Withdrawn

According to its Annual Report filed with the SEC for fiscal year 2018: "In 2018, CNH Industrial suspended business activities in Iran, other than those activities required to fulfill binding orders. Prior to the suspension of business activities in Iran, CNH Industrial had limited commercial activity in Iran conducted by non-US subsidiaries. In 2018, sales in Iran were significantly less than one percent of CNH Industrial’s revenues. In 2018, one of our non-US subsidiaries generated net revenues of approximately $4.6 million attributable to the sale of on and off-road trucks and spare parts to an entity that is indirectly owned or controlled by the Government of Iran. The Iran-related activity was negligible to our overall revenues and profits. Our activities in Iran comply in all material respects with applicable laws and regulations, including U.S. and other international trade sanctions."

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According to its Annual Report filed with the SEC for fiscal year 2017: "CNH Industrial has limited commercial activity in Iran, which is conducted by non-US subsidiaries. In 2017, sales in Iran were significantly less than one percent of CNH Industrial’s revenues.  In 2017, one of our non-US subsidiaries generated net revenues of approximately $11.3 million attributable to the sale of on and off-road trucks and spare parts to an entity that is indirectly owned or controlled by the Government of Iran."

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On February 24, 2016, a delegation of CNH officials met with Iran’s Arak HEPCO Company in Iran. (IRNA, “Arak HEPCO capacities introduced to Italian investors,” 2/24/2016)

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CNH Industrial, reportedly was part of a 370-member Italian trade delegation to Iran in late November 2015. (Press TV, “Fiat in talks for car manufacturing in Iran,” 11/29/2015).

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"Fiat and its sister companies, Fiat Industrial and CNH Global N.V. (CNH), said they will cease business activities in Iran in support of diplomatic efforts to convince the leaders of Iran to abandon its nuclear program, which is widely suspected of developing nuclear weapons. Iran has denied that it is making nuclear weapons... Fiat Industrial and CNH issued statements with the same wording. Fiat exports cars to Iran while Fiat Industrial exports buses and trucks under its Iveco brand. CNH Global builds farm and construction machinery that is sold in Iran." (Dow Jones, "Fiat Ban On Sales To Iran Seen As Victory In Sanctions Campaign," 5/25/2012)
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In a correspondance with the SEC in December of 2009, CNH disclosed details of its sales in Iran.

"CNH’s foreign subsidiaries’ total sales into Iran: $27.8 million in 2006, $42.9 million in 2007, $36.8 million in 2008, and $6.2 million in 2009.  In Iran, CNH’s foreign subsidiaries sell equipment to independent distributors or with the assistance of a commission agent."

(CORRESP for CNH GLOBAL N V, 12/7/2009)

Has suspended any new marine insurance contracts with Iran; had insured shipping and shipments for Iran following the nuclear agreement. (Carolyn Cohn, Jonathan Saul, "U.S. sanctions seen barring IT platform of insurer Lloyd's for Iran trade," Reuters, July 13, 2018.)

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Numerous subsidiaries provide insurance to Iran.

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"Zurich Insurance Group AG (ZURN) is among companies being questioned by New York’s insurance regulator in a widening probe into compliance with an Iran sanctions law, according to a person familiar with the matter. The state Department of Financial Services is asking insurers to explain their policies and procedures to avoid violations of the Iran Freedom and Counter-Proliferation Act of 2012, according to the person. The act took effect July 1. ‘The resulting sanctions could jeopardize the ability of any involved insurer to conduct business in the United States,’ the department said in a letter to the insurers obtained by Bloomberg News. ‘Recently, the Department learned that several companies have insured trades made with Iran.’ The regulator, led by Superintendent Benjamin Lawsky, contacted a group of insurers in June about compliance with the law. That group included Swiss Reinsurance Co. (SREN) and Lloyd’s of London. Besides Zurich, other companies contacted in the newest letter are American International Overseas Ltd., AXA Global Risks, and St. Paul Reinsurance Co. Ltd." (Bloomberg, Zurich Among Insurers Said to Be Probed in Expanded N.Y. Inquiry, 7/24/13)

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In a correspondance with the SEC, AXA disclosed details regarding their investments in Iran.

“There are three non-US subsidiaries of the AXA Group provide insurance coverage to local subsidiaries or branches of entities known by AXA to be controlled by the government of Iran:  AXA UK has entered into insurance relationships with the UK operations of four state-controlled Iranian banks (three advisory relationships and one UK group pension relationship.  AXA Corporate Solutions, a French AXA subsidiary, has underwritten marine and aviation insurance policies for six companies based in Iran.  AXA Spain holds a 10% co-insurance participation in a marine insurance cover for an Iranian ship (AXA Spain took this 10% co-insurance participation under an insurance program covering the fleet of a Spanish fishing company which subsequently sold one of its boats –with its insurance cover- to an Iranian company.  The German branch of an AXA Assistance French subsidiary provides reinsurance coverage for 16 Iranian insurance companies. These reinsurance programs cover compulsory travel insurance for Iranian citizens entering the “Schengen area” (which consists of the European Union states where the free movement of persons is established). (CORRESP for AXA, 12/8/2009) 

"Following the lifting of sanctions in January 2016, IranAir finalized contracts for purchasing 100 Airbus jets, 80 Boeing jets and 20+20 ATR [which is jointly owned by Airbus and Finmeccanica] aircraft. It has taken the delivery of 11 planes so far: one Airbus A321, two Airbus A330s and eight ATR 72-600s." (Financial Tribune, "50% of Iran’s Passenger Fleet Grounded by Technical Problems," 12/7/21).

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"Minister of Roads and Urban Development Mohammad Eslami says the international plane-manufacturing companies Airbus and Boeing intend to return to contracts they concluded with Iran several years ago. 'The plane-manufacturing companies are returning to implement the terms of the contracts,' Eslami was quoted as saying by Fars News Agency. 'It has been emphasized that the plane manufacturers should honor their obligations,' he added." (Financial Tribune, "Airbus, Boeing Plan to Return to Iran Deals," 5/19/21).

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"With reconciliation in the air at the Vienna talks to reinvigorate the 2015 nuclear agreement, Iran Air has been trying to press Boeing BA +1.1% to revive a large order for jets signed in 2016. Local media in Iran have reported that the national carrier has sent a letter to Boeing demanding it honor its commitments. Managing director Alireza Barkhor told the Islamic Republic News Agency that it wants to revive the contract for buying airplanes. In a brief statement from Boeing in response to questions for this article, the company said “Boeing will continue to follow the U.S. government’s lead with respect to engagement with Iranian airlines.” It did not confirm whether it had recently received any correspondence from Iran Air or other Iranian carriers, or what the status is of the 2016 order." (Forbes, "Iran Tries To Revive $16 Billion Deal For 80 Boeing Jets," 4/20/21).

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"Under U.S. sanctions law, the Treasury’s Office of Foreign Assets Control (OFAC) must grant approval for U.S. investigators and Boeing Co to participate and potentially travel to Iran. Boeing said on Friday it was working with the Federal Aviation Administration and National Transportation Safety Board “on the necessary applications and approvals from OFAC for the appropriate export licenses.”" (Reuters, "Treasury will grant waivers to allow U.S. participation in Iran crash probe," 1/10/2020).

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According to its Annual Report filed with the SEC for fiscal year 2019: "In connection with the U.S. withdrawal from the Joint Comprehensive Plan of Action (Iran Nuclear Agreement), we engaged in activities during the third quarter that were required to unwind and terminate all agreements with Iranian airlines entered into prior to the withdrawal. These activities were authorized by a license from the U.S. Office of Foreign Assets Control (OFAC), and generated no revenues or profits. In addition, during the fourth quarter Iran Aseman Airlines requested Boeing support, and we replied that the current laws of the United States do not permit Boeing to provide any services, parts, or aircraft without a license from OFAC."

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"Aside from the energy sector, the country's aviation industry — thirsty for renovation following decades of Western embargos — was quick to finalize voluminous purchases from Airbus and Boeing. Nevertheless, US pressure forced a halt on the deliveries and a suspension of the fledgling agreements." (Al Monitor, "Chinese energy giant bids farewell to $5 billion Iran project," 10/8/2019).

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"Boeing will not deliver aircraft to Iran in light of US sanctions, effectively aborting a pair of large contracts with Iranian carriers, a Boeing spokesman said today. "We have not delivered any aircraft to Iran, and given we no longer have a license to sell to Iran at this time, we will not be delivering any aircraft," the Boeing spokesman said.

"We did not factor the Iran orders into our order backlog either." The announcement follows President Donald Trump's decision last month to pull the United States out of the landmark 2015 nuclear accord between Iran and major powers that had cleared the way for a relaxation of sanctions on Iran." (June 6, 2018).

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"Under the announcement, companies selling commercial aeroplanes to Iran will be particularly hit. Companies such as Airbus and Boeing - which had agreed deals with Iran to sell 100 and 80 aircraft respectively after the 2015 deal - stand to lose billions of dollars because of the use of US-made parts in construction." (May 11, 2018)

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"Among U.S. companies, plane maker Boeing has signed the biggest deals, and U.S. Treasury Secretary Steven Mnuchin said Tuesday that its existing licenses — as well as those of its European competitor, Airbus Group — would be invalidated. In December 2016, Airbus signed a deal with Iran's national carrier, IranAir, to sell it 100 airplanes for around $19 billion at list prices. Boeing later struck its own deal with IranAir for 80 aircraft with a list price of some $17 billion, promising that deliveries would begin in 2017 and run until 2025. Boeing separately struck another 30-airplane deal with Iran's Aseman Airlines for $3 billion at list prices. Boeing has yet to deliver any aircraft to Iran under those deals and said that it will "continue to follow the U.S. government's lead."" (May 9, 2018).

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Boeing said in a statement that it had signed a memorandum of understanding with state carrier Iran Air “expressing the airline’s intent to purchase Boeing commercial passenger airplanes.” (August 18, 2017).

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"Leaders from Boeing reportedly traveled to Tehran recently to meet and sign a deal with a top former Iranian Revolutionary Guards Corps (IRGC) member who threatened to blow up U.S. forces in the Persian Gulf region, raising new questions about the U.S. aerospace company's continued efforts to ink multi-billion dollar deals with the Iranian regime. Representatives from Boeing traveled to Iran last month to meet with Hossein Alaei, CEO of Aseman Airlines, which is owned and controlled by the state. Boeing is moving forward with a $3 billion dollar deal to sell new planes to Aseman despite fierce opposition on Capitol Hill and direct evidence Iran has used commercial aircraft to ferry weapons and fighters across the region." (Washington Free Beacon, ""Boeing Reps Meet With Iranian Terror Leader Who Threatened to 'Destroy' U.S. Forces," 5/1/17).

"Boeing Co. is making "steady progress" to complete the terms of an 80-jetliner sale to Iran Air and expects to deliver the initial planes next year, the first U.S. aircraft exports to Iran since the country's revolution in 1979.  "That remains on track," Chief Executive Officer Dennis Muilenburg told reporters Monday following the planemaker's annual general meeting in Chicago. "It's really important that at every step of the process, we're working on this hand-in-hand with the U.S. government." The $16.6 billion deal with Iran Air and a separate $3 billion agreement with Iran Aseman Airlines bring two of President Donald Trump's initiatives into conflict: his campaign vows to "get tough" on Iran and his promise to bolster U.S. exports supporting thousands of manufacturing jobs." (Bloomberg, "Boeing Moves Ahead on Delivering First Jets To Iran Next Year," 5/1/17.

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"President Trump should cancel airplane sales to Iranian airlines that facilitate terrorism, a pair of Republican lawmakers urged Monday. 'Iran's commercial airlines have American blood on their hands,' Sen. Marco Rubio, R-Fla., and Rep. Peter Roskam, R-Ill., wrote in a letter to Trump. A government decision to block the aircraft sales would provoke an uproar at home and abroad. It would cost Boeing, which has inked a pair of deals to sell 110 to Iran-based airlines, about $20 billion. It could deter American and European businesses from investing in Iran, which the regime's leaders have argued amounts to violation of the nuclear agreement that former President Barack Obama's team negotiated." (Washington Examiner, "Lawmakers To Trump: Cancel Obama-Backed Boeing Sales To Iran," 4/10/17).

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"IranAir may get its first new Boeing jetliner a year earlier than expected under a deal to take jets originally bought by cash-strapped Turkish Airlines, Iranian media and industry sources said. Iran had been expected to receive the first of 80 aircraft ordered from the U.S. planemaker in April 2018, but at least one brand-new aircraft is reported to be sitting unused because it is no longer needed by the Turkish carrier. Industry sources said Boeing was in negotiations to release at least one 777-300ER originally built for Turkish Airlines, which is deferring deliveries due to weaker traffic following last year's failed coup attempt in Turkey. Boeing said it never comments on talks with customers. The airlines involved were not immediately available for comment.  Iran's Deputy Roads and Urban Development Minister Asghar Fakhrieh-Kashan told the semi-official Mehr news agency the first Boeing 777 aircraft would reach Tehran within a month. It would be the first new U.S.-built jet delivered to Iran since the 1979 Islamic revolution." (Reuters, "IranAir May Receive First Boeing Jet Sooner Than Planned," 4/10/17).

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"Sen. Marco Rubio, R-Fla., on Sunday said a new multi-billion dollar deal between Boeing and an Iranian airline 'should be canceled.' 'We should be increasing sanctions significantly on Iranian and Russian interests that are helping Assad. In particular, this Boeing deal should be canceled,' Rubio said. Last week, Boeing said it had agreed to sell $3 billion in airplanes to an Iranian airline, though President Trump could thwart the deal. Rubio also said Sunday he is 'concerned' about the Trump administration's Syria strategy following Secretary of State Rex Tillerson's comments about tackling the Islamic State before stabilizing Bashar Assad's country. The Foreign Relations Committee member is worried that new comments by Tillerson do not take the necessary steps against helping Syria and its allies." (Washington Examiner, "Rubio: Cancel Boeing deal to hurt Russia, Syria," 4/9/17).

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"Boeing Co. agreed to sell up to 60 of its most popular jets to an Iranian airline, doubling down on the country amid uncertainty over the Trump administration's tolerance for U.S. business dealings in Iran. Boeing said Tuesday it signed a memorandum of agreement with privately owned Iran Aseman Airlines for the sale of 30 Boeing 737 Max single-aisle planes, with options for another 30. The list price for all 60 jets is $6 billion. Plane makers typically offer steep discounts, and the real value of the deal could be significantly lower. Still, the sale is the first major deal between a U.S. company and an Iranian one since the inauguration of President Donald Trump, an outspoken critic of closer ties with Tehran. Boeing said it had received permission from the U.S. government to negotiate the sale, though it still needs signoff from the U.S. Treasury's Office of Foreign Assets Control. If approved, the first planes will arrive in Iran by 2022." (Wall Street Journal, "Boeing Agrees To First Plane Sale To Iran Under Trump," 4/4/2017).

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"The head of IranAir took delivery on Wednesday of the first new Western jet under an international sanctions deal... The 189-seat plane is the first of 100 ordered from Airbus following a deal reached in 2015 between Tehran and world powers to lift nuclear-related sanctions against Iran, in return for restrictions on the country's nuclear activities... The airline has also ordered 80 aircraft from Boeing and is expected to seal an order for 20 turboprops from Europe's ATR." (Reuters, "IranAir Takes Delivery of First Airbus Jet Post-Sanctions," 1/11/2017).

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"Iran said on Sunday it had negotiated to pay only about half the announced price for 80 new Boeing airliners in an order that the American planemaker had said was worth $16.6 billion... Despite Iran's great need for new planes to replace those from the sanctions era, it has entered the market at a time when Boeing, Airbus and smaller planemakers have all faced a downturn in orders, and are therefore expected to offer deep discounts." (Reuters, "Iran Says It's Getting Planes from Boeing at Half the Price," 1/1/2017).

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The landmark deal by Boeing Co. to sell planes to Iran faces a rocky flight path before the company can begin delivering the aircraft in 2018, experts say. The sale, priced as of Sunday at $16.6 billion, covers 80 aircraft, and the first deliveries would begin in 2018. The contract was reached within the terms of a U.S. government license issued to Boeing in September, the company said in a statement. But the sale is subject to a number of contingencies, including regulatory approvals, potential financing difficulties and other problems. Chief among them, the experts said, is the potential for the U.S. government, after the Donald Trump administration takes office, to revoke the licenses that authorized the sale in the first place. (Wall Street Journal, "Boeing Deal with Iran Faces Turbulence Before Delivery," 12/13/2016).

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"Aircraft maker Boeing Co is making progress on a deal to provide more than 100 commercial airplanes to Iran though none will be delivered in 2016, the company's top executive said on Tuesday... "We won't deliver any aircraft under that deal this year - these are deliveries that are a year, two, three downstream," Boeing Chief Executive Officer Dennis Muilenburg told reporters on the sidelines of a conference in Chicago on future technologies. "But it's significant opportunity for us and I'm pleased to see that we're making steady progress." ... Muilenburg said Boeing is "in the final stages of working through the deal structure with our customers in Iran" while also working through the U.S. government licensing process." (Reuters, "Boeing 'Making Progress' on Airplane Deal with Iran: CEO," 10/4/2016). 

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The U.S. government has given plane makers Boeing Co. and Airbus Group SE the all-clear to deliver jetliners to Iran Air in one of the highest-profile trade breakthroughs since nuclear sanctions were lifted on the Islamic Republic in January… Airbus on Wednesday said some of those deliveries may occur as early as this year, a spokesman said… Rep. Peter J. Roskam (R., Ill.), a critic of Iran plane deals, said, “There is a still a long way to go and many more hurdles to overcome before Iran can actually take delivery of these planes—and thankfully Congress is committed to making the process as difficult and expensive as possible.” Other obstacles remain, including plane financing. The U.S. approval “does not make the use of dollars significantly easier. So any financing will have to be in euro, already a challenge for a dollar-denominated asset,” said Bertrand Grabowski, managing director of aviation finance at DVB Bank SE. He added that government export credit agencies will have to play “a critical role for the first financing, there is no alternative.” That could be a challenge for Boeing. The U.S. government’s Export-Import bank, which can back plane deals, is restricted from supporting Iran-related transactions. Export credit agencies backing Airbus signaled they are ready to support a deal with Iran. (The Wall Street Journal, "U.S. Gives Boeing, Airbus Go-Ahead to Send Airliners to Iran," 9/21/2016).

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Asghar Fakhrieh Kashan, Iran’s deputy transport minister, announced on state TV that the Iranian regime intended to invite Boeing to Tehran to discuss the purchase of at least 100 airplanes. (Fortune, “Boeing Has Gotten an Invite From Iran to Talk Planes,” 3/4/2016).

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According to its Annual Report filed with the SEC for fiscal year 2015: "Section 219 of the Iran Threat Reduction and Syria Human Rights Act of 2012 and Section 13(r) of the Securities Exchange Act of 1934, as amended (the “Act”), require disclosure of certain activities, transactions or dealings relating to Iran that occurred during the period covered by this report. Disclosure is required even if the activities, transactions or dealings were conducted in compliance with applicable law. We have disclosed such activities in our Quarterly Report on Form 10-Q for the second quarter of 2015 and such disclosure is incorporated herein by reference. During the fourth quarter of 2015, we agreed to sell aircraft maintenance manuals to Iran Air Tours. We generated no revenues or net profits during the fourth quarter of 2015 from these activities. These sales were authorized by a license from the U.S. Office of Foreign Assets Control (“OFAC”). Boeing applied for the OFAC license consistent with guidance from the U.S. government in connection with ongoing negotiations between the “P5+1” nations and Iran related to, among other things, the safety of Iran’s civil aviation industry. We may engage in additional activities pursuant to this license, which sales may require additional disclosure pursuant to Section 13(r) of the Act."

"Boeing Co is bullish on the Iranian market, believing that the Islamic republic's self-assessment for new aircraft is accurate. 'We've done a pretty good assessment on our side and we think the demand, should things open up, would be very strong,' Marty Bentrott, vice president - sales, Middle East, Russia & Central Asia at Boeing, told reporters in Dubai on Monday at the Arabian Travel Market (ATM). Iran has been barred by sanctions from buying western aircraft since the 1970s. But negotiations over its nuclear programme with the United States and other world powers that are set to come to close next month have raised hopes that the sanctions will be lifted. Last year, Iran's top aviation official said the country's airliners would need to order 400 aircraft over the next 10 years to replace its depleting and ageing fleet. Bentrott agreed that Iran's need for new aircraft 'would be in that ballpark'. In April 2014, Boeing was granted a license by the US Treasury Department to sells spare parts for commercial aircraft to Iran. The license has been extended on a number of occasions as the negotiations between Iran and the world powers progressed." (Gulf News, "Boeing bullish on Iran as nuclear negotiations near close," 5/4/15)

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"Iran says it has concluded three contracts with US aviation giant Boeing after it signed the Geneva nuclear agreement with the P5+1 group of countries in late 2013. Farhad Parvaresh, the CEO and Chairman of the country's flagship airline Iran Air, said on Saturday that the contracts with Boeing mostly involve repairing plane motors. 'Iran Air has so far received seven motors of its planes after they were repaired as the result of the contracts with Boeing,' Parvaresh said. 'There are several other motors that are being repaired by Boeing in a foreign country,' he said." (PressTv, Iran says three deals signed with Boeing," 2/25/15) 

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"Boeing said on Wednesday it had sold aircraft-related goods to Iran Air in the third quarter, marking the first acknowledged dealings between U.S. aerospace companies and Iran since the 1979 U.S. hostage crisis.The Chicago-based aerospace and defense company said in a filing that it sold aircraft manuals, drawings, navigation charts and data to Iran Air to help improve the safety of Iran's civil aviation industry. The sales did not include spare parts for aircraft, which were thought to be likely since Iran Air's fleet of planes includes vintage Boeing and Airbus jetliners delivered as long ago as 1978. Boeing and General Electric (GE.N) said in April that they had received export licenses from the U.S. Office of Foreign Assets Control allowing them to sell parts for commercial aircraft to Iran under a temporary sanctions relief deal that began in January." (Reuters, Boeing books first sales to Iran since 1979, 10/22/14)

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“U.S. planemaker Boeing has disclosed an agreement with Iran to provide airplane parts, relaxing a three-decade freeze in ties as part of a broader package of sanctions relief. The agreement sets out general terms and conditions for the ‘potential sale of certain goods and services related to the safety of flight,’ Boeing said in a regulatory filing. It marks the first acknowledged dealings between U.S. aerospace companies and Iran since the 1979 U.S. hostage crisis led to sanctions that deepened during the decade-old international dispute over Iran's nuclear program. Boeing said its agreement with state carrier Iran Air covered airplane parts, manuals, drawings, service bulletins, navigation charts and data. Boeing has also opened discussions with Iran Air Tours, a subsidiary of Iran Air, for similar goods and services, it said… In April, Boeing and engine maker General Electric said they had received licenses from the U.S. Treasury Department to export spare parts. European planemaker Airbus reiterated on Thursday that it had applied for a U.S. export license but said it had not yet reached an agreement with Iran on how to implement it.” (Reuters, Boeing reaches plane parts deal with Iran, 7/24/14)

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“However, Boeing Co, the world's biggest airplane maker, and engine maker General Electric Co said on Friday they had received licenses from the U.S. Treasury Department to sell certain spare parts for commercial aircraft to Iran under an interim deal agreed in November that went into effect on January 20…The preliminary deal provides for the sale of parts to Iranian flag carrier Iranair, whose fleet includes vintage Boeing and Airbus jetliners delivered as long ago as 1978…He said the license covered only components needed to ensure continued safe flight operations of older Boeing planes sold to Iran before the 1979 revolution, and did not allow any discussions about sales of new aircraft to Iran…A senior Iranian official told Reuters in November that Iran could require between 250 and 400 jets if and when sanctions are lifted completely.” (Reuters, “Iran aviation official in Vienna to discuss sanctions relief,” 4/8/14)

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“Boeing Co, the world's biggest airplane maker, and engine maker General Electric Co said on Friday they had received licenses from the U.S. Treasury Department to export certain spare parts for commercial aircraft to Iran under a temporary sanctions relief deal that began in January...A Boeing spokesman said his company received the license this week and would now contact officials in Iran to determine which parts were needed. He said the license covered only components needed to ensure continued safe flight operations of older Boeing planes sold to Iran before the 1979 revolution, and did not allow any discussions about sales of new aircraft to Iran. ‘It's very limited,’ said the spokesman. The sales would be the first acknowledged dealings between U.S. aerospace companies and Iran since the 1979 U.S. hostage crisis led to U.S. sanctions that were later broadened during the dispute over Iran's nuclear activities…Boeing said the license was granted under the temporary sanctions relief deal, and was aimed at helping improve the safety of Iran's aircraft. ‘We take the safety of flight issue very seriously,’ said the Boeing spokesman. He had no immediate details on how many parts would be sold to Iran, or their potential value. Analysts say the sales could help American companies position themselves for potential sales of new aircraft if a broader softening of sanctions is agreed. A senior Iranian official told Reuters in November that Iran could require between 250 and 400 jets if and when sanctions are lifted completely.” (Reuters, “Boeing, GE say get U.S. license to sell spare parts to Iran,” 4/5/14)

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“Multiple companies currently exploring new business ventures in Iran are also cashing in on highly lucrative contracts with the U.S. Defense Department, raising questions about whether their dealings with Iran could run afoul of U.S. law. At least 13 major international companies have said in recent weeks that they aim to reenter the Iranian marketplace over the next several months. The companies have received Pentagon contracts totaling well over $107 billion, according to a Washington Free Beacon analysis that tracked DoD contracts awarded since fiscal year 2009. Many of the companies, which include carmaker Renault and oil giants such as BP, have already sent high-level trade delegations to Tehran to meet with Iranian officials about striking new business deals…These companies include Boeing and General Electric—which have DoD contracts worth $87 and $12 billion respectively—as well as the Italian oil company Eni, Merck, Safran, Vitol, Bosch Rexroth, Sanofi Pastuer, and AVL.” (Washington Free Beacon, “Pentagon Contractors Exploring Business with Iran,” 2/25/14)

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"U.S. aerospace companies are seeking permission to sell airliner parts to Iran for the first time in three decades, in a key test of the temporary relief on sanctions given under talks to curtail Iran's nuclear activities. At least two leading manufacturers, Boeing and engine maker General Electric, have applied for export licenses in a six-month window agreed by Iran and six world powers in November, industry officials and other sources familiar with the matter said. If approved, the sales would be the first acknowledged dealings between U.S. aerospace companies and Iran since the 1979 U.S. hostage crisis led to sanctions that were later broadened during the dispute over Iran's nuclear activities…A source familiar with the matter said that Boeing, the world's biggest manufacturer of passenger jets, had also filed a request for permission to export parts to Iran. Boeing declined to comment, referring questions to the U.S. State Department, which in turn referred queries to the U.S. Treasury. A spokeswoman for the Treasury Department, which enforces international sanctions, declined to comment on specific license requests or applications.” (Reuters, “Exclusive: Testing detente, U.S. firms move to sell jet parts to Iran,” 2/21/14)

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"In January 2004, the nose-wheel of an Iran Air Boeing 747 passenger airplane collapsed on landing in Beijing. Iran Air and the Civil Aviation Administration of China agreed to use the French civil aviation agency to conduct the accident investigation. This license authorized Boeing to export an electronic data map that was needed by investigators to gain access to the information on the flight data recorder." (New York Times, "Licenses Granted to U.S. Companies Run the Gamut," 12/24/10)

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In a correspondance with the SEC in 2009, Boeing disclosed details of their contracts and activities in Iran.

“Boeing’s principal contacts with the Sanctioned Countries [Iran] consist of products and services solely related to the safe operation of Boeing commercial aircraft and to the launch of commercial communications satellites on behalf of a consortium in which Sudan has a minor participation.”

“ The contacts with the Sanctioned Countries [Iran] have been limited to flight safety and commercial satellite launch activities, the sale of exempted flight-related navigational materials and the provision of international trip planning services.”

“Contracts with Iran include:

• Boeing and National Transportation Safety Board authorized to share EAR99 information with Iranian civil aviation authorities regarding a Kyrgyz Airlines B737 incident in Kyrgyzstan.
• Boeing and National Transportation Safety Board authorized to share additional information with Iranian civil aviation authorities regarding a Kyrgyz Airlines B737 incident in Kyrgyzstan.
• Pending request to assess safety-critical parts and services that may be needed to ensure the safe operation of Boeing aircraft in Iran.” 

(CORRESP for BOEING CO , 10/14/2009)

Iranian oil, gas, petrochemical and power industries services company Petrokalooj cites Honeywell as a supplier on its website.

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According to its Annual report filed with the SEC for fiscal year 2018: "Following our completion of the wind-down activities authorized by OFAC after the United States’ withdrawal from the Joint Comprehensive Plan of Action, we have now ceased doing business in Iran."

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"Honeywell has booked around $115 million of revenues from Iran through its non-U. S. subsidiaries since the beginning of 2016, largely in the past year, according to regulatory filings. Unless Honeywell is able to fulfill $100 million in current contracts by early November, it could lose future potential revenue, given that the firm indicated in its SEC disclosures that those contracts aren’t yet completed. U.S.-based Honeywell spokeswoman Victoria Streitfeld said the company and its non-U. S. subsidiaries “operate within the parameters of all applicable U.S. and international regulations and will continue to do so.”" (5/31/2018).

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In the fiscal year ended December 31, 2017, the non-U.S. subsidiaries of our UOP business, part of Performance Materials and Technologies, engaged in the following activities related to Iran’s oil, gas and/or petrochemical sectors:
 

• Delivered services to Iranian counterparties pursuant to new and existing contracts, which resulted in revenue of approximately $54.2 million (expected total value of these contracts is approximately $81.2 million).
• Sold non-U.S. origin products to non-U.S. third-parties for end-use in Iran pursuant to new and existing contracts, which resulted in revenue of approximately $1.8 million (expected total value of these contracts is approximately $3.5 million).
• In the fiscal year ended December 31, 2017, the non-U.S. subsidiaries of our Process Solutions business, part of Performance Materials and Technologies, engaged in the following activities related to Iran’s oil, gas and/or petrochemical sectors:
• Sold non-U.S. origin products to non-U.S. third-parties for end-use in Iran pursuant to new contracts, which resulted in revenue of approximately $1.4 million (expected total value of these contracts is approximately $6.9 million).
• Sold approximately $0.4 million of non-U.S. origin products to distributors (including an Iranian distributor) for use in the gas distribution sector in Iran.  

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In 2017 the U.S. state of California identified Honeywell as a company under review for potentially having subsidiaries that have contracted to sell gas meters and absorbents for end use in the Iranian petrochemical industry.

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In 2017 the U.S. state of Michigan listed Honeywell on its Iran restricted companies list rendering Honeywell ineligible for investment and/or state contracting.

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According to its Annual Report filed with the SEC for fiscal year 2017: "In the fiscal year ended December 31, 2017, the non-U.S. subsidiaries of our UOP business, part of Performance Materials and Technologies, engaged in the following activities related to Iran’s oil, gas and/or petrochemical sectors:    

• Delivered services to Iranian counterparties pursuant to new and existing contracts, which resulted in revenue of approximately $54.2 million (expected total value of these contracts is approximately $81.2 million).
• Sold non-U.S. origin products to non-U.S. third-parties for end-use in Iran pursuant to new and existing contracts, which resulted in revenue of approximately $1.8 million (expected total value of these contracts is approximately $3.5 million).
• In the fiscal year ended December 31, 2017, the non-U.S. subsidiaries of our Process Solutions business, part of Performance Materials and Technologies, engaged in the following activities related to Iran’s oil, gas and/or petrochemical sectors:  
• Sold non-U.S. origin products to non-U.S. third-parties for end-use in Iran pursuant to new contracts, which resulted in revenue of approximately $1.4 million (expected total value of these contracts is approximately $6.9 million).
• Sold approximately $0.4 million of non-U.S. origin products to distributors (including an Iranian distributor) for use in the gas distribution sector in Iran.

We intend to continue doing business in Iran under General Licenses H and I or under a specific license issued by OFAC, and otherwise in compliance with all applicable laws. Such activities may require additional disclosure pursuant to Section 13(r) of the Act."

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"A new round of talks between Iran and UOP LLC Petroleum industry company of America has kicked off over investment and supply of new technologies. Association of Petrochemical Industry Corporations (APIC) announced that a fresh round of negotiations has begun between Iran’s petrochemical officials and three major American and European petrochemical companies with the main axes of talks being construction of new polymer units, knowledge and technology transfer as well as issuance of license for new petchem plans. On the sidelines of K Trade Fair 2016, the world's premier fair for the plastics and rubber industry in Germany, high ranking officials of Iran’s petrochemical industry held meetings with authorities of France’s Total and Air Liquide as well as America’s UOP, formerly known as Universal Oil Products." (Mehr News, "US petchem giant ready to return to Iran," 10/24/2016).

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According to its Annual Report filed with the SEC for fiscal year 2016: "In the three months ended December 31, 2016, the UOP business, part of Performance Materials and Technologies, engaged in the following activities related to Iran’s oil, gas and/or petrochemical sectors:

• Settled outstanding claims with Iranian counterparties under contracts originally entered into in compliance with then-applicable sanctions laws. Revenue in the three months ended December 31, 2016 from these settlements was approximately $28.6 million.
• Delivered services to Iranian counterparties pursuant to new and existing contracts, which resulted in revenue of approximately $1.3 million in the three months ended December 31, 2016, (expected total value of these contracts is approximately $4.2 million).
• Sold non-U.S. origin products to non-U.S. third-parties for end-use in Iran pursuant to new and existing contracts, which resulted in revenue of approximately $0.1 million in the three months ended December 31, 2016 (expected total value of these contracts is approximately $0.9 million).

In the three months ended December 31, 2016, the Process Solutions business, part of Performance Materials and Technologies, sold approximately $1.7 million of non-U.S. origin products to distributors (including an Iranian distributor) for use in the gas distribution sector in Iran.

In the three months ended December 31, 2016, the Industrial Safety business, part of Safety and Productivity Solutions, sold approximately $0.1 million of non-U.S. origin products to a non-U.S. distributor for use in the oil sector in Iran.

In addition to the activities described above, we previously disclosed in our periodic reports activities, transactions or dealings relating to Iran occurring in the first, second and third quarters of 2016. Our non-U.S. subsidiaries intend to continue doing business in Iran under General License H in compliance with all applicable laws, which sales may require additional disclosure pursuant to Section 13(r) of the Act."

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According to its Annual Report filed with the SEC for fiscal year 2015: "A non-U.S. wholly-owned subsidiary of Honeywell (the Non-U.S. Subsidiary) inadvertently made four ground shipments of low value, non-U.S. items from Turkey to Uzbekistan from December 2013 to 
March 2014 that transited through Iran en route to Uzbekistan on trucks operated by a third party transportation vendor (the Vendor) retained by the Non-U.S. Subsidiary. The Non-U.S. Subsidiary hired the Vendor to facilitate shipment and the Vendor further engaged a trucking company to provide surface transport. The Vendor proposed the transport route for the shipment. The shipment of the items via Iran occurred inadvertently as a result of non-U.S. person employees approving the transport route proposed by the Vendor. Honeywell disclosed these past transactions voluntarily to the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC).

The Non-U.S. Subsidiary did not pay, directly or indirectly, any duties or taxes to the Government of Iran as a result of these shipments because the shipments were made under TIR (Transports Internationaux Routiers) Carnets, a treaty system which allows for the transport of merchandise through contracting parties from the customs office of departure to the customs office of destination without payment of customs duties/taxes in transiting countries. Further, the Non-U.S. Subsidiary made all payments for shipping services to the Vendor on a flat-fee basis at a rate of $11,800 per shipment, and the Non- U.S. Subsidiary did not reimburse the Vendor for any fees or other expenses incurred in Iran."

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“U.S. company, UOP, has not delivered a special catalyst to Iran's Isfahan Refinery under pressures as a result of sanctions imposed on Iran's oil sector. Abbas Kazemi, Managing director of National Iranian Oil Refining and Distribution Company, said that Iranian producers have been participating to produce the catalyst inside the country, Iran's Mehr news agency reported on May 20. The catalyst will be used in producing high-quality gasoline by the refinery, he noted…According to media reports, currently, some 6,000 tons of the catalysts is being used in the country per year. Iran imports some $2 billion worth of catalysts, additives, and equipment from European and Asian countries annually.” (Trend, “U.S. company shuns selling catalyst to Iranian refinery,” 5/20/14)

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According to its Annual report filed with the SEC for fiscal year 2012: "The Company and its subsidiaries have a current policy not to conduct business with Iran." 

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"Shell and UOP LLC, a unit of U.S.-based Honeywell International Inc., were among the companies named in the report published today by the state-run news agency." (Bloomberg, "Shell, UOP Among Companies Put on Blacklist by Iran, Mehr Says," 1/6/2012)

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"A pressure group, United Against Nuclear Iran (UANI), is urging industrial conglomerate Honeywell International Inc to stop selling security technology to Iran, the group said on Thursday.

Honeywell security products can be used for surveillance of oil pipelines and nuclear reactors, UANI said in a letter faxed to Honeywell it provided exclusively to Reuters.

The sale of security technology, via a British subsidiary, violates company guidelines for business conduct, UANI said, adding it may sue or pressure the New York Stock Exchange to delist Honeywell if the company continues operations in Iran.

In response, Honeywell said it made a commitment not to undertake new projects in Iran, but is fulfilling its contractual obligations in accordance with U.S. and EU laws and regulations.

'Should the U.S. Congress pass a law that prohibits subsidiaries of U.S. companies from doing business in Iran, Honeywell will comply fully as it does with all other laws in the countries in which it operates,' the company said in a statement.

Honeywell shares were up 0.5 percent at $45.49 in afternoon trading on the New York Stock Exchange.

TARGETING IRAN'S OIL INDUSTRY

New York-based UANI has pressured industrial companies to stop serving Iran's energy sector. The group has said Ingersoll-Rand Plc, General Electric Co, Huntsman Corp and Caterpillar Inc have agreed to sever ties with Iran.

'In the face of overwhelming bipartisan support in the U.S. Congress to economically isolate Iran's oil and natural gas industry, Honeywell continues to make key contributions to the development of Iran's oil industry,' UANI President Mark Wallace said in a letter to Honeywell Chairman and CEO David Cote.

UANI said Honeywell regulatory filings have provided "zero disclosure" about dealings with Iran.

The group's website lists 200 companies targeted over their dealings with Iran, which it argues is developing a secret nuclear weapon and sponsors terrorism.

Its list includes names such as Royal-Dutch Shell Plc, Hewlett-Packard Co, Advanced Micro Devices Inc and Coca-Cola Co. (Reuters, "U.S. Group Targets Honeywell Over Iran," 4/8/10)

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"Honeywell acquired 100 percent ownership of Universal Oil Products (UOP), based in Des Plaines, Ill., in 2005. UOP has a British subsidiary that conducts business in Iran; it is part of a consortium with Axens, Technip, Sinopec Engineering Inc. and several Iranian firms that is expanding and upgrading the Arak Refinery in Iran. The project, budgeted to cost $3.7 billion, could nearly triple gasoline production, from 34,000 to 100,000 barrels per day, according to various news reports and FACTS Global Energy, an expert in the industry. Honeywell is a top federal contractor, and UOP recently won a $25 million grant to help develop renewable energy sources. In a statement, the company said that in early 2009 it committed to the State Department that it would not undertake any new projects in Iran, but that it is fulfilling its contractual obligations relating to the Arak refinery. 'Should the U.S. Congress pass a law that prohibits subsidiaries of U.S. companies from doing business in Iran, Honeywell will comply fully,' the statement said." From 2000 through March 2010, Honeywell has been the recipient of $12.9 billion in U.S. federal funds. (The New York Times, "Profiting from Iran, and the U.S.", 3/6/10)

According to its Annual Report filed with the SEC for fiscal year 2013: "Section 219 of the Iran Threat Reduction and Syria Human Rights Act of 2012 (TRA) added subsection (r) to Section 13 of the Exchange Act.  That subsection requires issuers to disclose whether affiliates engaged in specified activities or transactions relating to Iran. The reporting requirement extends to activities that were permissible under U.S. law at the time they occurred.  As previously reported, in 2007, Flowserve implemented a phased withdrawal from Iran, Syria and Sudan. During the phased withdrawal, Company policy permitted foreign subsidiaries to engage in certain limited business with those countries, including the provision of spare parts for previously supplied equipment so long as those shipments complied with U.S. and other applicable law. In 2010, Flowserve France S.A.S., a Flowserve affiliate, made one shipment of spare parts valued at approximately €25,843 to Kala Naft in Iran. The 2010 shipment complied with U.S. law at the time, as it did not involve U.S. persons and did not involve any U.S.-origin content. Pursuant to Company policy, the shipment was reviewed by internal compliance personnel in Europe at the time to ensure compliance with U.S. and other applicable law.

Effective December 31, 2011, our foreign subsidiaries were directed to complete their withdrawal from Iran, Syria, and Sudan. At that time, no payment had been received from Kala Naft for the 2010 shipment of spare parts.  In the course of a compliance review in the first quarter of 2013, the Company discovered that our foreign affiliate received a final payment of €10,000 on March 15, 2013 associated with the 2010 shipment. The Company requested specific authorization from the Office of Foreign Assets Controls  (“OFAC”) at the U.S. Department of the Treasury to process that payment, as it was received one week after the expiration of the OFAC general license described at 31 C.F.R. 560.555. Additionally, through a subsequent compliance review, the Company discovered that two earlier payments of approximately €5,000 and €8,845 were received on March 22, 2012 and October 3, 2012, respectively, in connection with the 2010 shipment. Receipt and processing of those earlier payments were permissible under U.S. and other applicable law at the time.  Net profit associated with the 2010 shipment was approximately €18,000.  Flowserve and all of the Company's affiliates have withdrawn from the Iranian market.  Flowserve does not intend or expect to continue any activity related to those countries other than foreign government-mandated inspections, which we plan to conclude as soon as possible."

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"Flowserve, which makes flow control equipment used in the oil and gas industry and has sold power and hand pumps to the Department of Defense, said in 2009 filings with the SEC that due to 'growing political uncertainties' its foreign subsidiaries had in 2006 begun a voluntary phased withdrawal from conducting new business in countries designated as state sponsors of terrorism, including Iran, Syria and Sudan. 'The aggregate amount of all business done by our foreign subsidiaries for customers in Iran, Syria and Sudan accounted for less than 1 percent of our consolidated global revenue in 2008,' the company said, adding that while it was voluntarily phasing out new business with those countries, "our foreign subsidiaries may independently continue to honor certain existing contracts, commitments and warranty obligations in compliance with U.S. and other applicable laws and regulations."

From 2000 through March 2010, Flowserve has been the recipient of $71.1 million in federal funds. (The New York Times, "Profiting from Iran, and the U.S.", 3/6/10)

Listed as an approved vendor by NIOEC, NPC, POGC, NIGCENG, NISOC, SADAF, NIGC and IOOC.

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According to its Annual Report filed with the SEC for fiscal year 2012: "Subsequently, in October 2012, the Company adopted a policy prohibiting all business with the government of Iran or any person subject to the jurisdiction of Iran. This recently adopted policy is consistent with the Iran Threat Reduction and Syria Human Rights Act of 2012 (“ITRSHRA”), which expanded sanctions against Iran effective in October 2012 and instituted disclosure requirements in annual and quarterly reports for public companies engaged in, or affiliated with an entity engaged in, specified activities under the ITRSHRA. This policy was effective immediately and applied to all contracts, including those in existence on the effective date of the policy.

During 2012, Guascor received payments from a customer in Iran pursuant to a contract for the sale of gas-powered generators. Guascor entered into this contract in January 2011, prior to it being acquired by the Company, and the shipments to the customer pursuant to this contract were not in violation of the U.S. sanctions on Iran or the Company’s policies in place at the time. Payments under the contract were received through a letter of credit issued in June 2011 by Bank Tejarat, an Iranian bank (the “Bank”). Guascor has not engaged in any direct dealings with the Bank, which was selected solely by the Iranian customer. However, Guascor was designated by the customer as the beneficiary under the letter of credit. On January 23, 2012, after the letter of credit was issued, the Bank was designated by the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) as subject to sanctions pursuant to Executive Order 13382. During 2012, Guascor received a total of three payments from the customer via the Bank-issued letter of credit totaling €1.2 (approximately $1.6), two of which, totaling €0.9 ($1.2) were received in November 2012 after the expanded sanctions against Iran were in effect. There were no net profits associated with the receipt of these payments under the letter of credit. Guascor is in the process of winding down all transactions with Iran in accordance with a general license from OFAC and, with the exception of one final payment of €0.1 (approximately $0.1) that is scheduled to be received on or before March 4, 2013, under the Bank-issued letter of credit, no additional dealings with or involving the Bank are contemplated. The Company has fully disclosed the receipt of these payments to OFAC, requesting a finding that no violation has occurred, and has requested from OFAC a license with respect to the final payment scheduled to be received in March 2013. Although there is a risk of sanctions associated with the November 2012 payments, under the particular facts and circumstances described above, the Company believes that sanctions, if any, would not have a material adverse effect on our financial condition.

The Company’s foreign subsidiaries’ aggregate 2012 sales into countries that are subject to these policies was less than 1% of the Company’s total sales in 2012 and only included sales to Iran before the new expanded sanctions against Iran went into effect in October 2012. We did not make any sales to Iran after these new sanctions were effective.

Although such sales are not material in magnitude to our overall business, certain investors may view even this level of business in such countries adversely. This could have an adverse impact on the market price of our common stock and our Senior Subordinated Notes." 

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Several days after coverage in the New York Times (below), Dresser-Rand issued a press release explaining that it had barred its subsidiaries from entering into new business contracts with Iran. 

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"Dresser-Rand, a Texas-based oil and gas equipment supplier, said in multiple filings with the SEC, including as recently as last month, that 'from time to time, certain of our foreign subsidiaries operate in countries that are or have previously been subject to sanctions and embargoes imposed by the U.S. government and the United Nations, including in Iran, Sudan and Syria.'"

As of March 2010, Dresser-Rand is classified as being "Active" in Iran. From 2000 through March 2010, Dresser-Rand has been the recipient of $215.1 million in federal funds. (The New York Times, "Profiting from Iran, and the U.S.", 3/6/10)

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

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Ingersoll-rand is listed as a participating company at the 14^th International Exhibition of Transportation & Urban Services & Related Industries which takes place October 27-30^th, 2016 in Tehran Iran. (Participating International Companies)  

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"New Jersey-based Ingersoll Rand, which has won lucrative contracts from the U.S. military, has been selling industrial air condition and air compression systems to Iran through foreign subsidiaries since at least 2000, according to the company. The National Iranian Drilling Company states on its Web site that it uses Ingersoll Rand compressors in its work. Spokesman Paul Dickard said that compressed air systems have a wide variety of applications,  and "it wouldn't be outside the range of possibility" that Ingersoll Rand systems would be used in the oil and gas sectors or even a nuclear plant, where such equipment is commonly found. Mr. Dickard said the company is evaluating what he called its "minor" business in Iran in light of the current political climate, adding: "We will want to think very seriously about whether we want to continue participating in Iran if it puts at risk other business that might be more lucrative for us."  From 2000-2009, the company was the recipient of $422.1 million US federal funds.  They have withdrawn their investments in Iran.  (The New York Times, "Profiting from Iran, and the US," 3/6/2010)

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“Havacaran Industrial Technologies is the distributor of Ingersoll Rand Air Compressors in Iran” (Havacaran website). On its website, Havacaran has posted a certificate from Ingersoll Rand, which formally certifies that it is a distributor "for performing sales & after sales service for Centrifugal (CENTAC), Oil Free Dry Rotary Screw (SIERRA), Oil Injected Rotary Screw (SSR) and Reciprocating (T-30, ESH, PHE) Air Compressors and down stream accessories like air dry & filters" (Havacaran Website, "Certificate"). Ingersoll-Rand, in consortium with Havacaran, participated in Iran’s 12^th international oil show in 2007 (Iran's 12th Oil Show, "Exhibitors List").

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The National Iranian Drilling Company (NIDC), a subsidiary of the state-owned National Iranian Oil Company (NIOC), states on its website that the company uses Ingersoll Rand compression systems (NIDC website).

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SATCO (Sameh Afzar Tajak Co.) is a private commercial company in Iran "working in the operation, maintenance, procurement and planning of power stations, automotive industries, steel industries and oil fields" (SATCO website, "About Us"). Ingersoll Rand is one of seven "Principals" affiliated with SATCO, selling assembly and industrial tools as well as material handling products (SATCO website, "Principals"). SATCO has sold products to several oil, gas and petrochemical companies, such as the state-owned National Iranian Drilling Company, as well as numerous light and heavy industries, power stations, the steel industry and automotive industry (SATCO website, "Sales").

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Ingersoll Rand, in consortium with SATCO, participated in Iran’s 12^th international oil show in 2007 (Iran's 12th Oil Show, "Exhibitor List"). SATCO was also an exhibitor at Iran's13th annual oil show in 2008 (Iran's 13th Oil Show, "Exhibitors").

Ingersoll Rand's Distributor Certificate to Havacaran (Havacaran Website, "Certificate")

Aker Solutions is listed on the March 1, 2020 and March 1, 2021 Report to the New Jersey Legislature Iran Divestment as a prohibited company. 

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"Aker Solutions reportedly has a subsidiary with business agreements in Iran, which may include the transfer of petroleum research technology to Iran. Aker Solutions had previously been removed from the CalSTRS Iran-related securities list. However, in 2016, CalSTRS reinitiated the review process due to potentially new involvement. In 2017, CalSTRS designated Aker Solutions as “Being Monitored” and maintained that status in 2019. In 2020, CalSTRS removed Aker Solutions after further review of the company’s internal controls to prevent sanction violations."

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In December 2019 CalPERs removed Aker Solutions from its Iran Divestment List after receiving confirmation that the company has no targeted business activities in Iran, and reviewing the companies' internal controls to prevent sanctions violations.

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Aker ASA is listed in the March 1, 2019, Report to the New Jersey Legislature Iran Divestment Act. 

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Aker Solutions had previously been removed from the CalSTRS Iran-related securities list. However, in 2016, CalSTRS reinitiated the review process for reportedly having a subsidiary with business agreements in Iran which may include the transfer of petroleum research technology to Iran. In 2017, CalSTRS designated Aker Solutions as “Being Monitored” and maintained that designation in 2018.

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In 2017, the U.S. states of California and Florida, listed Aker Solutions on their state lists of Companies Doing Business with the Iranian Petroleum/Natural Gas, Nuclear and Military Sectors, rendering Aker Solutions ineligible for investment and/or state contracting.

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Norway’s Aker Solutions signed a MoU to modernize the Iranian oil industry in 2016.

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"Aker has exported products produced in Asia to the oil and gas sector in Iran, and a German subsidiary - Wirth - has exported drilling equipment to Iran. A spokesman, Jannick Lindbaek, said the company has no current business in Iran due to commercial and contractual reasons, but stressed that the company doesn't feel precluded from selling products again to Iran's oil and gas sector: "We don't have a bilateral boycott of Iran. We're following all Norwegian foreign policy," he said. The company has received $6.3 million in revenue and benefits from the US government.  Their activities in Iran are currently active.  (The New York Times, "Profiting from Iran, and the US", 3/6/2010)

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“Two European concerns—Wirth, from Germany, and Seli, from Italy—sold tunnel-boring equipment to Iran for its Ghomroud water project. Wirth’s contract was concluded after Germany’s export-control agency, BAFA, determined that the machines involved in this project, being intended only for civilian use, were not subject to embargo.

Overseeing the tunnel project, however, was Sahel Consulting Engineers, a company owned by the IRGC. Nor is this connection a secret. The website of Wirth’s subsidiary in Iran features images of the Ghomroud construction site. The sign welcoming visitors to the project bears the logo of the IRGC, and the same logo is visible above the tunnel entrance…

Once the digging is finished, though, the equipment belongs to the subsidiary businesses of the IRGC, which can do with them what they wish. Intelligence photographs have regularly indicated that much of Iran’s clandestine nuclear program is being built deep underground, in bunkers accessible by means of tunnels. The machinery and technology for constructing such tunnels can only have been provided by Wirth and Seli.” ("The Iranian Shell Game,"  July-August 2008)

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“Wirth and Seli – German and Italian companies producing sophisticated tunnel-boring machinery – have supplied their machines and technical assistance to IRGC companies, for instance. Their business was not subject to any restrictions or embargoes, yet intelligence reports have repeatedly suggested that much of Iran’s clandestine nuclear program is being built deep underground, in bunkers that are accessible through tunnels – tunnels which only such technology could build.” (Transatlantic Institute,  "Iran's Deceptive Ways,"  May 2008) 

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“German producer of tunnel boring machinery – proudly boasts on its website that ‘… a new water supply system is created in the Iranian mountains of Isfahan, Wirth machines are used.’ Indeed they are. The problem is that one of Wirth’s project clients in Iran is Sahel Consulting Engineers – a company owned by the Iranian Revolutionary Guard Corps (IRGC). Wirth has so far declined to comment on the matter.” (BESA Center for Strategic Studies, “ Iran's Deceptive Commercial Practices ,” 4/15/08)

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“The project management contract for South Pars phases 9 and 10 offshore Iran, was awarded Aker Kvaerner from Pars Oil and Gas Company in April. This contract, worth approximately USD 25 million, represents a breakthrough in Iran, which holds the world’s second largest oil and gas reserves.” (Aker Kvaerner O&G Group AS,  Board of Directors Memo , January-June 2005)

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“Aker Kvaerner will assist the national operator Pars Oil and Gas Company (POGC) in managing the USD 1.8 billion total contract (EPC) for the development project comprising phases 9 and 10 of the South Pars gas field located offshore Iran in the Persian Gulf. Aker Kvaerner has partnered up with the Teheran based, private engineering company Hirbodan for the contract

Aker Kvaerner has a history as a product and technology supplier in Iran, providing processing equipment, drilling equipment and wellheads. The new project management contract represents the first field development engagement for Aker Kvaerner in Iran. ‘This is a good project for Aker Kvaerner. Our track record on executing large projects and the teaming up with a competitive Iranian partner were important winning factors for the contract’, says Aker Kvaerner's Executive Vice President Mr. Simen Lieungh.” (EuroInvestor.com, “ Breakthrough Contract in Iran: South Pars phases 9 & 10 ,” 4/27/05)

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“Be it…a water-supply system in Iran – as an employee of Aker Wirth, you will be there as progressive technology is created and put to use in the field. And the fields of activity open to you at Aker Wirth are as diverse as our technologies and work sites.” ( Aker-Wirth website )

German insurer Allianz (ALVG.DE) is preparing to wind down Iran-related business due to possible U.S. sanctions, a spokesman said on Tuesday. “We are analyzing our portfolio to identify Iran-related business,” he said in an e-mailed statement. “This analysis is ongoing and we are developing wind-down plans for relevant business to ensure appropriate termination within the defined periods.” (May 15, 2018).

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Allianz participated in the Iran Post Sanctions Business forum (the “Forum”) in Berlin on January 24-25, 2017. 

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In January 2016, however, Reuters reported that Allianz “would evaluate potential opportunities in the country [Iran].”  (Reuters, “Global insurers plot cautious course to Iran,” 1/24/2016). 

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"Allianz SE (ALV.XE), Europe's largest primary insurer by gross premiums, said Friday it is suspending business in Iran amid calls for tighter sanctions against the country after the International Atomic Energy Agency censured Tehran for its nuclear enrichment program.

'Allianz has decided not to renew insurance treaty business in Iran because of political developments in the region. This business amounts to negligible premiums,' Allianz said in a statement, without being more specific." (Dow Jones Newswires, "Allianz Suspends Iran Business, Hannover Re Honors Sanctions," 2/19/10)

Rickmers-Linie lists a contact in Tehran. (Company Website)

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"The Hamburg-based shipping line, Rickmers-Line, has signed a $120-million contract with the Iranian company [Sadra Group] for building four multi-purpose ships.  The project to construct these ships was launched in March and necessary technical equipment has been purchased.  Each of these ships will have the capacity to transport 24,000 tons of cargo. As per the agreement, the four ships will have to be delivered between July 2007-2008.  Several other shipbuilding projects are underway in Iran.  The International Maritime Organization has 140 member-states with Iran among the top 20." (Zaywa, "Sadra Signs $2.4b Shipbuilding Contract," 6/18/06)