Malaysia

On June 1, 2020, the Ohio Police & Fire Pension Fund (“OP&F”) listed Suria KLCC on its scrutinized companies Iran/Sudan list.   On September 24, 2008, OP&F adopted an Iran and Sudan Divestment Policy, which notes, “[t]he purpose of this Policy is to divest and restrict the purchase of stocks and bonds (“direct holdings”) issued by a publicly traded Company… with “scrutinized active business operations” in Iran and Sudan.”  

According to publicly accessible ship-monitoring data, since January 1, 2016, vessels for which MBC is the Group Owner have called at Iranian ports.

According to publicly accessible ship-monitoring data, since January 1, 2016, vessels for which Duta Marine is the Group Owner and Operator have called at Iranian ports.

According to publicly available shipping information, Container Ship ONYX 1 (IMO: 9270804), managed by Blue Ocean Ring, has called at Iranian ports on four occasions since November 5, 2018, most recently in March 2019.

"According to the defendant’s guilty plea, from 2008 until late 2011, Ghodskani was a Tehran-based employee of Fanavar Moj Khavar (Fana Moj), a company located in Tehran, Iran. In 2009, Ghodskani, along with co-defendant Alireza Jalali and others, established Green Wave Telecommunication, Sdn Bhn, (Green Wave), a company located in Kuala Lumpur, Malaysia, that operated as a front for Fana Moj. As part of the conspiracy, Ghodskani falsely represented herself as an employee of Green Wave to U.S. companies in order to acquire export-controlled technology from the United States. To accomplish these acquisitions, Ghodskani, Jalali and others concealed the ultimate destination and end users of the exported technology." (Iran Watch, "Iranian Citizen pleads Guilty to Conspiring to Facilitate the Illegal Export of Technology to Iran," 8/9/2019).

On September 19, 2007, Petronas Dagangan was added to the Florida State Board of Administration List of Prohibited Investments (Scrutinized Companies) due to its involvement in Iran. As of March 9, 2021, Petronas Dagangan remains on the SBA list of prohibited investments. 

--

In 2020, the U.S. state of Mississippi listed Petronas Dagangan 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.

--

Petronas Dagangan is listed on the June 4, 2019 and July 12, 2019 Florida State Board of Administration list of prohibited investments (Scrutinized companies) for Iran related business.

--

Petronas Dagangan Bhd is listed on the Alaska Retirement Management Board's March 2019 and June 2019 list of companies doing business with Iran.

On June 16, 2011, Petronas Chemicals was added to the Florida State Board of Administration List of Prohibited Investments (Scrutinized Companies) due to its involvement in Iran. As of March 9, 2021, Petronas Chemicals remains on the SBA list of prohibited investments. 

--

In 2020, the U.S. state of Mississippi listed Petronas Chemicals 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.

--

Petronas Chemicals is listed on the June 4, 2019 and July 12, 2019 Florida State Board of Administration list of prohibited investments (Scrutinized companies) for Iran related business.

--

Petronas Chemicals Bhd is listed on the Alaska Retirement Management Board's March 2019 and June 2019 list of companies doing business with Iran.

A Malaysia-based front company;

Controlled by Saeed Valadbaigi, an Iranian businessman under indictment in the United States for allegedly attempting to export nuclear nonproliferation-controlled materials from the United States to Iran;

From 2009 to 2012, was allegedly used by Valadbaigi in an attempt to transship controlled U.S.-origin 7075 T6 aluminum tubing (ECCN 1C202.a) and to transship 4130 steel and 9310 steel from Industrial Metals and Commodities (IMC) in Belgium through Malaysia to Iran without the required licenses; in 2009, was allegedly used by Valadbaigi to transship U.S.-origin titanium sheets through the Republic of Georgia, the United Arab Emirates (UAE), and Malaysia to Iran without the required licenses;

Uses virtual office services provided by Servcorp, uses Servcorp’s Kuala Lumpur address in shipping forms;

In August 2012, was the subject of a post-shipment verification visit by a U.S. Department of Commerce Export Control Officer (ECO);

Conducts general trading and provides management services;

Incorporated in Malaysia in 2008, dissolved as of July 20, 2018; (Source: Federal Register)

On March 18, 2014, Putrajaya was added to the Florida State Board of Administration List of Prohibited Investments (Scrutinized Companies) due to its involvement in Iran. As of March 9, 2021, Putrajaya remains on the SBA list of prohibited investments. 

--

In 2020, the U.S. state of Mississippi listed Putrajaya 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.

--

On June 1, 2020, the Ohio Police & Fire Pension Fund (“OP&F”) listed Putrajaya Management on its scrutinized companies Iran/Sudan list.   On September 24, 2008, OP&F adopted an Iran and Sudan Divestment Policy, which notes, “[t]he purpose of this Policy is to divest and restrict the purchase of stocks and bonds (“direct holdings”) issued by a publicly traded Company… with “scrutinized active business operations” in Iran and Sudan.”  

-

On June 8, 2017, the Protecting Florida’s Investments Act (“PFIA”) was signed into law. The PFIA requires the State Board of Administration (“SBA”), acting on behalf of the Florida Retirement System Trust Fund (“FRSTF”), to assemble and publish a list of “Scrutinized Companies” that have prohibited business operations in Sudan and Iran. Once placed on the list of Scrutinized Companies, the SBA and its investment managers are prohibited from acquiring those companies’ securities and are required to divest those securities if the companies do not cease the prohibited activities or take certain compensating actions. As of May 28, 2020, the Florida State Board of Administration (“SBA”) continues to list Putrajaya Management on its list of “Scrutinized companies with Activities in the Iran Petroleum Energy Sector.” 

--

On January 13, 2020, the South Dakota Investment Council submitted a report to the Executive Board of the Legislative Research Council regarding compliance with SDCL 4-5-48 to 4-5-60, Iran Divestiture. Included in this report is an Iran Scrutinized Companies list of all prohibited investments for which the internal managers and direct external managers are instructed not to purchase any company on the list. Putrajaya Management is included on this list.  

--

As of December 31, 2019, the Alaska Retirement Management Board lists Putrajaya Management as a company doing material business with Iran.  

--

Putrajaya is listed on the June 4, 2019 and July 12, 2019 Florida State Board of Administration list of prohibited investments (Scrutinized companies) for Iran related business.

--

Putrajaya is listed on the June 2019 Alaska Retirement Management Board, Companies Doing Material Business with Iran list.

--

Putrajaya is listed on the March 2019 Alaska Retirement Management Board, Companies Doing Material Business with Iran list.

--

On March 13, 2019, the Mississippi Department of Finance & Administration identified Putrajaya Management 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.”  

--

In 2017 the U.S. state of Alaska, Florida, Mississippi, listed Putrajaya Management on its list of companies doing material business with Iran rendering Putrajaya Management ineligible for investment and/or state contracting.

--

In 2018 the U.S. state of Iowa, Ohio listed Putrajaya Managements an Iran restricted company rendering Putrajaya Management ineligible for investment and/or state contracting.

--

In 2014, 2015, 2016 and 2017 Putrajaya Managements was listed on the Texas Pension Review Board List of Scrutinized Companies doing business in Iran pursuant to Chapter 807.054, Government Code.  

In 2017 the U.S. state of California listed MMC as a company under review for possibly providing consulting projects on Iranian energy projects.