USA

In April 2014, CNA was subpoenaed by the New York Department of Financial Services (“NYDFS”) “as part of a probe of potential sanctions violations involving Iran … demanding information related to their dealings with Swiss-based commodities giant Glencore Xstrata and its Iranian metals trade.” (Reuters, “New York regulator subpoenas four insurers in Iran sanctions probe-source,” 4/9/2014). In response, a CNA spokesman emailed, “[w]e have been cooperating with the department’s investigation…. CNA has a very robust compliance program and we are confident that we followed the law.” (Bloomberg, “N.Y. Said to Subpoena Four U.S. Insurers in Iran Probe,” 4/8/2014).

ColisExpat is a French company that connects Iranians with Amazon services, potentially allowing Amazon to circumvent US sanctions. According to its website, "ColisExpat receives your Amazon purchases and forwards them at your house in Iran."

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The sanctioned entities reportedly got around Amazon’s screening process by using common alternative spellings of a sanctioned region like spelling Crimea as Krimea or by shipping items to the foreign missions of the sanctioned nations like Iran. Last year Apple paid around $467,000 to settle similar allegations that it violated U.S. sanctions by doing business with a blacklisted entity for more than two years because the company’s screening tool failed to account for differences in punctuation and letter cases. (Forbes, "Amazon Agrees To Pay $135,000 In Settlement For Violating U.S. Sanctions," 7/10/2020).

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"In early August, Iranians took to Twitter to report that they had received emails from Amazon Web Services (AWS) informing them that their accounts had been disabled in compliance with United States government sanctions and export control regulations." (Al Jazeera, "Locked Out: Why is Amazon blocking Iranians from its services?" 10/2/2019). 

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"Amazon has become the latest major American technology company to block Iranians from accessing its products and services due to U.S. government sanctions that prohibit companies from providing products or services to people based in Iran. Iranian developers who are now banned from using Amazon Web Service (AWS), which offers the worlds most extensive cloud computing platforms, will feel the greatest impact, as well as those who use those developers’ websites, services and products including virtual private networks (VPNs) that enable users to circumvent online censorship." (Center for Human Rights in Iran, "More Iranians Forced to Rely on Unsafe Online Hosting After Amazon Ban," 8/7/2019).

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In July 2017 Amazon disclosed the government probe in documents filed with the SEC. The company said that between Jan 2012 and June 2017 it sold and delivered nearly $25,000 worth of merchandise to an Iranian embassy outside of Iran, and another $8,100 to other individuals with ties to the Iranian government, according to the filing.

The products it sold included books, jewelry, toys, health and beauty products, electronics, lawn and patio equipment, and musical instruments

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"Amazon.com Inc. on Friday disclosed Iranian business ties that may have violated U.S. sanctions, warning that it may be penalized after a regulatory review of the activities. The company said in a regulatory filing that from 2012 to 2016 it "processed and delivered orders of consumer products for certain individuals and entities located outside Iran covered by the Iran Threat Reduction and Syria Human Rights Act (ITRA)"... Amazon said Friday it sold a variety of consumer products to individuals and unspecified groups controlled or owned by the Iranian government. The goods ranged from apparel to software to pet products and cost $50 to about $2,400, according to the filing. Amazon said it doesn't plan to sell to these accounts in the future." (Bloomberg,  "Amazon Discloses Iranian Business Ties, Warms of Penalities," 2/10/2017).

"To comply with US sanctions, Apple removed some Iranian apps from its App Store back in 2017 and one of them was Snapp, a popular ride sharing service in the country. However, at some point, the developers snuck it back in the App Store hidden within a music app called RadickRadio…" (9to5mac, 1/30/2020).

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"Like most other American businesses, Apple doesn't have a store in Iran and doesn't sell its products in a country targeted with tough economic sanctions by President Donald Trump. But at a shop in Tehran, Iranians can buy an array of Apple tech gadgets, including iPhones and Mac laptops. It's not an official Apple store approved by the Silicon Valley tech giant, but the company's sleek smartphones and watches make their way into the country anyway. "I think this is the best brand in the world for any computer," the young shop owner, standing in front of an "Apple store" sign, told NBC News' Lester Holt. "These are very popular here." The bustling shop illustrates how Iranian businesses try to sidestep the chilling effect of U.S. sanctions imposed by Trump, and that at least some citizens still have enough spending money to afford the latest tech consumer item." (NBC News, "Iranian people try to sidestep Trump's tough sanctions," 8/19/2019).

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 "Apple Inc. has blocked enterprise programs due to its rule for app distribution policy, which is worldwide and is not limited to Iran, head of the Information Technology Organization of Iran, Amir Nazemi, told Mehr on Thursday." (Tehran Times, "Apple's enterprise program block is not limited to Iran: official," 3/1/2019).

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"iPhone users in Iran discovered today that they’re no longer able to access the App Store, in what appears to be a total block of the country, according to Bleeping Computer. While Apple doesn’t sell phones or operate the App Store in Iran, Iranians could still import Apple products from another county and set them up to access portions of the App Store meant for other regions. It appears that now, Apple has closed that loophole, blocking any traffic coming from inside Iran from accessing the App Store in any capacity." (The Verge, "Apple appears to have totally cut off IRan from the App Store," 3/15/2018).

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According to an August 2017 NYT article, “officially Apple has no presence in Iran. Because of American sanctions against the country, the company’s iPhones are not legally available for sale here, and Apple does not offer a version of its App Store in the country….Apple told Iranian developers in February to remove any payment options in their apps to prevent Iranian money from entering the United States in violation of the sanctions. Iran had developed its own internal online payment system, shaparak, in response to the sanctions. After the Apple notice, almost all Iranian apps, including Snapp, switched to shaparak, cash and other methods of payment.”

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Reports coming out of Iran suggest that Apple has allegedly started removing iOS apps originating from the country’s startups and developers. Prior to this, Apple had, in a limited manner, opened up its App Store to Iranians in September 2016 and appeared to be gradually lifting some of the limitations, periodically, since then. According to credible tech news site Techrasa, the biggest Iranian e-commerce service, Digikala, which has millions of users, had its app removed from the App Store just a few days ago. While there is no official App Store available for the territory of Iran, many companies registered their apps as being outside of Iran to be able to get onto the store. (TechCrunch, "Apple Has Allegedly Began Removing Iranian iOS Apps from the App Store," 1/29/2017).

Intrepid Aviation chief executive Olaf Sachau viewed “Iran as an attractive market for plane-leasing companies to do business, [but recognized] the U.S. election outcome means tapping the market isn’t on the agenda for now.” (Wall Street Journal, “Plane-Leasing Companies Cautious on Iran Before Trump Presidency,” 1/18/2017).

"Big aircraft lessors still are reluctant to do business in Iran. 'We will remain cautious,' said John Plueger, chief executive of Air Lease Corp... Years of sanctions have left Iran with one of the world’s oldest airline fleets in need of modernization. But full order books at Airbus and Boeing mean Iranian carriers can only slowly get new planes." (The Wall Street Journal, "Plane-Leasing Companies Cautious on Iran Before Trump Presidency," 1/19/2017).

 "In late October, a top spokesman at Viceroy Hotel Group, told Gulf News the company was eyeing Iran, but would prefer to see other hotels’ experience in that market first before launching a property there...." (Gulf News, "Marriott 'very keen' to pursue opportunities in Iran," 12/7/2016).

"A few days after Donald Trump’s shock election victory, U.S. aviation salesman Adam Meyer took the kind of call he knew was coming -- a small Iranian airline wanted to know if its plan to repair a fleet of aging American jets would still be possible. “We have to wait and see,” Meyer, Middle East and Africa managing director for Minnesota-based Brite Air Parts Inc., recalled telling the concerned executive. “Trump can definitely make it difficult for us as an American company, but I’m trying to stay on the side of optimism.” Brite Air is among scores of foreign and Iranian businesses, from oil majors to car makers, whose prospects were dented when Trump became president-elect. Plans are hinged on an Iran open for business after most sanctions were lifted by last year’s nuclear agreement, a deal attacked by Trump as ripe for renegotiation or shredding... Meyer at Brite Air says Europeans businesses have forged ahead in Iran as U.S. firms await export licenses. He’s spent three years laying the groundwork to sell parts and engines to Iranian carriers, and was attending an international air show on Iran’s Kish Island -- a free-trade zone in the Persian Gulf -- at the time of the Congress vote." (Bloomberg News, "Deal Maker or Deal Shredder: Billions Ride on Trump Iran Policy," 11/22/2016).

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Attended the 2016 Iran Aviation Summit. 

According to its website, AT&T does not offer "Text, pics and video messaging" in Iran. AT&T WIFI calling is also not available in Iran. AT&T does offer prepaid international calling to landlines and mobile devices in Iran.

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AT&T services are offered in Iran through the network carrier RightTel.

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"This past week, a spokesman for AT&T acknowledged that the company was providing voice and data service in Iran to its customers with American phones through a partnership with a local firm, RighTel. An employee at the Iranian company, fully owned by a state entity, confirmed the partnership. While the announcement that Airbus and Boeing will provide dozens of jetliners to Iranian carriers garnered worldwide headlines last month, the deal that AT&T clinched in March, making it the only American provider to offer phone service in Iran, flew under the radar... It remains unclear how AT&T and RighTel will settle accounts. A representative for AT&T said the company would not disclose information on financial arrangements made with the Treasury or with its Iranian partner. One possible clue: RighTel is owned by the Social Security Organization of Iran, a state entity that has large stakes in several domestic banks." ( The New York Times, "Sign of Thaw With Iran: American Cellphones Ringing in Tehran," 10/8/2016).

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According to its Annual report filed with the SEC for fiscal year 2012: "AT&T had no activities in 2012 that required reporting under ITRA. AT&T holds a 9.55% interest in América Móvil, which is more fully described on page 71 of the 2012 Annual Report to Stockholders. América Móvil has reported to AT&T that it and certain of its subsidiaries have entered into roaming interconnection agreements with MTN Irancell. To date, América Móvil and its subsidiaries have no revenues under the agreement. We understand that América Móvil intends to continue this relationship."
 

"Procter & Gamble Co. confirmed today that the company plans to stop selling products in Iran as a result of President Donald Trump pulling the United States out of an agreement to limit Tehran’s ability to develop nuclear weapons." (6/4/2018).

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"Like many Western firms, Procter & Gamble Co. is eyeing new opportunities in Iran following the relaxing of trade sanctions earlier this year. But for a Swiss subsidiary of the U.S. consumer goods giant, Iran already is a very familiar market. Starting with market research in 2003, and culminating with more than $100 million in sales in the year ended in mid-2010, Geneva-based Procter & Gamble International Operations SA’s business in 'Parthia'—an in-house byword for the Middle Eastern country—was a success story. The operation relied on a legal exception. Until 2012, foreign subsidiaries of American firms could do business in Iran, as long as no U.S. passport or green-card holders were involved. Internal Procter & Gamble International Operations documents reviewed by The Wall Street Journal provide a rare glimpse into the careful, behind-the-scenes efforts undertaken on behalf of U.S. companies to do business legally in Iran several years ago, amid the sanctions—which have barred trade, with limited exceptions... A P&G spokeswoman said, 'We are looking to increase the distribution of our existing brands and expand the portfolio of brands' in Iran, and making a related hiring effort." (Wall Street Journal, "After a Taste of Doing Business in Iran, P&G Is Eger to Re-Engage," 7/13/2016)