Japan

According to publicly accessible ship-monitoring data, since January 1, 2016, vessels for which Eastern Car Liner is the Operator have called at Iranian ports.

According to publicly accessible ship-monitoring data, since January 1, 2016, Daiichi Chuo-owned vessels have called at Iranian ports on several occasions.

On the official website of Zist Tajhiz Pooyesh Company, Gastec Corporation is mentioned as their official business partner. Zist Tajhiz Pooyesh Company is added on February 3, 2017 to the Specially Designated Nationals (SDN) list maintained by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) for suppling goods to Mabrooka Trading, which procures items for Iran-based Navid Composite, a subsidiary of U.N.-sanctioned Sanam Industries Group;

Japan’s Fuji Oil Co., which will not make a final decision until after discussions with the government and other refineries, will likely replace Iranian shipments with shipments from Saudi Arabia, Qatar, and the United Arab Emirates if it has to. JXTG Holdings Inc., a refiner, plans to follow government guidance, and if necessary will replace Iranian supplies with supplies from the Middle East, West Africa, and possibly the United States. (June 29, 2018).

"The IRISL signed the memorandum of understanding (MOU) with Japan's Suzue Corporation and Kamigumi in Singapore, Iran's Maritime News Agency reported on April 4. Under the deal, the sides will survey grounds for cooperation in construction of dry ports and investment in Iran's port terminals. Once the preliminary studies are completed, the sides will sign an operational contract." (April 2017)

According to its Annual Report filed with the SEC for fiscal year 2018: "During the fiscal year ended March 31, 2018, Nomura Research Institute, Ltd. (“NRI”), an affiliate in which we hold, directly and indirectly, 38.5 % of the outstanding share capital, has engaged in meetings and discussions on potential business development with entities that are or may be owned or controlled by the Government of Iran. There were no revenues or profits arising directly from these meetings and discussions.

In addition, NRI entered into several contracts with an investment and development company and a governmental organization, both of which are owned or controlled by the Government of Iran, pursuant to which NRI agreed to perform benchmark investigations, conduct comparative analyses and provide other consulting services to facilitate development projects. During the period covered by this report, these contracts and related activities generated gross revenues of ¥8,579,814. Due to costs of providing services, there were no profits attributable to these contracts.

Further, NRI entered into contracts with another entity pursuant to which NRI receives certain services related to the work that NRI is performing for the aforementioned investment and development company and governmental organization. These contracts did not, on their own, generate any revenues or profits for NRI. After consultation with NRI and on the basis of information publicly available to us, we believe that this other entity is a private entity that is not owned or controlled by the Government of Iran.

NRI also made payments to the Government of Iran to obtain entry visas to travel to Iran in connection with the activities described above.

Sanctions relief regarding Iran was implemented in 2016 in accordance with the Joint Comprehensive Plan of Action (“JCPOA”) reached by the permanent members of the United Nations Security Council (China, France, Russia, the United Kingdom and the United States), Germany, the EU, and Iran to ensure that Iran’s nuclear program is used for peaceful purposes. Despite the JCPOA, certain activities, including transactions involving targeted Iran-related persons and entities and transactions that implicate U.S. jurisdiction, remain subject to sanctions. However, on May 8, 2018, President Trump announced his decision to cease the United States’ participation in the JCPOA and to re-impose the U.S. nuclear-related sanctions targeting Iran that were lifted under the JCPOA. In conjunction with this announcement, President Trump issued a National Security Presidential Memorandum (“NSPM”) directing the Secretary of State and the Secretary of the Treasury to prepare immediately for the re-imposition of all of the U.S. sanctions lifted or waived in connection with the JCPOA, to be accomplished as expeditiously as possible and in no case later than 180 days from the date of the NSPM. As a result, new business that is contrary to the re-imposed sanctions will be sanctionable immediately upon re-imposition, and business that pre-dates May 8, 2018 will be subject to wind-down periods of 90 days or 180 days, as applicable, following which parties will be exposed to the risk of sanctions or an enforcement action under U.S. law.

In light of the above, NRI intends to discontinue the activities described above."

--

During the fiscal year ended March 31, 2017, certain non-U.S. affiliates of the Company engaged in the following activities with entities that are or may be owned or controlled by the Government of Iran:

  •   Nomura Research Institute, Ltd. (“NRI”), an affiliate in which we hold, directly and indirectly, 37.2% of the outstanding share capital, has engaged in meetings and discussions on potential business development with entities that are or may be owned or controlled by the Government of Iran. There were no revenues or profits arising directly from these meetings and discussions.In addition, NRI entered into several contracts with an investment and development company, which is owned or controlled by the Government of Iran, pursuant to which NRI agreed to perform benchmark investigations, conduct comparative analyses and provide other consulting services to facilitate development projects. Performance under these contracts is ongoing. During the period covered by this report, these contracts and related activities generated gross revenues of $1,743,500 and estimated net profits of $261,525. Further, NRI entered into a contract with another entity pursuant to which NRI receives certain services related to the work that NRI is performing for the aforementioned investment and development company, and performance under this contract is also ongoing. This contract did not, on its own, generate any revenues or profits for NRI. After consultation with NRI and on the basis of information publicly available to us, we believe that this other entity is a private entity that is not owned or controlled by the Government of Iran.

NRI also entered into a contract with an entity pursuant to which NRI receives certain services related to the exploration of business opportunities in Iran in the cardiovascular treatment field, and performance under this contract is ongoing.

--

According to its Annual report filed with the SEC for fiscal year 2016: "During the fiscal year ended March 31, 2016, certain non-U.S. affiliates of ours engaged in the following transactions or dealings with entities that are or may be owned or controlled by the Government of Iran.

• Nomura Asset Management Co., Ltd., Nomura Asset Management Malaysia Sdn. Bhd. and the Dubai Branch Office of Nomura Asset Management U.K. Limited, our direct and indirect wholly-owned subsidiaries, have engaged in discussions on business development with entities owned or controlled by the Government of Iran. Certain of our non-U.S. affiliates made payments to the Government of Iran to obtain entry visas to travel to Iran in connection with these discussions.
• Nomura Research Institute, Ltd., an affiliate in which we hold, directly or indirectly, 36.8% of the outstanding share capital, has engaged in discussions on business development with entities that are or may be owned or controlled by the Government of Iran. Certain of our non-U.S. affiliates made payments to the Government of Iran to obtain entry visas to travel to Iran in connection with these discussions.
• Nomura International plc, our indirect wholly-owned subsidiary, has interacted with a multilateral development financial institution that supports the economic development of its member countries, largely in Africa, the Middle East and Southeast Asia, in connection with a potential financing transaction for the client of the institution. The Government of Iran holds a minority ownership interest in this institution. Nomura International plc has had no direct dealings with the Government of Iran and, on the basis of information available to us, we do not believe that the Government of Iran controls this institution.

These activities were conducted in accordance with applicable law, and we do not believe that the activities were sanctionable under applicable law. We have not generated any revenues from these activities during the period covered by this report.

In light of recent changes in the international economic sanctions regime relating to Iran, we intend to continue to engage in the activities described above and may engage in similar activities in future periods; however, any such activities will be conducted in accordance with all applicable laws, and we do not intend to engage in any activities that are sanctionable under applicable law."

On February 16, 2021, Iowa Public Employees' Retirement System removed Mitsubishi Materials from its Iran Prohibited Companies List. 

--

As of December 2020, Rhode Island continues to list Mitsubishi Materials as an Iran scrutinized company for active involvement of at least $20-50 million in Iran's energy sector.

--

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

--

In 2018 the U.S. state of Iowa listed Mitsubishi Materials as an Iran restricted company rendering Mitsubishi Materials ineligible for investment and/or state contracting.

--

In 2017 the U.S. state of Rhode Island, South Carolina listed Mitsubishi Materials on its list of companies doing material business with Iran rendering Mitsubishi Materials ineligible for investment and/or state contracting. 

During the fiscal year ended March 31, 2017, Minebea Intec GmbH and Minebea Intec Bovenden GmbH & Co. KG, both majority-owned subsidiaries of MINEBEA MITSUMI, sold measurement equipment, such as weighing cells, to both two joint venture companies involving the Iranian Ministry of Petroleum and/or the National Petrochemical Company of Iran, as well as four other Iranian petrochemical companies, in each case in the ordinary course of business. The revenue from the transactions with the two joint venture companies for the fiscal year were 1,000 Euro and 24,000 Euro, respectively. The revenue from the transactions with the four other Iranian petrochemical companies for the fiscal year were 62,000 Euro, 6,000 Euro, 4,000 Euro and 3,000 Euro, respectively. Altogether, these transactions contributed an insignificant amount in net profits to MINEBEA MITSUMI. MINEBEA MITSUMI believes that the above transactions do not subject it or its affiliates to U.S. sanctions. Minebea Intec GmbH and Minebea Intec Bovenden GmbH & Co. KG do not currently intend to cease selling the products described above to the above entities.

According to its Annual Report filed with the SEC for fiscal year 2019: "We had approximately 0.4 million MAUs in Iran in December 2019, and our business with Iran represented approximately 0.002% of our revenues in 2019, which consisted primarily of sales of Stickers and in-game items in the ordinary course of business. In February 2017, LINE PLAY Corporation, which is owned by LINE Plus Corporation, our wholly-owned subsidiary in Korea, established a local branch in Iran, which subsequently ceased all operations and remains closed as of December 31, 2019."

--

According to its Annual Report filed with the SEC for fiscal year 2018: "We had approximately 0.8 million MAUs in Iran in December 2018, and our business with Iran represented approximately 0.006% of our revenues in 2018, which consisted primarily of sales of Stickers and in-game items in the ordinary course of business. Our website containing media content directed at users in Iran, which we had launched in May 2016, was closed in November 2018. In February 2017, LINE PLAY Corporation, which is owned by LINE Plus Corporation, our wholly-owned subsidiary in Korea, established a local branch in Iran, which subsequently ceased all operations and remains closed as of December 31, 2018."

--

 "On May 5, 2016, we launched a website containing media content directed at users in Iran. In February 2017, LINE PLAY Corporation, which is owned by LINE Plus Corporation, our wholly-owned subsidiary in Korea, established a local branch in Iran, which subsequently ceased all operations and remains closed as of December 31, 2017. LINE Plus Corporation met with officials from a governmental research institute in Iran in conjunction with our market research initiatives in Iran, and in January 2017, entered into a two-month research contract with the Iran Telecommunication Research Center (ITRC) to gain a better understanding of the Iranian mobile market and relevant regulatory considerations. We did not generate any revenue from the contract, which expired in 2017." (2017)

--

According to its Annual Report filed with the SEC for fiscal year 2016: "In December 2016, we had approximately four million MAUs in Iran. In addition, LINE provides Official Accounts to local Iranian celebrities and engages in promotional activities directed at users in Iran. On May 5, 2016, we launched a website containing media content directed at users in Iran. LINE Pay is available to users in Iran, Cuba, Sudan and Syria. Our business with Iran represented approximately 0.03% of our revenues for the year ended December 31, 2016. In February 2017, we established a local branch through our subsidiary, LINE PLAY Corporation. Our subsidiary, LINE Plus Corporation, has met with officials from the Government of Iran in conjunction with our business expansion efforts in Iran. In January 2017, LINE Plus Corporation entered into a two month research contract with the Iran Telecommunication Research Center (ITRC). The purpose of the research contract was for LINE to explore business opportunities in Iran and gain a better understanding of the Iranian mobile market and relevant regulatory considerations. We will not generate revenue from the contract, and we do not plan to renew the contract."

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