Withdrawn

Tadano

Industry
Construction
Value of USG Contracts
6
Value of USG Contract Source
http://www.usaspending.gov/explore?fromfiscal=yes&fiscal_year=2010&contractorid=299625&fiscal_year=&tab=By+Prime+Awardee&fromfiscal=yes&carryfilters=on&Submit=Go
Symbol
TYO: 6395
States
TX
Country
Japan
Sources

"Now owned by the Japan-based Tadano, Demag is featured extensively on Jobasin's website. Jobasin’s CEO, owner, and Managing Director is Alexander Jozak (a.k.a. Ali Jozak), a German- Iranian who was arrested late last year for illegally supplying equipment to Iran, including products used for Iran’s illegal ballistic missile program. According to a report in BILD titled “Hamburg entrepreneurs helped mullahs build bombs,” Jozak is believed to have “procured industrial
equipment with his company and delivered it illegally to Iran through middlemen.”"

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"A Japanese heavy machinery manufacturer said it has cut business ties with the Iranian government following a report that its cranes have been used for public executions. The company's announcement came several days after United Against Nuclear Iran President Mark D. Wallace published an op-ed in Los Angeles Times where he names the Japanese Tadano company as one of several companies exporting cranes to Iran. 'In response to Iran's brazen attempts to intimidate and terrorize its own people, United Against Nuclear Iran has launched a Cranes Campaign. The goal is to educate crane manufacturers worldwide about the Iranian regime's clear misuse of their products and how such use can tarnish their brand image,' Wallace wrote." (YnetNews. "Japanese firm cuts ties with Iran over crane executions," 7/15/11)

 

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Tadano is Japan's largest manufacturer of cranes and lifting equipment. Tadano manufactures all-terrain cranes, aerial work platforms, truck cranes, boom trucks, and other construction equipment (Company Website). In 2010, Tadano had over $1 billion in net sales (Annual Report). Tadano has a large American presence.

Tadano lists an Iranian subsidiary, IER Iran, on its website. IER Iran imports a wide variety of construction equipment, including Tadano cranes, into Iran. Tadano's cranes are used by the Iranian regime to publicly execute dissidents (Photo).

 

SK Energy

Industry
Energy
Symbol
KRX:096770
Country
South Korea
Sources

In January 2021, the State of New Jersey Department of the Treasury listed SK Energy as a company engaged in prohibited activities in Iran pursuant to P.L. 2012, c. 25 ("Chapter 25"). 

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On October 14, 2020, SK Energy remained on the Tennesse Department of General Services list of persons it determines engage in investment activities in Iran, as described in 12-12-105.

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As of July 1, 2020, SK Energy is listed as an entity “determined, based on credible information available to the public, to be engaged in prohibited activities in Iran pursuant to New Jersey P.L. 2012, c.25 (“Chapter 25”). 

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In 2020, the U.S. state of Mississippi listed SK Energy 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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As of June 8, 2020, SK Energy is listed on the Pennsylvania Department of General Services Iran Free Procurement List. Entities included on this list are ineligible to enter into a contract with the Commonwealth of Pennsylvania for goods and services worth at least $1,000,000 per sections 3501-3506 of the Commonwealth Procurement Code, 62 Pa. C.S. §§ 3501-3506.  

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As of April 15, 2020, SK Energy is included as an entity determined to be non-responsive bidders/offerers pursuant to The New York State Iran Divestment Act of 2012.  

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As of April 15, 2020, SK Energy is included on the Tennessee list of persons it determines engage in investment activities in Iran, as described in § 12-12-105. 

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On March 13, 2019, the Mississippi Department of Finance & Administration identified SK Energy as a company “engaged in investment activities in Iran, providing funds, goods or services valued at $20,000,000 or more in the energy sector of Iran.”  

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In 2018 and 2019 Tennessee used the New York list of “Entities determined to be non-responsive bidders/offerers pursuant to the New York State Iran Divestment Act of 2012.” SK Energy was included on this list in 2018 and 2019. Tennessee states "Inclusion on this list would make a person ineligible to contract with the state of Tennessee, if a person ceases its engagement in investment activities in Iran, it may be removed from the list."

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“South Korea's crude imports from Iran surged 104 percent in February from a year earlier as refiners hiked purchases ahead of maintenance shutdown starting from March, according to the country's customs data and a refining source. South Korea imported 1.1 million tonnes of Iranian crude last month, or 294,069 barrels per day (bpd), up 4.5 times from January and double from a year earlier, preliminary customs data showed on Saturday…’The two refiners had to hike the imports ahead of maintenance shutdown starting from March. Before and after the maintenance, refiners usually import more to meet annual import contracts,’ a Seoul-based refining source told Reuters. Of four South Korean refiners, SK Energy and Hyundai Oilbank are the only ones that buy Iranian oil on a regular basis. Their Iranian crude imports can vary from month to month as one of the two refiners that buy from the OPEC receives the oil only every other month. SK Energy will shut a 260,000 bpd No. 5 crude distillation unit (CDU) and a 57,000-bpd No.1 gasoline-making unit in the second quarter for maintenance, a spokesman at parent SK Innovation Co Ltd said. Hyundai Oilbank will shut its No.1 110,000-bpd CDU in April for maintenance, it said last month.” (Reuters, “S.Korea Feb Iran oil imports soar ahead of shutdown," 3/15/14)

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"South Korea's Iranian crude imports fell in October from September, meeting a targetted 15 percent cut in its shipments from the OPEC member for the June-November period to secure an extension of its six-month U.S. sanctions waiver…outh Korea imported 420,402 tonnes of Iranian crude last month, or 99,405 barrels per day (bpd), down more than a quarter compared with September and down nearly a half from a year earlier, preliminary customs data showed on Friday…The total means South Korea met the 125,814 bpd it aims to achieve in its imports from Iran in the six months through November…South Korea's Iranian crude imports vary from month to month as one of the two Korean refiners that buys from Iran receives oil only every other month, according to industry sources. The imports unexpectedly jumped in July from the year-earlier period before dropping off again in August. SK Energy and Hyundai Oilbank are the only South Korean refiners that take Iranian oil on a regular basis. South Korea, the world's fifth-largest crude buyer, imported a total of 10.7 million tonnes of crude last month against 11.1 million tonnes in October 2012, data from the Korea Customs Service also showed on Friday." (Reuters, "S.Korea's Oct Iran oil imports drop, meet target," 11/15/13)

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"South Korean refiners SK Energy and Hyundai Oilbank are the only two in the country to import Iranian crude. Spokesmen at both refiners declined to comment." (Reuters, "South Korea Pledges 15 Percent Cut to Iran Oil Imports," 06/24/13)

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"South Korea's imports of Iranian crude in March fell 16.2 percent from a year ago to 4.02 million barrels, data from the state-run Korea National Oil Corp showed on Monday, after its biggest refiner SK Energy shut a crude unit for maintenance... But imports from sanctions-hit Iran should surge month-on-month to 190,000 bpd in April as SK Energy's 110,000-bpd crude distillation unit returned to operation on April 16 after 30 days of maintenance... Its two buyers of Iranian crude, refiners SK Energy and Hyundai Oilbank, are shutting a combined 560,000 bpd of refinery capacity for planned maintenance between March and June." (Reuters, "Update 1 - S.Korea's Iran Crude Imports for March Down 16.2 pct Y/Y," 4/22/2013)

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"South Korean refiners will cut imports of Iranian crude during the six months to May by about a fifth from a year earlier, to avoid sanctions by Washington, government and industry sources told Reuters on Monday. Last week the United States granted 180-day waivers on Iran sanctions to China, India, South Korea and some other countries after they cut oil purchases from the Islamic Republic... South Korea, the world's fifth largest importer of crude, and one of Iran's biggest oil customers, gave the assurance on the size of the cuts in talks with the United States following discussions with Korean refiners, the sources said. Such a cut would imply South Korean imports of about 147,814 barrels per day (bpd) over the period to next May, since the country imported 184,767 bpd of Iranian crude from December 2011 to May 2012. Two refiners, SK Energy and Hyundai Oilbank, now import about 200,000 barrels per day of crude from Iran." (Reuters, "South Korea to Cut Iran Crude Imports 20 Percent," 12/10/12)

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"South Korea's biggest oil refiner SK Energy loaded a second cargo of crude in Iran last week, a government source said on Wednesday, as Seoul resumes Iranian oil shipments after a near two-month gap caused by a European Union ban on insurance cover... A spokesman for SK Energy's parent firm confirmed last week that another Iranian cargo of the same volume was already on its way to South Korea. 'SK Energy lifted its second cargo in Iran last week,' said the source at South Korea's economy ministry, adding that SK Energy's first cargo had not arrived yet in Korea. SK Energy and its parent SK Innovation declined to comment... Of South Korea's four refiners, only SK Energy and Hyundai Oilbank import Iranian crude. SK Energy's term contracts with Iran this year provide for imports of two Very Large Crude Carriers (VLCCs) of crude per month, or 4 million barrels, and Hyundai Oilbank imports one VLCC per month, or 2 million barrels, according to the economy ministry source." (Reuters, "S.Korea's SK Energy lifts 2nd Iran crude cargo-source," 9/26/2012)

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"South Korean refiners will resume imports of up to 200,000 barrels per day of Iranian crude from September, economy ministry sources said on Monday, ending a two-month gap due to a European Union ban on insurance cover for Iranian oil... Total imports envisaged at resumption will be six million barrels per month, or 200,000 bpd. SK Energy will import four million barrels per month and Hyundai Oilbank will import two million barrels per month, the economy ministry source added. This is the volume refiners agreed in term contracts with Iran for this year... A spokesman at SK Innovation, which owns SK Energy, told Reuters last Friday that the talks with Iran were progressing well, and the refiner expected to resume the imports around September loading." (Reuters, "S.Korea to resume Iran oil imports from Sept -econ min sources," 8/20/12)

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"South Korean refiners plan to resume buying crude from Iran in September after a two-month hiatus due to a European Union embargo that made shipping the oil difficult, government and refining sources said on Wednesday. The refiners have, like their Chinese and Indian counterparts, asked Iran to deliver crude on Iranian tankers, government and industry sources said. This shifts the responsibility to Iran for insurance, sidestepping a ban in the EU on insurers from covering Iranian shipments... South Korean refiners and the National Iranian Tanker Company (NITC) are close to finalising a deal that would allow loading to resume from September, sources said.'Refiners have requested Iran to deliver crude, and the deal is almost reached,' a government source with direct knowledge of the matter said... Two refining sources confirmed the request had been made to NITC. SK Energy and Hyundai Oilbank are the only two South Korean refiners that import Iranian crude. The refiners would buy a similar quantity of oil as they had prior to the July stoppage, sources said. There may be some variance month by month due to the size of vessels available for imports from NITC, one refining source said." (Reuters, "S.Korea to resume buying Iranian crude in Sept," 8/8/12)

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"There's a 'high chance' that South Korea will resume importing Iranian crude oil in the near future, Minister of Knowledge Economy Hong Sukwoo said Thursday… Iranian officials have since offered accident insurance coverage worth a maximum of $1 billion on Iranian tankers shipping crude oil to South Korea, a Hyundai Oilbank official said earlier this month. Hyundai Oilbank and SK Energy, the two South Korean refiners that imported Iranian crude, are considering Iran's offer to provide shipping services, officials from both companies have said… South Korea usually imports around 10% of its crude-oil requirements from Iran, but that percentage declined to 7.4% in the first six months of this year." (Dow Jones, "S Korea Oil Imports to Iran Seen Restarting," 7/26/12)

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"South Korea became the first major Asian consumer of Iranian crude to announce a halt to imports after the government said they would be suspended from July 1 due to a European Union ban on insuring tankers carrying Iranian oil... Of South Korea's four refiners, only SK Energy and Hyundai Oilbank import Iranian crude. Sources said both refiners will stop importing from Iran when the EU insurance embargo takes effect from July 1." (Reuters, "South Korea to halt Iran oil imports as EU ban bites," 6/25/12)

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"Earlier this month, two South Korean shipping companies said they had suspended importing Iranian crude due to a separate EU embargo set to come into force from July. SK Shipping, which handles the needs of refiner SK Energy, said it shipped its last cargo from Iran early this month and it would arrive by the end of June... SK Energy and Hyundai Oilbank are the only Korean refiners still importing Iranian oil. They said the suspension was temporary as Seoul seeks an exemption from the EU measures." (France 24, "S.Korea reports sharp fall in Iran oil imports,"6/25/12)

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"SK Innovation fully owns SK Energy, the country's largest oil refiner, which relies on Iran for around 10%-15% of its crude-oil imports." (The Wall Street Journal, "Official: South Korea Has No Plans To Halt Iran Crude," 5/22/2012)

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"South Korea's largest oil refiner SK Energy <096770.KS> will stop Iranian oil imports after the ban takes effect, two sources with direct knowledge of the matter said on Monday... 'SK Energy won't lift Iranian crude oil after lifting a 2 million barrel cargo in early June,' one of the two sources said. SK Energy will not import Iranian oil for July arrival.'... SK Energy had agreed to import 130,000 barrels per day (bpd) of Iranian crude this year under a long-term supply deal, while Hyundai Oilbank had agreed to import 70,000 bpd." (Reuters, "Exclusive: South Korea poised to halt Iran oil imports from July: sources," 5/21/2012)
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"South Korea will make sharp cuts in imports of Iranian crude from June as tightening Western sanctions make it impossible to secure insurance cover for tankers to ship the crude, industry and company sources said... With no resolution in sight, Hyundai Oilbank, one of two buyers of Iranian oil in South Korea, has decided to stop lifting cargoes from June, industry sources told Reuters. But bigger counterpart SK Energy is sticking with its plan to lift annual committed volumes at least until June. For July onwards, SK Energy, the country's largest refiner, is in talks with the government to secure insurance cover for tankers shipping the oil. If the government disagrees, the company will have little option but to halt purchases, said the sources, who declined to be identified as they are not authorized to talk to the media." (Chicago Tribune, "South Korea's Iran crude imports to plunge from June: sources," 4/26/12)

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"SK Energy will buy the additional crude, taking 130,000 bpd in 2012, up 10,000 bpd on the year, a government source said. An SK Energy spokesman declined to comment when asked about the deal... SK Energy could replace Iranian oil with imports from elsewhere in the Middle East if it needed to, although that might cost more money, an SK Energy source said." (Reuters, "S.Korea buys more Iran oil but eyes alternatives," 1/4/2012)

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"'We don't see any impact on crude imports from Iran,' a source at South Korea's largest refiner SK Energy said. 'While we cannot disclose the term import barrels for 2011, I can tell next year's oil import from Iran will continue as much as this year's.'

 An official at Hyundai Oilbank also said the term volume for 2011 will be stable from 2010. SK Energy and Hyundai Oilbank are the only buyers of Iranian crude in the country among four refiners.    Trade with Iran accounts for less than 1.5 percent of South Korea's overall trade but Iran is an important supplier of crude oil to South Korea, which imports all of its crude needs.

 Iran is South Korea's fourth-largest crude supplier. South Korea imported 67.1 million barrels of Iranian crude between January and November this year, accounting for 8 percent of the country's total crude imports, down about 10 percent from a year earlier." (Reuters, "Iran's Asian crude buyers see flow steady despite financial sanctions," 12/30/10)

Response

"Neither SK Energy nor any of its affiliates has manufacturing or mining plants, employees, facilities, investments, jount ventures, ownership or any fiduciary, monetary or physical presence in Iran." (8/7/2020). 

JPMorgan Chase

Industry
Banking, Financial Services
Symbol
NYSE:JPM
Country
USA
Contact Information
Sources

"Americans taken hostage in the 1979 siege of the U.S. embassy in Iran sued JPMorgan Chase & Co. over David Rockefeller’s role in persuading the U.S. to allow the deposed Iranian leader into the country." (Bloomberg, "Iran Embassy Hostages Sue JPMorgan Over Rockefeller Role," 3/19/2020). 

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"Despite the changes to the US, EU and UN sanctions on Iran under the Joint Comprehensive Plan of Action (“JCPOA”) in January 2016, JPMC is still not permitted either by law or JPMC policy to engage in any activities with or involving Iran, the Iranian government or any Iranian financial institutions. JPMC may consider, on a case-by-case basis, certain activities and transactions that are exempt or licensed by OFAC." (Compliance with Iran Sanctions)

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During the first quarter of 2017, a foreign-incorporated subsidiary of JPMorgan Chase & Co. processed a payment in the amount of EUR 1,466 for its client, a non-U.S. international organization, where the payment originated from entities owned or controlled by the Government of Iran. The payment, which was received into the client’s account, was for the purchase of informational materials and was therefore an exempt transaction pursuant to 31 C.F.R. 560.210(c). JPMorgan Chase & Co. charged a fee of EUR 2.50 for this transaction. JPMorgan Chase & Co. may in the future engage in similar transactions for its clients to the extent permitted by U.S. law.

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According to its Annual Report filed for fiscal year 2015: "During 2015, JPMorgan Chase Bank, N.A. processed one payment from Iran Airtours on behalf of a U.S. client into such client’s account at JPMorgan Chase Bank, N.A. Iran Airtours is a subsidiary of Iran Air, which, at the time of the payment, was designated pursuant to Executive Order 13382. This transaction was authorized by and conducted pursuant to a license from the Treasury Department’s OFAC. JPMorgan Chase Bank, N.A. charged a fee of U.S. dollar $4.25 for this transaction. JPMorgan Chase Bank, N.A. may in the future engage in similar transactions for its clients to the extent permitted by U.S. law."

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According to its Annual Report filed for fiscal year 2014: "In addition, during 2014, JPMorgan Chase Bank, N.A. processed one payment from Iran Air on behalf of a U.S. client into such client’s account at JPMorgan Chase Bank, N.A. Iran Air is designated pursuant to Executive Order 13382. This transaction was authorized by and conducted pursuant to a license from the Treasury Department’s Office of Foreign Assets Control (“OFAC”). JPMorgan Chase Bank, N.A. charged a fee of US$ 3.50 for this transaction. Iran Air overpaid such U.S. client when it made the initial payment to the client. Therefore, upon its U.S. client’s request, the Firm transferred the overpayment back to Iran Air in the fourth quarter of 2014 and charged a fee of US$ 5.50 for the transfer. As with the initial transaction, the transfer of the overpayment to Iran Air was authorized by and conducted pursuant to an OFAC license. JPMorgan Chase Bank, N.A. has no current intention to continue such activities but may in the future engage in similar transactions for its clients to the extent permitted by U.S. law."

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"U.S. regulators are expected to order JPMorgan Chase & Co to correct lapses in how it polices suspect money  flows, two people familiar with the situation said, in the latest move by officials to force banks to tighten their anti money-laundering systems. The action against JPMorgan, which is expected as soon as Friday, would be in the form of a cease-and-desist order, which regulators use to force banks to improve compliance weaknesses, the sources said. JPMorgan will probably not have to pay a monetary penalty, one of the sources said... A JPMorgan spokeswoman declined to comment... The inquiry on JPMorgan, the biggest U.S. bank, dates back several months, the sources said. The first public signs that JPMorgan had issues with its transaction monitoring systems emerged in August 2011. At that time JPMorgan agreed to pay $88.3 million to settle Treasury Department allegations that it engaged in prohibited transactions linked to Cuba and Iran. A source familiar with the expected order said JPMorgan did not adequately fix dozens of anti-money laundering issues cited previously by regulators, forcing them to take formal action. Under the order, JPMorgan is expected to be required to bolster systems it uses to monitor risk and transactions, the sources said." (Reuters, "Exclusive: JPMorgan faces action on laundering controls," 1/11/13)

 

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"This license was so heavily redacted by OFAC at the request of JPMorgan Chase that it is impossible to say exactly what was authorized other than the fact that it involved a letter of credit that somehow ran afoul of the sanctions against Iran." (New York Times, "Licenses Granted to U.S. Companies Run the Gamut," 12/24/10)

Dell Computer Corporation

Industry
Technology
Value of USG Contracts
9832
Value of USG Contract Source
http://www.usaspending.gov/explore?fromfiscal=yes&fiscal_year=2001&contractorid=146905&fiscal_year=&tab=By+Prime+Awardee&fromfiscal=yes&carryfilters=on&Submit=Go
Symbol
NASDAQ:DELL
States
TX
Country
USA
Sources

In June 2016, the Embassy of the Government of Iran located in the Republic of Ireland placed an order for Dell desktop computers, computer stands, and a server for a total purchase price of approximately 8,816 Euros (approximately $9,941 at the exchange rate for U.S. dollars at the date of such order). We did not accept the order, but such embassy subsequently deposited prepaid funds in the amount of its purchase order in a local bank for our account. These funds remain blocked at the local bank, and we do not intend to engage in future activity with respect to this matter.

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According to its Annual Report filed with the SEC in 2012: "We are disclosing the following information pursuant to Section 13(r) concerning activity by a UK affiliate of Quest Software, Inc. (“Quest Software”), which Dell acquired on September 27, 2012. The disclosure is regarding a maintenance services software renewal transaction with Melli Bank PLC valued at 106.13 British pounds (approximately $169.90 at the exchange rate for U.S. dollars on the renewal date) and marketing activity.

Quest Software specializes in business software. On September 10, 2012, prior to our acquisition of Quest Software, Quest Software (UK) Ltd., then a UK subsidiary of Quest Software, renewed two software maintenance licenses with Melli Bank PLC. The first license, for Quest Recovery Manager for Exchange software, had been in effect for seven years before the renewal, while the second license, for Spotlight on Messaging software, had been in effect for four years before the renewal. Recovery Manager for Exchange software enables users to search and retrieve message-level data and compare contents between different mailboxes. Spotlight on Messaging is a business software program that helps manage messaging and real-time communications and provides troubleshooting solutions. Marketing activity also occurred prior to and after the acquisition with respect to Quest customers generally, including Melli Bank PLC, but no transactions were concluded other than the license renewal transaction.

Melli Bank PLC is a wholly-owned subsidiary of Bank Melli in Iran. Melli Bank PLC is headquartered in London and is listed by the Treasury Department's Office of Foreign Assets Control as a Specially Designated National.

The profit on the license renewal transaction was no more than the annual renewal transaction value indicated above. Following our acquisition of Quest Software and our discovery of the renewal transaction, we terminated all software maintenance activity under the licenses. We will not engage in future activity under the licenses."
 

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"This license authorized a shipment of computers to an embassy in Tehran." (New York Times, "Licenses Granted to U.S. Companies Run the Gamut," 12/24/10)

Cabot Specialty Chemicals Inc.

Industry
Chemicals
Symbol
NYSE:CBT
Country
USA
Sources

"Cabot received this license after it assisted in a sales transaction of silicon dioxidebetween two non-U.S. parties. The company applied for the exception after learning that the goods would be shipped via the Iranian government-owned shipping line known as Irisl. 'The items in question are already loaded onto containers at the dock and ready to be loaded onto the vessel, which is due to depart the port of Antwerp, Belgium, on Monday,' the company's lawyers, in the firm of Baker & McKenzie, wrote to OFAC on May 11, 2001. OFAC's director, Adam J. Szubin, stressed that the approval came seven years before Irisl was blacklisted by the United States for aiding Iran's nuclear and ballistic missile programs. Up until then, he said, the agency made case-by-case exceptions to a broad prohibition against dealing with Iranian companies in situations like this one in which the company had no prior knowledge that an Iranian entity was involved in the transaction and granting the license did not involve a direct payment from a United States person or company to an Iranian entity." (New York Times, "Licenses Granted to U.S. Companies Run the Gamut," 12/24/10)

Archer Daniels Midland Company (ADM)

Industry
Food and Beverage
Symbol
NYSE: ADM
Country
USA
Sources

"Two sources said the increasing difficulties had prompted U.S. agribusiness company ADM (ADM.N) to halt trading with Iran since August. An ADM spokeswoman declined to comment." (Reuters, "Exclusive: Ships with one million tonnes of grain stuck outside Iran's ports in payment crisis," 10/2/2019).

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Over the last three presidential administrations, the United States government has granted Archer Daniels Midland Company 48 special licenses to do business in Iran. (New York Times, "Companies with Permission to Bypass Sanctions," 12/24/10)

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"After years of difficulty caused by economic sanctions, suppliers are hoping a nuclear deal will make it easier to win lucrative contracts to sell wheat, sugar and other food to Iran…Top global agribusiness groups such as Cargill and Archer Daniels Midland Co and others like Swiss commodities trader Glencore-Xstrata have been among the dominant players in Iran's food trade. Those three firms confirmed they sell agricultural products to Iran, and said the activity was in compliance with sanctions." (Reuters, "Food suppliers look to win Iran contracts after nuclear deal," 11/28/13)

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According to its Annual Report filed with the SEC for fiscal year 2012: "On or about July 25, 2012, an 80% owned and controlled affiliate of the Company hired a vessel to transport a cargo of grain.  The shipping arrangements and payment for $481,800 for the transportation were made directly with the charterer of the vessel. Neither the names of the vessel nor the charterer were listed on the United States Department of the Treasury’s Office of Foreign Assets Control’s (“OFAC”) List of Specially Designated Nationals (the “SDN List”).  It was later determined by the Company and its bank that the vessel involved was beneficially owned by the Islamic Republic of Iran Shipping Lines (IRISL), a sanctioned party.  The Company voluntarily disclosed the matter to OFAC.  The involvement of a sanctioned party was inadvertent and unintentional and we believe the result of a concerted effort by Iran to hide its ownership of the vessel.  Neither the Company nor its affiliate nor other of its subsidiaries have any intention of continuing such activity with a prohibited party. There was no profit that can be attributed to this specific transportation activity.  This disclosure is made pursuant to Section 219 of the Iran Threat Reduction Act which requires that an issuer disclose in its annual or quarterly report filed with the Securities and Exchange Commission if any of its affiliates engaged in an OFAC reportable transaction."

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"This license authorized Archer Daniels Midland Company to fulfill a contractual obligation it had in connection with a 'string transaction.' Companies enter into such transactions when they sell goods on a commodities market. Often, they have no way of knowing where the goods will end up. In this case, Archer Daniels Midland found out that its goods were destined for Iran after it entered into the transaction, according to its application. OFAC said it generally grants licenses in this type of situation because failing to do so could bring American commodities trading to a halt." (New York Times, "Licenses Granted to U.S. Companies Run the Gamut," 12/24/10)

Albemarle Corporation

Industry
Chemicals
Symbol
NYSE:ALB
States
NC
Country
USA
Sources

According to its February 28, 2018 SEC disclosure, Albemarle said, "We do not intent to continue doing such business in Iran." (SEC, "Form 10-K," 2/28/2018).

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Listed as a sponsor of the 13th Iran Petrochemical Forum that took place in Tehran, Iran in April 2017.

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The US Government granted Albemarle Corporation a license to sell ibuprofin in Iran. (New York Times, "Licenses Granted to U.S. Companies Run the Gamut," 12/24/10)

Hyundai Corporation

Industry
Manufacturing
Value of USG Contracts
129
Value of USG Contract Source
http://usaspending.gov/explore?fromfiscal=yes&fiscal_year=2001&contractorid=298168&fiscal_year=&tab=By+Prime+Awardee&fromfiscal=yes&carryfilters=on&Submit=Go
Symbol
KRX:011760
States
CA
NY
Country
South Korea
Sources

As of May 17, 2021, Iowa's Public Employee's Retirement System lists Hyundai on its Iran Scrutinized Companies List.

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As of August 15, 2019, the state of Iowa listed Hyundai on its Iran scrutinized companies list.

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"A week after it was announced that French carmaker Peugeot-Citroen had left the Iranian market, Japan’s Mazda and South Korean Hyundai have also suspended contracts with Iran, according to a member of the parliamentary Industries and Mines Commission. In an interview with the parliament-affiliated website, Valiyollah Maleki said June 12, “Mazda and Hyundai’s interests in the U.S. market are much more than in Iran, and they will not sacrifice their profit for the sake of Iran.”" (June 13, 2018).

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"So despite concerns over regulation and reputation, that opportunity explains the caravan of container carriers that started resuming service to Iran back in January. The Iranian port at Bandar Abbas now welcomes ships from Evergreen, Hyundai, OOCL, Hanjin, “K” Line, KMTC, X-Press, Yang Ming, and many more..." (Global Trade, "Transportation/Logistics:Iran is Back Open for Business," 11/1/2016).

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The Hyundai Corporation is a general trading company specializing in a wide variety of shipping, industrial, chemical, and electrical products. Hyundai Heavy Industries owns a controlling stake  in the Hyundai Corporation.

In 2005, Hyundai Corp signed a $1.9 billion contract to provide Iran with materials “in the fields of shipbuilding, machinery, steel & metal, chemicals, home appliances, etc.” Hyundai Corp’s Tehran Office website contains a Major Products section, which contains a litany of sensitive products with wide applicability in the Iranian energy, petroleum, and even defense industries. This products include: oil tankers, LNG carriers, diesel engines, signaling systems, optical cables, conductor wires, high voltage cables, transmission cables, steel, aluminum, zinc, polypropylene, other chemicals, and consumer electronics. 

Transammonia

Industry
Chemicals
States
NY
Country
USA
Sources

Transammonia actively does business in Iran via a Swiss subsidiary. (CNBC. "Transammonia:A Story of American Business in Iran," 12/7/10)

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Transammonia has performed business dealings with the Iran Petrochemical Commercial Company (IPCC), which is the subsidiary and international trading arm of the National Petrochemical Company (NPC). NPC is wholly owned by the Iranian government. It is responsible for the development and operation of the country's petrochemicals sector and is the second largest producer and exporter of petrochemicals in the Middle East after Saudi Arabia's Sabic.

On June 16, 2010, the U.S. Treasury Department added NPC and its subsidiary IPCC to the Iranian Transactions Regulations (ITR), which “prohibit transactions between U.S. persons and the Government of Iran. These identifications allow U.S. persons and others to identify Iranian Government entities and protect themselves against the risks posed by such entities.” (U.S. Department of Treasury, “Fact Sheet: U.S. Treasury Department Targets Iran’s Nuclear and Missile Programs,” 6/16/10)
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February 2010: “Transammonia purchased 23,000 tonnes from IPCC at $370/tonne FOB for late March loading from BIK [(Bandard Imam Khomeinei)].” (Chemical News & Intelligence, 2/24/10)

July 2009: “This price was $18/tonne lower than last done spot business in the Middle East, [1]which was concluded at $200/tonne FOB following a sale by Iran's Petrochemical Commercial Co (PCC) to trader Transammonia.” (Chemical News & Intelligence, 7/3/09)

May 2009: “Trader Transammonia confirmed it had purchased 23,400 tonnes from Iran Petrochemical Commercial Co (IPCC) at $200/tonne FOB (free on board) with 30 days' credit… Transammonia will ship 15,000 tonnes on 18-21 May on the Marycam Swan for shipment to the southeast Asia. The balance of the purchase will be lifted later, it said.” (Chemical News & Intelligence, 5/14/09).

May 2006: The Agricultural Support Services Company of Iran (ASSC) “received nine offers from traders and purchased urea from Transammonia at Euro212/tonne cost and freight (CFR) southern Iranian ports.” (Chemical news & Intelligence, 5/8/06)

Karsan Otomotiv

Industry
Automotive
Symbol
IST: KARSN
Country
Turkey
Sources

Karsan Otomotiv is Turkey’s only multi-branded commercial vehicle producer. Karsan’s website notes that it “makes the production of Peugeot Partner under Peugeot license, Hyundai HD 35/75 under Hyundai license, Renault Trucks Premium Uzunyol, Premium Lander and Kerax under Renault Trucks license, Citroen Berlingo under Citroen license and J9 Premier under its own brand.” Karsan was ranked 267th in the list of “Turkey’s Top 500 Industrial Organizations” in 2008. (Company Website)

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On March 9, 2011, following extensive discussions, UANI announced that Karsan had ended its business in Iran. Karsan had demonstrated that it had withdrawn from Iran and committed to foregoing any business in Iran until such time as Iran fulfills its obligations to the international community related to its illegal nuclear program. (UANI, "UANI Applauds Turkish Company Karsan for Ending Its Business in Iran," 3/9/11)

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Karsan entered into a five-year exclusive distribution agreement in 2007 with Iran’s Sanat Khuodro Kamau to export J9 minibus models to Iran. (Karsan Report, May 10, 2007)

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A Karsan company report on February 15, 2008, notes that the company “signed a contract to export J9 Premier to Iran, which will be sold to some Middle East countries via Iran.”

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A July 2010 press release indicated that the updated J10 model would be sold in Iran, Syria, and African countries. (Press Release)