Withdrawn

Following the removal from the January 29, 2019 Florida list, South Dakota Investment Council also removed Daelim from its Iran Scrutinized Companies list effective April 18, 2019. 

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In 2019 Daelim was removed from the Texas Comptroller List of Companies Engaging in Scrutinized Business Operations in Iran. 

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Effective September 10, 2019, Daelim was removed from the Pennsylvania Treasury's Iran Scrutinized Activities list because the company documented cessation of all substantial business activities in Iran. 

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According to the Maryland State Retirement and Pension System March 31, 2019 report, "The Retirement System received a response form one company, Daelim Industrial, which resulted in the company being removed from the list of restricted companies." (Maryland State Retirement System, "March 31, 2019"). 

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According to the January 2019 Florida State Board of Administration Investment Report, "Daelim is no longer seen as a scrutinized company due to the company’s cancellation of projects
in Iran and commitment to no longer engage in scrutinized operations in Iran. On November 13, 2018, Daelim provided correspondence to the SBA detailing the termination of its Iran operations. External research providers also confirm such action. The company publicly stated its intentions to withdraw from Iran on May 31, 2018." (Florida State Board of Investments, "Florida Statutes - Jan 29, 2019"). 

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Daelim is listed as a partner of the Iranian firm, Chagalesh Consulting Engineers (“Chagalesh”).  (Chagalesh Website, “About”).  

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Daelim Industrial Co was removed from the March 2019 Alaska Retirement Management Board, Companies Doing Material Business with Iran list.

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Daelim  is listed on the January 2019 Entities prohibited from Contracting with Public Entities in California list.

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In January 2019 Colorado's PERA included Daelim on its Iran list.

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Daelim is listed as a company under review following correspondence dated 10/31/18 from the company, on the CalPERS November 2018 Iran Divested/Restricted companies list.

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In 2018 Daelim was listed on the Texas Comptroller List of Companies Engaging in Scrutinized Business Operations in Iran.  

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In June 2009, Daelim Industrial Co. Ltd. won a contract to build pipelines for a liquefied natural gas storage facility in Iran. Until 2018, CalSTRS research providers had shown Daelim Industrial Co. Ltd. continued to be involved in several natural gas-related projects in Iran. In 2009, Daelim Industrial Co. Ltd. was designated as “Restricted From Additional Purchase.” In 2010, CalSTRS divested holdings of the company and designated the company as “Divested and Restricted.” CalSTRS maintained the “Divested and Restricted” designation through most of 2018. However, CalSTRS removed the “Divested and Restricted” designation after the company confirmed it curtailed operations and ties to Iran and after reviewing the company’s internal controls.

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"South Korea’s Daelim Industrial said on Friday that a contract worth 2.23 trillion won ($2.08 billion) for a refinery project in Iran was canceled.

The order was canceled as the Esfahan Refinery Upgrading Project failed to procure financing because of economic sanctions imposed on Iran, Daelim said in a regulatory filing." (June 1, 2018).

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"South Korea's construction giant Daelim Industrial Company said work is in full swing at the Isfahan Oil Refinery project site in Iran, and on track for completion by the end of 2020. The plant currently meet about 22 per cent of Iran's demand for oil products with a capacity to process 375,000 barrels per day of oil, according to Shana. The South Koreans have undertaken to provide E1.9 billion ($2.27 billion) for improving and optimizing facilities at Isfahan Oil Refinery, stated the report citing Alireza Arman Moqadam of National Iranian Oil Refining and Distribution Company. The project, which kicked off last December, is likely to be completed by the end of 2020." (December 31, 2017).

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In 2017, the U.S. states of Alaska, California, Colorado, Connecticut, D.C., Florida,  Iowa, Illinois, Maryland, Minnesota, Mississippi, New York, North Carolina, Ohio, Pennsylvania, Rhode Island, South Carolina , Tennessee, Texas and  South Dakota listed Daelim on its Iran scrutinized companies list rendering Daelim ineligible for investment and/or state contracting.

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"Daelim Industrial Co., a major construction firm in South Korea, said on December 29 that it has received a letter of award (LOA) from Iran’s Esfahan Oil Refining Co. (EORC) to improve oil refinery facilities. The deal, which is worth 2.3 trillion won (US$2.0 billion), is the largest contract secured by a domestic construction company in Iran. The project is to add facilities that will be used to produce high value-added products to the oil refinery in Isfahan, located 400 kilometers south of Tehran, the capital of Iran. Under the deal to be officially signed in January 2017, Daelim Industrial will be in charge of design, equipment and material procurement, construction and financing. Construction will take 48 months after groundbreaking." (BusinessKorea, "Daelim Wins $2B Construction Deal in Iran," 12/29/2016).

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The National Iranian Oil Company and South Korea's Daelim Industrial Co. have signed a memorandum of understanding, worth $4 billion, on upgrading the Isfahan Oil Refinery. The document calls for reducing the refinery's input of feedstock by 16,000 barrels per day, lowering mazut output by 10 million liters a day with the help of advanced technology as well as boosting daily gasoline production by 8.5 million liters, Mehr News Agency reported. (July 21, 2016).

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In 2016 Daelim was re-listed on the Texas Pension Review Board List of Scrutinized Companies doing business in Iran pursuant to Chapter 807.054, Government Code. 

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In 2015 Daelim was removed from the Texas Pension Review Board List of Scrutinized Companies doing business in Iran pursuant to Chapter 807.054, Government Code after the company responded to their placement on the Scrutinized Companies List by stating that Daelim, "has substantially ended all work on its existing projects in Iran and it is in the process of winding down all activities in Iran." 

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Company website lists operations in Iran as part of global network. (Company Website)

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“Korean construction firms are paying attention to Iran, the fourth largest client in the global construction market. Responding to the lifting of sanctions against Iran, they are taking swift actions, such as strengthening market survey and preparing to enter the market…Korean construction firms are taking actions behind the curtains while watching international political situations. Hyundai E&C and Daelim, two major constructors in Korea, have operated a local office in Tehran where Korean and Iranian employees work together in order to re-enter the Iranian market at some point. An official from a large construction firm said, ‘Since gaining trust from a client is very important in the Middle East, Korean construction firms have maintained relationships (with Iranian clients) even after sanctions.’ Kwon Myeong-gwang, an ICAK manager in charge of Iran and Kuwait markets, said, ‘Iran is a big market, and projects that couldn’t be embarked on due to economic sanctions may come to the market all at once,’ adding, ‘Construction of oil and gas facilities is promising.’” (The Dong-A Ilbo, “Will thawing sanctions against Iran boost construction business?” 2/2/14)

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In 2013 and 2014 Daelim was listed on the Texas Pension Review Board List of Scrutinized Companies doing business in Iran pursuant to Chapter 807.054, Government Code. 

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"Daelim Industrial Co had a nearly $1.5 million U.S. government contract to build family housing at a military base in South Korea at some point between mid-2011 and late 2012, the General Accountability Office said in a report on Monday. The GAO is the investigative arm of Congress... Such companies should also be denied contracts with the U.S. government, it says. The GAO did not say how much Daelim's investments in Iranian energy were worth... Daelim was one of at least seven companies from China, India, South Korea  and South Africa that continued to have investments in Iran in 2012, the GAO said in December, in a report required by a U.S. sanctions law. A Daelim spokesman in Seoul said the company was simply completing a construction project in Iran that predated the U.S. sanctions. He added that the building contract did not constitute an investment in Iran's energy sector, as stipulated in the U.S. sanctions law, and that Daelim had not signed any new contracts in the Islamic Republic since 2010. Daelim, which the GAO said had helped to develop Iran's South Pars gas fields and a liquefied natural gas project in Tombak, was the only one of the companies found also to hold a contract with the U.S. government, the GAO said on Monday." (Reuters, "South Korea firm had U.S. contract while investing in Iran gas: GAO," 2/26/2013)

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In 2011, Daelim 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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"Daelim, a South Korean engineering and construction giant, has been active in Iran since 1975, building refineries, as well as natural gas and power plants. In 2007, it signed a refinery deal worth $700 million to the company. And in 2009, Daelim struck a deal worth $600 million to the company to help Iran develop a phase of the South Pars gas fields, a spokesperson confirmed. While doing business in Iran, it has won contracts from the United States, including a $111 million contract awarded last year to build family housing towers for the Army. The Iran Sanctions Act prohibits investments above $20 million in a given year in Iran's energy sector. Investments are defined as deals in which a company purchases shares or enters into a contract that provides for royalty payments. But investments also are defined as deals in which a company enters into a contract that includes responsibility for the development of petroleum resources, which is what landed Daelim on a list of potential Iran Sanctions Act violators put together by the Congressional Research Service. In a statement, the company said that it had disputed the listing and did believe its construction work in Iran met the law's criteria. 'Based on our review, we never did anything that violated the law and we never did any investment in Iran,' the company said."  The company has received $174 million from the US government for their business in Iran during 2000-2009.  Their investments are currently active in Iran, and the company has been listed by the New York Times as a possible violator of the Iran Sanctions Act. (The New York Times, "Profiting from Iran, and the US," 3/6/2010)

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"Commerzbank AG, Germany's second-largest lender, will pay at least $1.4 billion to settle federal and state claims that it violated U.S. sanctions, a person briefed on the matter said. The settlement, part of a deferred-prosecution agreement that would also resolve a separate money-laundering matter, may come as soon as this month, said the person, who asked not to be identified because the discussions aren't public... The accord is the latest settlement with a global bank over dealings with blacklisted countries, including Iran and Sudan. In June, BNP Paribas SA pleaded guilty to violating U.S. sanctions laws and agreed to pay a record $8.9 billion to resolve the case." (Bloomberg, Commerzbank Said to Near $1.4 Billion U.S. Settlement, 3/5/15)

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"Commerzbank AG's expected settlement with authorities over alleged violations of U.S. sanctions and anti-money laundering laws is likely to exceed $1 billion (636.42 million pounds) in penalties, according to a person familiar with the probes. The settlement is still being negotiated, and a deal before the end of the year is unlikely, two sources said. Margarita Thiel, a spokeswoman for Commerzbank, Germany's second-largest lender, declined to comment. Commerzbank was close to an agreement in September with U.S. prosecutors and regulators over its dealings with Iran and other countries subject to U.S. sanctions, Reuters has reported, citing sources." (Reuters, "Commerzbank settlement with U.S. likely to exceed $1 billiion - source," 12/11/14)

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“German lender Commerzbank AG is expected to pay between $600 million and $800 million to resolve investigations into its dealings with Iran and other countries under U.S. sanctions, sources familiar with the matter said. The penalty, previously reported to be more than $500 million, includes a demand from New York's top banking regulator, Benjamin Lawsky, for more than $300 million from the bank, the sources said… Among the violations being investigated are Commerzbank's transactions for the Islamic Republic of Iran Shipping Lines, one of the sources said. The state-sponsored shipping company was designated for economic sanctions by the United States in 2008 for allegedly supporting Iran's proliferation of weapons of mass destruction. The source said Commerzbank was alleged to have done business with the company despite knowing that it was sanctioned.” (Reuters, "Exclusive: Commerzbank may pay $600 million-$800 million to settle U.S. probe - sources," 7/9/14)

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“State and federal authorities have begun settlement talks with Commerzbank, Germany’s second-largest lender, over the bank’s dealings with Iran and other countries blacklisted by the United States, according to people briefed on the matter. The bank, which is suspected of transferring money through its American operations on behalf of companies in Iran and Sudan, could strike a settlement deal with the state and federal authorities as soon as this summer, said the people briefed on the matter, who were not authorized to speak publicly… The contours of a settlement, which the authorities have only begun to sketch out, are expected to include at least $500 million in penalties for Commerzbank, the people added.” (New York Times, "U.S. Scrutiny for Banks Shifts to Commerzbank and Germany", 7/7/14)

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“As part of talks in Geneva over the nuclear question, Tehran is pressing world powers to speed up trade finance arrangements on humanitarian deals involving both Western and Iranian banks, according to an Iranian government document seen by Reuters and sources familiar with the initiative. Iranian government officials and international trade sources say Tehran wants to simplify complex trade finance arrangements potentially worth billions of dollars, which would alleviate pressure on the country's sanctioned banking system…Iranian government officials said the document, which has been sent to Iran's Supreme National Security Council, tasked with safeguarding Tehran's interests, listed the following banks as ‘available for further actions’: Standard Chartered Bank (London), Societe Generale (Paris), Banque de Commerce et de Placements (BCP) (Geneva), UniCredit Bank (Munich), Commerzbank (Frankfurt), United Bank (Zurich) and BHF Bank (Frankfurt). It was not clear whether these banks had been approached to provide finance. Two business executives familiar with the initiative said they were aware that Standard Chartered, Societe Generale, Commerzbank were among those on the wish list. Commerzbank, Societe Generale, United Bank and BCP all declined to comment. A spokeswoman for Standard Chartered said the bank was not involved and would not get involved in any transaction with any party from Iran.” (Reuters, “Western banks cold-shoulder Iran trade finance scheme,” 3/13/14)

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“The broader banking sanctions still in place [under the interim deal] are creating some ambiguities. The senior banker said Iranian authorities told businessmen that seven European banks including Commerzbank and Société Générale had been designated to transfer the $4.2bn in blocked funds but 'some kind of dilemma' remained over which Iranian banks could receive the money as most are affected by the broader banking sanctions still in place.” (Financial Times, “Easing of sanctions raises hopes for Iranian economy,” 1/19/14)

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"Several other banks - including Deutsche Bank, Germany's second biggest lender Commerzbank, UniCredit's German unit HVB, and French banks BNP Paribas and Credit Agricole - have said they have received inquiries from U.S. authorities or are reviewing transactions to check whether they are potentially in breach of U.S. sanctions, suggesting any investigations are at an early stage." (Reuters, "Analysis: StanChart hit may not dog other banks as much as feared," 9/4/2012)

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"President Barack Obama signed into law new sanctions on Iran that, for the first time, will bar from the American market foreign companies that work with Iranian businesses charged with aiding Tehran's nuclear program and the suppression of democracy.

Among those that could face legal challenges and fines are Japan's Big Three banks—Mitsubishi UFJ Financial Group Inc., Sumitomo Mitsui Financial Group and Mizuho Financial Group Inc.—as well as European firms such as Commerzbank Bank AG and Deutsche Bank AG, all of whom have businesses inside Iran.

A spokesman for Commerzbank declined to comment on the effect of the law, saying the bank wasn't familiar with its details. He said Commerzbank has been reducing its exposure to Iran since 2007.

A recent report by Avi Jorisch, a former Treasury Department intelligence official, details how the Big Three Japanese banks, Deutsche Bank and Commerzbank continue to maintain bank accounts for Bank Sepah, Iran's oldest financial institution.

Bank Sepah has been blacklisted by both the U.N. and the U.S. in recent years for its alleged role in assisting Tehran's development of weapons of mass destruction.

Spokesman Reiner Rossman declined to comment on any relationship Commerzbank had or has with Bank Sepah."

(Wall Street Journal, "U.S. Adds Its Own Sanctions on Iran," 7/2/2010)

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"Another step the Obama administration should take is to sustain American pressure on foreign banks and oil companies to halt their dealings with Irans energy sector. This effort has led such major firms as Germanys Deutsche Bank and Commerzbank, Englands HSBC, Credit Suisse and Royal Dutch Shell to halt or limit their business with Iran." (The Baltimore Sun, "FACING THE IRANIAN THREAT," 12/9/08)

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"U.S. outreach to foreign banks and to oil companies considering investing in Irans energy sector has reportedly convinced more than 80 banks and several major potential oil-field investors to cease all or some of their business with Iran. Among them: Germanys two largest banks (Deutsche Bank and Commerzbank), London-based HSBC, Credit Suisse, Norwegian energy company StatoilHydro, and Royal Dutch Shell."(The Wall Street Journal, "How To Put The Squeeze On Iran," 11/13/08)

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"European giants HSBC, Deutsche Bank and Credit Suisse have pulled out of Iran while BNP Paribas, Commerzbank and Dresdner Bank have severely curtailed their business with the Islamic republic." (Gulf Daily News, "US imposes sanctions on major Iran banks," 10/26/07

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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)

BP's form 20-F filed with the SEC for fiscal year 2021 states: "To our knowledge, none of BP's activities, transactions or dealings are required to be disclosed pursuant to ITRA Section 219, with the following possible exception. On 17 July 2018, BP Iran Limited terminated its lease of an office in Tehran. The office had been used for administrative activities. In 2021, taxes with an aggregate US dollar equivalent value of approximately $1,600 were paid from a BP trust account held with Tadvin Co. to Iranian public entities. No gross revenues or net profits were attributable to these activities."

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"An oil tanker run by BP Plc is being kept inside the Persian Gulf in fear it could be seized by Iran in a tit-for-tat response to the arrest by Gibraltar last week of a vessel hauling the Islamic Republic’s crude. The British Heritage, able to haul about 1 million barrels of oil, was sailing toward Iraq’s Basrah terminal in the south of country when it made an abrupt u-turn on July 6." (Bloomberg, "BP Oil Tanker Shelters in Persian Gulf on Fear of Iran Retaliation, " 4/8/2019).

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According to its 2019 SEC disclosure, BP reported the following: "To our knowledge, none of BP’s activities, transactions or dealings are required to be disclosed pursuant to ITRA Section 219, with the following possible exceptions:

• Prior to 30 November 2018, Rhum, located in the UK sector of the North Sea, was operated by BP Exploration Operating Company Limited (BPEOC), a non-US subsidiary of BP, and Rhum was owned under a 50:50 unincorporated joint arrangement between BPEOC and Iranian Oil Company (U.K.) Limited (IOC) which was initially established in 1974. During 2018, BP recorded gross revenues of $177.3 million related to its interests in Rhum. BP had a net profit of $87.7 million for the year ended 31 December 2018.
• BP has sought to carry out its role as operator of the Rhum joint arrangement in compliance with US sanctions and has obtained a series of specific OFAC licences relating to the ongoing operation of the Rhum field.
• In November 2017, BPEOC entered into an agreement with IOC for the sale and purchase of an IOC entitlement to Forties blend crude oil. The parties agreed to set off the purchase price - £29.89 million ($39.88 million equivalent) - against IOC’s share of operating costs incurred or to be incurred by BPEOC as operator of the Rhum field under the Rhum joint operating agreement. 604,976 net barrels of Forties blend crude oil was loaded at a North Sea terminal in January 2018 and delivered to BP’s Rotterdam refinery. Upon delivery at BP’s Rotterdam refinery, the Forties blend crude oil was comingled with other products for refining, and therefore BP is unable to ascertain an amount of gross revenue or gross profit attributable to it.
• During 2018, BPEOC received £223,693 ($298,456 equivalent) (net of tariffs) from BPEOC Forties Pipeline System in respect of monies owed to IOC in relation to the purchase of IOC’s share of Onshore Raw Gas at the Kinneil terminal of the Forties Pipeline System. BP and IOC agreed to set off the £223,693 ($298,456 equivalent) against IOC’s share of operating costs incurred or to be incurred by BPEOC as operator of the Rhum field under the Rhum joint operating agreement.
• During 2018, BPEOC received £2.79 million ($3.73 million equivalent) (net of tariffs) from a non-US third party in respect of the sale to such non-US third party of certain NGLs redelivered from the St Fergus terminal. These NGLs had been acquired by BPEOC from IOC at the St. Fergus terminal. BP and IOC agreed to set off the £2.79 million ($3.73 million equivalent) against IOC’s share of operating costs incurred by BPEOC as operator of the Rhum field under the Rhum joint operating agreement.
• As noted above, on 30 November 2018, BP completed the sale of its ownership stake in the Rhum joint arrangement and transferred its role as operator to Serica. Prior to the sale, on 5 October 2018, Serica and BP received a conditional licence from OFAC relating to the ongoing operation of the Rhum field. The licence was valid until 31 October 2019 and was conditional upon arrangements being put in place before 5 November 2018 relating to the interests in Rhum held by IOC. An updated licence from OFAC on substantially the same terms and a letter of comfort permitting all non-US persons to support Rhum activities in compliance with US secondary sanctions were issued on 2 November 2018. On the same date the conditions in such OFAC licence in respect of the interest in Rhum held by IOC were met in full. These conditions were satisfied through arrangements which provide that all benefits accruing from and relating to IOC’s interest in Rhum will be held in escrow, by a trust and management company (Rhum Management Company) set up for this purpose, for such period as US sanctions apply. The arrangements are designed to ensure that neither IOC nor any direct or indirect parent company of IOC (including any member of the Government of Iran) will derive any economic benefit from Rhum, or exercise any decision-making powers in respect of Rhum, during that period. From satisfaction of the OFAC licence conditions on 2 November 2018, BP dealt with the Rhum Management Company in respect of Rhum joint venture matters.
• In December 2018, BP made a cash transfer of £2.69 million ($3.59 million equivalent) to Rhum Management Company. This transfer represented the net amount of IOC funds in the Rhum joint venture account which had not, to that date, been set off against IOC’s share of operating costs incurred by BPEOC as operator of the Rhum field under the Rhum joint operating agreement.
• BP does not expect to enter into any further similar arrangements with IOC or any member of the Government of Iran in relation to the Rhum field. BP will continue to purchase from Serica’s liftings from Rhum or provide services to Serica as the operator of Rhum.
• On 17 July 2018 BP Iran Limited terminated its lease of an office in Tehran. The office had been used for administrative activities. In 2018, taxes, including rental tax payments associated with the Tehran office, with an aggregate US dollar equivalent value of approximately $11,000, were paid from a BP trust account held with Tadvin Co. to Iranian public entities. No gross revenues or net profits were attributable to these activities.
• During 2018, certain BP employees visited Iran for the purpose of meetings with Iranian government officials and other Iranian nationals and attending conferences. Payments were made to Iranian public entities for visas and taxes in relation to such visits with an aggregate US dollar equivalent value of approximately $3,000. In addition, certain BP employees met with Iranian government officials and other Iranian nationals outside of Iran. No gross revenues or net profits were attributable to these activities, save where otherwise disclosed. BP will continue to monitor and assess business opportunities in Iran which are compliant with EU and US laws applicable to BP including potentially attending meetings in connection with this purpose." (SEC, "20-F," 3/29/2019). 

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"BP has stopped work on the Rhum gas field in the North Sea, which it has a 50-percent stake in, sharing it with the National Iranian Oil Company. The company cited the reintroduction of US sanctions against Tehran as the reason." "BP suspends work on gas field shared with Iran," RT, May 31, 2018.

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“BP has decided to defer some planned work on the Rhum gas field in the North Sea while we seek clarity on the potential impact on the field of recent US government decisions regarding Iran; Rhum is co-owned by an Iranian company. BP always complies with applicable sanctions.” (May 23, 2018).

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European oil companies could be particularly hit - French company Total signed a $5bn deal with Iran after the agreement, while BP has a joint venture to operate the Rhum gas field with Iran's state oil company. (May 11, 2018).

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In 2017, the U.S. states of Iowa and South Carolina listed BP on its state list of Doing Business with the Iranian Petroleum/Natural Gas, Nuclear and Military Sectors, rendering BP ineligible for investment and/or state contracting.

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Nov 2017 – “London-based BP this week agreed to sell to North Sea producer Serica Energy three fields in the aging offshore basin, including the Rhum field which is co-owned by a subsidiary of Iran’s national oil company.”

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"BP and Iran's state-run oil company received a license from the U.S. Treasury last year to operate their joint gas field in the North Sea following the lifting of Western sanctions on Tehran, BP said on Thursday.  Production at the Rhum field was suspended in 2010 when Europe imposed sanctions on Iran over its nuclear program and only resumed four years later after Britain agreed to set up a temporary management scheme whereby all revenue due to Tehran would be held until sanctions were lifted. Following the removal of European Union and United Nations sanctions on Iran in January 2016, the temporary management scheme ceased. Iran regained control of its stake and on Sept. 29, 2016 BP obtained a license from the U.S. Treasury, through its sanctions enforcement arm - the Office of Foreign Asset Control (OFAC), to continue operations at the field, BP said in its 2016 annual report." (Reuters, "U.S. Granted BP License To Operate Joint North Sea Field With Iran," 4/6/2017).

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"BP has opted out of the first wave of agreements to develop oil and gas reserves in Iran after the lifting of international sanctions - setting it apart from its two biggest European rivals Royal Dutch Shell and Total... BP has not applied to take part in a forthcoming tender of exploration and production rights in Iran, according to people briefed on the matter, and has no immediate plans for separate agreements of the kind reached by Shell and Total. These people said the main reason was commercial. "It's a question of where the best returns on investment can be made and BP has plenty of attractive opportunities elsewhere," said one. However, these people acknowledged the continued existence of some US sanctions against Iran - and the prospects of a hardline stance against Tehran by the Trump administration - was a particular deterrent for BP. Although based in the UK, BP has the biggest US exposure of any European oil group; about 40 per cent of its shareholders and 30 per cent of its employees are American, including Bob Dudley, chief executive." (Financial Times, "BP Opts Out of Iran Deals Ahead of Trump Hard Line on Tehran," 1/2/2016).

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"The National Iranian Oil Company has signed new spot oil export contracts with BP and the Anglo-Dutch Royal Dutch Shell to provide them with oil and gas condensates, director for international affairs at NIOC said on Wednesday... A spot contract is a deal for buying or selling a commodity for settlement (payment and delivery) on the spot date, which is normally two business days after the trade date. A spot contract is in contrast with a forward contract where terms are agreed now but delivery and payment will occur at a future date." (Financial Tribune, "Iran Signs Spot Contracts with Shell, BP," 12/29/2016).

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"BP has created a new executive committee to explore business in Iran which will exclude its American chief executive Bob Dudley in a bid to avoid potential violations of U.S. sanctions still in place. The new committee is headed by BP's chief financial officer Brian Gilvary, who is a British national. Gilvary will coordinate the oil major's operations in Iran and any discussions with the country's national oil company, according to industry sources. The move highlights the lengths to which multinationals will go to exploit lucrative new business in Iran, which is only slowly emerging from years of isolation that crippled the OPEC member's energy-reliant economy... BP's new executive committee also includes Bernard Looney, upstream chief executive, who is Irish, Dev Sanyal, chief executive of alternative energy and executive vice president, regions, an Indian national, and General Counsel Rupert Bondy, a Briton. "The separate governance structure does not involve Bob or any other U.S. citizens and was set up for Bob's own protection," one source said... Last month, Dudley said: "Iran is a large oil and gas province "... We're going to have to be very careful. We don't want to violate any sanctions." (Reuters, "Exclusive: BP ring-fences CEO Dudley from Iran decision-making," 11/22/2016).

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

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"Iran’s state-owned oil company sold condensate to BP Plc for the first time since sanctions were lifted in January, marking the country’s re-emergence as one of the world’s top suppliers of crude oil and natural gas liquids. National Iranian Oil Co. will supply South Pars condensate to BP for loading between September and October, said an NIOC official, asking not to be identified because of internal policy. The shipment may be used by one of BP’s own refineries or resold to other users, the official said by phone." (Plc for the first time since sanctions were lifted in January, marking the country’s re-emergence as one of the world’s top suppliers of crude oil and natural gas liquids. National Iranian Oil Co. will supply South Pars condensate to BP for loading between September and October, said an NIOC official, asking not to be identified because of internal policy. The shipment may be used by one of BP’s own refineries or resold to other users, the official said by phone." (Bloomberg, "Oil Major BP Buys First Iranian Oil Since Sanctions Eased," 10/5/2016).

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"'A cargo of one million barrels of natural gas condensate was delivered to BP,' Mohsen Ghamsari was quoted as saying by Iran's semi-official Mehr news agency. 'So far NIOC has sold two cargos of crude oil and gas condensate to two British companies,' Ghamsari said, without naming the second company... Ghamsari said negotiations are underway for NIOC to sign long-term contracts with BP and Royal Dutch Shell, Mehr reported." (Retuers, "Iran sells first cargoes of oil, condensate to British companies - Mehr news," 10/3/2016).

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"Iran's oil minister met BP PLC and Total SA on Wednesday, in a sign of renewed interest for the country's oil sector. International sanctions ban Western oil companies from entering Iran's oil fields. Earlier this week, Tehran failed to reach a final nuclear agreement with world powers, which could have eased such restrictions. Speaking to reporters, Iranian oil minister Bijan Zanganeh said he met representatives of BP PLC--the first such reported meeting with the British oil giant--and France's Total SA to discuss a possible entry in the country. Total, which was represented by new Chief Executive Officer Patrick Pouyanne, and BP have both previously said they won't work in Iran unless sanctions are lifted. Separately, Mr Zanganeh also met Vagit Alekperov, president of Russian oil giant Lukoil. Speaking to reporters, Mr. Alekperov said that 'as soon as sanctions [are] lifted, we are hoping [to] enter' the country. He also said Lukoil would like to participate in bidding round for new oil contracts which is due early next year, but which has been postponed several times." (Dow Jones, "Iranian Oil Minister Meets With BP, Total and Lukoil," 11/26/14)

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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…Renault, for instance, resumed shipping car parts to Iran in January of this year. The French automaker has received at least $111,170 from the Pentagon, according to publicly available data. BP representatives reportedly attended an Iran oil investor conference that included Iranian President Hassan Rouhani and the country’s oil minister.” (Washington Free Beacon, “Pentagon Contractors Exploring Business with Iran,” 2/25/14)

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"Iran will have a new, attractive investment model for oil contracts by September, its president and oil minister told some of the world's top oil executives here on Thursday, part of its drive to win back Western business. Iranian President Hassan Rouhani and Oil Minister Bijan Zanganeh said their new administration was keen to open up to Western investments and technology, executives who attended the meeting said. They also stressed the importance of fossil fuel, with global energy demand rising. ‘The fact that the president of Iran came to the meeting today... is clearly a sign that Iran wants to open up to international oil companies,’ said Paolo Scaroni, chief executive of Italy's Eni, who was at the meeting. ’It was an impressive presentation,’ said one of three further oil executives who were at the meeting and spoke with Reuters on condition of anonymity. ’They said they are working on a new model to work with investors and are happy to see us,’ he added. ‘They not only need money but technologies. They are happy to have consultations about how new contracts shall work. They want to decide on the model by September.’ ’The message was - look at us, our geological risks are minimal, reserves are huge, come and we will create competitive terms and you will be happy. Your return on investments will be acceptable,’ another executive said. Along with ENI, France's Total, Britain's BP , LUKoil and GazpromNeft from Russia, and several other companies were present.” (Reuters, “Iran lures oil majors with new contracts pledge,” 1/23/14)

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“For foreign firms, the biggest prize in Iran is undoubtedly its sanctions-crippled oil and gas sector. ’Iran clearly has huge resources. Its production has been curtailed in recent years,’ oil company BP said in a statement. ‘It clearly has a lot of potential.’ It cautioned, however, that ‘this is likely to be a very complicated political process.’” (AP, “European businesses rushing to find Iran bonanza,” 1/22/14)

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"Speaking to reporters ahead of a meeting of the Organization of the Petroleum Exporting Countries, Iran's oil minister, Bijan Zanganeh, said, 'We have no limitations for U.S. companies.' Asked who he would like to see return or enter Iran, he named European giants Total SA, Royal Dutch Shell PLC, Eni SpA, Statoil ASA and BP PLC...'I am talking to some of them,' he said, without saying which...BP's name stands out in this group of European companies because it didn't enter Iranian projects after the Islamic Revolution. BP's predecessor company, Anglo-Iranian Oil, played a controversial role under the previous regime of the Shah." (Wall Street Journal, "Iran Wants U.S. Companies to Develop Oil Fields," 12/4/13)

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"Britain could be close to agreeing a deal to ease sanctions that have stopped gas production from the North Sea's Rhum field, jointly owned by BP (BP.L) and the National Iranian Oil Co., the Mail on Sunday newspaper said.Production from the field, which once supplied 5 percent of Britain's gas output, has been suspended since 2010 as a result of international sanctions against Iran. But with signs of a thaw in relations between Iran and the West, the government now hopes to win agreement from the European Union and the United States for a sanctions waiver in the near future, the newspaper said, citing people close to the talks. One stumbling block to a deal, however, could be concerns from companies involved in financing and servicing the field that any exemption for the producers would not fully protect them from legal action, it added . . . A spokesman for BP declined to comment on the possibility of a waiver being granted. 'As operator of the field our priorities are two-fold - to ensure the field remains safe and that we remain compliant with the law,' he said. 'It is up to the government to decide on the longer-term options.'" (Reuters, "Britain pushing to ease sanctions on BP gas field," 9/22/12)

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"The U.K. government is in talks with the U.S. and the European Union over a possible exemption to Iranian sanctions that would allow BP BP.LN +0.03% PLC to restart a North Sea natural gas field partially owned by a Tehran-controlled company…BP's Rhum field, in the North Sea, is 50% owned by an affiliate of Iran's state oil company. BP closed it in 2010 amid tightening U.S. and EU sanctions aimed at stopping Iran's nuclear program. It is unclear exactly what shape the possible exemption might take, or whether a deal will be reached in the end. But recent efforts stem from newly adopted EU regulations, which allow exemptions under specific conditions. 'The BP gas field could be exempted from sanctions under an EU Council Regulation adopted in December 2012 amending previous regulation on restrictive measures against Iran,' an EU spokeswoman said. The spokeswoman declined to comment on talks over the exemption. 'We are working with the EU to ensure the long-term security of the Rhum North Sea gas field and will be making an announcement on this in due course,' said a spokeswoman for the U.K.'s Department of Energy and Climate Change. A spokeswoman for the U.S. State Department confirmed discussions had been held with the British government on the issue, but declined to provide details…Rhum is 50% owned by IOC UK, which is controlled by the state-owned National Iranian Oil Co., via a Malaysia-based unit. It was producing around 5.4 million cubic meters of gas a day before it was shut down in 2010, according to BP. That is about 5% of current U.K. output. The joint venture was set up in 1973 when Iran was still ruled by the Shah. Gas was discovered in the field in 1977, but because of the technically challenging nature of the reservoir, it only started producing in 2005. EU officials say it is the only Western-Iranian joint venture of its kind in the bloc." (Wall Street Journal, "U.K. Seeks Exemption From Iranian Sanctions for BP Gas Field," 9/16/13)

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"Several western oil companies also supply jet fuel to the airport - Royal Dutch Shell, BP and Chevron - but they say they source it outside the UAE and in full compliance with sanctions on Iran." (Reuters, "Dubai flights rely on fuel refined from Iranian oil," 4/24/2013)

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"Naftiran owns a 10 percent stake in the Shah Deniz project in Azerbaijan which is co-led by BP and Norway's Statoil and which is estimated to contain 1.2 trillion cubic meters of gas." (Reuters, "EU sanctions target Iran oil, gas, tanker companies," 10/16/2012)

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"Reuters has learned that on February 1, [Iranian oil-trading firm] Naftiran Intertrade increased its holding in British oil giant BP Plc by 1.85 million shares. It now holds a stake worth more than $190 million (121 million pounds). In addition to the shareholding, the Iranian company's ties to BP include the Rhum gas field in the North Sea, a venture that's now suspended due to sanctions. It also has active projects like a gas field with BP in Azerbaijan, and an investment with Royal Dutch Shell in fuel distribution in Senegal . . . A spokesman at BP said the company would not comment on individual shareholders. 'However we regularly review and take legal advice to ensure our compliance with sanctions legislation. We remain confident that BP is in full compliance with all applicable sanctions regimes including UN, EU regulations and US law, and will remain in compliance,' he said. 'We continue to monitor the situation closely' . . . Under the European sanctions, if a corporate entity is believed to have reasonable cause to suspect that it may be making funds available - either directly or indirectly - to someone on the sanctions list, British or European authorities could investigate or even prosecute." (Reuters, "Special Report - For Iran oil trader, Western ties run deep," 2/16/12)

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"Refiners in South Africa include Shell, BP, Total, Chevron, petrochemicals group Sasol , and Engen, majority-owned by Malaysian state oil group Petronas. BP, Chevron, Sasol and Engen said earlier this year that they have either stopped or were not sourcing any Iranian crude. Trade data from March showed, however, that imports of Iranian crude had gone up from the previous month." (Reuters, "S.Africa keen to replace Iranian crude with Nigerian," 5/24/2012)

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"While some open sources reported that BP sold gasoline to Iran in 2009 or 2010, other open sources reported that BP stopped selling gasoline to Iran in 2008." (U.S. Government Accountability Office, Report: "Firms Reported in Open Sources to Have Sold Iran Refined Petroleum Products between January 1, 2009 and June," September 3, 2010)

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BP continues to be actively engaged in the Iranian petroleum industry through joint ventures with Iranian oil companies. BP is currently partnering with the Iranian governmental-controlled Naftiran in the North Sea and Azerbaijan; these projects are worth over $2.4 billion per year (Time Magazine, "Sleeping with the Enemy: BP's Deals with Iran", 6/18/2010).

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"Still, given all the controversy over Iran's nuclear program, many companies decline to discuss their Iranian oil purchases. Companies like Shell and BP have said they have stopped selling gasoline to Iran.

But they rarely mention that they continue to buy crude or other Iranian oil products, which generally is a much larger and more lucrative business than gasoline deliveries" (The Wall Street Journal. "Oil Trade with Iran Thrives Discreetly," 5/20/10).

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"BP, in a 2009 filing with the Securities and Exchange Commission, said it had interests in and was the operator of two fields and a pipeline located outside Iran in which the National Iranian Oil company had an interest. The company also said in the filing that it buys small quantities of crude oil from Iran for sale to third parties in Europe and for its own refineries in South Africa and Europe and, through a joint venture, blends small quantities of lubricants for sale there. In addition, BP was one of several companies that provided Iran with gasoline, but Toby Odone, a spokesman for BP in London, said the company decided in 2008 to cease such shipments."  The company was alloted 3.5 million acres from the US government for their business in Iran during 2000-20009.  Their investments in Iran are currently active. (The New York Times, "Profiting from Iran, and the US," 3/6/2010)

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"An AP review of corporate SEC filings found dozens of companies that have done business in Iran in recent years or said their products or services may have made it there through other channels. Some are household names: PepsiCo, Tyson Foods, Canon, BP Amoco, Exxon Mobil, GE Healthcare, the Wells Fargo financial services company, Visa, MasterCard and the Cadbury Schweppes candy and beverage maker." (Associated Press, "From bull semen to bras, Iran still buys American," July 9, 2008)

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"In recent months, Iran has, according to the respected trade publication International Oil Daily and other sources including the U.S. government, purchased nearly all of this gasoline from just five companies, four of them European: the Swiss firm Vitol; the Swiss/Dutch firm Trafigura; the French firm Total; British Petroleum; and one Indian company, Reliance Industries." (Orde F. Kittrie, Op-Ed, "How To Put The Squeeze On Iran," The Wall Street Journal, November 13, 2008)

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Listed by U.S. Government as doing business in Iran. (U.S. Securities and Exchange Commission, List of Companies Doing Business With State Sponsors Of Terror, Removed from the internet in July of 2007)

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"Last Friday, Thyssen-Krupp, a steel-making conglomerate, said a representative of Iran - the company's third biggest shareholder - no longer would hold a seat on its supervisory board. In remarks to shareholders, Thyssen-Krupp supervisory board chairman Gerhard Cromme said he regretted having to remove the Iranian, but failure to do so would have created considerable economic disadvantages for the company. Thyssen-Krupps move came as BP chief executive officer John Browne reiterated that the oil company would refrain from exploring business opportunities in Iran." (The Globe and Mail, "Two big EU firms ease ties with Iran," January 28, 2005)

GE and Baker Hughes will cease operations in Iran in accordance with U.S. law. The trade licenses that the company had been operating under are expected to be revoked in November. (Forbes, 6/8/2018).

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According to its Annual report filed with the SEC for fiscal year 2018: "In January 2016, the U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) issued General License H authorizing U.S.-owned or controlled foreign entities to engage in transactions with Iran if these entities meet the requirements of the general license. On May 8, 2018, President Trump announced that the United States will cease participation in the Joint Comprehensive Plan of Action (JCPOA) and begin re-imposing the U.S. nuclear-related sanctions. On June 27, 2018, OFAC revoked General License H and added Section 560.537 to the Iranian Transactions and Sanctions Regulations (ITSR), which authorized all transactions and activities that are ordinarily incident and necessary to the winding down of activities previously approved under General License H through November 4, 2018. Prior to May 8, 2018, certain non-U.S. BHGE affiliates conducted limited activities, as described below, in accordance with General License H. As of November 5, 2018, non-U.S. BHGE affiliates have concluded all activity previously conducted under General License H in Iran. These activities were conducted in accordance with all applicable laws and regulations.
During the year ending December 31, 2018, but prior to the expiration of the wind down period for General License H, non-U.S. BHGE affiliates conducted the following reportable activities:
•
A non-U.S. affiliate of BHGE received five purchase orders and attributed €31.4 million ($36.0 million) in gross revenues and €8.6 million ($9.9 million) in net profits related to the sale of valves and parts for industrial machinery and equipment used in gas plants, petrochemical plants and gas production projects in Iran.

• A second non-U.S. affiliate of BHGE received 12 purchase orders and attributed €0.1 million ($0.1 million) in gross revenues and less than €0.1 million ($0.1 million) in net profits to the sale of valves and other spare parts for use in the petrochemical industry in Iran.
• A third non-U.S. affiliate of BHGE attributed €0.3 million ($0.3 million) in gross revenues and €0.1 million ($0.1 million) in net profits to transactions involving the sale of films used in the inspection of pipelines in Iran.

These non-U.S. affiliates do not intend to continue the activities described above. The Company has ended all of these activities in full compliance with U.S. sanctions and at this time does not intend to seek specific U.S. Government authorization to collect revenues associated with previously reported projects.

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According to its Annual Report filed with the SEC for fiscal year 2016: "In January 2016, the U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) issued General License H authorizing U.S.-owned or controlled foreign entities to engage in transactions with Iran if these entities meet the requirements of the general license. Pursuant to this authorization, a non-U.S. BHGE affiliate received seven purchase orders during the fourth quarter of 2017 for the sale of goods pursuant to General License H that could potentially enhance Iran’s ability to develop petroleum resources. The purchase orders cover the sale of valves and parts for industrial machinery and equipment used in gas plants, petrochemical plants and gas production projects in Iran. These purchase orders are valued at less than €0.1 million ($0.1 million), less than €0.1 million ($0.1 million), less than €0.1 million ($0.1 million), €0.3 million ($0.3 million), €0.7 million ($0.8 million), €0.1 million ($0.1 million) and €0.8 million ($1 .0 million). This non-US affiliate also received a cancellation of a previously reported contract for the sale of spare parts for gas turbines. This purchase order cancellation reduces previously reported contract values by €12.3 million ($12.9 million). This non-U.S. affiliate attributed €6.8 million ($8.2 million) in gross revenue and €1.4 million ($1.7 million) in net profits against previously reported transactions during the quarter ending December 31, 2017.
A second non-U.S. BHGE affiliate received three purchase orders during the fourth quarter of 2017 for the sale of spares parts to support the development of offshore petroleum resources. The three purchase orders are individually valued at less than €0.1 million ($0.1 million), less than €0.1 million ($0.1 million), and less than €0.1 million ($0.1 million) each. This non-U.S. affiliate did not recognize any revenue or profit during the quarter ending December 31, 2017.
A third non-U.S. BHGE affiliate received a purchase order pursuant to General License H valued at €0.2 million ($0.2 million) during the fourth quarter of 2017. The non-U.S. affiliate also received a purchase order at the very end of the third quarter valued at €0.3 million ($0.3 million). Both purchase orders cover the sale of films to be used in inspection of pipelines in Iran. This non-U.S. affiliate did not recognize any revenue or profit during the quarter ending December 31, 2017. All of these non-U.S. affiliates intend to continue the activities described above, as permitted by all applicable laws and regulations."

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"Baker Hughes, through its foreign subsidiaries, had done work in Iran's oil and gas sectors, but decided several years ago to get out of both Iran and Sudan. A spokesperson said that the company finished all major warranty work it was contractually obligated to do in 2007."  The company has received $7.6 million in revenue and benefits from the US government for their business in Iran during 2000-2009.  They have since withdrawn their investments in Iran. (The New York Times, "Profiting from Iran, and the US," 3/6/2010)

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"At first, even companies incorporated in the United States - including such Schlumberger rivals as Halliburton, Weatherford, and Baker-Hughes - got around US sanctions by utilizing their overseas subsidiaries to perform work in Iran. Then the Sept. 11, 2001, terrorist attacks sparked federal investigations into whether US personnel were involved in the subsidiaries operating in Iran. Facing tighter scrutiny, negative publicity, and investor anger, all three of Schlumberger's main American competitors pulled out of Iran." (The Boston Globe, "Oil firm sidesteps sanctions on Iran," 12/7/08)

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"More importantly, even the threat of unilateral sanctions has been effective as recently as last year. As state after state has ramped up efforts to divest pension funds from companies invested in Iran, and as S 970, the Smith-Durbin Iran Counter-Proliferation Act, has garnered support in Congress, American companies like General Electric, Halliburton, and Baker Hughes with subsidiaries operating in Iran have rethought the wisdom of doing business with one of our nations most dangerous enemies. And as the United States has contemplated additional unilateral banking sanctions on Iran, banks across Europe have ratcheted back their exposure to the Islamic Republic, with some pulling out entirely." (AEI, The Iran Counter-Proliferation Act of 2007, April 21, 2008)

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"'Baker Hughes left Sudan in December and since then has been only doing warranty work stemming from contracts in Iran,' spokesman Gary Flaharty said. 'Baker Hughes is not starting new work in Iran,' he said." (The Houston Chronicle, "Weatherford to leave sanctioned countries," 9/11/07)

We note the following online reference to an ANZ Bank office apparently
located in Tehran, Iran (http://www.privatebanking.com/directory/middle-east-iran-tehran/banksrep-
offices/anz-bank-26).

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In August 2016 ANZ refused Australian customers’ transactions with Iran, fearing US Treasury’s reaction.

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Listed by U.S. Government as doing business in Iran. (U.S. Securities and Exchange Commission, List of Companies Doing Business With State Sponsors Of Terror, Removed from the Internet in July 2007)

"We have banned sales to and have no operational sites or employees in Iran. Previous to May 2018, certain limited sales were made in accordance with international agreements and sanctions." (Atlas Copco website)

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Atlas Copco is listed on the March 1, 2022 report to the New Jersey Legislature Iran Divestment as a prohibited company.

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Atlas Copco, headquartered in Nacka, interrupts its business with Iran. 
This, according to President Trump's message that the United States imposes sanctions on the country. "We have been following developments continuously and have made this decision," said Sara Liljedal, Press Manager at Atlas Copco. (Nackajätte bryter med Iran (Trump Effect – Nacka giant breaks with Iran),” Mitti (Sweden), August 7, 2018.) 

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In 2017, the U.S. state of Iowa listed Atlas Copco on its state lists of Companies Doing Business with the Iranian Petroleum/Natural Gas, Nuclear and Military Sectors, rendering Atlas Copco ineligible for investment and/or state contracting.

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According to the Atlas Copco website, “Atlas Copco has appointed a distributor and will use this company as a vehicle for expansion on the Iranian market.”  Atlas Copco Website, “Complex markets: Iran”

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"Atlas Copco has had a branch in Iran for the past 30 years, according to Senior Vice President Hans Sandberg. The company primarily sells compressors, mining and construction equipment and services there, with sales of about $15 million to $20 million a year, he said. The company has received contracts from several United States federal agencies, including the Fish and Wildlife Service to the Department of Defense."  The company received $9.2 million in benefits and revenue from the US government for their investments in Iran, during 2000-2009.  Their business in Iran is currently active. (The New York Times, "Profiting from Iran, and the US," 3/6/2010)

The Iranian Tamkar Gas Equipment Company states on its website that it and a consortium of foreign companies, including Swiss GreenField and German MAN group, signed a contract in 2003 to provide equipment for 57 compressed natural gas refueling stations. According to Tamkar's website, the company is manufacturing the CNG refueling stations under GreenField's license. GreenField notes on its website that it was purchased by Atlas Copco in March 2007 and continues to operate within the Atlas Copco family.

In 2005, another company, Intermech Ltd. was acquired by Atlas Copco South Pacific Holdings Pty Limited of Australia. Through its relationship with Atlas Copco, the company lists an office in Tehran on its website.

According to the government of New Zealand, Intermech Ltd. and Iranian Pars Compressor Co. won a $20 million joint contract in August 2003 from the Iran Fuel Consumption Optimization Organization to build CNG refueling stations throughout Iran. According to a company press release, Intermech shipped 25 packages of equipment to Iran in April 2009; the "order was a follow up after the first successful shipment of 50 packages in 2008."

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Atlas Copco has an Iran portal and lists that it has an office in Tehran, Iran on its company website.

According to the company's website location map, they are no longer located in Iran.

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ABB's Annual Report filed with the SEC for fiscal year 2020 states: "In 2018, certain non-U.S. subsidiaries of ABB, in accordance with applicable laws, provided electrical equipment, automation systems and on-site services to OEMs, distributors, panel builders, EPC contracting companies and other customers for Iranian business. ABB discontinued its Iranian business on November 4, 2018. ABB is completing minor work on a long-term contract which is being performed in line with applicable sanctions. The revenues attributable to these products and services in 2020 amounted to approximately $2 million."

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ABB is featured on the website of the Iranian firm, DIBAGARAN FARAYAND (DIFACO).

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

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"The company was reported as potentially seeking business opportunities in Iran In 2018 CalPERS designated the company as under review. In 2019 CalPERS changed the designation to “being monitored” because CalPERS’ initial screening has not identified the company as having involvement in the regions and/or activities targeted by the Act. CalPERS has maintained the company in “monitor” status for 2020. CalPERS continues to monitor the company for possible changes in status relevant to the Act."

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

• According to its website, Amitis is an authorized representative for ABB in Iran. (http://amitistech.com/abb-instruments-tools). 

• "The U.S. Iran Threat Reduction and Syria Human Rights Act of 2012 requires U.S. listed companies to disclose information relating to certain transactions with Iran. In 2018, certain non-U.S. subsidiaries of ABB, in accordance with applicable laws, provided electrical equipment, automation systems and on-site services to OEMs, distributors, panel builders, EPC contracting companies and other customers for Iranian business. The revenues attributable to these products and services in 2018 amounted to approximately $81 million, of which $31 million is attributable to our discontinued operations. ABB discontinued its Iranian business in 2018, except for minor work on a few long-term contracts which is being performed in line with applicable sanctions." (United State Securities and Exchange Commission, "20-Form F," 3/28/2019). 

• In 2017, ABB Ltd. disclosed that it had reopened its Iranian office and had started to seek business in the country. ABB Ltd. had previously been removed from the Iran-related securities list. In 2017, CalSTRS designated ABB Ltd. as “Under Review” for potentially having new ties to Iran. In 2018, CalSTRS removed ABB Ltd. after reviewing the company’s business in Iran and internal controls to prevent sanction violations.
• ABB is reviewing international sanctions developments regarding Iran and finalizing existing contracts in line with such developments. “Sensitive Countries,” ABB, June 2018.
• Six delegates from ABB are listed as registered delegates at the 3rd Europe-Iran forum that took place from May 3-4, 2016 in Zurich, Switzerland. (Registered Delegates and Press at the 3rd Europe-Iran Forum).
• According to its Annual Report filed with the SEC in 2013: "In 2012, certain non-U.S. subsidiaries of ABB, in accordance with applicable laws, provided electrical equipment and site services to customers in the power and minerals sectors that are owned or controlled by the government of Iran. The gross revenues attributable to these deliveries and services in 2012 amounted to approximately $3 million and had a net profit of less than $0.5 million. In December 2012, ABB completed or exited all of its then remaining business in Iran. This concluded a process which started with ABB's decision in November 2007 to wind down its business in that country."
• "California’s department of general services, which awards its public contracts, has contacted more than 150 companies seeking clarification regarding Iran. The companies include... ABB, the Swiss electrical engineering group. ABB said it had adopted new policies regarding Iran: a statement on its website says that in May 2011 it 'decided to complete its exit from all business in the oil and gas sector in Iran by the end of September.'" (Financial Times. "California tightens screw on trade with Iran," 6/27/11)
•  "In an October 2008 filing with the Securities and Exchange Commission, ABB said it did $372 million in business with Iran from 05-07, and a smaller amount to Syria, primarily selling products like power generation equipment and semiconductors. This January, the company announced it had stopped taking orders for new business and was winding down work on existing contracts." The company received $266.5 million in revenue and benefits from the US government between 2000 and 2009. Their business in Iran is active but they have not had any new investments. (New York Times, "Profiting from Iran, and the US" 3/6/2010)
•  ​​​“Swiss engineering group ABB AG has stopped taking new orders in Iran with a view to ending operations there, a spokesman said on Sunday, confirming a newspaper report.‘It's been some time since we've taken any new orders,’ ABB spokesman Wolfram Eberhard said, adding the company had stopped doing so more than 12 months ago. "We're finishing up old contracts."He said ABB now employed some 30 people in Iran, down from 100, and that many of its contracts had been for infrastructure projects and had run into financing difficulties. He said he had no exact date for when all business would be finished.” (Reuters, “ABB, other Swiss firms halting Iran business,” 1/31/10)
• New York State Comptroller Thomas P. DiNapoli also announced Tuesday the $110 billion fund would freeze an additional $300 million in seven other companies...The decision comes after two years of reviewing these companies, the potential risk of the investments and, in some cases, humanitarian efforts in these countries. "We don't expect our investments to benefit regimes that support genocide and terrorism," said DiNapoli...The fund also plans to monitor and prohibit further investment in ENI (E), Repsol YPF (REP), Royal Dutch Shell PLC (RDSA), Total SA (TOT), ABB Ltd. (ABB), Alstom (ALO.FR) and Snam Rete Gas (SNMRY). Additionally, it plans to focus on other industries including telecommunications. (Wall Street Journal, "NY Comptroller To Divest $86.2M In State Pension Fund Investments," 6/30/09 and The Office of New York State Comptroller Thomas P. DiNapoli)
• A source familiar with the naughty list says both ABB, a Swiss engineering giant that does business in Iran, and the China National Petroleum Corp., which operates in Sudan, are included. (TIME, "Rules of Disengagement," 5/12/08)
• Listed by U.S. Government as doing business in Iran. (U.S. Securities and Exchange Commission, List of Companies Doing Business With State Sponsors Of Terror, Removed from Internet in July 2007)
• ...ABB Swiss bank, Credit Suisse, the agrochemical firm, Syngenta, and the engineering group, second biggest and Total, as well as the Siemens"The blacklist is based on latest annual reports of the companies. They are mostly non-U.S. and include Unilever, Cadbury,HSBC, Nokia,
• ABB's business activities with Iran will continue but account for less than 1 percent of the company's sales, according to spokesman Wolfram Eberhardt." (Xinhua, " Swiss Company Irritated Over U.S. Blacklist," 7/2/07)
• For its part, ABB said an "information offensive" was needed to explain its position to investors. The engineering group has been doing business with Iran, according to the SEC list...