Netherlands

Louis Dreyfus Commodities Metals is listed as an attendee at the Iranian Base Metals Conference that took place from September 6-7, 2016 in Tehran, Iran. (Iranian Base Metals Conference Attendees, 2016).

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"The world's largest commodity trading houses are first in line to profit from the much expected return of Iran to global markets as Tehran and Washington enter into the final three-months of nuclear talks. While the global oil industry has been seen as the biggest beneficiary of a thaw, commodities traders including Cargill Inc. Glencore Plc, Vitol BV, Trafigura Beheer BV and Louis Dreyfus Commodities BV have a long history in Iran, helping to export its oil and import daily basics like gasoline, wheat and rice... 'We like other people have talked to the Iranians,' Vitol CEO Ian Taylor said in an interview. 'They used to be major players in the markets, but obviously none of us will do anything unless sanctions are actually lifted.'" (Bloomberg, "Top Commodity Trading House Line Up for Iran's Return to Market," 4/20/15)

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Over the last three presidential administrations, the United States government has granted Louis Dreyfus Corporation 19 special licenses to do business in Iran. (New York Times, "Companies with Permission to Bypass Sanctions," 12/24/10)

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"The company was licensed to export “poultry, meat, cotton” and bulk agricultural commodities to both Sudan and Iran. The bulk commodities ranged from kidney beans and lentils to sunflower oil and beet sugar." (New York Times, "Licenses Granted to U.S. Companies Run the Gamut," 12/24/10)

Noted for conducting business with Iranian banks. (Avi Jorisch, "Iran's dirty banking," 2010)

Former name for Airbus.

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EADS is a global leader in aerospace and defense. Germany, France, the Netherlands and Spain all own a stake in the company. Notable subsidiaries of EADS including the airplane manufacturer Airbus and the helicopter manufacturer Eurocopter.

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In 2005, it was also reported that EADS provided nuclear parts to Iran through sales to a South Korean company, Kyung-Do Enterprises:  “The French firm EADS Sodern was one such company involved in the illegal transactions though it was unaware of the final destination of its exports.” Iran purchased 300 units of Nickel 63 from the South Korean company: “This radioactive material is needed for firing electrons used in a nuclear bomb’s trigger mechanism.” (Iran Focus, “Iran acquiring nuclear parts from Europe,” 7/25/05)

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“Since the European Union does not impose restrictions on sales of civil products to Iran, Eurocopter and AgustaWestland market their products in the country, but the US sanctions restrict the Europeans’ offerings to just a few models.” (Globalsecurity.org, “Iran Aviation Industry”)

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 In April 2005, Aviation International News reported that “Eurocopter is well represented in Iran. Last year it won the state tender to supply three AS 365N3 Dauphins outfitted for search-and-rescue and maritime surveillance. Those helicopters, scheduled to be delivered next year, will be the first Dauphins in the nation… Eurocopter estimates Iran’s total demand for civil helicopters to be 100 to 150 units during the next two or three years… Eurocopter predicts that the Dauphin will be the best-selling helicopter in the nation in the years ahead.”

“Last year Iran’s Ministry of Industry and Mines took delivery of an AS 350B3 to use for geological survey. The manufacturer also delivered six AS 350B3s to the Ministry of Oil for Helicopter Services Organization, which is using the new models to supplement its two AS 350B2s, the first French-made helicopters delivered to Iran after the Islamic Revolution under 2000 and 2002 deals.”

“Eurocopter also provides support for the Alouette IIIs and BO 105s operators acquired before the revolution that remain operational with civilian organizations. A total of 30 of these aging types remain airworthy and operate mostly with Helicopter Services Organization.” (Aviation International News, “Helo makers find market in Iran,” April 2005)

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In February 2005, EADS and its subsidiary Eurocopter, marketed their products at that year’s Iran Air Show. When questioned about the American sanctions on Iran, an EADS representative stated, “ As a European company, we're not supposed to take into account embargoes from the U.S.” He added, “The emphasis here is on our civil helicopters. We are not offering military helicopters here.” Nonetheless, a military helicopter was “prominent on the company's video in Iran.” (MSNBC, “European Firms Display Wares in Iran,” 2/23/05)

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See Video: Corresponding NBC Nightly News Investigative Report on European defense firms doing business in Iran. (NBC Nightly News, “European Defense Firms Eager to Sell to Iran”)

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Eurocopter was also an exhibitor at the 2007 Iranian Air Show. (2008 Iran Kish Air Show, “Exhibitors”)

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ATR is an Italian-French aircraft manufacturer and a joint venture of EADS and Finmeccanica, which each own a 50% stake of the company. The EADS website lists in 2002 that ATR sold one ATR 72-500 aircraft to Iran Aseman Airlines (EADS Website, “ATR results in line with 2002 objectives,” 1/22/03). The ATR 72 model is a short-haul regional airliner. Other ATR aircraft are active in Aseman’s Airlines fleet (Aseman Airlines website, “About Us”)

According to its Annual Report filed with the SEC in 2013: "We have not conducted, and do not intend to conduct, any further business activities in Iran or with Iranian counterparties."

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According to an Annual report filed by LyondellBasell affiliate Evertec, "Certain non-U.S. subsidiaries of our predecessor, LyondellBasell AF, licensed processes to construct and operate manufacturing plants in Iran that produce polyolefin plastic material, which is used in the packaging of household and consumer goods. The subsidiaries also provided engineering support and supplied catalyst products to be used in these manufacturing operations. In 2009, the Company made the decision to suspend the pursuit of any new business dealings in Iran.

As previously disclosed by the Company, in 2010, our management made the further decision to terminate all business by the Company and its direct and indirect subsidiaries with the government, entities and individuals in Iran. The termination was made in accordance with all applicable laws and with the knowledge of U.S. Government authorities. As part of the termination, we entered into negotiations with Iranian counterparties in order to exit our contractual obligations. As described below, two transactions occurred under settlement agreements in early 2012, although the agreements to cease our activities with these counterparties were entered into in 2011. In January 2012, one of our non-U.S. subsidiaries received a final payment of approximately €3.5 million for a shipment of catalyst from an entity that is 50% owned by the National Petrochemical Company of Iran.

Our shipment of the catalyst was in February 2012 as part of the agreement related to our termination and cessation of all business under agreements with the counterparty. In 2012, the gross revenue from this limited activity was approximately, €4.2 million and profit attributable to it was approximately, €2.4 million.

In January and February of 2012, one of the Company’s non-U.S. subsidiaries provided certain engineering documents relating to a polyolefin plastic process to a licensee comprising three Iranian companies, one of which is 20% owned by the National Oil Company of Iran. The provision of documents was the Company’s final act with respect to the termination and cessation of all business under agreements with the counterparties. No gross revenue or profit was attributable to this activity in 2012. The transactions disclosed in this report do not constitute violations of applicable anti-money laundering laws or sanctions laws administered by the U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC), and are not the subject of any enforcement actions under the Iran sanction laws. We have not conducted, and do not intend to conduct, any further business activities in Iran or with Iranian counterparties.”"

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“LyondellBasell Industries NV, one of the world's biggest plastic and chemical producers, will end its business operations in Iran to shield itself against penalties the U.S. could soon impose on companies for violating trade sanctions.” (The Wall Street Journal, “LyondellBasell Will Quit Iran,” 8/5/10)

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Firm/country: LyondelBasell/The Netherlands;

Firm activity: Supplying technology for new HDPE petrochemical plant in Kermanshah, increasing capacity by 300,000 metric tons per year;

Status: Expected completion 2009 to 2010;

Commercial activity: Not reported;

Firm comment: Confirmed activities. Noted that profits from the two projects are small compared to its European operations.

(GAO report 2010 - "Firms Reported in Open Sources as Having Commercial Activity in Iran’s Oil, Gas, and Petrochemical Sectors")

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"Lyondell Basell Company had previously participated in Amirkabir and Jam petrochemical complexes’ development plans. National Petrochemical Company’s Project Manager Jalil Ebrahimpour said for his part that the abovementioned petrochemical complexes are parts of the Dena ethylene pipeline, each with the annual projected HDPE output of 300,000." (Tehran Times, "World praises Iran’s petrochemical achievements: LyondellBasell exec," 6/10/2009) 

ABN AMRO is currently owned by the Royal Bank of Scotland Group.

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On its website, ABN AMRO states that it "has a stricter policy regarding trade with the countries below [including Iran]. Are you trading or are you going to trade with one of these countries? Then we ask you to always contact the bank in advance. We can then inform you about the (im)possibilities to carry out transactions for you. You limit the risk that we will not execute your transaction on the basis of legal or internal provisions. Regularly check the ABN AMRO website and the authorities such as the UN, EU and US. You will then be sure that you have the most up-to-date information."

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"Dutch bank ABN AMRO ABNd.AS said it had facilitated transactions [with Iran] related to food, healthcare, medical equipment and agriculture to a limited extent and with specific clients. But it also told Reuters 'the recent restrictive measures on Iranian banks do pose challenges.'" (Reuters, "Global traders halt new Iran food deals as U.S. sanctions bite - sources," 12/21/18)

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"Since 2009, the Justice Department, the Treasury Department and the Manhattan district attorney’s office, working largely in concert, have brought charges against five foreign banks, contending they moved billions of dollars through their American subsidiaries on behalf of Iran, Cuba and North Korea, sponsors of terrorism and drug cartels. The cases against the five banks all included deferred prosecution agreements and required the banks — ABN Amro, Barclays, Credit Suisse, Lloyds and most recently ING — to forfeit a substantial amount of assets. The cases typically have not involved United States banks. Unlike foreign institutions, American banks were prohibited from originating or receiving such transactions from Iran. That enabled them to largely sidestep the conduct that has helped ensnare foreign banks." (New York Times, "Deutsche Bank’s Business With Sanctioned Nations Under Scrutiny," 8/17/12)

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"ABN AMRO Bank, now owned by Royal Bank of Scotland Group, agreed in 2006 pay $70 million in penalties assessed by U.S. regulators related to alleged dealings with entities from Iran and Libya." (Daily Mail, "Obama to target Lloyd's of London in plan for tougher sanctions on Iran," 10/2/09)

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"A new line of investigation has focused on banking relationships. In December, ABN Amro paid $80m in penalties after it was found to have violated rules on dealing with Iran and Libya, while UBS paid $100m in 2004 after admitting breaches of rules on transactions with Iran, Libya, Cuba and Serbia. Both ABN Amro and UBS have reduced their Iran operations, as has Credit Suisse. But it has emerged that the Justice Department is probing three more banks - HSBC, Standard Chartered and France's BNP Paribas." (The Independent, “UK banks caught in Iran sanctions probe,” 2/5/06)

"KLM, the Dutch subsidiary of Air France-KLM, said on Friday it had ceased flying over Iran and Iraq only after the downing of a Ukrainian plane on January 8." (JPost, "Air France-KLM: Stopped flying over Iran after downing of Ukraine plane," 1/17/2020).

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"Dutch airline KLM says it will halt flights to Tehran “as a result of the negative results and financial outlook” following the U.S. withdrawal from the Iranian nuclear accord. The airline, part of the Air France KLM group, made the announcement in a short statement on its website Saturday. KLM said its last flight will leave Amsterdam on Sept. 22 and return on Sept. 23." (July 8, 2018).

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"Dutch flag carrier KLM has resumed flights to Iran after a three-year hiatus. Carrying a Dutch trade mission, headed by Minister of Infrastructure and Environment Melanie Schultz van Haegen, on board, a KLM flight landed in Tehran’s Imam Khomeini International Airport on Sunday at 00:05 Tehran local time. “KLM has tried to strengthen its network by adding Tehran as its 14th new destination in 2016,” KLM President and Chief Executive Officer Pieter Elbers was quoted by the news portal of Iran’s Ministry of Roads and Urban Development as saying. As per the new schedule, four weekly services will be operated on Sunday, Tuesday, Thursday and Friday between Amsterdam Airport Schiphol and Tehran." (Financial Tribune, "KLM Lands in Tehran for 1st Time in 3 Years," 10/24/2016). 

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Daily flights from Tehran's Imam Khomeini Airport(IKA) to multiple counties in Europe (Company Website)

KLM and Air France "have become the largest European airline group: one group, two airlines, and three businesses." (KLM Website, "Air France KLM") 

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"Air France-KLM will suspend its Amsterdam-Tehran service starting April 2013, a spokesman for the carrier said. It currently flies to Iran four times a week." (Reuters, "Two airlines suspend Iran flights as economy weakens," 1/12/2013)

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"The company operates regular flights to and from Iran. The airline has flown the route on and off since 1948, a spokeswoman said. The company received loan guarantees from the U.S. Export-Import Bank to purchase airplanes from Boeing."  From 2000-2009, the company was the recipient of $1.4 billion US federal funds.  Their business in Iran is currently active.  (The New York Times, "Profiting from Iran, and the US," 3/6/2010)

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"Some major Western airlines were continuing to fly to Tehran, though, namely Lufthansa, Austrian Airlines, KLM and Alitalia." (The Daily Star, "Airlines stop Iran flights as currency crisis bites," 10/8/2012)

According to its Annual Report filed with the SEC for 2019: "Unilever operates in Iran through a non-US subsidiary. In 2019, sales in Iran were significantly less than one percent of Unilever’s worldwide turnover. During the year, this non-US subsidiary had approximately €1,334 in gross revenues and less than €547 in net profits attributable to the sale of food, personal care and home care products to the Hotel Homa Group, which is owned by the Social Security Organization of Iran, and IRR Mohammad Rasoullah Pharmacy & Kowsar ‘Veterans of IRGC’, which are affiliated with the Islamic Republic Revolutionary Guard Corps. Income, payroll and other taxes, duties and fees (including for utilities) were payable to the Government of Iran and affiliated entities in connection with our operations. Our non-US subsidiary maintains bank accounts in Iran with various banks to facilitate our business in the country and make any required payments to the Government of Iran and affiliated entities. While we currently continue our activities in Iran, we are continuously evaluating such activities in the light of the evolving regulatory environment."

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Unilever N.V. (a Dutch company) disclosed in 2016 that its non-U.S. subsidiary, among other relevant transactions, “advertised our products on television networks that are owned by the Government of Iran or affiliated entities,” and further noted that “[i]ncome, payroll and other taxes, duties and fees (including for utilities) were payable to the Government of Iran and affiliated entities in connection with our operations” in the country.

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"Unilever, acting through its Iranian subsidiary, has signed a joint venture partnership with Golestan Company, the makers of Golestan tea and one of Iran’s best known consumer goods companies. The agreement was signed on November 29, but was formally announced this week." (December 2017)

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Unilever is one of the companies listed as a speaker at the HR Trends Summit taking place from October 18-19, 2016 in Tehran, Iran. (Speakers).

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"Unilever, which manufactures products like Dove soap, has been in the Iranian market since at least 2003, operating factories there and maintaining an office in Tehran, according to news reports and the company's Web site. It also sells its products to the American military."

From 2000-2009, the company was the recipient of $842.1 million US federal funds.  Their business in Iran is currently active.  (The New York Times, "Profiting from Iran, and the US," 3/6/2010)

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Several renowned German companies are involved in major Iranian infrastructure projects, especially in the petrochemical sector, like Linde, BASF, Lurgi, Krupp, Siemens, ZF Friedrichshafen, Mercedes, Volkswagen and MAN. (Thai Press Reports, IRAN/GERMANY IRANIAN-GERMAN TRADE UP 78%, December 8, 2008)

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Unilevers Turkish holdings, valued at YTL 100 million, are indicators of its faith in the Turkish economy, said local company spokesman Ebru Senel Erim. The Istanbul offices vast market ranges from Iran, Kazakhstan, Uzbekistan, Turkmenistan, Armenia, Georgia, Tajikistan and Azerbaijan in the East to Macedonia, Albania, Moldova, Romania, Kosovo and Bosnia in the West. (Turkish Daily News, ISTANBUL BECOMES MANAGEMENT HUB, December 17, 2007)

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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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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, Christine Seib, May 27, 2006)

According to its Quarterly Report filed with the SEC for the quarterly period that ended March 31, 2020: "In 2013, Schlumberger completed the wind down of its service operations in Iran. Prior to this, certain non-US subsidiaries provided oilfield services to the National Iranian Oil Company and certain of its affiliates (“NIOC”).

Schlumberger’s residual transactions or dealings with the government of Iran during the first quarter of 2020 consisted of payments of taxes and other typical governmental charges. Certain non-US subsidiaries of Schlumberger maintain depository accounts at the Dubai branch of Bank Saderat Iran (“Saderat”), and at Bank Tejarat (“Tejarat”) in Tehran and in Kish for the deposit by NIOC of amounts owed to non-US subsidiaries of Schlumberger for prior services rendered in Iran and for the maintenance of such amounts previously received. One non-US subsidiary also maintained an account at Tejarat for payment of local expenses such as taxes. Schlumberger anticipates that it will discontinue dealings with Saderat and Tejarat following the receipt of all amounts owed to Schlumberger for prior services rendered in Iran."

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As stated in its 2017 SEC 10-K: "Schlumberger’s residual transactions or dealings with the government of Iran during 2017 consisted of payments of taxes and other typical governmental charges. Certain non-US subsidiaries of Schlumberger maintain depository accounts at the Dubai branch of Bank Saderat Iran (“Saderat”), and at Bank Tejarat (“Tejarat”) in Tehran and in Kish for the deposit by NIOC of amounts owed to non-US subsidiaries of Schlumberger for prior services rendered in Iran and for the maintenance of such amounts previously received. One non-US subsidiary also maintained an account at Tejarat for payment of local expenses such as taxes. Schlumberger anticipates that it will discontinue dealings with Saderat and Tejarat following the receipt of all amounts owed to Schlumberger for prior services rendered in Iran.

During the fourth quarter of 2016, a non-US subsidiary entered into a memorandum of understanding (“MOU”) with NIOC relating to the non-disclosure of data required for the technical evaluation of an oilfield project.  In the first quarter of 2017, the Schlumberger subsidiary provided NIOC with written notice that it was terminating the MOU, effective March 11, 2017. The MOU did not involve the provision of services.  During the second quarter of 2017, and in furtherance of the termination of the MOU, the Schlumberger subsidiary had residual dealings with the NIOC consisting solely of the return of client data."  

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In 2017 the U.S. state of Michigan listed Schlumberger on its Iran restricted investment list rendering Schlumberger in eligible for investment and/or state contracting.

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On January 3, 2017, the National Iranian Oil Company (“NIOC”) listed Schlumberger as one of the “designated 29 non-Iranian companies [ ] qualified to participate in its pending tender round for upstream projects.”  (Oil & Gas Journal Website, “NIOC qualifies 29 firms for tender round,” 1/3/2017).  

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Schlumberger reportedly signed a memorandum of understanding in November 2016 with a NIOC subsidiary, National Iranian South Oil Company, “over the development of several southern oil fields.” (Mehr News Agency, “Schlumberger enters Iran again,” 12/26/2016).

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"Schlumberger Ltd., the world’s largest oil driller by market value, said Sunday it had signed a preliminary deal to study an Iranian oil field, as Donald Trump’s presidential victory has yet to deter U.S.-connected companies from dealing with Tehran. The contract is one of the most prominent signed since the Nov. 8 election. Mr. Trump has vowed to undo a nuclear pact with Tehran signed last year by global powers. The pledge has led many international companies to freeze their plans to enter the Islamic Republic despite the country’s huge potential as an energy and consumer market. But a spokesman for Schlumberger, one of the world’s largest oil-services companies, told The Wall Street Journal it has signed a memorandum of understanding with the state-run National Iranian Oil Company “for the non-disclosure of data required for a technical evaluation of a field development prospect.” Though it is incorporated in Curaçao in the Dutch Antilles, Schlumberger has one of its headquarters in Houston, while some of its shares trade in New York. If completed, the deal would be the first in Iran for Schlumberger since European sanctions for the company to leave the country in 2010." (Wall Street Journal, "Schlumberger Signs Early Oil Deal With Iran," 11/28/2016).

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"Schlumberger NV, the world's No.1 oilfield services provider, said it would look at returning to Iran once the sanctions are lifted. 'When the sanctions are lifted and when it is permissible, we will evaluate going back in,' Chief Executive Paal Kibsgaard said on a post-earnings call." (Ahram Online, "Schlumberger says Evaluating Iran Return After Sanctions End," 7/17/15)

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"The U.S. Justice Department said on Wednesday that a subsidiary of Schlumberger Oilfield Holdings had pleaded guilty to violating U.S. sanctions related to Iran and Sudan and would pay a $237.2 million fine. The oil well manufacturing company also agreed to a three-year period of corporate probation, during which it will cease all operations in Iran and Syria and hire an independent consultant to review its policies on complying with sanctions. 'For years, in a variety of ways, this foreign company facilitated trade with Iran and Sudan from Sugar Land, Texas,' U.S. Attorney Ronald C. Machen, Jr. said. 'Today's announcement should send a clear message to all global companies with a U.S. presence: Whether your employees are from the U.S. or abroad, when they are in the United States, they will abide by our laws or you will be held accountable,' Machen warned. In a statement, Schlumberger said it voluntarily ceased oilfield operation in Iran as of the second quarter of 2013 and said it has ceased oilfield operations in Sudan as of the plea agreement." (Reuters, "REFILE-UPDATE 3-Schlumberger Pleads Guilty to Violating U.S. sanctions on Iran, Sudan" 3/25/2015)

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"Oil field services giant Schlumberger Ltd. said in a securities filing that it wound down its operations in Iran, which ran at a loss. The disclosure, made late Wednesday in a securities filing under sanctions law requirements that went into effect in February, said non-U.S. subsidiaries of Schlumberger provided oilfield services to the National Iranian Oil Co. in the first half of the year as the company completed its wind-down of the operations during the second quarter. Schlumberger earned $102 million in revenue during 2013 for the Iranian activity, resulting in a net loss of $69 million, it said in the filing. The company, which is the world’s largest oil field services firm, reported quarterly revenue of $11.2 billion, up more than 8% from the same period in 2012." (The Wall Street Journal, "Schlumberger Discloses Iran Operations Wind-Down, 7/25/2013")

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"Khazar has also been working with Schlumberger, one of the last Western oilfield services firms currently operating in Iran. However, in January, Schlumberger, which has principal offices in Houston, Paris, and the Hague, announced that it will exit the country by the end of this year, after having booked USD 418m in revenue in 2012 through oilfield services provided by 'certain non-US subsidiaries' to the NIOC. 'Schlumberger intends to discontinue such activity in Iran in 2013 and is currently winding down its operations there,' the company stated in its annual report, adding that Schlumberger will leave once its ongoing contracts in the country expire." (Financial Times, "Iran seeks Chinese proxies to further offshore drilling ambitions," 5/31/2013) 

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"The world's largest oil-services company has quietly promised the US State Department that it will pull out of Iran when its current contracts are complete, a spokesman for Schlumberger Ltd. has confirmed, marking what could be a major victory in the US struggle to cut off Iran's access to funds for its nuclear program. 'If it is true, it's huge,' said Richard Modesette, a former Commerce Department special agent. But internal company documents obtained by The Boston Globe show that Schlumberger - which is under investigation for possible sanctions violations - has signed contracts worth hundreds of millions of dollars that it intends to complete before it exits. Those contracts will keep the company, believed to be the last Western oil-services firm in Iran, working in the oil-rich country until least 2013, a delay that has angered some US officials....But if Iran agrees to curb its nuclear program, sanctions could ease by the time Schlumberger’s last contract expires....In that case, the firm could just keep on doing business." (Boston Globe, "Oil firm says it will withdraw from Iran," 11/12/10)

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"The oil exploration giant has long been active in Iran and continues to provide drilling and exploration services to Iran's oil and gas sector, according to filings with the Securities and Exchange Commission. "We work in more than 80 countries around the world, including Iran, and we abide by the rules in those countries," said a company spokesman, Stephen Whittaker, adding: "We don't take a position on what the country does or doesn't do. It is what it is."" 

From 2000-2009, the company was a recipient of $30.7 million US federal funds.  Their investments in Iran are currently active, however there are no plans for new investments.  (The New York Times, "Profiting from Iran, and the US." 3/6/2010)

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Schulmberger lists a regional "Iran GeoMarket" headquarters office in Tehran (Company website, 7/13/09)

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"But the device - developed by the oil-services firm Schlumberger in labs in Connecticut and Texas - was brought to Iran through a legal loophole that allows multinational corporations to use foreign subsidiaries to sidestep US sanctions, according to a Globe investigation. Schlumberger acknowledges that its US-developed tool has been used in Iran, and a spokesman said the company followed all applicable laws and regulations." (The Boston Globe, "Oil firm sidesteps sanctions on Iran," 12/7/08)

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"In the early 1940 s, Texaco paid for its own dealings with hostile regimes such as Nazi Germany and Imperial Japan. And there are similarities with Schlumbergers business in Sudan, Iran and Venezuela, Rewcastle says. Schlumberger is the only major E&P company left in Iran and Sudan, he says. But its operations are well-diversified throughout the world. Its business sprawls over regions where drilling demand is surging, Gengaro says." (Investors Business Daily, "Schlumberger Makes Itself The Go-To Oil Services Firm," 8/1/07)

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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)

KPMG AG Partner Dr. Ulrich von Zanthier spoke at the 7th Banking & Business Forum Iran Europe (“the Forum”) at the Maritim Hotel in Berlin on October 18-19, 2018. (Maleki Website, “7th Banking & Business Forum Iran Europe”).

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April 2010: KPMG has ended its business relationships in Iran. (The New York Times, "Companies Feeling More Pressure to Cut Iran Ties," 4/24/10)

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"Bayat Rayan, a subsidiary of KMPG, has been operating in Iran since 1955. They are the number one international accounting firm in Iran, according to the company. KPMG also provides accounting and auditing services to the United States federal government."  From 2000-2009, the company was the recipient of $1.2 billion US federal funds.  Their business in Iran is currently active.  (The New York Times, "Profiting from Iran, and the US," 3/6/2010)

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Iran is part of KPMG’s MESA (Middle East & South Asia) region. Iran’s country profile lists that there are 60 KPMG professionals in Iran (KPMG Website, “Countries in KPMG’s MESA region”). “Bayat Rayan” is the member firm of the KPMG network representing the company in the country (KPMG, “Iran: Taxation of International Executives,” 2008).

In 2008, KPMG produced a 21-page Iran specific-report, "Taxation of International Executives" (KPMG, “Iran: Taxation of International Executives,” 2008).

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"In addition to its presence in UAE, KPMG is widely represented in the Middle East region and has offices in Bahrain, Qatar, Egypt, Kuwait, Lebanon, Jordan, Oman, Yemen, Saudi Arabia and Iran." (KPMG Release, “KPMG in the UAE announces the results of their business intelligence survey,” 12/17/08)

According to its Annual Report filed with the SEC for 2019: "ING has a policy not to enter into newrelationships with clients from these countries and processes remain in place to discontinueexisting relationships involving these countries. At present these countries are Cuba, Iran, North Korea, Sudan and Syria."

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ING Bank maintains a policy not to enter into new relationships with clients from Iran and processes remain in place to discontinue existing relationships involving Iran. (2017)

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ING Chairman Jeroen van der Veer provided a keynote address at the 3rd Europe-Iran Forum on May 3, 2016.  (Europe-Iran Forum Website, “3rd Europe-Iran Forum: Program”). 

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Despite hopes of a new dawn for Iran's economy after nuclear-related sanctions were lifted, major Western banks are reluctant to do business with the Islamic republic for fear of US retribution. President Hassan Rouhani has said that to reach the target of eight-percent growth needed to modernise the industrial sector and relaunch the hobbled economy, Iran needs up to $50 billion in foreign investment every year. But without the big foreign banks, that looks impossible. "For the moment, the little European banks have agreed to work with us," said Parviz Aghili, head of the private Middle East Bank in Tehran. They include banks from Italy, Austria, Switzerland, Germany and Belgium, he said without naming them. "But not a single medium-sized or big bank has so far agreed to do it," he added... The limited number of institutions that do deal with the Islamic republic include Raiffeisen Bank and Erste Bank from Austria, Mediobanca and Banco Popolare of Italy, Germany's EIH, KfW and AKA banks, Belgium's KBC, ING of the Netherlands and Turkey's Halk, according to a banking expert in Tehran. "These banks have established working relations with the Iranian banks to open letters of credit for fairly small sums of 10, 20 or 50 million dollars." But they lack the resources to finance big projects like the deal struck between Iran and European aircraft manufacturer Airbus for 118 airplanes, or oil and gas development projects, the expert said. (AFP, "Iran banking hobbled by Western reluctance to engage," 9/13/2016).

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"Since 2009, the Justice Department, the Treasury Department and the Manhattan district attorney’s office, working largely in concert, have brought charges against five foreign banks, contending they moved billions of dollars through their American subsidiaries on behalf of Iran, Cuba and North Korea, sponsors of terrorism and drug cartels. The cases against the five banks all included deferred prosecution agreements and required the banks — ABN Amro, Barclays, Credit Suisse, Lloyds and most recently ING — to forfeit a substantial amount of assets. The cases typically have not involved United States banks. Unlike foreign institutions, American banks were prohibited from originating or receiving such transactions from Iran. That enabled them to largely sidestep the conduct that has helped ensnare foreign banks." (New York Times, "Deutsche Bank’s Business With Sanctioned Nations Under Scrutiny," 8/17/12)

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"ING Bank [a subsidiary of ING Group,] has agreed to pay a record penalty of $619 million for illegally moving billions of dollars through the U.S. banking system on behalf of Cuban and Iranian clients and threatening to fire employees if they failed to conceal the origin of the money . . . the bank, a unit of ING Groep NV, one of the Netherlands largest banks, used a system to 'strip,' or delete, references to Cuba and Iran and, through more than 20,000 separate transactions, successfully moved more than $2 billion through the U.S. financial system . . . [ING] engaged in transactions with Iran's central bank and state-owned National Iranian Oil Co."  (Wall Street Journal, "ING Fined a Record Amount," 6/12/12)

Noted for conducting business with Iranian banks. (Avi Jorisch, "Iran's dirty banking," 2010)

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"Dutch bancassurer ING Group NV repeated that it could face 'significant' fines due to a U.S. investigation of operations in countries which are under sanctions by U.S. authorities, such as Iran and Cuba. The United States imposes economic sanctions and export controls on Cuba, Iran, Sudan and Syria, viewing them as state sponsors of terrorism and limiting the scope for companies to do business there... A U.S. judge last August approved a $298 million settlement by British bank Barclays Plc over charges that it had violated U.S. trade sanctions by doing deals in Cuba, Iran, Libya, Sudan and Myanmar."(Reuters, "ING says could face fines following U.S. investigation," 7/27/10) 

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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)