owned non-U.S. subsidiary in our Fluids segment serving the pumps end market sold non-U.S. origin spare parts related to the oil, gas and/or petrochemical sectors to Iranian counterparties pursuant to new contracts, which resulted in revenue of approximately €101,660 and net profits of approximately €71,536 in 2017 (expected total revenue from these contracts is approximately €12.1 million). “

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According to its Annual Report filed with the SEC for fiscal year 2013: "During the disclosure period, Automatik Plastics Machinery GmbH ("Automatik"), a German affiliate of Maag Pump Systems, which we acquired on March 13, 2012, exported from Germany European-origin equipment used in the processing of polystyrene pellets and PET chip to two entities in Iran, Tabriz Petrochemical (“Tabriz”) and Shahid Tondgoyan Petrochemical (“Shahid Tondgoyan”), which we understand are owned or controlled by the Government of Iran.  All of the exports except one were made prior to August 10, 2012, the date of enactment of the Iran Threat Reduction and Syria Human Rights Act of 2012 (“ITRA”).  Automatik made two exports to Tabriz on February 24, 2012 and May 8, 2012, with total revenue and net profit values of €51,550 and €14,759, respectively. Automatik made three exports to Shahid Tondgoyan on March 6, 2012, July 19, 2012, and August 8, 2012 with total revenue and net profit values of €516,831 and €162,588, respectively. The only export made after the enactment of the ITRA was made to Shahid Tondgoyan on October 4, 2012, with a revenue and net profit value of €20,388 and €7,411, respectively. This last export was made prior to the October 9, 2012 date of the Presidential Executive Order that made it a violation of U.S. law for owned or controlled foreign subsidiaries after October 9, 2012 to knowingly engage in transactions with the Government of Iran or any person subject to the jurisdiction of the Government of Iran.  For most of these exports, Automatik received official written confirmation from the German Government that it did not require a license under German law and for the others it received oral confirmation no license was required.  Automatik also received a payment in November 2012 for a prior order that was not shipped and will not be shipped in the future. Given the SEC guidance that issuers should disclose all activities, including those taking place prior to ITRA's enactment on August 10, 2012, we are including all exports by Automatik Germany to government entities in Iran during 2012.  Management has instructed all of the Company's non-U.S. affiliates not to engage in any trade transactions with Iran."

Diacron participated in the Iran-Italy Summit 2017 (“the Summit”), that took place in Rome, Italy on November 27, 2017. The
Summit was held in cooperation with the Tehran Chamber of Commerce, Industries Mines and Agriculture (“TCCIM”). (The European House Ambrosetti, “Iran-Italy Summit”),

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According to its website: "The Diacron group has been present in Iran since 2016, after years of experience and networking in this country that led, among other things, to the publication of the How to do business guide in Iran. 100 questions, 100 answers . At the Bra Seminar he will participate with an intervention by Lorenzo Bagnoli on corporate and tax aspects in investments."

Česká confirmed to the media in April 2016 that it has reentered the Iranian market, explaining that “[w]e try to support the export activities of our corporate customers.”  (Banks EU, “ČSOB and Česká Spořitelna first among Czech banks to resume their work with Iran,” 4/7/2016).  Further, Česká’s website relates that Deputy Head of Correspondent Banking, Barbora Procházková, is responsible for contact with banks in Iran.  (Česká website, “Contacts”). 

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Sub. Of EGB Ceps Holding

Cabot has no commercial ties with the sanction-designated Iranian entity, Ervin Danesh Aryan Company (“Ervin Danesh”); does not intend to initiate business with Ervin Danesh; has not authorized the use of the Cabot logo or name by Ervin Danesh, and; following UANI’s letter, will take substantive steps to rectify the advertised but false impression of business ties between Cabot and Ervin Danesh, including by issuing a “cease and desist” notice to Ervin Danesh demanding they remove “all references to Cabot and its products from their website.” We also note that Cabot “is not currently engaging in any sales of products into Iran.” 

"French state-owned bank Bpifrance has abandoned its plan to set up a mechanism to aid French companies trading with Iran, in the face of U.S. sanctions against Tehran. Earlier this year, the bank had said it was working on a project to finance French companies that wished to export goods to Iran despite U.S. sanctions. “It’s put on hold,” said Nicolas Dufourcq, Bpifrance’s chief executive. “Conditions are not met (...) Sanctions are punitive for companies.”" (1/24/2018)

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On September 24, 2017, The New York Times reported that Bpifrance “will finance investment projects of French companies in Iran from 2018, granting up to 500 million euros ($598 million) in annual credits.”  (New York Times, “French State Bank Bpifrance to Fund Projects in Iran, CEO Tells Paper,” 9/24/2017). 

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This report followed an earlier article from October 2016, which reported that “officials from the Bpifrance and Export Development bank of Iran (“EDBI”) discussed expansion of ties….”  (Financial Tribune, “Bpifrance, EDBI Discuss Ties,” 10/24/2016).

Several banks have announced since the U.S. JCPOA exit a cessation of transactions with Iran: DZ Bank and Allianz of Germany; Oberbank of Austria; and Banque Wormser Freres of France. (Iran Sanctions)

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"May stop Iran trades because of concerns about accessing U.S. dollars." (Benoit Faucon and Sarah McFarlane, "King Dollar Tightens Noose on Iranian Economy," The Wall Street Journal, June 25, 2018.)

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In January 2017, the Reserve Bank of India (“RBI”), based on information obtained from the Indian Embassy in Tehran, named Banque Worms SA (“Banque Worms”) as one of a number of international banks with correspondent banking relationships with Iranian banks.  (RBI Website, “FAQs [Names of International banks which have entered into a correspondent banking relationship with Iranian banks],” 1/19/2017).

"Bank Alpinum terminates business dealings with Iran - including those that are not affected by the current Iran sanctions, but where the client lives in Iran. This was decided by the Board of Directors in mid-March, as the bank announced on Friday." (5/24/2019)

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In January 2017, the Reserve Bank of India (“RBI”), based on information obtained from the Indian Embassy in Tehran, named Bank Alpinum AG (“Bank Alpinum”) as one of a number of international banks with correspondent banking relationships with Iranian banks.  (RBI Website, “FAQs [Names of International banks which have entered into a correspondent banking relationship with Iranian banks],” 1/19/2017).

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Bank Alpinum has agreed to speak at the Impulse Event: Iran in Biel, Switzerland on June 29, 2017.  (S-GE Website, “IMPULSE EVENT: IRAN”). 

Letter was written over participation in the Iran Telecom Innovation October 2017 exhibition. ATDI informed UANI

We didn’t know that CRA Iran was sanctioned in May 2017...we inform you that our company will not participate in the Iran telecom innovations 16-19 October 2017 exhibition.

AMEL has no commercial ties with the sanction-designated Iranian entity, Ervin Danesh Aryan Company. 

Aleastur's website notes that the company and "its suppliers, customers, agents, distributors, supplied Companies, freight forwarders, forwarding agents, logistic Companies, clients, and any other kind of collaborator of ALEASTUR group" are prohibited from engaging in business with Iranian entities.

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We noted the attendance of Asturiana de Aleaciones, S.A. (“Aleastur”) at the 4th International Iran Aluminium Conference (the “Conference”) on May 11-12, 2016 in Tehran.  Aleastur confirmed to UANI it is not considering any investments or any other undertakings in Iran nowadays, nor in the future.