USA

FMC Technologies merged with France's technip in January 2017 to form TechnipFMC. (November 2017)

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"This license involved the settlement of a legal dispute. Before the imposition of the sanctions against Iran, FMC had a trade contract with Daewoo UK to provide equipment and perform installation and warranty work at a facility on Kharg Island in Iran. The ultimate contracting authority for the project was the National Iranian Oil Company. After sanctions were imposed, FMC ceased all work on the project. Daewoo then initiated a legal claim against FMC. For complex legal reasons, the payment of a $710,000 settlement by FMC to Daewoo required a license from OFAC." (New York Times, "Licenses Granted to U.S. Companies Run the Gamut," 12/24/10)

"This license authorized DynCorp, a United States contractor in Afghanistan, to ship supplies through Iran to Afghanistan for Afghanistan's Central Poppy Eradication Force." (New York Times, "Licenses Granted to U.S. Companies Run the Gamut," 12/24/10)

In June 2016, the Embassy of the Government of Iran located in the Republic of Ireland placed an order for Dell desktop computers, computer stands, and a server for a total purchase price of approximately 8,816 Euros (approximately $9,941 at the exchange rate for U.S. dollars at the date of such order). We did not accept the order, but such embassy subsequently deposited prepaid funds in the amount of its purchase order in a local bank for our account. These funds remain blocked at the local bank, and we do not intend to engage in future activity with respect to this matter.

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According to its Annual Report filed with the SEC in 2012: "We are disclosing the following information pursuant to Section 13(r) concerning activity by a UK affiliate of Quest Software, Inc. (“Quest Software”), which Dell acquired on September 27, 2012. The disclosure is regarding a maintenance services software renewal transaction with Melli Bank PLC valued at 106.13 British pounds (approximately $169.90 at the exchange rate for U.S. dollars on the renewal date) and marketing activity.

Quest Software specializes in business software. On September 10, 2012, prior to our acquisition of Quest Software, Quest Software (UK) Ltd., then a UK subsidiary of Quest Software, renewed two software maintenance licenses with Melli Bank PLC. The first license, for Quest Recovery Manager for Exchange software, had been in effect for seven years before the renewal, while the second license, for Spotlight on Messaging software, had been in effect for four years before the renewal. Recovery Manager for Exchange software enables users to search and retrieve message-level data and compare contents between different mailboxes. Spotlight on Messaging is a business software program that helps manage messaging and real-time communications and provides troubleshooting solutions. Marketing activity also occurred prior to and after the acquisition with respect to Quest customers generally, including Melli Bank PLC, but no transactions were concluded other than the license renewal transaction.

Melli Bank PLC is a wholly-owned subsidiary of Bank Melli in Iran. Melli Bank PLC is headquartered in London and is listed by the Treasury Department's Office of Foreign Assets Control as a Specially Designated National.

The profit on the license renewal transaction was no more than the annual renewal transaction value indicated above. Following our acquisition of Quest Software and our discovery of the renewal transaction, we terminated all software maintenance activity under the licenses. We will not engage in future activity under the licenses."
 

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"This license authorized a shipment of computers to an embassy in Tehran." (New York Times, "Licenses Granted to U.S. Companies Run the Gamut," 12/24/10)

"This license was issued after Senator Edward M. Kennedy's office called OFAC on behalf of this Massachusetts-based company on July 12, 2006, then wrote a follow-up letter on Nov. 29, 2006. The license authorized the sale of the HUMAC NORM Multi-Joint Evaluation and Exercise System to Sepehran Company for resale in Iran to, among other entities, the National Olympic Academy of Iran, which trains Iran's athletes. The product, which was deemed to be an allowable medical device export, is an exercise machine used in sports rehabilitation. Rob Potash, the vice president of Computer Sports Medicine, said he believed that the sale of American products to Iranians helped to improve the United States' image there." (New York Times, "Licenses Granted to U.S. Companies Run the Gamut," 12/24/10)

"This license authorized the company to complete the sale and delivery of Mexican-origin goods, the precise nature of which OFAC redacted, to China, even though the goods had been shipped via the Iranian government-owned shipping line known as Irisl. Irisl has since been designated as an entity involved in helping the Iranian regime obtain technology it needs for its ballistic missile and nuclear programs. The license also allowed the bank that issued the letter of credit for the sale, HSBC, to make good on its obligations. In granting the license, OFAC wrote that Cometals had advised the agency that it was subject to large daily fees for every day that the vessel was not unloaded as well as possible financial claims from the Chinese customer for failing to deliver the goods. OFAC granted the license 'in order to enable Cometals to avoid significant financial loss,' it said. While OFAC was under no obligation to grant this license given that it involved an Iranian entity, OFAC's director, Adam J. Szubin, stressed that Irisl was not added to a special United States blacklist of proliferators until five years after this license was issued. Up until then, he said case-by-case exceptions were made in cases like this one in which the company did not know that an Iranian entity was involved when it entered into the transaction, and in which granting the license did not involve a direct payment from a United States person or company to an Iranian entity." (New York Times, "Licenses Granted to U.S. Companies Run the Gamut," 12/24/10)

"New details about the U.S. sanctions-busting case against Huawei Technologies Co. emerged in court filings in Canada, including about the Chinese telecom giant’s alleged dealings in Iran, Syria and Sudan. The filings also detailed discussions Huawei held with Citigroup Inc. C +0.68% and BNP Paribas SA BNPQY +0.08% about its Iran business. The documents released Tuesday allege that Huawei also had discussions with two other banks, Citigroup and BNP, about its Iran business, following the publication by Reuters of articles in 2012 and 2013 alleging that Huawei sold U.S.-made computer equipment in Iran via Skycom in violation of U.S. sanctions. They allege that Huawei representatives—including the company’s treasurer and Ms. Meng—told Citigroup that the company was in compliance with all sanctions, according to a 2017 email described in the filings. They also describe a 2014 BNP document in which Huawei described Skycom as “one of the business partners of Huawei.” HSBC and Standard Chartered have cut business ties with Huawei, deeming working with the company too risky, The Wall Street Journal reported in December. As of the end of last year, Citigroup continued to provide day-to-day banking services with Huawei outside the U.S., the Journal reported. A spokesman for Citigroup declined to comment. A Standard Chartered spokeswoman and a BNP spokeswoman declined to comment. An HSBC spokesman didn’t immediately respond to a request for comment."  (The Wall Street Journal, "Huawei Discussed Iran Business with Citi and BNP Paribas, Court Documents Show," 8/22/2019).

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According to its Annual Report filed with the SEC for fiscal year 2018: " During the fourth quarter of 2018, Citibank Europe plc, a subsidiary of Citibank, acting as an intermediary bank processed a transaction between two Irish banks involving the Iranian Embassy in Ireland. The total value of the payment was EUR 90.00 (USD 104.24). This transaction was for visa-related fees and is exempt pursuant to the travel exemption of the Iranian Transactions and Sanctions Regulations. Citibank Europe plc realized nominal fees for the processing of this payment."

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According to its 2017 SEC filing – “During the third quarter of 2017, Bank Handlowy w Warszawie S.A., a Citibank subsidiary located in Poland, processed three funds transfers involving the Iranian Embassy in Poland.  The value of the funds transfers was EUR 50, EUR 50, and EU 100 (approximately $60.00, $60.00 and $117.00), respectively.  In addition, a branch of Citibank N.A., located in India, processed a funds transfer involving the Iran Consulate General in India.  The total value of this payment was INR 1,368 (approximately $21.00).  These payments were for visa-related fees and Iran-related travel respectively.”

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According to its Annual Report filed with the SEC for fiscal year 2015: "In addition to Citi’s prior disclosures, a subsidiary of Citi, Banco Nacional de México (Banamex), identified that it inadvertently processed five domestic funds transfers to the Embassy of Iran in Mexico during the third quarter of 2015.  The total value of these five funds transfers was approximately MXP 3,320 (approximately $177.00).  Three of the payments were for visa services that are exempt under Office of Foreign Assets Control (OFAC) regulations and two were for consular services that going forward would be permissible under OFAC General License H for Banamex as a non-U.S. subsidiary of Citi.  The transactions, in aggregate, resulted in approximately MXP 10 (approximately $0.53) in revenue for Banamex."

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Over the last three presidential administrations, the United States government has granted Citigroup 37 special licenses to do business in Iran. (New York Times, "Companies with Permission to Bypass Sanctions," 12/24/10)

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"When it comes to U.S. sanctions on Iran, no detail is too small to overlook these days. Since February, publicly traded companies have filed nearly 500 disclosure forms about their business ties to Iran…Citibank disclosed that its branch in Bahrain made $4 in profit in the second quarter by processing ATM transactions involving Future Bank, a joint venture whose owners include two Iranian-linked banks barred from doing business with U.S. companies…And though Citibank’s ATM fees were minimal, the bank involved was partly owned by Bank Saderat, which has been on the Treasury Department’s sanctions list since 2006 for being a 'conduit' between Iran and Hezbollah, the militant Shiite Muslim movement based in Lebanon." (Washington Post, "Under new law, companies disclosing even tiniest dealings with Iran," 12/4/13)

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"OFAC granted a license on Dec. 27, 2007, to Citibank authorizing it to make good on an agreement its Japanese subsidiary had entered into in October. The bank had agreed to confirm that certain conditions in a letter of credit had been meet, after which a Malaysian exporter of split-system air conditioners to Turkey would be paid. Then the bank discovered that the goods were to be shipped aboard a vessel called the Iran Ilam that was owned by the Iranian government-run shipping line known as Irisl, thus requiring that the transaction be licensed. The license was issued even though the Treasury Department and OFAC suspected that Irisl was being used to smuggle goods into Iran in contravention of various embargoes, including banned technology the government needed for its ballistic missile and nuclear programs. Moreover, at the time the license was issued, the United States had evidence that five months earlier, the Iran Ilam itself had delivered a lathe that could be used to make precise metal parts needed for nuclear centrifuges from China to Iran’s Shahid Bagheri Industrial Group, according to government officials who requested anonymity to speak about an intelligence matter. Indeed, within months of issuing the license, OFAC announced at a news conference that the United States was adding Irisl to a special blacklist, after an investigation found that Irisl had falsified cargo records, relied on front companies and used other trickery to mask the true nature and destination of shipments. At the September 2008 news conference announcing the decision, OFAC's director, Adam J. Szubin, warned that banks and companies worldwide should be aware that they could be unwittingly aiding Iran’s quest for banned technology by doing business with Irisl: 'Irisl’s deceptive practices make it nearly impossible to determine whether its shipments are licit or illicit,' he said. Mr. Szubin acknowledged in an interview that he was under no obligation to issue the license to Citigroup, given that banks were already prohibited generally from doing business with Iranian entities. But he said that OFAC had issued licenses in cases like this in the past in which the bank had no way of knowing that Irisl was involved and Irisl would have been paid by a foreign third party anyway. To depart from that norm in this case, he added, risked opening up his agency charges of unfair treatment and litigation, and tipping off Irisl that it was under investigation."

"This license is one of at least three that OFAC issued involving the China Great Wall Industry Corporation. The licenses were issued after the Chinese company was added to the United States' special blacklist for supplying components to Iran's ballistic missile development program and before it was removed from the list on June 19, 2008. In one case, the agency licensed the Chinese company's lawyers, who were challenging the blacklisting, to receive legal fees. Two other cases involved wire transactions to or from China Great Wall. OFAC could have forced Citigroup to seize the funds, but said it chose instead to authorize the bank to return the money because China was unlikely to agree that the funds should be seized and therefore the bank would have almost certainly lost a legal battle to keep the funds blocked." (New York Times, "Licenses Granted to U.S. Companies Run the Gamut," 12/24/10)

Over the last three presidential administrations, the United States government has granted Chiquita Brands International 20 special licenses to do business in Iran. (New York Times, "Companies with Permission to Bypass Sanctions," 12/24/10)

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"This license was one of many given to Chiquita Brands, the banana grower, authorizing it to sell its produce in Iran; the purchasers' names have all been redacted by OFAC. The company was also authorized to sell its products in Libya while that country was still under sanction by the United States." (New York Times, "Licenses Granted to U.S. Companies Run the Gamut," 12/24/10)

Subsidiary of FlexiVan Leasing.

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Dole said in an SEC filing that it had terminated its business in Iran after the U.S. reimposed Iran sanctions in January 2020. 

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"This license authorized the export of canned fruit and vegetables to entities in Iran whose names OFAC redacted. The company's products include Dole Pineapple." (New York Times, "Licenses Granted to U.S. Companies Run the Gamut," 12/24/10)

"Cabot received this license after it assisted in a sales transaction of silicon dioxidebetween two non-U.S. parties. The company applied for the exception after learning that the goods would be shipped via the Iranian government-owned shipping line known as Irisl. 'The items in question are already loaded onto containers at the dock and ready to be loaded onto the vessel, which is due to depart the port of Antwerp, Belgium, on Monday,' the company's lawyers, in the firm of Baker & McKenzie, wrote to OFAC on May 11, 2001. OFAC's director, Adam J. Szubin, stressed that the approval came seven years before Irisl was blacklisted by the United States for aiding Iran's nuclear and ballistic missile programs. Up until then, he said, the agency made case-by-case exceptions to a broad prohibition against dealing with Iranian companies in situations like this one in which the company had no prior knowledge that an Iranian entity was involved in the transaction and granting the license did not involve a direct payment from a United States person or company to an Iranian entity." (New York Times, "Licenses Granted to U.S. Companies Run the Gamut," 12/24/10)

"This license authorized Bruce Foods to export Louisiana Hot Sauce brand products under the agricultural exemption to the United States trade embargo against Iran. The products were to be exported to Hall Kish on Kish Island, Iran, and Javaheri Company in Tehran." (New York Times, "Licenses Granted to U.S. Companies Run the Gamut," 12/24/10)