Withdrawn

Previously sold tunnel-boring equipment to Iran for a water project managed by the IRGC.

Aker Wirth operates in Iran through the WPS Group and previously sold tunnel-boring equipment to Iran for a water project that was managed by the IRGC. (Commentary Magazine, "The Iranian Shell Game," July, 2008)

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“Aker Wirth GmbH develops, manufactures, and sells drilling equipment and machinery in Germany and internationally. It offers tunnel and foundation boring machines for infrastructure projects; core components and solutions for the oil and natural gas industry; and pumping systems for mining and processing industries. The company’s products include draw works, mud pumps, and rotary tables and swivels; full-face tunnel boring, partial excavation, and slurry transport and processing equipment; onshore and offshore foundation, wind energy, and drill string and cutter equipment; and spare parts. It also offers second hand machinery, as well as provides service contacts. The company was formerly known as WIRTH Maschinen- und Bohrgeräte-Fabrik GmbH and changed its name to Aker Wirth GmbH on June 30, 2009. The company was founded in 1895 and is based in Erkelenz, Germany. As of September 4, 2007, Aker Wirth GmbH is a subsidiary of Aker Solutions ASA” (Bloomberg Business Week, "Aker Wirth GmbH – Private Company Information," 2010.)

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In the business of TBMs, “Aker Wirth manufactures and supplies tunnel boring machines for mechanized tunnel driving for all geological conditions and all environmental requirements. Aker Wirth machines are in use in tunnel boring projects all over the world and for the excavation of a wide variety of tunnels” (Mining Technology, Net Resources International, "Aker Wirth - Tunnel Boring Machines, Raise Boring and Full-Face Shaft Boring Machines," 2010).

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Wirth has an Iran office, WPS Group Ltd. (Iranian Wirth Subsidiary)

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An Iranian website features Wirth tunneling projects in Iran, including the Tabriz Metro Project.  (Iran Project website)
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Wirth has been involved in completed tunneling projects in Alborz and Ghomrud (World Tunnelling, “Iranian TBMs continue steady march,” December 23, 2009). 

Compania Espanola de Petroleos SAU, or Cepsa, said in an IPO prospectus that it took the "final shipment" of Iranian crude in September. The Suezmax tanker Monte Udala loaded a cargo of around 1 million barrels of Iranian crude on Sept. 29, which it delivered to Cepsa’s Huelva refinery about three weeks later, according to tanker tracking data compiled by Bloomberg.

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Spanish refiners Cepsa and Repsol have been using Madrid-based Ares bank but Cepsa will stop imports from early July, sources familiar with the matter said, as later cargoes had not been agreed prior to the sanctions announcement. Cepsa previously said that it would load crude until November and hoped for a waiver. ("Spooked by Trump, Europe's Iranian oil purchases set to plummet," Reuters, 6/29/2018.)

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“Our trading activity (remains) business as usual ... We continue to strictly conform with European Union and international laws and regulations,” a Cepsa spokesman said." (6/6/2018).

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On January 3, 2017, the National Iranian Oil Company (“NIOC”) listed CESPA as one of the “designated 29 non-Iranian companies [ ] qualified to participate in its pending tender round for upstream projects.”  (Oil & Gas Journal Website, “NIOC qualifies 29 firms for tender round,” 1/3/2017). 

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On February 14, 2016, the Wall Street Journal reported that a tanker “will carry 1 million barrels of Iranian crude oil to the European Union for Spain’s Compania Espanola de Petroleos, or Cepsa.” (Wall Street Journal, “Iran Launches First Oil Shipments to Europe in Three Years,” 2/14/2016).

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On March 7, 2016, Bloomberg reported that 1 million barrels of crude oil from Iran arrived in Europe at a refinery owned by Cia. Espanola de Petroleos.” (Bloomberg, “Iran Oil Lands in Europe for First Time Since Sanctions End,” 3/7/2016).

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"Iran continues its quest for new crude buyers, especially in Europe, but its loyal customer base will continue to hinge on countries like India and China, whose demand for Iranian crude has observed a steady rise this year. Iran has found interest for its crude in some unusual places in the past few months as it continues it diversify its list of buyers. Earlier this month it agreed to sell 1 million barrels of crude oil to Hungary via Croatia as it seeks to widen its post-sanctions customer base, which now includes cargoes sold to oil major BP, France's Total, Greece's Hellenic Petroleum, Spain's Repsol and Cepsa, Russia's Lukoil, Poland's Grupa Lotos, Portugal's Petrogal and Italy's Saras and Iplom. Iran said it has held talks with Bosnia and Herzegovina this week as it hopes to expand its list of crude oil export destinations. However, its shipments to Asia remain the pillar of its export market." (Platts, "Analysis: Iran eyes new crude oil buyers, Asia remains linchpin," 11/1/2016).

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"Other oil companies in the Mediterranean including Spain's Cepsa and three other Italian oil firms, ERG, Iplom and Saras have planned to take their last cargoes from Iran in June, other market sources said." (Reuters, "Eni suspends Iran's debt payments in oil," 5/31/2012) 

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“Compañía Española de Petróleos, S.A. (CEPSA) leads an industrial group made up of over 11,000 people, whose core activity is the refining of crude oil and marketing of petroleum products.

The company additionally has a strong petrochemicals division that is tightly integrated with the refineries, and is also involved in other energy-related businesses, such as oil and gas exploration and production, natural gas operations and electric power generation and sales.

CEPSA has been in the market for almost 80 years. Thanks to its flexibility and ability to adapt, CEPSA has become one of the leading companies in its sector in Spain. Through the progressive internationalisation of its activities, it also has business interests in Algeria, Brazil, Canada, Colombia, Egypt, Panama, Peru and Portugal, and sells its products all over the world” (Company website, “CEPSA – Profile”).

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"Cepsa, the second-largest oil company in Spain (behind Repsol YPF) refines 121,900 barrels of crude oil daily, primarily in three refineries. Its oil exploration and production efforts are focused on Algeria, Colombia, Egypt, Peru, and Spain. It has proved reserves of 172.5 million barrels of oil equivalent. Cepsa's marketing network includes more than 1,800 gas stations in Spain and Portugal. It also produces a range of chemical products (including polyester precursors, phenol, plasticizers, and polypropylene) and has gas and power interests. Spain's TOTAL controls 49% of Cepsa and Abu Dhabi's IPIC, 47%%" (Hoovers, “Compañía Española de Petróleos, S.A.,” 2010).

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As of April 2010, Cepsa imports 25 thousand barrels of crude oil per day from Iran. (Reuters, “Iran’s Crude Oil Buyers in Europe, Asia,” April 18 2010.)

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“Spain helps Iran in the fields of shipbuilding, oil and gas, power production and fishing, and Iran supplies Spain with mainly oil and petrochemicals.”

“In 2001, Iran exported to Spain $837 million worth of crude oil and various types of petrochemical products, while importing from that country $278 million worth of machinery, power turbines, medicine and chemical products. Trade activities aside, Spain has become a large non-Iranian investor in Iran's fossil energy and petrochemical industries over the last few years. This has reflected particularly in the activities of three major Spanish oil and petrochemical companies in that country. Repsol has invested 2 billion euros (roughly $2 billion) in exploring and extracting Iran's natural gas. The latter has uplifted the status of Spain in the Iranian economy, a result of the Iranians' efforts to reduce their consumption of oil and to switch to natural gas both for economic and environmental reasons.  Another Spanish oil company, Cespa, has been involved in the development of Iran's Cheshmekosh oilfield, while negotiating for its participation in developing certain Iranian offshore oilfields in the Persian Gulf. In the wake of President Khatami's visit to Spain, Cespa and the Spanish government expressed hope to settle disagreements with the Iranian government on the latter during the presidential visit” (Asia Times, "Spain seeks a bigger share in Iran," November 23, 2002).

"Refiners including France’s Total, Italy’s Eni and Saras, Spain’s Repsol and Cepsa as well as Greece’s Hellenic Petroleum are preparing to halt purchases of Iranian oil once sanctions bite, the sources said....Hellenic had to stop imports because the Swiss bank that it used was no longer processing payments to Iran, an industry source familiar with the situation said." (6/6/2018).

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In 2017 the U.S. state of South Carolina and Tennessee listed Hellenic Petroleum on its list of companies doing material business with Iran rendering Hellenic ineligible for investment and/or state contracting.

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Subsidiary of Paneuropean Oil and Industrial Holdings

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" Greece’s biggest oil refiner Hellenic Petroleum paid its first installment in June that amounted to €100 million." (June 2017)

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Iranian Deputy Oil Minister for International Affairs Amir Hossein Zamaninia described the fresh round of negotiations between Iran and Greece adding “during the two-day visit to the European country, a Memorandum of Understanding (MoU) was sealed for meeting Hellenic Petroleum’s debt to Iran.” (January 25, 2016).

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 "Greece's biggest oil refiner Hellenic Petroleum agreed on Friday to buy crude oil from Iran after negotiations with National Iranian Oil Company officials in Athens. The deal would make Hellenic Petroleum the first European refiner to restart trade relations with the Persian Gulf country after the lifting of international sanctions, Reuters reported." (January 2016) 

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"Iran continues its quest for new crude buyers, especially in Europe, but its loyal customer base will continue to hinge on countries like India and China, whose demand for Iranian crude has observed a steady rise this year. Iran has found interest for its crude in some unusual places in the past few months as it continues it diversify its list of buyers. Earlier this month it agreed to sell 1 million barrels of crude oil to Hungary via Croatia as it seeks to widen its post-sanctions customer base, which now includes cargoes sold to oil major BP, France's Total, Greece's Hellenic Petroleum, Spain's Repsol and Cepsa, Russia's Lukoil, Poland's Grupa Lotos, Portugal's Petrogal and Italy's Saras and Iplom. Iran said it has held talks with Bosnia and Herzegovina this week as it hopes to expand its list of crude oil export destinations. However, its shipments to Asia remain the pillar of its export market." (Platts, "Analysis: Iran eyes new crude oil buyers, Asia remains linchpin," 11/1/2016).

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“Founded in 1998, Hellenic Petroleum is one of the leading energy groups in South East Europe, with activities spanning across the energy value chain and in 11 countries. Its shares are primarily listed on the Athens Exchange (ATHEX: ELPE), and its market capitalisation amounts to about €2.2 billion” (Company Website).

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"Iran has blocked oil sales to two Greek companies, Hellenic Petroleum and Motor Oil Hellas after they failed to make payment, Iranian state television reported on Thursday. The English-language television network, Press TV, reported that Greece's top refiner Hellenic Petroleum and Motor Oil Hellas were barred from purchasing Iranian crude after they defaulted on their purchases. On Tuesday, a senior source at Hellenic Petroleum told Reuters the refiner had suspended purchases of Iranian crude because sanctions imposed by the Untied States and the European Union made it impossible to meet its oil payments." (Reuters, "Iran cuts oil to Greek firms over payment problems-Press TV," 4/5/2012)

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"Greece's largest company, Hellenic Petroleum operates four refineries: at Aspropyrgos, Elefsina, and Thessaloniki in Greece and Skopje in Macedonia. It also operates about 1,525 gas stations in Albania, Bulgaria, Cyprus, Georgia, Greece, Montenegro, and Serbia. It has 1,200 gas stations in Greece (23% of the retail market). Its other businesses include petrochemical production, oil and gas exploration, and infrastructure development. Hellenic Petroleum is owned by Paneuropean Oil and Industrial Holdings S.A. (35.89%) and the Greek government (35.5%)" (Company Profile, “Hellenic Petroleum S.A.,” Hoovers, 2010.)

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As of April 2010, Hellenic Petroleum imports 60 thousand barrels of crude oil per day from Iran. (Reuters, "Iran’s Crude Oil Buyers in Europe, Asia,” April 18 2010.)

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According to Greece’s Ministry of Foreign Affairs, “The Hellenic Petroleum Company has been cooperating with Iran for many years in the crude oil sector” ( Ministry of Foreign Affairs, “Bilateral Relations Between Greece and Iran,” December 2008).

“Layher International is a world-leading scaffolding producer and supplier for the petrochemical, energy, manufacturing and construction industries and for commercial, infrastructure, industrial and event applications.  With home offices in Germany, Layher has a respected global presence in Europe, Asia, South America, the United States and Canada.” (Layher USA Website- About us)

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"California’s department of general services, which awards its public contracts, has contacted more than 150 companies seeking clarification regarding Iran. The companies include Layher, a German construction group that recently told UANI it had not done business in Iran for six years, and ABB, the Swiss electrical engineering group."(Financial Times. "California tightens screw on trade with Iran," 6/27/11)

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“Kadiran Industrial Tools has established on 1985 and now it became on of major Iranians Oil-Gas & Petrochemical Suppliers.  Who held huge stock for Iranian market and both technically and commercially able to handle enquiries.”  [SIC]

The Kadiran website lists Layher as one of its suppliers (Kadiran Website).

According to its Annual Report filed with the SEC for fiscal year 2019: "During a portion of the period covered by this disclosure, Mizuho Bank was a party to a legacy counter guarantee that was opened in connection with activity of its customer for the benefit of an Iranian bank. When the guarantee was entered into, the bank in question, which is related to the Government of Iran, had not been designated under U.S. Executive Orders (“E.O.”) 13224 or 13382, although it was subsequently so designated. Mizuho Bank maintained this guarantee post-designation only after confirming that such a transaction did not involve prohibited or sanctionable activity under U.S. or other economic sanctions. As contractual obligations, this guarantee could not be exited by Mizuho Bank unilaterally. In the fiscal year ended March 31, 2019, Mizuho Bank received fees of less than ¥1 million attributable to this guarantee and earned net profits of less than that amount. Mizuho Bank terminated the counter guarantee in July 2018 before the issuance of E.O. 13846.

In the fiscal year ended March 31, 2019, Mizuho Bank conducted a limited number of fund transfers through accounts it maintains for or at a limited number of Iranian banks related to the Government of Iran and a bank designated under E.O. 13224, or through other correspondent banking accounts on behalf of such Iranian banks. These transfers were mainly associated with requests by our customers after the relaxation of applicable sanctions pursuant to the Joint Comprehensive Plan of Action and prior to the full re-imposition of such U.S. sanctions on November 5, 2018. Mizuho Bank has policies and procedures to process transfers through these accounts only after confirming that such transactions do not involve prohibited or sanctionable activity. Our non-U.S. offices engage in transactions relating to the Designated Countries on a limited basis and in compliance with applicable laws and regulations, including trade financing with respect to our customers’ export or import transactions and maintenance of correspondent banking accounts. In addition, we maintain a representative office in Iran." 

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"Will halt all iran transactions to comply with the reimposition of U.S. sanctions against Tehran later this year…The banking unit of Mizuho Financial Group Inc said later on Thursday it would take the same action..." (July 12, 2018).

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”Three Japanese big banks, namely the Bank of Tokyo-Mitsubishi UFJ, Sumitomo Mitsui Bank and Mizuho Bank, have started interactions in the form of telegraphic transfer—an electronic method of transferring funds—and L/C at sight  with a number of Iranian banks." (May 2017)

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Lists a representative office in Tehran, Iran on its company website. 

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"Reports issued by U.S. researchers attempting to document activity by multinational companies in Iran have named...units of Japan's three largest banks--Mitsubishi UFJ Financial Group Inc, Sumitomo Mitsui Financial Group and Mizuho Financial Group Inc--as doing business that could possibly run afoul of new U.S. rules. A widely circulated report issued this year by a former U.S. Treasury Department official on global banks doing business with Iranian banks named the Big Three Japanese financial institutions. Spokespeople for the three Japanese banks declined to comment on the accuracy of the report, or how the law might affect their operations in Iran." (Wall Street Journal, "New U.S. Law on Iran May Hurt Japanese Firms," 7/1/2010).

Mitsubishi UFJ Financial Group (MUFG) "moved Japanese employees stationed at their representative offices in Tehran to locations outside of the country... and restricted travel to [Iran and Iraq]." (Japan Times, "Japan Firms Pull Staff Out of Iran and limit travel to Iraq amid high tensions," 1/9/20)

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According to its Annual report filed with the SEC for fiscal year 2019: "During the fiscal year ended March 31, 2019, one of our non-U.S. subsidiaries engaged in business activities with entities in, or affiliated with, Iran, including counterparties owned or controlled by the Iranian government. Specifically, our non-U.S. banking subsidiary, MUFG Bank, issued letters of credit and guarantees and provided remittance and other settlement services mainly in connection with customer transactions related to the purchase and exportation of Iranian crude oil to Japan, and in some cases, in connection with other petroleum-related transactions with Iran by its customers. These transactions did not involve U.S. dollars nor clearing services of U.S. banks for the settlement of payments. For the fiscal year ended March 31, 2019, the aggregate interest and fee income relating to these transactions was less than ¥100 million, representing less than 0.005 percent of our total interest and fee income. Some of these transactions were conducted through the use of non-U.S. dollar correspondent accounts and other similar settlement accounts maintained with MUFG Bank outside the United States by Iranian financial institutions and other entities in, or affiliated with, Iran. In addition to such accounts, MUFG Bank receives deposits in Japan from, and provides settlement services in Japan to, fewer than 10 Iranian government-related entities and fewer than 100 Iranian government-related individuals such as Iranian diplomats in Japan, and maintains settlement accounts outside the United States for certain other financial institutions specified in Executive Order 13382, which settlement accounts were frozen in accordance with applicable laws and regulations. For the fiscal year ended March 31, 2019, the average aggregate balance of deposits held in these accounts represented less than 0.1 percent of the average balance of our total deposits. The fee income from the transactions attributable to these account holders was less than ¥20 million, representing less than 0.005 percent of our total fee income. Although there was no outstanding balance as of March 31, 2019, MUFG Bank had, during the fiscal year ended March 31, 2019, loans that were arranged prior to changes in applicable laws and regulations to borrowers in, or affiliated with, Iran, including entities owned by the Iranian government. For the fiscal year ended March 31, 2019, the agent fee income relating to these loan transactions was less than ¥20 million, representing less than 0.005 percent of our total interest and fee income.

MUFG Bank recognizes that following the withdrawal in May 2018 by the United States from the Joint Comprehensive Plan of Action, the United States has imposed secondary sanctions against non-U.S. persons who engage in or facilitate a broad range of transactions and activities involving Iran. MUFG Bank has taken the recent sanctions related developments into account and monitor any future transactions relating to Iran in order to comply with applicable U.S. and Japanese regulations as well as U.S., Japanese and other international sanctions."

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"Will halt all iran transactions to comply with the reimposition of U.S. sanctions against Tehran later this year…" (July 12, 2018). 

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According to its Annual Report filed with the SEC for fiscal year 2018: We have loan transactions with counterparties in or affiliated with Iran, the outstanding balance of which was less than ¥50 million representing less than 0.0001% of our total assets, as of March 31, 2018. We do not have any loans outstanding to the financial institutions specifically listed by the U.S. government. In addition to such loan transactions, our other transactions with counterparties in or affiliated with countries designated as state sponsors of terrorism consist of receiving deposits or holding assets on behalf of individuals residing in Japan who are citizens of countries designated as state sponsors of terrorism, processing payments to or from entities in or affiliated with these countries on behalf of our customers, and issuing letters of credit and guarantees in connection with transactions with entities in or affiliated with such countries by our customers. These transactions do not have a material impact on our business or financial condition. For a further discussion of transactions required to be disclosed under the U.S. Iran Threat Reduction and Syria Human Rights Act of 2012, see “Item 4.B. Information on the Company—Business Overview—Supervision and Regulation—United States—Disclosure pursuant to Section 13(r) of the Securities Exchange Act of 1934.”"

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As stated in its 2017 SEC disclosure: "During the quarter ended September 30, 2017, a non-U.S. subsidiary of MUFG engaged in business activities with entities in, or affiliated with, Iran, including counterparties owned or controlled by the Iranian government. Specifically, MUFG’s non-U.S. banking subsidiary, BTMU, issued letters of credit and guarantees and provided remittance and other settlement services mainly in connection with customer transactions related to the purchase and exportation of Iranian crude oil to Japan, and in some cases, in connection with other petroleum-related transactions with Iran by its customers.  In addition to such accounts, BTMU receives deposits in Japan from, and provides settlement services in Japan to, fewer than ten Iranian government-related entities and fewer than 100 Iranian government-related individuals such as Iranian diplomats, and maintains settlement accounts outside the United States for certain other financial institutions specified in Executive Order 13382, which settlement accounts were frozen in accordance with applicable laws and regulations."

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”Three Japanese big banks, namely the Bank of Tokyo-Mitsubishi UFJ, Sumitomo Mitsui Bank and Mizuho Bank, have started interactions in the form of telegraphic transfer—an electronic method of transferring funds—and L/C at sight  with a number of Iranian banks." (May 2017).

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According to its Annual report filed with the SEC for fiscal year 2016: "We have loan transactions with counterparties in or affiliated with Iran, the outstanding balance of which was approximately $0.8 million, representing less than 0.0001% of our total assets, as of March 31, 2016. We do not have any loans outstanding to the financial institutions specifically listed by the U.S. government. In addition to such loan transactions, our other transactions with counterparties in or affiliated with countries designated as state sponsors of terrorism consist of receiving deposits or holding assets on behalf of individuals residing in Japan who are citizens of countries designated as state sponsors of terrorism, processing payments to or from entities in or affiliated with these countries on behalf of our customers, and issuing letters of credit and guarantees in connection with transactions with entities in or affiliated with such countries by our customers."

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The Bank of Tokyo-Mitsubishi UFJ is Japan's largest bank and serves as the core retail and commercial banking arm of the Mitsubishi UFJ Financial Group.

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According to its Annual report filed with the SEC for fiscal year 2015: "We have loan transactions with counterparties in or affiliated with Iran, the outstanding balance of which was approximately $1.0 million, representing less than 0.0001% of our total assets, as of March 31, 2015. We do not have any loans outstanding to the financial institutions specifically listed by the U.S. government. In addition to such loan transactions, our other transactions with counterparties in or affiliated with countries designated as state sponsors of terrorism consist of receiving deposits or holding assets on behalf of individuals residing in Japan who are citizens of countries designated as state sponsors of terrorism, processing payments to or from entities in or affiliated with these countries on behalf of our customers, and issuing letters of credit and guarantees in connection with transactions with entities in or affiliated with such countries by our customers. These transactions do not have a material impact on our business or financial condition. For a further discussion of transactions required to be disclosed under the U.S. Iran Threat Reduction and Syria Human Rights Act of 2012, see “Item 4.B. Information on the Company—Business Overview—Supervision and Regulation—United States—Disclosure pursuant to Section 13(r) of the Securities Exchange Act of 1934.”"

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According to its Annual report filed with the SEC for fiscal year 2014: "We have loan transactions with counterparties in or affiliated with Iran, the outstanding balance of which was approximately $4.5 million, representing less than 0.001% of our total assets, as of March 31, 2014. We do not have any loans outstanding to the financial institutions specifically listed by the U.S. government. In addition to such loan transactions, our other transactions with counterparties in or affiliated with countries designated as state sponsors of terrorism consist of receiving deposits or holding assets on behalf of individuals residing in Japan who are citizens of countries designated as state sponsors of terrorism, processing payments to or from entities in or affiliated with these countries on behalf of our customers, and issuing letters of credit and guarantees in connection with transactions with entities in or affiliated with such countries by our customers. These transactions do not have a material impact on our business or financial condition. For a further discussion of transactions required to be disclosed under the U.S. Iran Threat Reduction and Syria Human Rights Act of 2012, see “Item 4.B. Information on the Company—Business Overview—Supervision and Regulation—United States—Disclosure pursuant to Section 13(r) of the Securities Exchange Act of 1934.”"

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"Mitsubishi UFJ Financial Group Inc. agreed to pay $250 million to the state of New York to settle claims it transferred billions of dollars for countries facing U.S. sanctions including Iran, Sudan and Myanmar. Bank of Tokyo-Mitsubishi UFJ Ltd., the main lending unit of Japan's biggest bank by market value, moved an estimated $100 billion through the state for government and privately owned entities on the Specially Designated Nationals list issued by the U.S. Treasury Department's Office of Foreign Assets Control (OFAC) between 2002 and 2007, the New York State Department of Financial Services (DFS) and New York Governor Andrew Cuomo said in a statement yesterday. The transfers involved about 28,000 clearing transactions and the bank routinely stripped information from wire transfer messages that could identify countries and people subject to international sanctions, the department said. The agreement follows HSBC Holdings Plc (HSBA)'s record settlement with the U.S. last year, stemming from sanctions aimed at pressuring Iran to halt its nuclear program. 'We have and will continue to take a hard line in rooting out misconduct at banks that threaten our national security,' Benjamin Lawsky, the superintendent of the department, said in the statement.” (Bloomberg, “Mitsubishi UFJ to Pay $250 million to NY Regulator,” 6/20/13)

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"The Bank of Tokyo-Mitsubishi UFJ Ltd. was ordered to transfer funds belonging to Iran-based entities to the families of 17 U.S. Air Force service members killed in a 1996 attack in Saudia Arabia... The assets at issue total about $357,000 and Bank of Tokyo said it doesn’t oppose releasing them, according to the filing." (Bloomberg, "Bank of Tokyo-Mitsubishi Must Give Iran Funds to U.S. Families," 1/29/2013)

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According to its Annual Report filed with the SEC for fiscal year 2012: "We, through our subsidiaries, engage in business activities with entities in or affiliated with Iran, including transactions with counterparties owned or controlled by the Iranian government, and our banking subsidiary has a representative office in Iran. The U.S. Department of State has designated Iran and other countries as “state sponsors of terrorism,” and U.S. law generally prohibits U.S. persons from doing business with such countries. We currently have business activities with entities in or affiliated with such countries in accordance with our policies and procedures designed to ensure compliance with regulations applicable in the jurisdictions in which we operate.

We have loan transactions with counterparties in or affiliated with Iran, the outstanding balance of which was approximately $4.7 million, representing less than 0.001% of our total assets, as of March 31, 2013. We do not have any loans outstanding to the financial institutions specifically listed by the U.S. government. In addition to such loan transactions, our other transactions with counterparties in or affiliated with countries designated as state sponsors of terrorism consist of receiving deposits or holding assets on behalf of individuals residing in Japan who are citizens of countries designated as state sponsors of terrorism, processing payments to or from entities in or affiliated with these countries on behalf of our customers, and issuing letters of credit and guarantees in connection with transactions with entities in or affiliated with such countries by our customers. These transactions do not have a material impact on our business or financial condition. For a further discussion of transactions required to be disclosed under the U.S. Iran Threat Reduction and Syria Human Rights Act of 2012, see “Item 4.B. Information on the Company—Business Overview—Supervision and Regulation—United States—Disclosure under Section 13(r) of the U.S. Securities Exchange Act of 1934.”

We are aware of initiatives by U.S. governmental entities and non-government entities, including institutional investors such as pension funds, to adopt or consider adopting laws, regulations or policies prohibiting transactions with or investment in, or requiring divestment from, entities doing business with Iran and other countries identified as state sponsors of terrorism. It is possible that such initiatives may result in our being unable to gain or retain entities subject to such prohibitions as customers, counter-parties or investors in our shares. In addition, depending on socio-political developments, our reputation may suffer due to our transactions with counterparties in or affiliated with these countries. The above circumstances could have an adverse effect on our business and financial condition.

Global financial institutions, including us, have become subject to an increasingly complex set of sanctions laws and regulations in recent years, and this regulatory environment is expected to continue. Moreover, the measures proposed or adopted vary across the major jurisdictions, increasing the cost and resources necessary to design and implement an appropriate global compliance program. The U.S. federal government and some state governments in the United States have enacted legislation designed to limit economic and financial transactions with Iran by limiting the ability of financial institutions that may have engaged in any one of a broad range of activities related to Iran to conduct various transactions in the relevant jurisdictions. The U.S. federal government recently strengthened the Iran-related regulations with the enactment in August 2012 of the Iran Threat Reduction and Syria Human Rights Act, which, among other things, imposes additional disclosure requirements. The Japanese government has also implemented a series of measures under the Foreign Exchange and Foreign Trade Act, such as freezing the assets of designated financial institutions and others that could contribute to Iran’s nuclear activities, and our most recently modified policies and procedures take into account the current Japanese regulatory requirements. There remains a risk of potential U.S. regulatory action against us, however, if U.S. regulators perceive the modified policies and procedures not to be in compliance with applicable regulations."

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"Japanese trading house Mitsubishi Corp has renewed its annual oil purchase deal with Iran but cut the loading volume to comply with U.S. sanctions against the Islamic nation, trade sources said on Friday…Mitsubishi's new contractual volume from April onwards remained unclear. The company had bought 15,000 barrels of crude per day (bpd), or more, last year."  (Reuters, "Japan's Mitsubishi renews Iran oil imports deal," 6/22/12)

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"Bank of Tokyo-Mitsubishi UFJ, which handles most of Japan's payments for oil imports from Iran, on Thursday said it had frozen transactions with Iranian banks after being ordered to do so by the New York District Court earlier this month." (Reuters, "Japan looks to central bank to pay for Iran oil: Nikkei," 5/21/2012)

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"The National Iranian Oil Co., the country’s state-run oil company, will stop Japanese refiners from picking up cargoes until it can find alternative ways to access payments received through accounts at the Bank of Tokyo unit of Mitsubishi UFJ Financial Group Inc. (8306), the officials said, declining to be identified because of company policies... A district court in New York told Mitsubishi UFJ this month to freeze at least $2.6 billion of Iranian assets held at the bank, Tomohiro Kosaka, a Tokyo-based spokesman for Mitsubishi UFJ, said today... Mitsubishi UFJ filed a petition of objection yesterday to the New York court, said Shinya Matsumoto, a spokesman for the lender in Tokyo." (Bloomberg Businessweek, "Iran Crude to Japan Said to Face Blocks After Court Order," 5/17/2012)

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"Two additional challenges are also in the mix for Tokyo. The first is the financing of oil imports from Iran. Annually, Japan’s oil trade with Iran runs around one trillion yen, or $13.1 billion. On January 19 the Nikkei Shimbun reported that 80 to 90 percent of those transactions are done by the Bank of Tokyo Mitsubishi UFJ, and the remainder by the Sumitomo Mitsui Banking Corporation." (CFR. "Japan's Iran Sanctions Dilemma," 1/31/12)

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"Reports issued by U.S. researchers attempting to document activity by multinational companies in Iran have named...units of Japan's three largest banks--Mitsubishi UFJ Financial Group Inc, Sumitomo Mitsui Financial Group and Mizuho Financial Group Inc--as doing business that could possibly run afoul of new U.S. rules... A widely circulated report issued this year by a former U.S. Treasury Department official on global banks doing business with Iranian banks named the Big Three Japanese financial institutions. Spokespeople for the three Japanese banks declined to comment on the accuracy of the report, or how the law might affect their operations in Iran." (Wall Street Journal, "New U.S. Law on Iran May Hurt Japanese Firms," 7/1/2010).

In December 2020 and January 2021, in two separate incidents, UANI alerted Maersk that their tankers were about to take on oil whose origin in Iran had been concealed. Maersk thereby halted the STS transfers. (Reuters, "Shipping Industry seeks to combat dark oil transfers at sea," July 13, 2021).

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“A.P. Moller-Maersk has changed the route its ships sail through the world’s busiest transit lane for seaborne oil shipments, citing safety concerns amid a rapid series of escalations between the U.S. and Iran. We have multiple assets, ships (and) people, crossing the Strait of Hormuz every day, every week. So far, we have not stopped serving the area (but) we have changed the path that the ships sail so we have changed the route.” (CNBC, "The World's largest shipping firm has altered its route through the Strait of Hormuz amid rising tensions," 7/20/2019).

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Shipping group A.P. Moller-Maersk on Thursday joined a growing list of companies preparing to call a halt to doing business with Iran, casting doubts on whether European leaders can keep alive a nuclear deal with Tehran.Maersk Chief Executive Soren Skou said: “With the sanctions the Americans are to impose, you can’t do business in Iran if you also have business in the U.S., and we have that on a large scale.” “I don’t know the exact timing details, but I am certain that we’re also going to shut down (in Iran),” Skou told Reuters in an interview following Maersk’s first-quarter earnings." (5/17/2018).

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"Denmark’s Maersk Line said separately it had ceased acceptance of the specific cargoes listed by the U.S. Treasury this week.“Our presence in Iran is limited. We will monitor the developments to assess any impact on our activities,” Maersk Line added." (5/12/2018)

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"Maersk Line has expanded its footprint in Iran by adding a second port of call less than three months after it resumed services to the country following the lifting of sanctions imposed on Tehran because of its nuclear program. The Danish carrier, which suspended services in 2012, has added the port of Bushehr to its Iran coverage, which was relaunched with calls to Bandar Abbas in October. Maersk, which also has an office in Tehran, the Iranian capital, said it selected the port because it is the largest gateway for transportation of goods in the province of Bushehr, with an annual throughput of seven million tons. The port of Bushehr can provide all containerized cargo services and, most significantly, refrigerated products." (JOC, "Maersk adds second Iranian call," 1/12/2017).

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"We are excited to announce that we have reinstated our services in Iran. This means that our customers can once again utilise our global network, large fleet of vessels and equipment, weekly departures, superior transit times and innovative suite of e-business solutions, both to and from Iran, subject to country specific regulations... At Maersk Line, we recognise the strong potential of the Iranian market and the crucial role it has in global trade. Marcus Connolly, Head of Sales, UAE Cluster, reaffirms “It is hugely exciting that after a 5 year absence, we are again able to offer Maersk Line services to customers to and from Iran. After a period of relative isolation, access to this new market will present significant growth opportunities for Maersk Line in a market that today represents approximately 700,000 FFE but is expected to grow significantly in the coming years.” (Maersk Line, "Maersk Line Returns to Iran," 10/24/2016).

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"Maersk Oil, the oil division of Danish group A.P. Moller-Maersk said on Thursday it had signed a memorandum of understanding with the National Iranian Oil Company (NIOC) to "explore opportunities for future cooperation". Maersk said it could not elaborate further. But NIOC Deputy Head for Development and Engineering Gholamreza Manuchehri told Iran's Mehr newsagency the talks concerned the second phase of development of the offshore South Pars field." (Reuters, "Maersk Oil in talks with Iran over oil fields," 10/20/2016).

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"Tougher conditions led to AP Moller-Maersk's Maersk Line, the world's biggest container company, pulling out entirely from Iran last year, joining an exodus including the world's number two and three MSC and CMA CGM and smaller groups like Germany's Hapag-Lloyd." (Reuters, "Iran faces fresh trade heat as more shipping firms exit," 5/7/2013) 

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"Maersk Line, the world's biggest container shipping company, has stopped port calls to Iran as Western sanctions pressure on the Islamic Republic mounts, a spokeswoman said on Tuesday... 'Maersk Line has ceased to call in Iran,' a spokeswoman for the unit of Danish group A.P. Moller-Maersk said... 'To date, Maersk Line's business in Iran has involved transporting foodstuffs and other goods, for example vehicles, for the benefit of the general civilian population. It is with regret that it is ceasing these activities,' the spokeswoman said. 'Maersk Line will maintain a dormant business entity in Iran and will look to resume business should the sanctions regime be eased.'... Since 2011, it has called at the small northern Iranian container port of Bushehr. The spokeswoman said Maersk Line halted loading cargo bound for Bushehr on September 30 and stopped loading outbound cargo from Bushehr on September 24. 'Maersk Line ceased its acceptance to all other ports than Bushehr in 2011,' the spokeswoman said. 'The discontinuation of services to and from Bushehr unfortunately reflects the difficulties servicing Iran as a whole.'" (Reuters, "Top shipping line Maersk says halts Iran service," 10/9/2012)

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"Danish oil and shipping group A.P. Moller Maersk says it will talk to Vitol to determine whether one of its tankers was used by the trading house to ship Iranian fuel oil. The Maersk Producer, a tanker chartered by Vitol from Maersk, received a fuel oil cargo of Iranian origin on Sept. 8, according to a document seen by Reuters. The cargo was transferred aboard the Danish tanker from Vitol's floating storage off Malaysia, the document shows, and shipped to storage in Singapore. Vitol admitted last week its Bahrain office had bought the Iranian fuel oil but said it had now ordered a stop to all trade with Iran, which is under European and U.S. oil and financial sanctions. Based in Switzerland and trading the oil from Bahrain, Vitol did not contravene sanctions... 'Not at any point did we know that the vessel would be used to transport oil under embargo and we will bring this up for discussion with Vitol at the highest level,' said Per Juul, managing director of the agent for Maersk, in an e-mail response to questions. 'If it is confirmed that it was Iranian oil the consequences will have to be discussed with Vitol...we have contacted our insurance company about this issue.' A spokesman for Vitol said the company would 'cooperate fully' in any talks with Maersk." (Reuters, "Danish shipper asks Vitol if tanker used for Iran oil," 10/3/2012)

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"Danish shipping and oil company A.P. Moller-Maersk has suspended new oil tanker deals with Iran due to European Union sanctions which will embargo imports of oil from the Islamic Republic into the bloc, a senior Maersk official told Reuters on Wednesday... 'As of 24 Jan 2012, all new fixtures involving Iran and all carriages of products with Iranian origin have been suspended,' said Henrik Ramskov, chief operating officer with Maersk Tankers, a unit of the Maersk group and one of the world's top tanker operators... A Maersk spokesman said its tanker unit made 14 Iran related voyages in 2011, 'representing a miniscule part of their activity.'" (Reuters, "Maersk suspends oil tanker trade deals with Iran," 2/8/2012)

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"The U.S. move led the world's top container player Maersk Line to suspend operations at several Iranian ports including Bandar Abbas... Danish shipping and oil group A.P. Moller-Maersk , which owns Maersk Line, said it was still engaged in business with Iran including the transport of provisions, natural gas and crude oil as well as bunker fuel supply to Maersk-related vessels, in compliance with sanctions. 'The group has and continues to update a comprehensive compliance program involving all relevant foreign trade controls,' it said." (Reuters, "Sanctions blowback crippling Iran's shipping trade," 12/1/2011)

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"The world's largest container firm suspended operations at several Iranian ports on Thursday, potentially disrupting critical food shipments as it complies with tightening U.S. sanctions. Maersk line, a unit of A.P. Moller-Maersk, manages several refrigerated ships and container vessels that transport food to the country, including wheat, rice and bananas from Asia. Shipments could be delayed for weeks as Maersk adjusts its operations in the Middle East, analysts said... The United States last week blacklisted Tidewater Middle East Co. and prohibited U.S. entities from any transactions with the major Iranian port operator, which manages over 90 percent of the country's container operations. 'Maersk Line is committed to complying with all relevant foreign trade controls and sanctions programmes,' said Morten Engelstoft, chief operating officer for Maersk Line in a statement on Thursday. 'In this connection, Maersk Line has decided to cease acceptance of, business to and from the Iranian ports of Bandar Abbas, Bandar Khomeini and Asaluyeh.' ... Maersk operates in other Iranian ports and could also divert shipments to Dubai, partnering with other companies that are not bound by U.S. sanctions aimed at curtailing Iran's alleged nuclear weapons programme... Tidewater-managed ports have been used to export arms or handle related material in violation of U.N. Security Council resolutions, the U.S. Treasury said last week. International sanctions are aimed at curtailing Iran's alleged nuclear weapons programme." (Reuters. "World's top shipper suspends some Iran ops over sanctions," 6/30/11)

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In July 2010, Maersk paid a $3.1 million fine to the US government for violating embargoes against both Iran and Sudan (Fox News, "Danish Shipping Firm Denies Violating US Sanctions Against Iran", 8/2/2010).

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Maersk Line lists two Iranian offices on its website, one in Tehran and one in Bandar Abbas, registered to the company Maersk Iran A.S. (Maersk Line Company Website).

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Maersk Iran A.S. lists Shaheed Rajee Container Terminal in Bandar Abbas, Khorramshahr Terminal in Khorramshahr, and Bandar Imam Khomeini Terminal in Bandar Imam Khomeini as service points for imports and exports (Maersk Line Export Services).

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Beginning on September 15, 2009, Maersk began offering “direct call to Bandar Abbas, Iran” on the FM1 line.  The company advertises “Direct service to/from Bandar Abbas…competitive transit time for Iran bound cargo…[and] transit time for Iran export cargo to Far East improved by 7 days along with direct coverage into Singapore and China” (Maersk Line Customer Advisory, 9/14/09).

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Maersk Line has weekly service in and out of the Iranian port of Bandar Abbas, on its Far East-Middle East FM1 line.  Other ports on the line include Dammam in Saudi Arabia, Jebel Ali Dubai in the U.A.E, Singapore, and multiple ports in China (Maersk Line Service Network Website).

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In June 2010, according to Maersk Line’s “Schedule by Port,” 15 Maersk Shipping Container Vessels came through the Iranian port of Bandar Abbas (Maersk Line Shipping Containers- Schedule by Port).  This includes the German-flagged Busan Express, the UK-flagged Hyundai Oakland, and the Greek-flagged Sea-Land New York.  The ships headed to ports in the U.A.E., Karachi, Singapore, China, and India (Maersk Line Shipping Containers- Schedule by Vessel).

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In June 2010, according to Maersk Line’s “Schedule by Port,” two ships made seven total trips to Khorramshahr Terminal.  The Cyprus-flagged MCP LINZ and the Ali 18 traveled between Khorramshahr (Iran), Jebel Ali Dubai (U.A.E.), and Bandar Khomeini (Iran) according to Maersk’s “Schedule by Vessel.”

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In June 2010, according to Maersk Line’s “Schedule by Port,” two ships made five total trips to Bandar Imam Khomeini Container Terminal in Iran.  The Cyprus-flagged MCP LINZ and the Ali 18 traveled between Bandar Khomeini (Iran), Jebel Ali Dubai (U.A.E.), and Khorramshahr (Iran) (Maersk Line Schedule by Vessel).

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The International Business Monitor lists Maersk as one of the shipping lines that does business in and out of the Iranian port of Bandar Abbas (International Business Monitor, “Iran Shipping Market Overview- Port of Bandar Abbas,” 4/28/2010).

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Maersk Tankers CEO Soren Skou said that 25 tankers worldwide are being used to store oil, 20 of which are commissioned by Iran.  Mr. Skou did not, however, specify if any of them are owned or operated by Maersk (Reuters, “Floating Oil Storage Ending: Maersk,” 5/27/2010).

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AP Moeller-Maersk does extensive business with the United States government, having earned nearly $4 billion ($3,980,588,981) in government contracts from 2000-2010, according to USASpending.gov. Nearly 95 percent of these funds came from the U.S. Defense Department. USASpending.gov also lists that Maersk Company Ltd., the British arm of AP Moeller Maersk, has received $480,484,505 in government contracts in the past decade, with more than 95 percent of those funds coming from the U.S. Defense Department.

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In 2010, Maersk Line Ltd, the US arm of Maersk Line, won a contract worth over $460 million to operate twelve U.S. Navy vessels.  Under the contract, Maersk Line Ltd will operate and maintain 10 ships in the US Navy Military Sealift Command’s Maritime Prepositioning Force and help the government manage its cargo.  The two other ships “carry ammunition, explosives, vehicles, and containerized cargo for the US Army’s prepositioning program.” The contract begins in 2010, and if all options are exercised, will continue until 2015 (Tradewinds.no, “Maersk Wins US Navy Work,” 6/1/2010).

Emerson subsidiary, Rosemount, is featured on the website of the Iranian firm, DIBAGARAN FARAYAND (DIFACO).

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The Iranian firm, Raya Tosee Tajhiz Paya (“Raya Tosee”), claims to be an authorized agent of Emerson in Iran.  (Raya Tosee Website, “Home.”). 

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Iranian sales agent Fatehin Sanat claims to have existing business ties with Aventics and Emerson. 

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In response to an inquiry for the U.S. Securities and Exchange Commission's Office of Global Security Risk regarding potential Iran business ties, Emerson Electric wrote:

"Emerson’s U.S. subsidiaries have been prohibited from conducting business with Iran, directly or indirectly, under the Company’s trade compliance requirements since the initial imposition of U.S. sanctions against Iran in 1995.

"After 1995 and before July, 2010, some of Emerson’s foreign subsidiaries, primarily in Europe, continued to transact a limited amount of lawful business with Iran.  This involved the sale of process equipment such as valves, transmitters and controllers; climate control equipment such as compressors; and, electric motors, drives, and uninterruptible power supply equipment.  That business was primarily conducted indirectly through OEMs, engineering companies and distributors.
 
"In July, 2010, after the passage of the Comprehensive Iran Sanctions, Accountability and Divestment Act of 2010, Emerson’s foreign subsidiaries implemented a prohibition on all new business with Iran, direct or indirect, even if such sales would have been legal.  When there was a legal basis for doing so, Emerson’s foreign subsidiaries terminated contracts that were entered prior to this ban.  Contracts for which there was no legal basis for termination remained in place, with a view to winding them down as soon as possible.  During the second quarter of fiscal 2012, the Company completed its remaining contracts." (SEC Correspondence, 3/16/2012)

As of July 2021, The US State of Mississippi did not list Essar 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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In 2020, the U.S. state of Mississippi listed Essar 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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"Began cutting oil imports from Iran in June with the aim of halting purchases by November 2018." ("India's Iran oil purchases to fade ahead of U.S. sanctions," Reuters, September 14, 2018.)

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"Indian private refiner Nayara Energy, a key buyer of Iranian oil, is prepared to replace Iranian oil if required under U.S. sanctions and hopes to settle dues owed to Tehran for past purchases ahead of a November deadline, its chief executive said." (6/5/2018).

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Essar Oil has settled about 2 billion euros ($2.5 billion) in dues to Iran to cover previous oil purchases and still owes the country about $616 million, Chief Executive B. Anand said on Thursday. (Reuters, 4/12/2018).

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In 2017 the U.S. states of Mississippi, South Carolina and Tennessee  listed EssarOil on its state list of companies doing business with Iran, rendering EssarOil ineligible for investment and/or state contracting.

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"Iran’s export of oil to India’s leading refiner “Essar Oil” doubled in Dec. 2017. Given the above issue, Iran exported more than 139,000 barrels of oil per day (BPD) to India in the same period, the report added." (December 2017)

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In 2016 Tennessee used the South Carolina list of "Entities Ineligible to Contract with the State of South Carolina or any Political Subdivision of the State per the Iran Divestment Act of 2014, S.C. Code Ann." as its list of persons it determines engage in investment activities in Iran. Essar Oil was included on this list in 2016. "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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“India's purchases of Iranian oil fell 4.1 percent in September, slipping from August when imports from Tehran hit their highest in at least 15 years, according to ship tracking data and a report compiled by Thomson Reuters Oil Research and Forecasts... . Essar Oil imported about 134,000 bpd…” (Reuters, "India's Sept Iran oil imports fall 4.1 percent on Aug - shipping data," 10/12/2016).

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"Indian media say the country's major oil companies have paid the first installment of outstanding oil dues to Iran. The payment of the installment at a total value of $700 million was made by Essar Oil, Mangalore Refinery and Petrochemicals (MRPL) and other Indian refiners on Wednesday. Essar Oil paid $335 million while MRPL paid about $300 million. The remainder of the payments was made by HPCL-Mittal Energy (HMEL) and Hindustan Petroleum Corp (HPCL)... According to what Iran and the P5+1 agreed in July, the US Treasury's Office of Foreign Assets Control (OFAC) would approve the banking mechanism for payment of $1.4 billion by Indian refiners in two equal installments to Tehran. The Indian media say the refiners had deposited the rupee equivalent of $700 million in Kolkata-based UCO Bank which transmitted the money to the Reserve Bank of India (RBI). The RBI will accordingly make arrangements for its onward remittance to Iran." (Press TV, "India pays first batch of Iran oil dues," 10/1/15)

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"Private-refiner Essar Oil was the biggest Indian client of Iran in 2014, followed by Mangalore Refinery and Petrochemicals Ltd and Indian Oil Corp." (Reuters, "India oil imports from Iran jump sharply in 2014," 1/16/15)

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In 2015 Essar was removed from Pennsylvania Treasury's List of Scrutinized Companies Determined as Having Involvement In Iran because the company's "involvement in purchases of crude oil falls uner the waivers granted by the U.S. government that meet Section (a)(2) of Act 44's expiration clause."

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"Essar Group, a $39 billion Indian conglomerate, is looking to tap frozen Iranian oil revenues to pay for its steel exports to Tehran, in a novel attempt to work around Western financial sanctions against the OPEC member state. The National Iranian Oil Company (NIOC) proposed the payment mechanism in August, potentially opening a new way to release oil export proceeds tied up in India under Western sanctions linked to Tehran's disputed nuclear program. According to industry and government sources, and letters reviewed by Reuters, Essar has asked the Indian government to free it from paying its share of oil dues to Iran, and instead offset them against a $2.5 billion deal to supply steel plate to a NIOC affiliate... Supplying steel to Iran is 'prohibited', while dealing with NIOC 'is very likely to fall foul of European Union and U.S. sanctions legislation,' said Jonathan Moss, partner and head of marine and trade at law firm DWF in London... The Iran Freedom and Counter-Proliferation Act of 2012 lists steel as a commodity subject to sanctions... India settles 45 percent of its oil trade with Iran in rupees, with the rest held back by the refiners who buy the oil. These unpaid funds are released as and when the West allows Iran access to them. Essar Oil buys oil from NIOC, while Essar Steel agreed in January to supply steel plate to Iranian Gas Engineering and Development Co (IGEDC), a NIOC affiliate. Deliveries of steel began in May, said a knowledgeable person at STC, adding that steel worth $100 million had been shipped so far. A source at the oil ministry valued the sales at $550 million. Ghadir Movahedzadeh, NIOC's financial director, proposed drawing on the 55 percent tranche of oil dues to pay for the steel deliveries in a letter to Essar Oil dated Aug. 26." (Reuters, "Exclusive: Indian Essar's planned oil-for-steel deal tests Iran sanctions," 11/28/14) 

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“Essar Oil and Mangalore Refinery and Petrochemicals Ltd were the only two Indian refiners that purchased oil from Iran in April.” (Reuters, “India's April Iran oil imports drop as buying spree cools,” 5/14/14)

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"India is set to pay Iran $1.65 billion over the next three months under an interim nuclear deal that eases sanctions on Tehran and gives it access to $4.2 billion in blocked funds, four sources with knowledge of the matter said…The Indian government has asked refiners to make the first payment by mid-May, three of the sources said, adding that refiners will settle all three tranches if payment is allowed by the United States and European Union. ‘The individual companies' share is to be worked out,’ one of the sources said…Three of the sources said Iran had asked India to make payments into the Central Bank of Iran's account with Oman's Bank Muscat BMAO.OM in Omani rails. ‘All I can confirm is that some movement is happening on payments by India to Iran, but the modalities as to which bank will be used by India to remit funds is yet to be worked out,’ said a western diplomat privy to the matter, who was not one of the four previously cited sources. Indian refiners Essar Oil, Bangalore Refinery and Petrochemicals Ltd, Hindustan Petroleum Corp  and HPCL-Mittal Energy Ltd together owe $3.6 billion to National Iranian Oil Co.” (Reuters, “India to make May-July oil payments to Iran - sources,” 4/23/14)

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“Essar Oil, Iran's top Indian client, imported 18.6 percent more oil from Tehran in 2013/14 after a jump in shipment volumes in the final quarter to end-March, according to tanker arrival data obtained from trade sources and assessed by Thomson Reuters Oil Analytics. The private refiner shipped in about 231,100 barrels per day (bpd) of Iranian crude in March, its highest monthly shipment since at least January 2011, reflecting a growth of about 90 percent from February and six times more than the volume in March 2013, the data showed. The higher volumes in the quarter were probably triggered by an interim deal agreement Tehran and six world powers in November for a loosening of trade sanctions in exchange for curbs on Iran's disputed nuclear programme. Essar shipped in about 105,700 bpd from Iran in the year to March 31, the data showed benefiting from discounts offered by Tehran. On the basis of actual loading from Iran, Essar lifted about 31 percent more oil than the contracted 80,000 bpd in the last fiscal year, a government source told Reuters. Iran accounted for about a third of Essar's total imports of about 3.28 million bpd in the last fiscal year, compared with 27.6 percent the year before, the data showed.” (Reuters, “India's Essar buys 18.6 pct more Iranian oil in 2013/14,” 4/17/14)

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“Private refiner Essar Oil and Mangalore Refinery and Petrochemicals Ltd had a deal to buy 80,000 bpd each from Iran in the last fiscal year. State-owned Indian Oil Corp signed for the other contracted term volumes of 25,000 bpd. Essar bought about 105,400 bpd, 32 percent higher than its contract, while MRPL shipped in 83,800 bpd, said the official. 'Essar took almost half of our overall imports from Iran (in 2013/14). They (Iran) are offering better deals than others in the Gulf,’ the official said. Essar Oil officials did not respond to an e-mailed request for further details.Iran has been offering free shipping and discounts on crude sales to Indian refiners to boost its exports.” (Reuters, “India cuts Iran oil imports nearly a fifth in 2013/14,” 4/17/14)

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“Private refiner Essar Oil will be the biggest Indian buyer of Iran's oil this financial year, replacing state-owned Mangalore Refinery and Petrochemical. Essar will have lifted about 30 percent higher than its contract volume of 80,000 bpd, said another government source. A jump in Essar's Iran oil imports comes as Iran is giving India a discount on crude and offering free delivery. Essar has offered to take about 5.36 million barrels in March from Iran, taking its annual purchases to 105,000 bpd. MRPL's oil imports from Iran will average about 84,000 bpd this fiscal year versus contract levels of 80,000 bpd, the third government source said.” (Reuters, “Exclusive: India to slash Iran oil imports to meet nuclear deal parameters - sources,” 3/11/14)

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“Essar Oil, a key buyer of Iranian oil, in January sharply raised imports from the Islamic state and also became the first Indian refiner to ship in the Brazilian heavy grade Polvo, tanker arrival data showed. India's oil imports from Iran more than doubled in January from a month earlier after sanctions on Tehran were eased due to an interim deal on its nuclear programme. Essar received 141,900 barrels per day (bpd) of oil from Iran last month, up from 54,200 bpd in December, according to the data obtained by Reuters. Shipments last month were about 31 percent higher than a year ago. Essar officials declined to comment. During the first 10 months of the fiscal year ending March 31, Essar imported 91,500 bpd oil, a decline of about 6 percent from the same period the year before, the data showed…Essar's total crude imports in January rose 81.5 percent from a low base in December, when it drew from inventory and cut purchases.” (Reuters, “India Essar's oil imports from Iran jump sharply,” 2/25/14) 

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In 2013, Essar was added to the Pennsylvania Treasury's List of Scrutinized Companies Determined as Having Involvement in Iran because of government oil-related activity. 

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"Essar Oil reduced its imports of Iranian oil by 16.4 percent in the first seven months of this fiscal year, tanker arrival data made available to Reuters showed. The private refiner received about 91,000 barrels per day (bpd) oil from Iran in April-October, the data showed, making up more than half of the total 170,000 bpd that India took from the sanctions-hit nation. The United States renewed six-month waivers on sanctions for India and other major buyers including China and South Korea last week in exchange for reduced purchases of oil from Iran. India's overall purchases from Iran for the April-October period are down about 40 percent from the same period a year ago as the state-run refiners cut volumes substantially…Essar's Iranian oil imports in the first ten months of the calendar year were down about 32.7 percent to 84,100 bpd. Last year, the refiner was stepping up purchases ahead of the start of additional sanctions in July 2012. Essar shipped in 106,000 bpd from Iran in October, a growth of 9.8 percent over September, the data shows." (Reuters, "India's Essar Apr-Oct Iran oil imports down 16.4 pct y/y-trade," 12/2/13) 

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"Indian refiners have asked the government to clarify if they can pay Iran for crude in euros after the National Iranian Oil Company (NIOC) requested settlement of some debts through a Turkish bank, Indian officials said on Wednesday…India now owes Iran about $5.3 billion for oil imports, government and refining sources said last week. In mid-October, NIOC informed Indian refiners that Halkbank was ready to restart channelling the payments to Iran, the sources told Reuters, declining to be named due to the sensitivity of the matter. NIOC said it had been informed that Halkbank could be used again by Iran's central bank. It was unclear from the communication from NIOC what had changed that would allow the payments to restart without contravening U.S. sanctions, the sources said…Indian refiners have yet to restart payments via Halkbank and have asked the government for guidance, the sources said…Indian refiners Essar Oil, Mangalore Refinery and Petrochemicals Ltd, Hindustan Petroleum and Indian Oil Corp have all bought crude from Iran and owe payment, sources said." (Reuters, "Indian refiners puzzle over Iran request for euro oil payment-sources," 11/13/13)

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"Iran is offering free delivery of crude to major client India, industry sources said, signalling that tough Western sanctions which have slashed its exports in half are --driving Tehran to increasingly desperate measures to keep oil flowing…Iran's remaining Indian clients - Mangalore Refinery and Petrochemicals Ltd, Essar Oil and Indian Oil Corp - could save freight of 70 cents to $1 a barrel on purchases from Iran, said one of the sources…India is one of Iran's few remaining clients along with other Asian buyers China, Japan and South Korea. (Reuters, "Iran offers to ship crude to India for free to boost sales," 11/7/13)

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"Refiner Mangalore Refinery and Petrochemicals Ltd (MRPL.NS) was the biggest importer of Iranian oil in September, replacing Essar Oil (ESRO.NS) by shipping in 133,000 bpd, the data showed." (Reuters, "India's Iran oil imports drop as refiners await insurance fund," 10/29/13)

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"Oil and container trade between India and Iran has been disrupted due to uncertainty over insurance cover, leaving some ships stranded outside ports in both countries, industry sources said. The delays had occurred because New Delhi had not yet extended approval for Iranian underwriters to provide insurance for container and tanker vessels calling at Indian ports, they said…A three-month approval by India for Iran's Kish P&I and Moallem Insurance Co to cover container and tanker vessels calling at Indian ports lapsed on September 27…Two Iranian vessels carrying oil for Indian refiner Essar Oil (ESRO.NS) -- Sundial, an aframax sized tanker, and a very large crude carrier Sunshine -- were waiting at an Indian port, the sources said." (Reuters, "Iranian trade with India hit by insurance delay - sources," 10/8/13) 

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"India aims to cut Iranian crude imports by 15 percent this fiscal year, the oil secretary said on Tuesday, differing from the oil minister who recently said he wanted to hold the shipments at last year's levels. Ahead of Prime Minister Manmohan Singh's visit to the United States last week, Oil Minister M. Veerappa Moily said Iranian imports should be held steady at 260,000 barrels per day (bpd) to save as much as $8.5 billion in foreign exchange as Tehran accepts partial payment in rupees. However, Oil Secretary Vivek Rae, the Petroleum Ministry's top bureaucrat, said on Tuesday that India targets oil imports of around 220,000 bpd from Iran in the year through March 2014…Mangalore Refinery and Petrochemicals and Essar Oil - the only Indian refiners currently importing Iranian crude - will import about 80,000 bpd each this fiscal year." (Reuters, "India aims to cut Iran oil imports by 15 pct - oil secretary," 10/1/13)

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"India's Essar Oil imported 21.1 percent more Iranian oil in June compared with a year earlier and shipped in Kazakhstan's CPC blend for the first time, tanker arrival data made available to Reuters showed, as the private refiner increased its appetite for testing new grades after expansion. Essar was the only Indian client of Iranian oil in June buying 138,900 barrels per day (bpd), a growth of 16.3 percent over May. The refiner, however, has cut Iranian oil imports by about a third in the first half of this year when it received 86,300 bpd as it stepped up purchases last year ahead of sanctions starting in July 2012... However, Essar continued using Iranian oil based on legal advice that EU sanctions are not applicable in this situation, a document made available to Reuters showed. But there is some uncertainty as it is up to reinsurers to interpret the sanctions." (Reuters, "Table-India Essar's June Iran Oil Imports Up 21.1 pct-trade," 7/24/13)

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"India's imports of crude oil from Iran more than halved in June from a year ago, as refiner Essar Oil became the only remaining Indian client of the sanctions-hit country, tanker data obtained by Reuters showed." (Reuters, "India's Iranian Oil Imports More than Half in June-trade," 7/23/13)

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"That has left the country's biggest refiner, state-owned Indian Oil Corp - whose insurance coverage is due for renewal only in November - and private refiner Essar Oil as Iran's only Indian clients, according to sources... This means Essar Oil would be Iran's sole customer in India from June to later this year, unless other Indian refiners find a way to insure plants processing Iranian crude or sanctions are eased." (Reuters, "India cuts Iran oil imports 42 pct, takes Venezuelan, other crudes," 6/17/2013) 

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"Mangalore Refinery and Petrochemicals Ltd and Essar Oil have said they would halt imports from Iran because of insurance problems, Vivek Rae told reporters." (Reuters, "India plans reinsurance fund to cover refiners using Iranian oil," 3/24/2013)

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"Essar Oil has more than halved oil imports from Iran in November and aims to reduce purchases further, a source with direct knowledge of the matter said, strengthening New Delhi's hopes of a continued waiver from U.S. sanctions. Privately-owned Essar was Iran's top Indian client in April to October, temporarily replacing state-run Mangalore Refinery and Petrochemicals Ltd, according to data available to Reuters, taking more than its term deal's average quantities... In November, Essar imported about 265,000 tonnes or about 64,500 barrels per day (bpd) crude from Iran, a decline of about 55 percent from the previous month and about a third of its imports a year ago, the source said... 'Essar will continue to reduce purchases from Iran as it wants to bring down imports from Iran to about 85,000 barrels per day in this fiscal year,' said the source. Essar imported about 109,000 bpd from Iran during April-October, according to Reuters data, and has been criticised by state-run refiners for not cooperating with them in India's effort to reduce shipments from the Islamic nation... Essar has an annual deal with Iran to import about 100,000 bpd oil in this fiscal year ending March 31, 2013 and the planned reduction is in line with a verbal directive from the government to reduce imports by 15 percent. Essar, which operates a 400,000 bpd refinery at Vadinar in western Gujarat state, has meanwhile significantly raised processing of heavy and ultra-heavy grades, including those from Latin America, to improve refining margins... Essar aims to buy 15-20 percent of its oil needs from the domestic market, 35-40 percent from Latin American sources, and 30-40 percent from the Middle East, it said in May." (Reuters, "Essar slashes Iran imports in Nov; to continue with cuts-source," 12/4/2012)   

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"While India's state-run refiners are adhering to the government's verbal order to cut imports from Iran by at least 15 percent, their efforts could be undermined by private refiner Essar and now HMEL... Essar sources, however, said their Iranian crude purchases would average 85,000 bpd in financial 2012/13 (April-March), a decline of 15 percent from an originally contracted 100,000 bpd. From April-August Essar has bought an average 102,000 bpd." (Reuters, "India's HMEL bought 2 million barrels of Iranian oil: sources," 10/13/2012)

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"Essar Oil, the only private refiner in India that buys Iranian oil, has raised imports of oil from Tehran by a third in July compared with June and about 37 percent from a year ago, according to tanker discharge data made available to Reuters. Essar has renewed its term deal with Iran to buy 100,000 barrels per day (bpd) oil in 2012/13 (April-march) but plans to cut purchases by 15 percent after a verbal directive by the government. However, the refiner has shipped in an average 104,000 bpd since April." (Reuters, "India Essar's July Iran oil imports rise a third from June-trade," 8/31/12)

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"Falling imports pushed Iran to sixth position in the list of India's biggest suppliers of oil in July, compared with the third position it enjoyed in June and No. 4 a year ago. The shortfall is being made up with extra barrels from the world's biggest exporter, Saudi Arabia, as well as the United Arab Emirates, which emerged as the fourth-biggest supplier to India. While state-run refiners have stepped up imports from Nigeria, which was third-biggest supplier in July, private refiner Essar Oil has turned its focus to Latin America. Essar, which raised the use of heavy and ultra-heavy crude oil in April-June, has signed a deal to buy 12 million barrels of oil from Colombia . . . In July Essar emerged as Iran's top Indian client replacing Mangalore Refinery and Petrochemicals, which lifted only a fifth of planned Iran imports in July. MRPL is looking at alternatives to make up for the Iran shortfall . . . Essar's imports rose by a third in July to 154,400 bpd compared with June, the data showed, while MRPL's declined 86 percent to 22,200 bpd . . . Essar has renewed its annual deal of 100,000 bpd with Iran for this fiscal year starting April 1 but plans to lift 15 percent less volumes, while MRPL has reduced the size of its deal to 100,000 bpd compared with 124,000 bpd of 2011/12." (Reuters, "India cuts July Iran oil imports by over 40 pct y/y-trade data," 8/21/12)

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"Essar Oil, the only private refiner in India that buys Iranian oil, has significantly raised imports from the sanctions-hit nation in June, reversing the declining trend of the previous three months, ahead of tighter western sanctions that came into effect from July, according to tanker discharge data made available to Reuters…The private refiner more than trebled monthly imports from Iran in June to 114,700 bpd -- and they were about 70 percent more than a year ago. Essar is set to become the biggest Indian buyer from the Islamic Republic in July replacing Mangalore Refineries and Petrochemicals Ltd…Essar got nearly 44 percent of its crude imports from Iran in January-June. Overall imports by Essar rose nearly 17 percent during January-June to 284,400 bpd, the data shows." (Reuters, "India Essar's June Iran oil imports soar, break 3 mth trend," 7/19/2012)

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"India's biggest buyer of Iranian oil may only import one-fifth of the 3.3 million barrels of crude it had scheduled for July due to insurance and shipping difficulties caused by European Union sanctions on Tehran, industry sources said.

The possible drop in imports by state-owned refiner Mangalore Refinery and Petrochemicals Ltd (MRPL) underscores the problems the EU sanctions, which ban most of the world's major insurance firms from covering shipments of Iranian oil, have created for Iran's major Asian customers China, India and Japan since coming into effect on July 1.

Along with U.S. sanctions, the EU measures, which include an oil embargo, has so far halved Iran's year-on-year oil sales…India had initially allowed state-owned refiners to use Iranian tankers to ship oil purchases from Iran but swiftly backtracked to benefit its own shipping industry, stipulating that state-run oil firms must use Indian ships and allowing limited coverage by state-run insurers for Iranian cargoes. 

Private energy firm Essar Oil, which is not restricted by the government's shipping and insurance regulations on Iran, on Wednesday received 2 million barrels of oil in an NITC tanker." (Reuters, "India's main Iran oil buyer may cut July imports," 6/12/12)

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"India's Essar Oil, one of Iran's key Indian clients, has significantly reduced purchases from the santions-hit nation in May and switched to Latin American grades, which accounted for about a third of its overall imports during the month, tanker discharge data made available to Reuters show. Essar, which earlier this week completed an expansion of its Vadinar refinery in western Gujarat state to double capacity to 400,000 barrels per day (bpd), stepped up imports from Iran in January-March to meet last fiscal year's commitment and build stocks by July when tighter sanctions come into effect, making payments, insurance and supplies more uncertain.It bought about 33,000 bpd in May, down more than 70 percent both from April and a year ago. In April its Iranian oil imports declined by about a quarter from March and 6 percent from a year ago. Essar got nearly half its crude imports from Iran in January-May. Overall imports by Essar rose 16 percent during January-May, the data shows. The refiner significantly raised imports from Iraq in May, to replace Iranian volumes. Essar, whose crude slate comprises mainly Middle Eastern grades, also made a rare purchase of Venezuela's Leona 22 grade and Brazil's Jubarte oil in April-May, as the complexity of its plant has also been increased to process heavy and ultra heavy grades. Essar imported about 127,000 bpd oil from Iran in January-May, data showed." (Reuters, "India Essar's May Iran imports down over 70 pct- Trade," 6/8/12)

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"India does not allow state refiners to import oil on a delivered basis, a facility which privately-run Essar Oil has begun using." (Reuters, "Indian refiner MRPL turns to Iran for oil insurance -sources," 5/21/2012)

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"Essar Oil Ltd. (ESOIL),  the operator of India's  second-largest non-state refinery, provisionally hired a crude tanker to load from the Iranian port of Kharg Island, shipping data show...  Rabin Ghosh, a Mumbai-based spokesman for Essar, declined to comment." (Bloomberg, "Essar Refinery in India Makes Preliminary Booking of Iran Crude," 5/10/2012)

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"Iran is poised to lose at least 192,000 barrels a day of crude-supply contracts, or about 9.5 percent of its global exports, as Asian buyers curb purchases amid western sanctions targeting the nation's oil trade. Mangalore Refinery & Petrochemicals Ltd. (MRPL) and Essar Oil Ltd., India's biggest buyers of Iranian crude, and China International United Petroleum & Chemical Co. have reduced or plan to cut purchases from the Islamic Republic by as much as 15 percent. China and India are Iran's largest customers. In Japan, the only Asian country to get an exemption from U.S. sanctions after it demonstrated reductions in purchases, Cosmo Oil Co. plans to cut imports by 25 percent, while JX Nippon Oil & Energy Corp. suspended talks with the Persian Gulf nation over a 10,000 barrel-a-day contract." (Bloomberg, "Iran May Lose 9.5% of Oil Contracts as Asian Buyers Cut Imports," 5/3/12)

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"India's top two importers of crude oil from Iran will reduce shipments from the Persian Gulf nation by at least 15% this financial year, the latest sign that New Delhi is playing ball with Washington's efforts to shut-down Iran oil trade despite public pronouncement from Indian officials that they will continue to buy from Tehran. The government has asked state-owned Mangalore Refinery & Petrochemicals Ltd. and Essar Oil Ltd., a private company, to cut their imports in the year through March 2013 due to demands from the U.S., said two people with direct knowledge of the matter. 'Definitely, there is a lot of pressure from the U.S.,' one of the people said. A spokesman for India's oil ministry did not immediately respond to a request for comment." (WSJ, "Under U.S Pressure, India to Cut Iran Imports," 5/2/12)

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According to its website, "Essar Oil is a fully integrated oil & gas company of international scale with strong presence across the hydrocarbon value chain from exploration & production to oil retail. It has a global portfolio of onshore and offshore oil & gas blocks, with about 45,000 sq km available for exploration. Essar Oil has over 300,000 bpsd (barrels per stream-day) of crude refining capacity that is being expanded to 750,000 bpsd. There are over 1,300 Essar-branded oil retail outlets in various parts of India" (Company Website).

Essar Oil is part of the Essar Group, a “multinational conglomerate and a leading player in the sectors of Steel, Oil & Gas, Power, Communications, Shipping Ports & Logistics, Construction and Minerals. With operations in more than 20 countries across five continents, the group employs 60,000 people, with revenues of about USD 15 billion” (Company Website).

Essar’s 10.5 mtpa refinery in Vadinar, Gujarat “has the capability to produce petrol and diesel suitable for use in India as well as advanced international markets” (Company Website).

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"The top Indian oil importer in the first quarter was Essar Oil, buying 142,000 bpd compared with 88,000 bpd in the first quarter of 2011, the Petrologistics data showed. Essar plans to expand its refining capacity and will raise the capacity of its giant Vadinar refinery to 405,000 bpd this year." (Reuters, "India replaces China as Iran's top oil client," 4/13/2012)

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As of April 2010, Essar Oil imports 50 thousand barrels of crude oil per day from Iran. (Reuters, "Iran’s Crude Oil Buyers in Europe, Asia," April 18 2010)

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"So keen is the Essar Group to keep its plans for a $1.6 billion steel plant in Minnesota safe, that it has agreed to back away from a proposed oil refinery in Iran. In a letter to Minnesota Gov. Tim Pawlenty dated Oct. 31, Essar Group’s Americas president, Madhu Vuppuluri, said the company was exploring the possibility of building a refinery in Iran and bidding on exploration blocks, but would adhere to U.S. regulations limiting companies’ operations in the country." (Forbes, "Essar Backs Off On Iran," 11/1/2007)

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Essar continued to develop its business in Iran as of 2006, as mentioned in an article listed under Essar media reports from that year: “Essar Global is also expanding its base in Qatar, Iran and Sharjah” (Business Standard, "Essar to raise $530 mn, pledges Hutch stake part," October 05, 2006).

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Essar’s growing trade with Iran in the early 2000s was described in a media report found on the Essar company website: “The Essar group intends to increase import of crude from Iran and export of steel - produced by Essar Steel - to the West Asian country in a big way." "This is apart from the Indian industry's overall attempt to increase exports to Iran as the balance of trade is currently heavily tilted in its favour.” “The Chairman of the Essar Group, Mr Shashikant N. Ruia, told Business Line: ‘We will be exploring the possibility of increasing our trade with Iranian companies in general.’ Mr Ruia is a member of the high-powered trade delegation of the Federation of Indian Chambers of Commerce and Industry (FICCI) to Iran” (Business Line, "Essar to increase trade with Iran," April 08, 2001).

Bobcat lists Tehran-based Touranto Co. P.J.S., a company supplies/construction equipment distributor, as an authorized dealer on its website (Bobcat Company Website).

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In the products section of its website, Touranto Co. lists the Bobcat 553 Loader among its available merchandise (Touranto Company Website).

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An article from Hitachi Construction Machinery, a subsidiary of Japanese company Hitachi, states the following:

"This privately owned company supplies earth moving/material handling machinery and accessories to America, Asia and Europe from leading manufacturers such as Bobcat, Terex, Indeco, Montabert, and Hitachi" (Hitachi Company Website).

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Touranto Co. is also listed on the Iran International Centre of Food and Agriculture Trade website (Irangrofood.com) business directory as distributor of "mini loader bobcats" (Website).

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View image separately to see details on distributor of Bobcat equipment in Iran