USA

According to an Iranian newspaper, KBR’s U.K. subsidiary has signed a Memorandum of Understanding with the Iranian firm, Pardis Petrochemical Company (“PPC”) to “provide technology and services at [PPC’s] ammonia and urea complex” in Assaluyeh, the southern port city.  According to Iran’s Financial Tribune newspaper, PPC is “one of the world’s top producers of the two compounds that form the building block of many products, including plastics, explosives, textiles, pesticides, fertilizers and resin products.”  (Financial Tribune, “US Firm, Iranian Petrochemical Co Sign Agreement,” 1/30/2018).  

"Insurance broker Arthur J. Gallagher & Co will continue to monitor developments on the U.S. withdrawal from the 2015 international agreement designed to deny Tehran the ability to build nuclear weapons, the company said on Friday.“Whatever the decision from the U.S. administration, we will take appropriate action in compliance with all applicable laws as is our customary practice, said Anna Rozenich, the company’s spokeswoman. AJG has British and Norwegian subsidiaries that have brokered insurance and advised clients on activities related to Iran’s oil and gas industry." (5/18/2018).

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According to its quarterly report filed with the SEC in 2018: "On May 8, 2018, President Trump announced his decision to re-impose secondary sanctions against Iran. In response, on June 27, 2018, OFAC revoked General License H, with a provision for winding down transactions previously authorized under General License H.

In light of the above, our subsidiaries intend to discontinue acting as an insurance broker in connection with insurance coverages previously authorized by General License H, prior to the conclusion of the applicable wind-down period."

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In third quarter 2018, our U.K. domiciled subsidiary, Arthur J. Gallagher (UK) Limited, acted as insurance broker in obtaining insurance coverage for activities related to Iran’s oil, gas and petroleum industries. This subsidiary assisted clients in obtaining insurance coverage for activities including the supply and transport of oil, crude oil, heavy fuel oil and gas to and from Iran, and the docking and loading of oil shipments in Iran. (SEC Filing, 2018).

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As stated in its quarterly report filed with the SEC: In the fourth quarter of 2017, our U.K. domiciled subsidiary, Arthur J. Gallagher (UK) Limited and our Norway domiciled subsidiary, Bergvall Marine AS, acted as insurance brokers and advised clients in obtaining insurance coverage for activities related to Iran’s oil, gas and petroleum industries. In June 2014, we acquired a business in the U.K. that, beginning in 2011, had assisted its client, Bimeh Iran Insurance Company (UK) Limited (Bimeh), obtain certain insurance policies. In March 2014, the predecessor business placed a 12-month employers liability policy for Bimeh, with a premium of £371. In March 2015, after the acquisition, one of our U.K. subsidiaries assisted Bimeh with the renewal of the policy for a further 12 months, at the same premium of £371 plus a £50 administrative fee (generating total gross revenue for our U.K. subsidiary of approximately $117 and net profit of approximately $23). The policy was not renewed when it expired in March 2016, and Bimeh is no longer a client of our U.K. subsidiary.

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According to its Quarterly report filed with the SEC in 2016: "In second quarter 2016, our U.K. domiciled subsidiary, Arthur J. Gallagher (UK) Limited (which we refer to as AJGUK) acted as insurance broker and advised clients in obtaining insurance coverage for activities related to Iran’s oil, gas and petroleum industries. AJGUK assisted clients in obtaining insurance coverage for a variety of activities in Iran, including insurance coverage for:

• the operation of offshore drilling rigs by Iranian companies;
• the supply of crude oil to and from Iran;
• the transport and storage of oil from Iran;       
• the shipment of heavy fuel oil to and from Iran;
• the docking and loading of oil shipments in Iran; and
• the operation of a vessel by an Iranian company to survey pipelines used for oil and gas."

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According to its Quarterly Report filed with the SEC in 2016: "In first quarter 2016, our U.K. domiciled subsidiary, Arthur J. Gallagher (UK) Limited (which we refer to as AJGUK) placed insurance coverage for shipments of Iranian crude oil, petroleum and petroleum products. These activities, which were conducted in compliance with applicable law, are being disclosed pursuant to Section 13(r) of the Exchange Act.

On January 16, 2016, the U.S. lifted the nuclear-related “secondary sanctions” imposed against Iran. In connection with this event, the U.S. Treasury Department’s Office of Foreign Assets Control (which we refer to as OFAC) issued General License H, which authorizes U.S.-owned or U.S.-controlled foreign entities to engage in certain transactions involving Iran that would otherwise be prohibited by section 560.215 of the Iranian Transactions and Sanctions Regulations.

Following OFAC’s issuance of General License H and pursuant to General License H, AJGUK engaged in two separate insurance transactions with entities based outside the U.S. that involved the placement of insurance policies that included coverage for shipments of Iranian crude oil, petroleum and petroleum products. The total revenue generated by these transactions was approximately €32,000 (or approximately $36,000). The net profit attributable to these placements is difficult to calculate with precision, but is estimated to be approximately €6,000 (or approximately $7,000). AJGUK currently intends to continue placing insurance policies that provide coverage for activities authorized by General License H."

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According to its Quarterly report filed with the SEC for fiscal year 2012: "In 1998, Heath Lambert Limited (which we refer to as HLL), domiciled and acting in the capacity of a reinsurance intermediary in the UK, placed a marine hull reinsurance contract with Bimeh Iran Insurance Company (UK) Limited (which we refer to as Bimeh) on behalf of a UK-based ceding insurer. A loss covered by the contract occurred that same year. We acquired HLL in May 2011. One month later, as part of winding down legacy matters, HLL submitted to Bimeh a claim for payment on the reinsurance contract. In June 2012, HLL received £9,353.00 (US$14,343.75) from Bimeh representing Bimeh’s portion of the claim due to the UK-based ceding insurer. We do not believe the placement of the policy, the submission of the claim or the receipt of funds was prohibited by U.S. laws or regulations. In July 2013, HLL offered to send these legacy reinsurance funds to the UK-based ceding insurer. The offer was declined by the ceding insurer due to Bimeh’s involvement. No revenue or profit was generated by HLL in handling or holding the funds. HLL intends to hold the funds in accordance with company policy and applicable laws until authorized with the appropriate license to remit payment to the UK-based ceding insurer."

"The company was reported as potentially having a subsidiary with ties to petrochemical production 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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According to its Annual Report filed with the SEC for fiscal year 2019: "As authorized by the U.S. Treasury’s Office of Foreign Assets Control (OFAC), a non-U.S. subsidiary of the Company completed sales of products used for process and water treatment applications in upstream oil and gas production related to the operation of and production from the Rhum gas field off the Scottish coast (Rhum) totaling $0.7 million during the subsidiary’s fiscal year ended November 30, 2019, and a nominal amount of sales of such products during December 2019. The net profit before taxes associated with these sales for each period were $0.1 million and nominal, respectively. Rhum is jointly owned by Serica Energy plc and Iranian Oil Company (U.K.) Limited. Our non-U.S. subsidiary intends to continue the Rhum-related activities, consistent with a specific license obtained from OFAC by its customers, and such activities may require additional disclosure pursuant to the abovementioned statute."

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According to its Annual report filed with the SEC for fiscal year 2018: "Our non-U.S. subsidiary timely completed the winding down of its business activities in Iran pursuant to the wind-down license. For its fiscal year 2018, through the completion of the wind-down period, our non-U.S. subsidiary completed the following sales related to businesses in our Energy operating segment to a distributor in Dubai and two distributors in Iran: sales of products used for process and water treatment applications in (i) upstream oil and gas production and (ii) petrochemical plants totaling $4.7 million. The net profit before taxes associated with these sales is estimated to be $0.9 million.

In addition to the foregoing, as authorized by OFAC, a non-U.S. subsidiary of the Company completed sales of products used for process and water treatment applications in upstream oil and gas production related to the operation of and production from the Rhum gas field off the Scottish coast (Rhum) totaling $0.6 million during the subsidiary’s fiscal year ended November 30, 2018, and additional sales of such products totaling $0.1 million were completed during December 2018. The net profit before taxes associated with these sales for each period were nominal. Rhum was previously jointly owned by BP Exploration Operating Company Limited (BP) and Iranian Oil Company (U.K.) Limited. BP completed the sale of its ownership stake in the Rhum joint arrangement and transferred its role as operator to Serica Energy plc on November 30, 2018. Our non-U.S. subsidiary intends to continue the Rhum-related activities, consistent with a specific license obtained from OFAC by its customers, and such activities may require additional disclosure pursuant to the abovementioned statute."

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Ecolab has reported that a subsidiary has sold products for upstream oil and gas production and petrochemical plants in Iran. In 2017, CalSTRS designated Ecolab as “Under Review” for potentially having ties to Iran. In 2018, CalSTRS removed Ecolab after confirming the company was winding down activities in Iran and reviewing the company’s business with Iran and internal controls to prevent sanction violations.

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In 2017 the U.S. state of California identified Ecolab as a company under review for Ecolab has reported that a subsidiary has sold products for upstream oil and gas production and petrochemical plants in Iran.

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According to its Annual Report filed with the SEC for fiscal year 2017: "a wholly-owned non-U.S. subsidiary of the Company completed the following sales related to businesses in our Energy operating segment pursuant to and in compliance with the terms and conditions of OFAC’s General License H: sales of products used for process and water treatment applications in (i) upstream oil and gas production and (ii) petrochemical plants totaling $5.9 million during the subsidiary’s fiscal year ended November 30, 2017, and additional sales of such products totaling $0.4 million during December 2017, were made to a distributor in Dubai and two distributors in Iran. The net profit before taxes associated with these sales is estimated to be $1.6 million and $0.1 million, respectively. Our non-U.S. subsidiary intends to continue doing business in Iran under General License H in compliance with U.S. economic sanctions and export control laws, which sales may require additional disclosure pursuant to the abovementioned statute."

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According to its Annual Report filed with the SEC for fiscal year 2016: "a wholly-owned non-U.S. subsidiary of the Company completed the following sales related to businesses in our Energy operating segment pursuant to and in compliance with the terms and conditions of OFAC’s General License H: sales of products used for process and water treatment applications in (i) upstream oil and gas production and (ii) petrochemical plants totaling $535,000 during the subsidiary’s fiscal year ended November 30, 2016, and additional sales of such products totaling $571,000 during December 2016, were made to a distributor in Dubai and two distributors in Iran. The net profit before taxes associated with these sales is estimated to be $117,180 and $351,192, respectively. Our non-U.S. subsidiary intends to continue doing business in Iran under General License H in compliance with U.S. economic sanctions and export control laws, which sales may require additional disclosure pursuant to the abovementioned statute."

On August 31, 2017 DuPont merged with Dow Chemicals to create DowDuPont.

Illinois-based Dover, a manufacturing conglomerate, said the revocation of License H would end its business in Iran. Dover had been selling spare parts for pumps used in Iran’s energy infrastructure and was set to earn more than $16 million in revenue from contracts signed there since the beginning of 2017, according to regulatory filings. (June 5, 2018).

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In its 2017 SEC 10:K filing Dover notes: “In connection with the easing of certain sanctions by the U.S. against Iran in January 2016 and in compliance with the economic sanctions regulations administered by U.S. Treasury’s Office of Foreign Assets Control (“OFAC”), a wholly-owned non-U.S. subsidiary in our Fluids segment serving the pumps end market sold non-U.S. origin spare parts related to the oil, gas and/or petrochemical sectors to Iranian counterparties pursuant to new contracts, which resulted in revenue of approximately €101,660 and net profits of approximately €71,536 in 2017 (expected total revenue from these contracts is approximately €12.1 million). “

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According to its Annual Report filed with the SEC for fiscal year 2013: "During the disclosure period, Automatik Plastics Machinery GmbH ("Automatik"), a German affiliate of Maag Pump Systems, which we acquired on March 13, 2012, exported from Germany European-origin equipment used in the processing of polystyrene pellets and PET chip to two entities in Iran, Tabriz Petrochemical (“Tabriz”) and Shahid Tondgoyan Petrochemical (“Shahid Tondgoyan”), which we understand are owned or controlled by the Government of Iran.  All of the exports except one were made prior to August 10, 2012, the date of enactment of the Iran Threat Reduction and Syria Human Rights Act of 2012 (“ITRA”).  Automatik made two exports to Tabriz on February 24, 2012 and May 8, 2012, with total revenue and net profit values of €51,550 and €14,759, respectively. Automatik made three exports to Shahid Tondgoyan on March 6, 2012, July 19, 2012, and August 8, 2012 with total revenue and net profit values of €516,831 and €162,588, respectively. The only export made after the enactment of the ITRA was made to Shahid Tondgoyan on October 4, 2012, with a revenue and net profit value of €20,388 and €7,411, respectively. This last export was made prior to the October 9, 2012 date of the Presidential Executive Order that made it a violation of U.S. law for owned or controlled foreign subsidiaries after October 9, 2012 to knowingly engage in transactions with the Government of Iran or any person subject to the jurisdiction of the Government of Iran.  For most of these exports, Automatik received official written confirmation from the German Government that it did not require a license under German law and for the others it received oral confirmation no license was required.  Automatik also received a payment in November 2012 for a prior order that was not shipped and will not be shipped in the future. Given the SEC guidance that issuers should disclose all activities, including those taking place prior to ITRA's enactment on August 10, 2012, we are including all exports by Automatik Germany to government entities in Iran during 2012.  Management has instructed all of the Company's non-U.S. affiliates not to engage in any trade transactions with Iran."

Diebold Nixdorf’s authorized partner in Lebanon, Tamer Frères, advertises a presence in Iran at the top of its webpage.  (Wincor Nixdorf Website, “Banking Sales Middle East”; Tamer Frères Website, “Homepage”).

Attended the 18th International Trade Show on Innovative CIT Solutions which took place in Tehran, Iran on October 16-19, 2017  and reported business operations with the Iranian companies AKTIS and Gostarsh Salem Iranian Telecom (Iran Telecom Innovations Show, “Exhibitors & Products”; AKTIS Website, “Brands [Coriant])”; GSI Website [cached], “Our Partners”).

According to its Annual Report filed with the SEC for fiscal year 2018: "Prior to our fourth quarter 2018 acquisition of Sky, a non-U.S. subsidiary of Sky entered into two licensing agreements that licensed some of Sky’s owned programming content to a broadcasting company that is owned and controlled by the Government of Iran. The first agreement was entered into in June 2012, and was amended in July 2016, to license 150 hours of programming content for various three-year license terms for a one-time fee of €86,250. The last remaining programming license under this agreement expires in January 2019. The second agreement was entered into in June 2015 to license 80 hours of programming content for various three-year license terms for a one-time fee of €45,700. To date, no programming content has been provided, and the license fee has not been paid, pursuant to the agreement. We believe that Sky conducted its licensing activity in compliance with applicable laws and that the licenses are for the permissible exportation of informational materials pursuant to certain statutory and regulatory exemptions from U.S. sanctions."

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In 2018, the U.S. state of Michigan listed Comcast on its state list of Companies Doing Business with the Iran rendering Comcast ineligible for investment and/or state contracting.

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In its January 2017 SEC report Comcast notes: “We are not aware of any activity, transaction or dealing during the year ended December 31, 2017 that requires disclosure under the Act, except with respect to a January 2016 licensing agreement by a non-U.S. subsidiary of DreamWorks Animation prior to our August 2016 DreamWorks Animation acquisition. The agreement licensed a prior season of a children’s animated television series for a three-year, non-cancelable term and for a one-time fee of $5,200 to a broadcasting company that is owned and controlled by the Government of Iran. The broadcasting company paid the license fee in the first quarter of 2016. We believe that DreamWorks Animation conducted its licensing activity in compliance with applicable laws and that the license is for the permissible exportation of informational materials pursuant to certain statutory and regulatory exemptions from U.S. sanctions.”

Cabot has no commercial ties with the sanction-designated Iranian entity, Ervin Danesh Aryan Company (“Ervin Danesh”); does not intend to initiate business with Ervin Danesh; has not authorized the use of the Cabot logo or name by Ervin Danesh, and; following UANI’s letter, will take substantive steps to rectify the advertised but false impression of business ties between Cabot and Ervin Danesh, including by issuing a “cease and desist” notice to Ervin Danesh demanding they remove “all references to Cabot and its products from their website.” We also note that Cabot “is not currently engaging in any sales of products into Iran.” 

"Panid Engineering Co., a private domestic firm based in Tehran, has reportedly reached an agreement with US-based Pall Corporation to build a plant for manufacturing filters for the oil industry, the managing director said. "Talks were held between Panid and a delegation from the American company on the sidelines of the 22nd International Oil, Gas, Refining and Petrochemical Exhibition in Tehran, said Neda Mousavizadegan, whose company is a member of the Society of Iranian Petroleum Industries Equipment Manufacturers, Shana reported Wednesday. "The two sides reached an agreement to establish a plant for manufacturing oil and gas filtration systems in Karaj (40 km west of Tehran). This is the first official collaboration between Iranian and American manufacturers in the petroleum sector (after the 1979 Islamic Revolution)" Mousavizadegan said." (Financial Tribune, "US Firm To Build Oil Filter Plant In Iran," 5/11/2017).