Japan

“The Japan Energy Group engages in a comprehensive array of upstream and downstream activities, from petroleum exploration and development, refining, and petroleum product sales to liquefied petroleum gas (LPG), lubricants, and petrochemical products” (Company website).

"The Japan Energy is a core group company operating under the JX Holdings,Inc. JX Holdings has been established through the joint share transfer by Nippon Oil Corporation and Nippon Mining Holdings, Inc. All the businesses of the both Group Companies shall be integrated, restructured and reorganized under JX Holdings, resulting the incorporation of three core business companies, Petroleum Refining and Marketing Business Company, Oil and Natural Gas Exploration and Production Business Company and Metals Business Company, which is scheduled to be made on July 1, 2010” (Company website).

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As of April 2010, Japan Energy imports 75 thousand barrels of crude oil per day from Iran. (Reuters, "Iran’s Crude Oil Buyers in Europe, Asia," April 18 2010)

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News sources in late 2007 reported Japan Energy switching from dollars to yens to pay for Iranian crude oil: “Recent reports indicate that Japanese refiners Cosmo Oil Co. and Japan Energy Corp. have decided to stop paying Iran in US dollars in exchange for oil imports, following Iran's request. By asking its customers to pay in currencies other than the dollar, Iran aims to counter US pressure and protect itself against the weakening American currency."

"Japan Energy is the country's sixth-largest refiner that consumes around 400,000 barrels a day of crude. Around 12 percent of that amount comes from Iran" ("Oil bourse update: Japanese to pay Iran in Yen," October 9, 2007).

Iranian company Diesel Motor A.F.Z. (“Diesel Motor”) cites Hitachi as a customer on its company website. (Diesel Motor Website, “Home”).

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"Hitachi Ltd. has signed a preliminary agreement to supply advanced equipment and technology for the Persian Gulf Bid Boland Gas Refinery project in the southern Khuzestan Province. The agreement includes the supply of compressors, vapor recovery units and gas storage equipment by the Japanese conglomerate, NIPNA, the official portal of the National Petrochemical Company, reported on Tuesday." (July 2017)

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United Against Nuclear Iran (UANI) on Thursday announced that Japanese technology conglomerate Hitachi has decided to end its business in Iran. Following discussions with UANI, Hitachi this week informed UANI that it "has stopped all new business with Iran and is in the process of winding down contracts pre-existing our policy directive to end all new business." (UANI Press Release, "UANI Applauds Hitachi for Ending Its Business in Iran, Following Discussions with UANI", 12/1/2011) 

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Hitachi has installed ten highly advanced H-25 gas turbines since 2007 (Hitachi Website. “Thermal Power Systems: Experience”) and over 17 induction motors for industrial plants in the Iranian energy sector since 2006.  One of the end-users for these induction motors was the Arak Petrochemical Corporation, a company listed by the British government as an entity of potential concern for WMD-related procurement. (Hitachi Website. “Induction Motor. Supply Record: Iran”; Iran Watch. “Arak Petrochemical Corp”)

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Hitachi has provided the Ghadir Urea and Ammonia Petrochemical Company (“Ghadir”) with seven induction motors since 2008.  Ammonia and urea both have widely recognized military uses.  Ammonium nitrate fertilizer, for example, “is used to make 95% of the bombs in Afghanistan (Global Security. “Explosives– Ammonium Nitrate”).  The Iranian government’s National Petrochemical Company owns a 48 percent share of Ghadir and has also been listed as an entity of potential concern for WMD related procurement (Iran Watch. “National Petrochemical Company”).  

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Hitachi's subsidiary, Hitachi Construction Machinery Middle East, published an article about its dealers on its website, in which it discusses Iran-based Touranto Co P.J.S, a “privately owned company (that) supplies earth moving/material handling machinery and accessories to America, Asia and Europe from leading manufacturers such as Bobcat, Terex, Indeco, Montabert, and of course Hitachi” (Hitachi Company Website). 

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In 2010, Hitachi Construction Machinery Middle East hosted a seminar with Touranto employees to increase product support revenue

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Hitachi global website lists Parkish Co. in Tehran as a service center (Hitachi Global Website).
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In a 2007 Correspondence with the SEC, Hitachi said the following (SEC correspondence with Hitachi, 3/30/2007):

"We have de minimis contacts in each of the five countries, Iran, the Sudan, Syria, North Korea and Cuba, designated as state sponsors of terrorism by the U.S. State Department. Total revenues received from all of the five countries combined were approximately ¥10 billion ($84 million), ¥8 billion ($67 million) and ¥4 billion ($37 million) for the years ended March 31, 2006, 2005 and 2004, respectively, which constitute approximately 0.1%, 0.09% and 0.05% of our consolidated revenues of respective fiscal year. We do not believe that the operations, either individually or in the aggregate, constitute a material investment risk to our security holders.  

Revenues to these countries primarily comprise maintenance of thermal power plants, sales of turbo compressors for oil refining plants, induction motors for industrial plants, construction machinery, flat panel TVs and DVD cameras. In the year ended March 31, 2004, we recorded revenues amounted approximately ¥0.2 billion ($1.4 million) from sales in North Korea, which represent sales by Hitachi, Ltd. of nuclear power equipment through the Korean Peninsula Energy Development Organization, a multi-lateral organization established by the U.S., South Korea and Japan, following the agreement between the U.S. and North Korea aiming to freeze and ultimately dismantle North Korea’s nuclear program.

We have no assets or liabilities in any of these countries. Revenues during these periods were derived from sales to unaffiliated third parties by Hitachi, Ltd. and certain of our subsidiaries. The sales into these countries were immaterial to each of these entities.

We anticipate that our sales into the aforementioned countries will not change significantly in the near future, unless there is a dramatic change in the political and security climate in these countries. Due to the immaterial amount of sales into these countries both individually and in the aggregate, we do not believe that these operations constitute a material investment risk to our security holders." 

Iranian electronic and telecommunications company Tavanco lists dozens of Panasonic products far sale on its website, including IP Terminals, Business Communications Servers and other telecommunications products.
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Listed as an approved vendor in Iran by NIOEC, NPC, NISOC, NIGC and IOOC.

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Panasonic lists multiple Iranian offices on its website.  The company has sales offices in Ahwaz, Isfahan, Mashhad, Shiraz and Tehran (Company Website).

The website www.panasoniciran.com names Alborz Taban Co. as "an authorized distributer of Panasonic brand Office Automation and CCTV products in Iran."

Listed as an approved vendor in Iran by NIOEC, NPC and SADAF.

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Seiko Epson Corporation (Epson) is an independent company part of corporate group, Seiko Group. Seiko Epson manufactures computers and peripherals, and other information and imaging equipment. According to their website, Epson is “a global technology company at the forefront of technological revolutions in imaging, robotics, precision machinery and electronics. Epson offers an extensive array of award-winning image capture and image output products for the consumer, photographic, business and graphic arts markets. The company is also a leading supplier of value-added point-of-sale (POS) printers and transaction terminals for the retail market” (Company Website).

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According to Business Monitor International, “Iran has long had more significant manufacturing capacity in computer peripherals, particularly printers and monitors… The first printers, from Olivetti and Epson, were assembled in Iran in 1994” (Business Monitor International, "Iran Q2 2010 (Market Overview Article)," 3/2/10).

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Maadiran Group features Epson products on its homepage. (Maadiran Group Website)

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Business Monitor International recognizes Maadiran Group as "one of Iran's largest consumer electronics and IT firms.”

“In 2007, Maadiran Group began mass production of five models of LG phones, adding to existing contracts for the assembly of LG monitors, Epson dot matrix printers and Olivetti bank slip printer. LG is an important brand for Maadiran. In 2008, the company was targeting the production of 850,000 LG-branded LCD and CRT monitors, and planned to increase its volume to 940,000 in 2009. Maadiran is also licensed to produce around 14,000 dot matrix printers for Epson annually.”

“Maadiran is an exclusive distributor for Sharp, LG, Olivetti, Epson and a number of other brands” (Business Monitor International, "Company Profile - Maadiran Group - Q2 2010.", 3/2/10).

Seiko Group includes Seiko Holdings Corporation, Seiko Epson and Seiko Instruments, all of which do business in Iran. Seiko Holdings Corporation primarily produces watches, and has a variety of divisions that deal with electronics, including Seiko NPC Corporation, which manufactures semiconductors (Company Website).

Seiko Instruments also produces semiconductor products, along with other electronic components, precision parts and technology (Company Website).

Seiko Epson manufactures computers and peripherals, and other information and imaging equipment. (Company Website).

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Seiko has a service center in Tehran. Company Website

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According to Business Monitor International, “Iran has long had more significant manufacturing capacity in computer peripherals, particularly printers and monitors… The first printers, from Olivetti and Epson, were assembled in Iran in 1994” (Business Monitor International, "Iran Q2 2010 (Market Overview Article)"  March 2, 2010).

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Maadiran Group features Epson printers on its homepage. Maadiran Group Website

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Business Monitor International recognizes Maadiran Group as "one of Iran's largest consumer electronics and IT firms."

"In 2007, Maadiran Group began mass production of five models of LG phones, adding to existing contracts for the assembly of LG monitors, Epson dot matrix printers and Olivetti bank slip printer. LG is an important brand for Maadiran. In 2008, the company was targeting the production of 850,000 LG-branded LCD and CRT monitors, and planned to increase its volume to 940,000 in 2009. Maadiran is also licensed to produce around 14,000 dot matrix printers for Epson annually."

"Maadiran is an exclusive distributor for Sharp, LG, Olivetti, Epson and a number of other brands" (Business Monitor International, "Company Profile - Maadiran Group - Q2 2010 Iran."  March 2, 2010).

Sharp manufactures consumer/information products and electronic components, including LCDs, solar cells, and other electronic devices (Company Website).

According to its website, “At Sharp Electronics Corporation, a U.S. subsidiary of Osaka-based Sharp Corporation - a company known worldwide for its unique one-of-a-kind electronic products and solutions, our challenge is to create a balance between work time and personal time, with products that can benefit people's lives at work, at home, and everywhere in between” (Company Website).

Sharp is a leading solar manufacturer, powering “more homes and businesses than any other solar manufacturer in the world.” Sharp uses semiconductors to create utility-scale solar cells for government use (Company Website).

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The Maadiran Group, “Iran's leading office equipment and technology systems supplier, manufacturer, and after-sales service provider,” features Sharp products on its home page. (Maadiran Group Website).

The Iran Office Machines Center, one of the three subsidiaries comprising Maadiran, "is the exclusive distributor in Iran for Olivetti, Optoma, Plustek, Epson, Sharp, LEXMARK, MEVA and LG Electronics." (Maadiran Group Website)

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According to Business Monitor International, Sharp has a long history of business in Iran: “While US vendors are restricted from direct involvement in the market, their Asian rivals, in particular, have fewer inhibitions. Many, including Samsung, LG and Sharp, have hastened to take advantage of the opportunity presented to them by building up distribution and even production strength in the country.”

“Iran has long had more significant manufacturing capacity in computer peripherals, particularly printers and monitors…Sharp has been perhaps the biggest player and was the brand of the first fax machine and first notebook computer to be produced in Iran in 1984 and 1985 respectively.”

“Iran's AV device production capacity is growing. In the 2005/06 fiscal year, Iran produced around 768,209 colour TV sets and 562,473 radios and cassette players, according to government figures. The industry started to develop in the 1990s with the first LCD projector, from Sharp, being manufactured in 1991 and the first CRT monitors in Iran from LG in 1993” (Business Monitor International, "Iran Q2 2010 (Market Overview Article)," March 2, 2010).

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Sharp electronics are sold elsewhere in Iran, through Hadid Persian Electronics. (Iranian Wholesale Website).

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Sharp’s corporate social responsibility policy states, “Sharp is committed to being a socially responsible company, conducting its operations with concern for the impact of its activities on its customers, suppliers, employees, communities and other stakeholders, as well as the environment. The company aims an overall positive impact on society by contributing to the culture, benefits, welfare and quality of life for people throughout the world, for its prosperity as a company is directly linked to the prosperity of the entire Sharp family.” (Company Website).

"The company was reported as potentially providing engineering services for power and gas processing plants 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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"JGC Holdings Corporation reportedly provides engineering services for power plants and gas processing plants in Iran. In 2017, CalSTRS designated JGC Corporation as “Under Review” for potentially having ties to Iran. CalSTRS maintained the “Under Review” status in 2018. In 2019, CalSTRS designated JGC Corporation as “Being Monitored.” In 2020, CalSTRS removed JGC Holdings Corporation after further review of the company’s internal controls to prevent sanction violations."

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On February 14, 2020, Iowa Public Employees' Retirement System removed JGC from its list of Iran Prohibited Companies.

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

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"In January 2017, Iran finalized talks with Japanese and South Korean companies to optimize oil refining process in two old refineries in Tehran and Bandar Abbas.

Based on a plan, the JGC Corporation and JCCP (Japan Cooperation Center, Petroleum) was supposed to renovate Tehran’s refinery." (Tasmin News, "Iran Begins Bartering for Oil Projects," 7/12/2019). 

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In 2017, CalSTRS designated JGC Corporation as “Under Review” for reportedly providing engineering services for power plants and gas processing plants in Iran. CalSTRS maintained the “Under Review” designation in 2018.
 

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Tehran Oil Refinery has signed a memorandum of understanding with two Japanese companies, JGC Corporation and Marubeni Corporation, on enhancing gasoline quality and quantity as well as reducing mazut output, the refinery’s managing director said. (May 7, 2018)

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In 2017 the U.S. state of California listed JGC Corporation as a company under review for reportedly providing engineering services for power plants and gas processing plants in Iran. 

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Lists an office in Tehran Iran on its company website.

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JGC was hired as a contractor to design the expansion of the National Iranian Oil Refining and Distribution Company's Arak refinery.

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JGC maintains an overseas office in Tehran, Iran. (JGC website."Global network")

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In 2012, JGC was removed from the Pennsylvania Treasury's List of Scrutinized Companies Determined as Having Involvement in Iran because its was considered to have "past involvement."

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In 2011, JGC 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 correspondence with Minnesota's State Investment Board in 2011: "JGC CORPORATION (“JGC”) is not participating in any project in Iran, neither as engineer/constructor nor as investor. Moreover, JGC has no revenue, outstanding contracts and assets in Iran, nor conducts any activities in the mineral-extracting, nuclear, defense or other sectors in that country."
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"Japanese energy producer Inpex Corp. (1605.TO) and plant maker JGC Corp. (1963.TO) are included in a list of companies that have been confirmed by the U.S. Government Accountability Office to have either signed an agreement to conduct business, invested capital or received payment for providing goods or services in connection with a Iranian oil, gas, or petrochemical projects during the 2005-09 period.

Inpex has been engaged in the development of the Azadegan oil field in southwestern Iran, and JGC participated in expanding a refinery located in Arak, western Iran, according to the GOA report, which was released April 22.

Members of the U.S. Congress are debating legislation that would impose unilateral sanctions against Iran over its uranium processing activities." (Down Jones Newswires, "Japan Not Too Worried Inpex, JGC On US Sanctions List," 4/27/10)

Fuji Heavy Industries' subsidiaries Subaru and Subaru Robin reportedly do business with Iran.

Subaru's parent company is Fuji Heavy Industries.

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"As a result, a variety of automotive brands are being presently imported into Iran including Toyota, BMW, Mercedes Benz (these three being the expensive and/or luxury brands), Rover, Ssangyong, Audi, Subaru, Rio LS, Hyundai (Sonata and Azar1), Citroen, Daimler-Chrysler, Proton, Countach, Volkswagen, Renault Leon, Altea..." (Business Wire, "Iran Ranked as the 16th Biggest Automaker of the World in the Year 2006," 6/10/07)

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"Another Japanese auto giant is going to situate itself in Iran's import-thirsty auto market this year. The sales of about 2500 Legacy sedans by Subaru are the prelude to this venture on the agenda, the Persian service of ISNA reported on Monday. The company, the fifth recent importer after Toyota, MB, BMW and Audi, will target the market with 2000cc version of Legacy to rival Toyota Camry in the coming May. Two other SUV-style models, Impreza and Forester, are expected to follow suite in the near future." (Payvand News. "Subaru to target Iran with Legacy model," 4/11/06)

"While identified by CalPERS in 2015 as not meeting threshold criteria for consideration under the Act, in 2017 the company was reported as potentially having operational trade business in Iran helping coordinate various types of businesses between Japanese and Iranian companies. 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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In 2020, the U.S. state of Mississippi listed Toyota Tsusho on its state lists of Companies Doing Business with the Iranian Petroleum/Natural Gas, Nuclear and Military Sectors, rendering it ineligible for investment and/or state contracting.

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On January 20, 2020, Minnesota SBI listed Toyota Tsusho as a scrutinized investment. The managers are explicitly instructed to refrain from purchasing securities on this list.

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On March 13, 2019, the Mississippi Department of Finance & Administration identified Toyota Tsusho as a company “engaged in investment activities in Iran, providing funds, goods or services valued at $20,000,000 or more in the energy sector of Iran

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In 2018, the California State Public Employees Retirement System (“CalPERS”) designated Toyota Tsusho “Under Review.” In 2019, CalPERS designated Toyota Tsusho as “Being Monitored” because CalPERS “initial screening has not identified the company as having involvement in the [activities] targeted by the [2019 California Public Divest from Iran] Act.

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In 2017, CalSTRS designated Toyota Tsusho Corp. as “Under Review” for reportedly having an operational trade business in Iran which helps coordinate various types of businesses between Japanese and Iranian companies. CalSTRS maintained the “Under Review” designation in 2018.In 2019, CalSTRS removed Toyota Tsusho from its list.

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In 2017 the U.S. state of California listed Toyota Tusho Corp as a company under review for reportedly having an operational trade business in Iran which helps coordinate various types of businesses between Japanese and Iranian companies.

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

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Subsidiary of Toyota Group.

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In 2016 Tennessee used the South Carolina list of "Entities Ineligible to Contract with the State of South Carolina or any Political Subdivision of the State per the Iran Divestment Act of 2014, S.C. Code Ann." as its list of persons it determines engage in investment activities in Iran. Toyota Tusho was included on this list in 2016. "Inclusion on this list would make a person ineligible to contract with the state of Tennessee, if a person ceases its engagement in investment activities in Iran, it may be removed from the list."

In 2018 Tennessee used the New York list of “Entities determined to be non-responsive bidders/offerers pursuant to the New York State Iran Divestment Act of 2012.” BPCL was included on this ist in 2018. Tennessee states "Inclusion on this list would make a person ineligible to contract with the state of Tennessee, if a person ceases its engagement in investment activities in Iran, it may be removed from the list."

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According to Reuters, Toyota Tsusho maintains its business relations with Iran. (Reuters, “Japan's JX renews Iran term crude contracts for 2016 – sources,” 1/5/2016).

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

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"Besides Mitsubishi, another trading house, Toyota Tsusho has been also lifting Iranian crude since April for the top two buyers, the sources added."a href="http://www.reuters.com/article/2012/06/22/japan-iran-mitsubishi-idUSL3E8HM3VC20120622">Japan's Mitsubishi renews Iran oil imports deal," 6/22/12)

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In 2011, Toyota Tsusho 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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" In 2009, Iran exported about 421,000 bpd of crude to Japan. It was overtaken by Qatar, however, as Japan's third-largest crude supplier.  Many of Japan's top refiners buy Iranian crude, including Showa Shell Sekiyu (5002.T), Nippon Oil (5001.T), Japan Energy, Cosmo Oil (5007.T). Trading house Toyota Tsusho (8105.T) also has a deal to buy crude from the Islamic republic." (Reuters, "Iran's crude export and fuel import customers," 4/13/2010)