Withdrawn

"MSC Mediterranean Shipping Company S.A., like other major container shipping lines, has been taking bookings for Iran-related trade after the 2015 JCPOA (Iran nuclear deal) effectively lifted certain sanctions on Iran in exchange for limits to its nuclear program. In consideration of the impending U.S. withdrawal from the JCPOA, and corresponding re-enlargement of its sanctions program, we regret to inform you that MSC is ceasing to provide access to services to and from Iran. The U.S. government has outlined a wind-down period in the coming months and we will do our utmost to collaborate with you to conclude this period with the minimum disruption to your business and to avoid any unnecessary inconvenience. While MSC is not accepting bookings for shipments originating from Iran, or destined to Iran, we will continue to carry certain legally acceptable cargoes during the wind-down period, notably for importation of foodstuffs." (5/16/2018)

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“MSC is reviewing its services, operations and business relationships to understand if any are impacted and will comply with the timetable set out by the U.S. government,” the private Swiss-headquartered group said in a statement on Friday…A shipping source said MSC had already stopped taking bookings for certain cargoes that would be impacted by the sanctions programme.” (5/12/2018)

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"As a result of the nuclear deal, Iran’s marine activities are now completely back to normal,” the official was quoted as saying in January. Mediterranean Shipping Company, the world’s second-largest shipping line in terms of container vessel capacity, and Evergreen Line are among top shipping lines that have resumed cooperation with Iranian ports." (October 19, 2017)

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"So despite concerns over regulation and reputation, that opportunity explains the caravan of container carriers that started resuming service to Iran back in January. Mediterranean Shipping Co. has returned, as has CMA GGM [likely CMA CGM misspelled]. Panalpina began planning for a potential lifting of sanctions two years before it happened, and now offers regular air, ocean and road services to Iran." (Global Trade, "Transportation/Logistics:Iran is Back Open for Business," 11/1/2016).

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“Fourteen international shipping lines have returned to Iranian ports following the implementation of the Joint Comprehensive Plan of Action (the formal name of the nuclear deal signed by Iran with the West), the deputy head of Ports and Marine Organization of Iran said. Mediterranean Shipping Company, the world’s second-largest shipping line in terms of container vessel capacity, and Evergreen Line are among the top shipping lines engaged in economic interactions with Iranian ports,” he said (Financial Tribune, "Int'l Shipping Lines Back to Iran," 9/27/2016).

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Operates as a liner & feeder in Iranian ports.  (Ports and Maritime Organization: Shipping Lines which operating in Iranian Ports)

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Uses Tidewater Middle East Co.’s private terminals in the Shahid Rajaee Port Complex. (Tidewater: Reflection of Tomorrow)

On June 23, 2011, the U.S. Treasury Department sanctioned Tidewater Middle East Co. (“Tidewater”), Iran’s major port operator, because the IRGC owns it and uses it for illicit activities including weapons shipments. (U.S. Department of the Treasury Press Center, “Treasury Sanctions Major Iranian Commercial Entities,” 6/23/11)  The EU followed with its own sanctions against Tidewater on January 23, 2012. (Official Journal or the European Union: Council Decision 2012/35/CFSP)

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Listed by the Iranian Ports and Maritime Organization as doing business with the Iranian Forogh Darya.  (Ports & Maritime Organization: Companies Affairs Department: Liners)

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MSC lists two agency offices in Iran in the cities of Tehran and Bandar Abbas. (Company Website)

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In the Persian 1384 (2005/2006), the Government of the Islamic Republic of Iran awarded MSC's Agents in the Islamic Republic of Iran, Sea Glow Shipping Agency LLC, the prestigious "Best Shipping Agency Company." In a statement, MSC said, "It is a matter of pride that the Sea Glow Shipping Agency LLC team in Iran have been able to get this prestigious award for the first full Persian year since we started commercial operations as agents for MSC in May 2004." ("Prestigious Award for MSC Agent in Iran," 8/22/06)

 

"CMA CGM, the world’s fourth biggest shipping company, said it has sufficient security measures in place to continue operating in the Persian Gulf region even as concerns mount over a possible dispute between Iran and major world powers. The Persian Gulf is a key route for oil tankers, while container shipping companies often use the Suez canal route. CMA CGM stopped services in Iran last year in light of U.S. sanctions but company chairman and CEO Rodolphe Saade said CMA CGM was still sailing through the Persian Gulf. “We are continuing to go there,” Saade told reporters at a business conference in Aix-en-Provence." (Reuters, "CMA CGM says it has sufficient security to operate in Persian Gulf," 7/7/2019).

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"French shipping group CMA CGM has decided to pull out of Iran following the Trump administration’s decision to renew sanctions on companies operating in the country, its chief executive said on Saturday." (July 7, 2018)

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Lists an office in Tehran, Iran.

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In Jan 2018 – CMA CGM restarted its third direct service between Iran and Asia.

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"CMA CGM Group has appointed CMA CGM Pars as its new agency in Iran as from May 1st, 2017." (CMA CGM, "New CMA CGM Agency In Iran," 5/4/17).

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"So despite concerns over regulation and reputation, that opportunity explains the caravan of container carriers that started resuming service to Iran back in January. Mediterranean Shipping Co. has returned, as has CMA GGM [likely CMA CGM misspelled]. Panalpina began planning for a potential lifting of sanctions two years before it happened, and now offers regular air, ocean and road services to Iran." (Global Trade, "Transportation/Logistics:Iran is Back Open for Business," 11/1/2016).

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"Fourteen international shipping lines have returned to Iranian ports following the implementation of the Joint Comprehensive Plan of Action (the formal name of the nuclear deal signed by Iran with the West), the deputy head of Ports and Marine Organization of Iran said. France’s CMA CGM, the world’s third largest container shipping group, called on Shahid Rajaei, Iran’s biggest container port at the mouth of the Strait of Hormuz, early August." (Financial Tribune, "Int'l Shipping Lines Back to Iran," 9/27/2016).

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"An Iranian official says the French CMA CGM shipping company has chosen southern Iranian Shahid Rajaei port as the port of call for its container ships. Ebrahim Idani, director general of Hormozgan Ports and Maritime Department, told reporters on Wednesday that the development has come after Iran and the P5+1 group of countries clinched an agreement over Tehran’s civilian nuclear program in Vienna last week... The Iranian official said France’s CMA CGM is the world’s third biggest shipping company which transports container goods and its first container ship will berth at Shahid Rajaei port in early August. 'The container ship, which will call at Shahid Rajaei port is the Andromeda. It is 363 meters (m) long with a draft of 15.5 m, which can carry 11,500 TEU of containers. It will unload its containers at the second terminal of Shahid Rajaei port,' he added. Idani stated that the Andromeda has started its journey from the Far East and is bound for the Persian Gulf. 'It has chosen 10 big ports for berthing along its way and since Shahid Rajaei port enjoys international standards for accommodating big vessels, the French ship has chosen it as one of its ports of call,' he added. The official noted that investments made in the development of Shahid Rajaei port in the past years have made it a suitable destination for giant container-carrying vessels. Shahid Rajaei port is located 23 kilometers west of Bandar Abbas, the capital city of southern Iranian province of Hormozgan. The port is equipped with 18 gantry cranes and 41 docks, which make it the biggest and most modern container port in Iran." (PressTV, "French container ship to call at southern Iranian port," 7/22/15)

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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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"CMA CGM, the world's third-largest container shipping group, stopped exports from Iran in July and since September has been scanning all containers bound for Iran from the UAE." (Reuters, "Sanctions blowback crippling Iran's shipping trade," 12/1/2011)

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"CMA CGM, the world's third-largest container shipping group, stopped export shipments from Iran in July and has been scanning all containers bound for the Islamic Republic since September, the French company said onWednesday... 'In July 2011 the CMA CGM group decided to stop all exports out of Iran,' the company said in an emailed statement to Reuters on Wednesday... CMA CGM had said in a note to customers in September it was introducing a scanning process from Khor Fakkan for all Iranian inbound container cargo, 'in order to maintain a safe service in regards of the international sanctions'... The shipping restrictions introduced by CMA CGM come after its announcement in June of extra security checks covering its activities in Iran, including the creation of an 'Iran Compliance Desk'. CMA CGM was criticised by certain members of the U.S. Congress for lax security in Iran after an arms seizure in March by Israel aboard one of the firm's ships, which the Israelis said concerned Iranian-supplied weapons bound for Gaza. The French group said it was the victim of a false freight declaration and was not accused of wrongdoing by Israel." (Reuters, "UPDATE 1-French shipper CMA CGM stops exporting from Iran," 11/30/2011)

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CMA CGM’s website lists two offices in Iran – an agency in Bandar Abbas and a head office in Tehran. Both are listed under the Jahan Darya Shipping Agency (CMA CGM Website).

Line Services

CMA CGM’s Cimex 1 Line travels between major East Asian ports [China, South Korea] and the Persian Gulf, stopping in Bandar Abbas and advertising “direct service to Iran.” The route is operated weekly by six vessels over 42 days (Cimex 1 Line Info).

CMA CGM’s Gulf Emirates Qatar Feeder Line is a triangular route between Qatar, the United Arab Emirates, and Iran’s Bushehr Container Terminal. The route is operated weekly by two vessels over 14 days (Gulf Emirates Qatar Feeder Line Info).

CMA CGM’s Swahili Express Line is a triangular route between East African ports, India, and the Persian Gulf, including Bandar Abbas. The route is operated every nine days by five vessels (Swahili Express Line Info).

Uses Tidewater Middle East Co.’s private terminals in the Shahid Rajaee Port Complex. (Tidewater: Reflection of Tomorrow)

On June 23, 2011, the U.S. Treasury Department sanctioned Tidewater Middle East Co. (“Tidewater”), Iran’s major port operator, in response to the fact that Tidewater is owned by the IRGC and used by the IRGC for illicit activities including weapons shipments. (U.S. Department of the Treasury Press Center,  “Treasury Sanctions Major Iranian Commercial Entities,” 6/23/11)  Tidewater is also sanctioned by the EU for being owned or controlled by the IRGC. (Official Journal or the European Union: Council Regulation (EU) No 267/2010)

Subsidiaries

CMA CGM’s wholly-owned subsidiary Delmas, which provides “intermodal services to and from Africa,” lists that it operates out of six Iranian ports: Asaluyeh, Bandar Abbas, Bandar Khomeini, Bandar Shahid Rejaie Sez, Bushehr Container Terminal, and Khorramshahr.

CMA CGM’s wholly-owned subsidiary ANL (Australia National Line), a cargo shipping company which ships “to/from and around Australia/New Zealand to anywhere in the world,” operates under ANL Singapore Pte Ltd in Iran. ANL East West Service covers Asia, the Middle East, Indian Subcontinent and Europe. Its ISC 1 line uses the port of Bandar Abbas. 

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CMA CGM conducts extensive business with the U.S. CMA CGM America LLC, the company’s U.S. branch, is headquartered in Norfolk, VA. Its website advertises that CGM CMA America provides 21 North American services, has posted sustained double-digit growth, and it is among the top ten container shipping companies in the U.S. (CMA CGM America LLC).

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CMA CGM has received over $18 million in US government contracts in the past decade, 97% of which came from the U.S. Navy (USAspending.gov).

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In January 2010, CMA CGM started port operations in Iran’s Bushehr port. CMA CGM chose Bushehr “due to its reasonable infrastructure established in the past few years ” and “announced its readiness to work with Bushehr port after months of studying and gaining assurance about the Iranian ports capability in exporting, importing and transiting containers.” CMA CGM announced at the time that it would “increase its activities in the [Bushehr] port 10 times more than present (Tehran Times, "Giant shipping line starts operation in Bushehr", 1/9/10).”

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Nigeria Incident – MV CMA CGM Everest
Iranian arms shipment to Africa

Violation: UN Security Council Resolution 1929 (Iran)

October 2010

• Nigerian authorities seized 13 shipping containers carrying illegal Iranian weaponry at Lagos’ Apapa Port. The containers included 107 mm artillery rockets (Katyushas), explosives and rifle ammunition. The arms were to be shipped next to Gambia, with the final destination of the cargo possibly the Gaza Strip.
• The MV CMA CGM Everest originally picked up the containers from the Iranian port of Bandar Abbas. CMA CGM says it was victim of a false cargo declaration, claiming the weapons were shipped in packages labeled as “glass wool and pallets of stone” and that the Iranian shipper “does not appear on any forbidden persons listing” (AP, “Nigeria: Shipper confirms weapons came from Iran,” 10/30/10).
• In November, Nigeria reported the seizure of the illegal arms shipment to the UN Security Council, accusing Iran of violating UN Resolution 1929. The resolution bans Iran from "supplying, selling or transferring directly or indirectly from its territory or by its nationals… any arms or related material.” Two Nigeria-based members of the Qods Force, an elite unit of the IRGC, were implicated in the arms shipment. (Reuters, “Nigeria Reports Iran Arms Seizure to UN,” 11/16/10)

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UAE Incident – ANL-Australia

North Korean arms shipment to Iran (potentially including BM-25 missile components)
Violation: UN Security Council Resolution 1874 (North Korea)

July 2009

• The UAE reportedly “seized a ship secretly carrying embargoed North Korean arms to Iran… The UAE reported the seizure to the UN sanctions committee responsible for vetting the implementation of measures, including an arms embargo, imposed against North Korea under Security Council resolution 1874 [banning all North Korean arms exports].”
• “The UAE reported the ship was carrying 10 containers of weapons and related items, including rocket-propelled grenades and ammunition [as well as detonators]. He [the UN diplomat] said the consignment had been ordered by Iran’s TSS, a company said to be linked to Iran’s Revolutionary Guard Corps and previously subject to international bans on importing weapons-related items” (Financial Times, “‘N Korean arms for Iran’ seized by UAE,” 8/28/09).
• The weapons were carried on the Australian vessel, the ANL-Australia, which was flying under a Bahamian flag. ANL is a wholly-owned CMA-CGM subsidiary. The exporting company was an Italian shipper, Otim, which exported the items from its Shanghai office (loaded in Dalian, China). The cargo manifest reportedly said the shipment contained oil-boring machines.
• The UN Security Council sanctions committee reportedly conducted its own investigation into the violation, as well as the Australian Department of Foreign Affairs and Trade. (The Wall Street Journal, “Cargo of North Korea Matériel Is Seized en Route to Iran,” 8/31/09)
• In December 2009, the nature of the cargo was described for the first time, which included: “2,030 detonators for 122mm [short-range] rockets, as well as electric circuitry and a large quantity of solid-fuel propellant” (The Washington Post, “Arms smuggling heightens Iran fears,” 12/3/09)
• In December 2009, the Japanese news agency Kyodo reported Iran had postponed the test launch of a new intermediate-range ballistic missile because they had not received the delivery of key electronic components allegedly contained in the intercepted North Korean shipment. According to a diplomatic source, “The shipment of the electronic components was supposed to be part of the new agreement signed in late 2008 between Iran and North Korea for the continued supply of the new missile's technology.” The components are said to be for the BM-25 (or Musudan) missile, which has a target range of 2,500 to 3,500 kilometers, thus posing a threat to most of Europe. Pyongyang reportedly exported components to assemble 19 such missiles to Iran in 2005. The BM-25 would be Iran’s longest-range missile. (Kyodo News International, “Iran delays missile test due to row with N. Korea over parts delivery,” 12/6/09)
• In November 2010, the BM-25 missile transfer was revisited when new information was revealed in the WikiLeaks-released U.S. diplomatic cables. According to the cable, secret American intelligence assessments have concluded that Iran has obtained a cache of advanced missiles, based on a Russian design. The missiles would for the first time give Iran the capacity to strike at capitals in Western Europe or Moscow, and they could potentially carry a nuclear warhead. (The New York Times, “Iran Fortifies Its Arsenal With the Aid of North Korea,” 11/29/10)

Lovat, a manufacturer of tunnel boring machines (TBMs) is a wholly-owned subsidiary of Caterpillar acquired in April 2008. (AP, “Caterpillar acquires tunnel boring company,” 4/2/08)

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Iran has been constructed tunnels to obscure and shield its nuclear program. (The New York Times, “Iran Shielding Its Nuclear Efforts in Maze of Tunnels,” 1/6/10)

Lovat’s business in Iran:

•  On its full worldwide contacts list, Lovat lists Mr. Amir Kheradmand of the Tehran-based “Tunnel Boresh Machine” as its main Iran contact. (Company Website) 
• Lovat’s website lists a completed drainage project in Tehran in its “Project section.” The project used a Lovat tunnel-boring machine. (Company Website) 
• The December 2009 article World Tunnelling magazine lists two recently completed Lovat tunneling projects for surface water collection in Khayyam and Bahmanyar. Lovat used the same tunnel-boring machine for both projects. (World Tunnelling, “Iranian TBMs continue steady march,” 12/23/09)

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"Tunnel builder Herrenknecht waived Iran business. We are relinquishing a deal with a contract of around 20 million euros…if the company had made the deal, we would have been exposed to the risk of being blistered.” (8/9/2018)

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Herrenknecht AG is listed as a participant at the 2017 Iran Oil Show that took place in Tehran, Iran.

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On its company website, Herrenknecht lists that it has three offices in Tehran, Iran. (Company Website)

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March 2016, HerrenkenchtHerrenknecht “talked openly about operations and his hope to maintain them despite growing political uncertainty.......  ‘You’ll laugh, but two of our machines have been operating in Tehran for the last 12 years to build a metro system.  The contract dates back to before the sanctions,’ said Martin Herrenkencht.”Herrenknecht.”  (Handelsblatt, “Drilling Down to the Essence,” 3/14/2016). 

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Herrenknecht Chairman Martin Herrenknecht “recently visited Tehran, meeting officials in the energy ministry and sewage department.  Before Western sanctions hit, Herrenknecht, which carries its 72-year-old founder's name, did 10 million to 15 million euros ($11 million-$17 million) of business a year in Iran.).  He said, 'I know what projects are coming and I'mI’m ready to sign when the sanctions are lifted.'"   (Reuters, “German Exporters Eye Lucrative Deals in Post-Sanctions Iran,” 7/5/15).  

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"As the Iran embargo looks likely to be lifted after negotiations between Western countries and Teheran on Iran's nuclear program seem set to achieve a settlement, German firms, in particular, are eager to breathe new life into their traditional business ties with the country. Currently, German exports to Iran amount to about 2.4 billion euros ($2.6 billion) - less than half what they were ten years ago, when sanctions were imposed. According to the German Chambers of Industry and Commerce (DIHK), that figure could easily multiply to a sum in the double-digit billions once sanctions will be lifted. At a conference in Frankfurt organized by the German Near and Middle East Association (NUMOV), about 250 German business leaders explored opportunities likely to open up in Iran in the near future. The one-day event on Tuesday, called 'Doing Business in Iran,' primarily dealt with the Iranian oil and gas industry, but also cast a light on the renewable energy and finance sectors... Martin Herrenknecht, owner of a German tunnel-boring machine manufacturer, expects tough competition from Asian rivals once his company re-enters the Iranian market after sanctions are lifted... In the years before sanctions were imposed on Iran, Herrenknecht's firm sold equipment worth between 10 million euros ($11.5 million) and 15 million euros annually to Iran. He hopes to re-launch his Iranian business fairly quickly as he wants to benefit from Teheran's plans to build a new subway line in the country's capital, as well as a new high-speed train ---connection and improvements to the national water and sewage systems." (DW, "German business looks to post-sanctions Iran boom," 5/19/15)

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"Germany’s multi-billion euro bilateral trade relationship with Iran continues unabated, even as evidence mounts that the Islamic Republic is determined to build a nuclear weapons capability. The Jerusalem Post has obtained an uncensored list from late 2011, showing hundreds of German and Iranian enterprises in a flourishing trade relationship . . . One company named is Baden-Württemberg-based engineering giant Herrenknecht AG, which appears to be delivering heavy tunneling equipment to Iran – some of which is promoted as having the capability of 'drilling down to depths of 6,000 meters.' In response to Post inquiries, an unidentified representative of the company wrote via email on Friday that it has 'comprehensively ensured that Herrenknecht excavation engineering and services solely reach projects which clearly pursue civil applications [metro tunnel construction, sewage pipes and water supply lines]' . . . Though EU sanctions have been in place since 2010 to bar oil and gas technology trade with the Islamic Republic, Herrenknecht participated in Iran’s most important oil trade show in 2012. To participate in the Iran oil show, companies are required to send their registration fees to Bank Mellat – which the EU and US had sanctioned due to its involvement in nuclear proliferation." (Jerusalem Post, "German firms still ship dual-use goods to Iran Jerusalem," 7/9/12)

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Over the past decade, Iran has quietly hidden an increasingly large part of its atomic complex in networks of tunnels and bunkers across the country...

Such tunneling conferences, held regularly in Tehran, draw global manufacturers of tunnel-boring machines — giant devices as big as locomotives that dig quickly through rocky strata...

Many of the companies keep offices in Tehran. Herrenknecht, a German firm considered the market leader, lists three. Engineers say Iran has hundreds of miles of civilian tunneling projects under way, including subways in Tehran, Isfahan, and Shiraz, highway tunnels across the country and water tunnels to irrigate the dry interior. (The New York Times, "Iran Shielding Its Nuclear Efforts in a Maze of Tunnels," 1/6/09)

AMD's website states that the company is "committed to fully comply with the United States and all applicable export and import laws and regulations governing the export, re-export, or import of AMD products, software, services and technology. AMD's Global Trade Compliance organization is responsible for providing guidance and support of AMD's global export and import compliance obligations... AMD products, services, and technology are prohibited for U.S. export or re-export to Cuba, Iran, North Korea, Sudan, and Syria or to any country or end-use subject to U.S. trade sanctions."

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AMD says it hasn't authorised any product shipments to Iran, directly or indirectly, but somehow the Iranian High Performance Research Center (IHPCRC), which is located at Tehran's Amirkabir University of Technology, says it has assembled a Linux-based system with 216 Opteron processing cores (an AMD product).  There is a connection through Thacker, also known as Sky Electronics, an authorised distributor of AMD products based in the United Arab Emirates. (The Enquirer, "AMD is inside Iran's missiles and supercomputers," 6/17/2009)

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In response to reports that AMD processors had been used to build Iran's most powerful supercomputer, the SEC wrote AMD the following correspondence on May 8, 2009:

"It appears from exhibit 21 to your Form 10-K, exhibit 99.1 to your Form 8-K, and the “AMD Worldwide” section of your website that you have operations in the Middle East and Africa, which are regions that include Iran, Syria, and Sudan. In addition, we are aware of a December 2007 news report that your processors have been used to build Iran’s most powerful supercomputer. Iran, Syria, and Sudan are identified by the State Department as state sponsors of terrorism, and are subject to U.S. economic sanctions and export controls. We note that your Form 10-K does not include disclosure regarding contacts with Iran, Syria, or Sudan. Please describe to us the nature and extent of any past, current, and anticipated contacts with the referenced countries, whether through joint ventures, distributors, resellers, or other direct or indirect arrangements. Your response should describe any products or technology you had provided to the referenced countries, directly or indirectly, and any agreements, commercial agreements, or other contacts you have had with the governments of those countries or entities controlled by those governments."

In a June 19, 2009 response letter to the SEC, AMD wrote:

"In response to the Staff’s comment, the Company advises the Staff that AMD has not had any direct authorized contacts with Iran, Syria or Sudan (collectively, the “Embargoed Countries”). The Company has not provided any products or technology to the Embargoed Countries and has had no agreements, commercial agreements or other business contracts with the governments of the Embargoed Countries or entities controlled by those governments.The Company has an established export management system (“EMS”) which sets forth strict policies relating to its export related activities. The Company has designed these policies to ensure compliance with U.S. export control laws. The EMS governs the review of all sales and shipments to countries which are subject to U.S. economic and export sanctions. In addition, it is the Company’s policy that all authorized distributors of AMD products contractually commit that they will fully comply with all U.S. export control laws with respect to their sales and shipments of AMD products. The Company also periodically requests that its authorized distributors reaffirm these commitments...

Supporting material sent to the Committee on Foreign Investment in the United States (“CFIUS”) in December 2008 corroborated the above findings. The responses detail the controls that AMD has in place, including EMS, to prevent its distributors from selling products to prohibited end-users. These materials also contradict the articles referenced by the Staff that AMD processors were used in the construction of an Iranian supercomputer, showing that there are no records that indicate any improper or illegal shipment of technology to Iran, Syria or Sudan by AMD. Again, we are happy to provide you with copies of these materials.

The Company respectfully advises the Staff that in the rare occasions in the past where the Company has discovered an unauthorized resale by a distributor or direct customer of its product to an Embargoed Country, AMD has immediately terminated the export of its products to such customers or distributors if such customer or distributor does not agree to immediately cease such sales."

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"Chipmaker AMD is red-faced after a bunch of Iranian boffins smuggled 216 Opteron chips into the country and built themselves a supercomputer. Iran has loads of trade embargoes against it as part of a punishment for not liking America much. One of the embargos forbids the import of IT gear so that the Iranians cannot get their paws on a supercomputer.

Scientists at the Iranian High Performance Computing Research Center at the country's Amirkabir University of Technology have said that they have built a supercomputer using 216 AMD Opterons in a Linux cluster. They think that it can manage 860 giga-flops. But the development is extremely embarrassing for AMD which claims it has never shipped its chips to Iran or allowed anyone else to do so. No doubt AMD is expecting a visit from US law enforcement people who want to know how the chips got to Iran.

A spokesAMD said that the company complies with all United States export control laws. Any shipment of AMD products to Iran by any authorised distributor of AMD would be a breach of the specific provisions of their contracts with AMD." (The Inquirer, "AMD probed over Iran supercomputer build," 12/7/09)

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"Despite federal antiterrorism trade sanctions that bar the sale of U.S.-made computer technology to Iran, a computing research center in Tehran claims to have used Advanced Micro Devices Inc.'s Opteron processor to build the Middle Eastern country's most powerful supercomputer. The Iranian High Performance Computing Research Center (IHPCRC), which is located at Tehran's Amirkabir University of Technology, said in an undated announcement on its Web site that it has assembled a Linux-based system with 216 Opteron processing cores. That's a relatively small supercomputer, with a claimed peak performance level of 860 billion floating-point operations per second, or gigaflops. But the research center said that the system, which will be used for weather forecasting and meteorological research, is the fastest built in Iran to date." (Computerworld, "Iranians claim to have built Opteron-based supercomputer," 12/6/07)

In October 2019, LNGL was removed from the Pennsylvania Treasury's List of Scrutinized Companies after it was determined there is no recent evidence of activities in Iran that meet the criteria of Act 44 of 2010. 

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In 2011, LNGL was added to the Pennsylvania Treasury's List of Scrutinized Companies Determined as Having Involvement in Iran because of oil-related investment of US $20 million since 1996.
 

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According to its website, "There has been no further progress on this project as the Company's full resources are dedicated to the Fisherman's Landing LNG Project at Gladstone Port in Queensland."

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On LNG. Ltd.'s company website, they have a page dedicated to their Iran natural gas project, the "Qeshm LNG Project" (see further details here).

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A United States Congressional Research Services Report states that in November 2006, LNG. Ltd. signed a pending/preliminary agreement with Iran to develop its Salkh and Southern Gashku fields. The proposal also calls for the construction of an LNG plant. (Congressional Research Service, "Iran Sanctions Act," July 23, 2008)

A week after it was announced that French carmaker Peugeot-Citroen had left the Iranian market, Japan’s Mazda and South Korean Hyundai have also suspended contracts with Iran, according to a member of the parliamentary Industries and Mines Commission.

In an interview with the parliament-affiliated website, Valiyollah Maleki said June 12, “Mazda and Hyundai’s interests in the U.S. market are much more than in Iran, and they will not sacrifice their profit for the sake of Iran.” (June 13, 2018).

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Mazda 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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Mazda lists the Bahman Group, based in Tehran, Iran, on its Middle East & North Africa distributor list. (Company Website)

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"UANI (United Against Nuclear Iran) group calls on Japanese car manufacturer Mazda and French Peugeot to end their business in Iran, UANI (United Against Nuclear Iran U.S. group) Communications Director Nathan Carleton told Trend. While a lot of car manufacturing companies have left Iran due to sanctions imposed on the Islamic Republic, according to Carleton despite the threat of sanctions, there are still some world-known car brands that do their business in Iran. Among them are Mazda and Peugeot. 'Mazda's ongoing business in Iran is egregious given that its vehicles are produced in Iran in partnership with the Bahman Group, a manufacturing conglomerate that is 45.5 percent owned by the Islamic Revolutionary Guard Corps (IRGC),' Carleton said. He went on to note that if Mazda does not end its Iran business, it should be sanctioned under presidential Executive Order 13645, which authorizes sanctions on entities 'knowingly engaged in a significant transaction for the sale, supply, or transfer to Iran of significant goods or services used in connection with the automotive sector of Iran.'" (Trend, "UANI calls on Mazda, Peugeot to end their business in Iran," 9/16/13)

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"The report said that aside from Nissan and Peugeot, such car brands as Chinese Lifan, Mazda, Suzuki, and Hyundai are still being manufactured in Iran." (Trend, "Five reasons why Iran's car manufacturing suffers blow after blow," 11/27/2012)

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"Mazda has been operating in Iran at least since 1972. The Bahman Group assembles Mazda cars for the company. The Sepah Cooperative Foundation, a large investment fund closely linked to the Iranian Revolutionary Guard Corps (IRGC), owns a 45 percent share of the Bahman Group, according to Iranian newspaper reports. (Among the links between the Sepah Cooperative Foundation and the IRGC: the general manager of the the Sepah Cooperative until this fall was IRGC commander Ahmad Vahid-Dastjerdi. Another notable head of the Sepah Cooperative Foundation was Mohsen Rafiqdoost, who helped found the IRGC. The Sepah Cooperative Foundation's stake in the  Bahman Group has also been reported by Rand Corporation, in a 2009 report prepared for the Office of the Secretary of Defense, as well as the think tanks the Washington Institute, and the Council on Foreign Relations reports.) Mazda spokesman spokesman Chris Keeffe said that his company's business in Iran complies with all Japanese and international laws. Mr. Keefe said he was not aware of the reports linking the Iranian Revolutionary Gaurd to the Bahman Group and threfore could not comment. Contracts for Mazda and Ford Motor Company, which owned one-third of Mazda until 2008 and remains one of its largest shareholders, include selling trucks and cars to the United States military."  From 2000-2009, the company was the recipient of $2.4 billion US federal funds.  Their investments in Iran are currently active.  (The New York Times, "Profiting from Iran, and the US," 3/6/2010)

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“Khalaji, of the Washington Institute, lists the Bahman Group, which manufactures cars for Mazda, among [Iran Revolutionary] guard-owned companies.” (Council on Foreign Relations, “Iran’s Revolutionary Guard,” 10/3/07)

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“Japan's Mazda, one-third-owned by Ford, has a joint venture with Iran's private Bahman group to make a version of the Mazda 323, and Chrysler parent DaimlerChrysler has licensed assembly of an E-class Mercedes-Benz.” (Fortune, “Made in Iran,” 9/12/06)

"A recent announcement by Iranian car company SAIPA that Kia Motor has halted its operations in Iran brought the role of foreign firms in Iran’s auto sector in sharp focus. On August 3, SAIPA announced that Kia Motors terminated its Iran operations due to US sanctions. This is while informed sources previously said that the South Korean company had suspended its operations in the country months ago. SAIPA has reported on its website, “Just like French car companies, Peugeot and Citroen, and the Chinese automaker Brilliance, Kia has also cut its ties with SAIPA.”" (Financial Tribune, "Carmakers Taken to Task for Iran Exit," 8/12/2019).

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"SAIPA auto company is to sign two joint production deals with East Asian automotive giants Nissan and Kia. The two companies previously had a strong presence in Iran.   Kia currently sends complete knock down (CKD) kits of the older version Kia Cerato as part of a assembly deal with SAIPA." (July 2017)

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Kia Motors resumed its knockdown business with Saipa, Iran's No.2 car maker, earlier this year. 1,200 Fortes (local brand: Serato) were locally produced during the first quarter. Kia has also sold 800 finished cars to the market, including some of the K3 model. The brand's representative sedan Pride had once been one of the most commonly seen cars on Iran's roads along with Peugeot, before the sanctions. (The Dong-A ILBO, “Hyundai to ‘knockdown export’ Mighty to Iran,” 5/18/2016). 

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There is currently a Facebook page entitled “Kia Motors Iran,” which links to the Iranian dealership Atlaskhodro and whose website also advertises for Kia.  (Facebook, “Kia Iran Motors,”; Atlaskhodro Website, “Homepage”).

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Kia states that it “has a long history of building locally to meet the specific needs of local customers, with assembly operations using ‘car kits’ (supplied from Korea), in … Iran… ”  (Kia Website, “KIA MOTORS CORPORATION”).

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Kia is part of the Hyundai Kia Automotive Group.

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"Managing Director of SAIPA auto manufacturing company said with regard to the existence of proper infrastructures in the country the government has put support for foreign investment on its agenda. Saeed Madani, speaking at the second International Conference on Auto Industry, further remarked that SAIPA auto manufacturing group is capable of manufacturing 945 thousand vehicles in the country plus 46 thousand in foreign sites such as Syria, Iraq, Venezuela and Sudan... He said negotiations have been held with Volvo and expressed hope that manufacture of this brand will commence jointly, adding that at present SAIPA has joint cooperation with Renault, Nissan, Kia..." (IRNA, "Support for Foreign Investment in Auto Manufacturing Industry," 12/1/14)

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"[T]he auto sanctions were lifted earlier this year after an interim nuclear agreement was reached between Iran and world powers and a final accord is still on the horizon, raising the prospect of better times for the industry. That will draw international suitors to Tehran on Monday for the second consecutive Iran Auto Show. Mercedes Benz, Volkswagen, Renault, Peugeot, Kia and Toyota have confirmed [they will attend]." (Agence France-Presse, "Foreign automakers find Iranian market has gone local," 11/30/14)

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"Iran totally imported 51,967 cars in the first half of the current Iranian calendar year (March 21 - September 22). Hyundai with 24,991 cars was the main exporter of cars to Iran in the mentioned period, Peykhabar News Website reported on Nov. 15. Kia Motors with 9,339 cars..." (Trend, "Korea’s Hyundai gains lion share of Iran’s car imports market," 11/16/14)

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"Last week, Qorbani announced that Benz, Volkswagen, Volvo, Fiat, Rover, Skoda, Renault, Peugeot, Kia and Toyota would take part in the Iranian auto expo, adding that the US car-manufacturers would also join the event. 'In case of desirable conditions, General Motors and Ford companies will also attend the event.' He continued that some leading car parts makers, including Siemens, FORD Mendo, Busch, FRW and ACI would attend the gathering. The event will start work on December 10." (Fars News, "55 Giant Int'l Carmakers, Part-Makers to Participate in Iranian Auto Expo," 11/2/14)

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“For example, Iranian auto manufacturer Pars Khodro produced 240,923 Kia Pride cars for one year between March 2011 and February 2012.  Given Hyundai Wia supplies 95 percent of its parts to Hyundai and Kia, the new sanctions will hurt the company's bottom line acutely.” (The Korea Economic Daily, “Hyundai Wia in Danger of Losing Big in Iran,” 6/27/13)

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"According to the report, 17 car brands have been permitted to be imported in the current year. The cars include Hyundai (2 models), ABT, Alfa Romeo (2 models), MG, SsangYong, Toyota, Renault (6 models), and Kia (2 models). Previously, 25 car brands were included in the list, such as South Korean brands (Kia and Hyundai), Chinese brands (SAIC motors), Italian brands (Fiat, Alpha Romeo), Japanese brands (Honda, Mitsubishi), German brands (ABT), and Swedish brands (Volvo)." (Azer News, "Iran bans imports of renowned car brands," 5/27/2013) 

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"South Korea's Kia Motors, whose Pride model is ubiquitous on Iranian roads, said Tuesday it had suspended exports to the Islamic state partly in response to Seoul's nuclear-related sanctions. 'South Korean government sanctions... were part of the decision,' Kia spokesman Michael Choo told AFP, declining to comment further. Kia's Pride, a small hatchback, accounts for 30-40 percent of all vehicles on Iran's roads, according to the company. The firm last year exported 4,210 complete vehicles to Iran and 17,040 cars in kit form for local assembly. Kia suspended all exports to Iran last month, including completed vehicles, kits and spare parts -- before South Korea's government announced its detailed measures but after it announced its intention to impose sanctions . . . Kia, with its larger partner Hyundai Motor, forms the world's fifth largest automaking group." (Google News, "South Korea's Kia halts exports to Iran," 9/13/10)

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"Kia has a production agreement with Saipa, Iran's second-biggest car producer. Saipa currently manufactures the Kia Rio under license. Kia entered the Iranian car market in 1993 when it won a contract to set up an assembly plant." From 2000-2009, the company was the recipient of $706,745 US federal funds. Their business in Iran is currently active.  (The New York Times, "Profiting from Iran, and the US," 3/6/2010)

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"Saipa 141 with a 1323 cc three cylinders engine has been described as a popular car because of its low fuel consumption, good customer service as well as cheap auto parts. Saipa 141 is a car made by Iranian carmaker Saipa using the platform of the Kia Pride Car." (Press TV, "Saipa launches production line in Syria," 7/3/09)

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"Foreign car makers seeking volume are gambling their US businesses - and getting away with it by licensing models in Iran, the country's 70 million population too big to ignore as markets elsewhere mature. Kia of Korea is producing a version of the Pride with Saipa, Peugeot a take on its popular 405 model with both Saipa and Iran Khodro, and Renault has a $300 million investment with Saipa to produce the Logan and the Megane." (Sydney Morning Herald, "Iran’s car industry stuck in 1970s gear," 10/16/06)

According to its Annual Report filed with the SEC: In 2019, the following activities are disclosed in response to Section 13(r) with respect to Santander UK and certain other affiliates of Santander (collectively, the Group). During the period covered by this report:

• Santander UK holds two savings accounts and one current account for two customers resident in the U.K. who are currently designated by the U.S. under the Specially Designated Global Terrorist (SDGT) sanctions program. Revenues and profits generated by Santander U.K. on these accounts in the three months ended March 31, 2019 were negligible relative to the overall profits of Santander.
• Santander UK held one savings account and one current account for another customer resident in the UK who is currently designated by the US under the SDGT sanctions program. The United Nations and European Union removed this customer from their equivalent sanctions lists in 2008. The customer relationship predated the designations of the customer under these sanctions. Santander UK determined to put a block on the accounts and the accounts were closed on January 14, 2019. Revenues and profits generated by Santander UK on these accounts in the three months ended March 31, 2019 were negligible relative to the overall profits of Santander.
• Santander UK holds two frozen current accounts for two U.K. nationals who are designated by the U.S. under the SDGT sanctions program. The accounts held by each customer have been frozen since their designation and have remained frozen through the three months ended March 31, 2019. The accounts are in arrears (£1,844.73 in debit combined) and are currently being managed by Santander UK Collections & Recoveries department. No revenues or profits were generated by Santander UK on these accounts during the three months ended March 31, 2019.

The Santander Group has undertaken significant steps to withdraw from the Iranian market such as closing its representative office in Iran and ceasing all banking activities therein, including correspondent relationships, deposit taking from Iranian entities and issuing export letters of credit, except for the legacy transactions described above. The Santander Group is not contractually permitted to cancel these arrangements without either (i) paying the guaranteed amount (in the case of the performance guarantees), or (ii) forfeiting the outstanding amounts due to it (in the case of the export credits). As such, the Santander Group intends to continue to provide the guarantees and hold these assets in accordance with company policy and applicable laws.

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SAMIH affiliate—Santander U.K. plc—held savings accounts for two SDNs during the year, even as it noted that SAMIH’s activity does not relate to any activity conducted by Laredo or Laredo’s affiliates. (SEC Disclosure)

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Santander is "the third largest bank in the world in terms of profits." In 2008, the Santander Group acquired the US-based Sovereign Bank. (Company Website)

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Banco Santander is also part of the Royal Bank of Scotland led consortium that owns ABN AMRO, which reportedly has done business with Iran. (ABN AMRO Company Website)

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"In July 2007, it was reported that Santander “was doing business with Teheran-based Sepah as recently as March [2007]… Trading with businesses that are blacklisted for alleged links to terrorism is a serious breach of US law and can have draconian consequences...Santander is thought to have opened accounts for Sepah in various European countries and in Teheran. Allegations have also been made that Santander had a banking relationship with another Iranian bank that the US is targeting for its alleged links to terrorists. Santander said: ‘Neither of these institutions has an open account with Santander.’ The Spanish bank appears to have ended its relationship with Sepah after March. No details are known about the nature of its contact with the other bank.

Santander said: ‘Banco Santander is confident that it complies with all relevant banking regulations in the territories in which it operates, and with international requirements placed on banks, including those concerning money-laundering and the financing of terrorism.’ Sepah, which is owned by the Iranian state, was placed on the US blacklist in January. At the time, Stuart Levey, under-secretary for terrorism and financial intelligence, said: ‘Sepah is the financial linchpin of Iran's missile procurement network and has actively assisted Iran's pursuit of missiles capable of carrying weapons of mass destruction.’" (The Daily Telegraph, "Santander Traded with Blacklist Iranian Bank," 7/23/07)

"The [Iranian] government has put a wholesale ban on imports of home appliances from South Korea, and is gearing up to apply bans on other foreign products. On September 29, Supreme Leader Ayatollah Ali Khamenei instructed President Ebrahim Raisi to ban the importation of home appliances, specifically from “two South Korean firms” which he didn’t name, reportedly to stave off the insolvency of domestic manufacturers. Yet there is no certainty that by ejecting Samsung and LG, it will be the South Korean corporations that will be at a loss. Instead, Iranian consumers are already peeved that the government has stripped them of credible options for their choice of domestic appliances, and they are now discovering that low-quality, inefficient homemade products are an inevitability for the foreseeable future." (Asia Times, "Iran bans goods from South Korea’s Samsung and LG," 11/29/21).

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According to the Republic of Korea Embassy in Iran's website, "Representatives from Samsung Electronics, LG Electronics, SK Networks and DL E&C, among others, attended [a] meeting [in Iran], and discussed the outcome of the recent visit of the Korean Prime Minister to Tehran, and shared the companies’ business activities as well as ways to promote the bilateral economic relationship between Korea and Iran." (4/18/21).

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On Friday, referring to the two Korean giants Samsung and LG that have left the Iranian market under the pressure of the U.S. sanctions, Iran's Foreign Ministry Spokesman said it would be much more difficult to return later for those who were "strong-armed by the United States to leave". Iran was a key market for the products of the two South Korean companies including TV and audio sets, home appliances, air conditioners and mobile phones....Both companies assembled some of their products in Iran but cut down on providing products and parts to Iran and have now completely stopped. In his tweet on Friday which came with a photo of workers pulling down a Samsung banner, Mousavi said that Iranians will "not forget friends who stand by their side at times of hardship". The two companies which stopped selling to Iran two years ago under the pressure of sanctions had not stopped their advertising in Iran. 

Samsung, like most other leading brands, stopped directly selling smartphones to Iran when the sanctions began. Samsung was officially represented in Iran and used to run after-sales service centers in major cities.

However, illegally imported smartphones of various brands such as Samsung and Apple are still quite abundant in the market." (Radio Farda, "Iran Warns Korean Giants Forced By Sanctions Not To Leave Market," 2/15/2020).

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LG Engineering is listed by the Iranian firm, Sazeh Consultants, as a “Participant” in the Borzooyeh Petrochemical Company project. (Sazeh Consultants Website, “About”).

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"Among Asian businesses rethinking their dealings with Iran are banks, oil companies and technology giants including Huawei Technologies Co., Lenovo Group, LG Electronics Inc. and Samsung Electronics Co. South Korean consumer-electronics giants Samsung and LG already have reduced exposure to Iran and are consulting with government officials in Seoul to determine whether they must withdraw from the nation entirely following the end of U.S. oil waivers, according to business people in Tehran who work with the companies. Iran had been financing purchases from both companies with funds generated from the sale of oil and crude-based products." (Wall Street Journal, "Asian Companies Pull Back From Iran Amid U.S. Pressure," 4/24/2019).

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Lists three sales subsidiary offices in Tehran, Iran on its company website. 

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

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"Iran Khodro Co., an automaker in Tehran, is in talks with LG International Corp. to develop electric vehicles for the Iranian market. 'Negotiations are under way,' said Hashem Yeke Zare, managing director of Khodro. The companies may clinch the deal in autumn, he said in an interview in Tehran. LG International, which is based in Seoul, would supply batteries and other components to the automaker and install charging stations. Khodro would make the cars. The partners aim to manufacture 60,000 vehicles by 2023. 'We are currently carrying out the plans to developing electric vehicles and to setting up charging infrastructure in Iran,' said an LG spokesman. The company declined to give further details before the deal closes." (Bloomberg, "Iranian Automaker in Talks with LG to Make Electric Vehicles," 6/29/2016)

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LG has a company website for Iran in Farsi.

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"Iran is in talks with three Japanese and South Korean oil and gas companies to invest in its oil and gas projects, Head of Investment Committee of the National Iranian Gas Company (NIGC) Asghar Soheilipour said. He said that Japan's Mitsubishi and South Korea's LG and Samsung are negotiating with NIGC to design, establish, and install gas refineries and pipelines, Iran's Mehr news agency reported on Jan. 13. Some Japanese and Italian companies have announced readiness to implement projects even before lifting the international sanctions, he noted." (Trend, "Iran in Talks with Japanese, Korean Oil and Gas Companies," 1/13/15)

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"Head of the investment committee of the Iran National Gas Company (INGC) Asghar Soheilipour said that his company was offering information about Iran's top priority gas projects to potential foreign and domestic investors... The official referred to Mitsubishi, LG and Samsung as corporations having announced readiness for making investments in Iran gas projects." (IRNA, "Official: Foreign firms eying investment in Iran gas industry," 1/3/15)

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In 2014, LG was removed from Pennsylvania Treasury's List of Scrutinized Companies Determined as Having Involvement in Iran due to a change in ownership.
 

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"In the electronics and home appliances sections, sales of LG and Sony flat-screen televisions come with attractive service plans and free home installations. Local brands, such as Pars, go mostly ignored." (The Washington Post, "Iran hopes to resist sanctions by boosting production," 10/27/2012) 

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"After being hit by European and U.S. sanctions, Iran's oil sales are stabilizing as the country entices buyers with attractive prices and a form of barter. But proposed new U.S. restrictions could further bite into its crude exports later this year . . . A form of barter set up by Iran provides an incentive to keep—or in the case of Seoul, to resume—its crude purchases. Faced with banking sanctions that impede its ability to receive crude proceeds and settle its bills for imported goods, the Islamic Republic increasingly gets paid into accounts based in the Asian countries where it sells the oil and in their local currency. Iranian traders then draw on the reserves to purchase goods exported to Iran. South Korean products are ubiquitous in Tehran—from smartphones made by Samsung Electronics Co. Ltd. to LG Electronics Inc. televisions and even costume dramas on local televisions; Iranian imports from the country amounted to $6 billion last year." (Wall Street Journal, "Iran Barters and Bargains to Help Oil Sales," 8/7/12)

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LG maintains a partnership with Fariran, an iranian security comapny. According to its website, Fariran has over fifty retailers in Iran, “and was founded with the purpose of importing, distributing and installing LG CCTV security systems in Iran.”  (Fariran Website, “About Us,” Accessed 8/6/2012) 

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LG surveillance equipment, including the LT903N(P) Speed Dome Camera, is clearly advertised for sale on the website of IRANCCTV. (IRANCCTV Website, “PTZ Speed Dome Camera,” Accessed: 8/6/2012) IRANCCTV is a regime entity that operates under the auspices of Iran’s Ministry of Culture, which has been described in the Iranian media as “a censorship agency” and “all-out mechanism of control and repression” that violently interrogates journalists and activists in Iran. (Reporters Without Borders, “While pointing finger at Bahrain, Iran uses culture ministry to interrogate journalists,” 5/24/2012)

"Samsung Electronics and LG Electronics accounted for a combined 30 percent of Iran's mobile phone market, Korean major newspaper Dong-a Ilbo reported in January." (Reuters, "South Korea may limit exports to Iran on payment concerns: sources," 5/17/2012)

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In 2011, LG was added to the Pennsylvania Treasury's List of Scrutinized Companies Determined as Having Involvement in Iran because of oil-related investment of US $20 million since 1996.
 

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"The lawmakers underlined a finding by the Congressional Research Service that 20 non-US firms may be in violation of the Iran Sanctions Act. They include Totalfina Elf of France; Italy's ENI; Bow Valley of Canada; the Netherlands' Royal Dutch Shell; Norsk Hydro of Norway; Russia's Lukoil; GVA Consultants of Sweden; Sheer Energy of Canada; LG of South Korea; Norway's Statoil; and Inpex of Japan." (AFP, “US lawmakers urge Obama to use Iran sanctions powers,” 10/21/09)

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"LG Electronics Inc. said Tuesday it has started producing handsets in Iran with a local partner. Production started this month, and the facility can make 1 million phones a year, LG spokeswoman Judy Pae said. Pae said she could not identify the Iranian partner or provide other details of the production arrangement or even the facility's location in Iran. Maadiran Group, which describes itself as Iran's leading technology and office automation company, said on its Web site in a Feb. 17 press release that it began producing five models of handsets under license from LG Electronics, the world's fifth-largest manufacturer of mobile phones . . . Pae said LG wants to be more competitive in the Middle East market, and the company plans to export the handsets to other countries in the region. In addition, by manufacturing in Iran, LG can avoid Iran's steep tax on imported handsets." (NBC News, "LG begins making mobile phones in Iran," 3/13/07)

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"GIANTS WITH A FOOT IN TEHRAN: Total, Shell, Statoil, BNP Paribas, Commerzbank, MTN, UPS, Linde, Technip, Nokia, Ericsson, Peugeot, Renault, OMV, Societe Generale, ENI, Mitsubishi, Sumitomo, Siemens, LG, Samsung, Bosch, Valeo, Nestle, Unilever, BAT, Japan Tobacco." (The London Times, "American pressure threatens UK firms," 5/27/06)

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"According to "Tehran Times", Iranian authorized dealers of the audio-visual, air conditioning systems and cellular phones affiliated to the Goldiran Co. got together in the Islamic Republic of Iran's Broadcasting (IRIB) Hall of Conferences in Tehran. The party was thrown in honor of S.S. Kim, chief executive officer and Vice President of the LG Electronics. Kim who is also the chief executive officer of Korean LG Electronics Company and among the 20 top economic managers in the world has received many awards in different managerial fields." (InfoProd, “Iran: Senior Managers of LG Electronics Hold Meeting in Tehran,” 11/18/04)

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"Iran signed a $1.6 billion contract with South Korea's LG Construction Co. Ltd. to further develop its huge South Pars offshore gas field in the Gulf. With the signing on Sunday, LG took a 42 percent stake in the project. The remaining 58 percent is held by the state-owned energy firms connected to the National Iranian Oil Company." (Associated Press, “Iran, LG of South Korea sign $1.6 billion gas deal,” 9/16/02)