USA

"Brown and Williamson Tobacco received a license to export cigarettes under the agricultural exemption to the United States trade embargo against Iran. OFAC redacted the names of the businesses in Iran that would be buying the cigarettes. Iran charges an import tax of more than 7 percent on cigarettes, according to Iranian customs officials." (New York Times, "Licenses Granted to U.S. Companies Run the Gamut," 12/24/10)

"The documents relating to this license have been so heavily redacted by OFAC that it is impossible to tell what was authorized. A company spokeswoman, Karen Gordon Quintal, said Bell Helicopter had received this and another license because it needed 'to store property of Iran and Iraq that Bell had possession of in the United States on the dates, respectively, when the assets of those countries were frozen. These licenses were required to enable Bell to store the assets, consisting principally of spare parts, in Bell’s U.S-based warehouse facility. Bell continues to store that property.'" (New York Times, "Licenses Granted to U.S. Companies Run the Gamut," 12/24/10)

In 2018, the U.S. state of Michigan listed Becton, Dickinson & Company on its state lists of Companies Doing Business with Iran, rendering Becton, Dickinson & Company ineligible for investment and/or state contracting.

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"In 2013 and 2014 Michigan divested $45 million from Becton Dickinson and Co., a U.S. medical supplies company that sells to Iran legally under federal regulations.

A Becton Dickinson spokesman said the firm was unaware it was a target of divestment by Michigan until contacted by Reuters. It said in a statement that its trade with Iran is authorized by the U.S. Treasury Department’s Office of Foreign Assets Control, which oversees federal sanctions." (Reuters, 4/13/2015). 

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According to correspondence filed with the SEC in 2010: "The Company’s sales into Iran during fiscal years 2009 and 2010 were $2,932,134 and $4,415,097, respectively, and we estimate fiscal year 2011 sales to be $3,140,758. The Company sold medical products pursuant to U.S. government licenses to Iranian pharmaceutical companies and through independent, third-party distributors that distribute the medical supplies and devices to end-users in Iran. The medical products sold into Iran are eligible for re-export to Iran under the Trade Sanctions Reform and Export Enhancement Act of 2000 (“TSRA”) “Ag/Med” program.

To the Company’s knowledge, the sales into Iran, Sudan and Syria were made in compliance with BD’s Global Trade Management System and complied with applicable laws and regulations.
The Company anticipates continued sales into the Middle East, including into Iran, Sudan, and Syria, and the Company will seek and obtain any required U.S. and other government licenses or authorizations to conduct such activities in full compliance with applicable laws. The Company reviews its export activities on a regular basis to ensure compliance with applicable economic sanctions and export control laws and mandates trade compliance training for all associates involved in the export, re-export or transfer of products, materials or technology originating from any BD location and shipped or transferred to any customer, vendor or distributor worldwide."

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Over the last three presidential administrations, the United States government has granted Becton, Dickinson & Company 49 special licenses to do business in Iran. (New York Times, "Companies with Permission to Bypass Sanctions," 12/24/10)

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"This medical device company and its French subsidiary were licensed to export goods, the precise nature of which OFAC redacted, to Iran." (New York Times, "Licenses Granted to U.S. Companies Run the Gamut," 12/24/10)

Bank of America's 10-K filed with the SEC for fiscal year 2021 states: "Pursuant to a specific license from the U.S. Treasury Department’s Office of Foreign Assets Control issued on May 28, 2021, during the fourth quarter of 2021, Bank of America, National Association (BANA), a U.S. subsidiary of Bank of America Corporation, processed one authorized wire deposit totaling $327,257 on behalf of a U.S. client into its account at BANA. The wire deposit settled invoices owed to the U.S. client and consisted of unblocked funds belonging to Jammal Trust Bank, which at the time of the deposit was designated pursuant to Executive Order 13224 [because of its links to Hezbollah]."

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A proposed class action lawsuit "alleges Bank of America has discriminated against consumers of Iranian and Middle Eastern descent by arbitrarily restricting and closing their accounts." (10/21/21)

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

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"OFAC redacted so much of this license file that it is impossible to tell what exactly it authorized, though what is clear is that it was related to another license, granted to BNP Paribas, involving the acquisition of equipment that was of Iranian origin. Bank of America, which was financing the deal, contended that the sale should be licensed because the goods had already been exported to another country." (New York Times, "Licenses Granted to U.S. Companies Run the Gamut," 12/24/10)

"On its Web site, Ardess International boasted of its ability to do business 'with any country in the Middle East notwithstanding any trade sanctions.' Ardess handles a number of companies that sell weight-lifting products like Anabolic Rush, which promises to help bodybuilders 'train with a ferocity that radiates from every corner of the gym.' Kenny Flores is a customer of Ardess whose company, MRM, sells sports performance-enhancing supplements like Driven, a high-performance workout concoction for 'serious athletes that truly want to reach peak performance, while annihilating their competition.' Mr. Flores said getting approval from the Iranian Ministry of Health to sell his products there was harder than getting approval from OFAC, but that it was well worth the effort. 'Iran is a young country - close to 60 percent of the population is under 45 years of age, and they are very health conscious,' he said, noting that his company had done hundreds of thousands of dollars worth of business there since obtaining the necessary approvals. Mr. Flores said Iran's nuclear ambitions are 'scary' and something that 'I'm definitely concerned about.' But, he added, 'as long as the government says it is O.K. to trade with them, we will trade with them.'" (New York Times, "Licenses Granted to U.S. Companies Run the Gamut," 12/24/10)

"Two sources said the increasing difficulties had prompted U.S. agribusiness company ADM (ADM.N) to halt trading with Iran since August. An ADM spokeswoman declined to comment." (Reuters, "Exclusive: Ships with one million tonnes of grain stuck outside Iran's ports in payment crisis," 10/2/2019).

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Over the last three presidential administrations, the United States government has granted Archer Daniels Midland Company 48 special licenses to do business in Iran. (New York Times, "Companies with Permission to Bypass Sanctions," 12/24/10)

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"After years of difficulty caused by economic sanctions, suppliers are hoping a nuclear deal will make it easier to win lucrative contracts to sell wheat, sugar and other food to Iran…Top global agribusiness groups such as Cargill and Archer Daniels Midland Co and others like Swiss commodities trader Glencore-Xstrata have been among the dominant players in Iran's food trade. Those three firms confirmed they sell agricultural products to Iran, and said the activity was in compliance with sanctions." (Reuters, "Food suppliers look to win Iran contracts after nuclear deal," 11/28/13)

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According to its Annual Report filed with the SEC for fiscal year 2012: "On or about July 25, 2012, an 80% owned and controlled affiliate of the Company hired a vessel to transport a cargo of grain.  The shipping arrangements and payment for $481,800 for the transportation were made directly with the charterer of the vessel. Neither the names of the vessel nor the charterer were listed on the United States Department of the Treasury’s Office of Foreign Assets Control’s (“OFAC”) List of Specially Designated Nationals (the “SDN List”).  It was later determined by the Company and its bank that the vessel involved was beneficially owned by the Islamic Republic of Iran Shipping Lines (IRISL), a sanctioned party.  The Company voluntarily disclosed the matter to OFAC.  The involvement of a sanctioned party was inadvertent and unintentional and we believe the result of a concerted effort by Iran to hide its ownership of the vessel.  Neither the Company nor its affiliate nor other of its subsidiaries have any intention of continuing such activity with a prohibited party. There was no profit that can be attributed to this specific transportation activity.  This disclosure is made pursuant to Section 219 of the Iran Threat Reduction Act which requires that an issuer disclose in its annual or quarterly report filed with the Securities and Exchange Commission if any of its affiliates engaged in an OFAC reportable transaction."

"This license authorized Archer Daniels Midland Company to fulfill a contractual obligation it had in connection with a 'string transaction.' Companies enter into such transactions when they sell goods on a commodities market. Often, they have no way of knowing where the goods will end up. In this case, Archer Daniels Midland found out that its goods were destined for Iran after it entered into the transaction, according to its application. OFAC said it generally grants licenses in this type of situation because failing to do so could bring American commodities trading to a halt." (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 American Pulp and Paper 128 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 authorized American Pulp and Paper to export wood pulp used for diapers to an Iranian company. According to the license, wood pulp was added by the United States Department of Agriculture to the list of allowable exportable agricultural commodities in 2001." (New York Times, "Licenses Granted to U.S. Companies Run the Gamut," 12/24/10)

"The American Pop Corn Company, which makes Jolly Time microwavable popcorn, received licenses to sell its product in Iran and the Sudan under a humanitarian exception for food and medical aid. Henry Lapidos, the company's food products export manager, said he had no problem selling to countries like these because it was good to 'show the American flag' by placing products like American Pop Corn's on supermarket shelves in places where anti-American sentiment runs strong. 'I don't see us supporting the ayatollahs. I don't think the Revolutionary Guard - that soliders would take microwavable popcorn in their backpacks when they go to war,' he said. Asked whether popcorn should be considered a humanitarian good eligible for export exceptions, Mr. Lapidos answered this way: 'Hairbrushes are not; iPods are not. But popcorn? It depends on how you look at it,' he said. 'Popcorn has fibers, which are helpful to the digestive system. So it could be considered humanitarian, though it's pushing the envelope.'" (New York Times, "Licenses Granted to U.S. Companies Run the Gamut," 12/24/10)

"American Life received a license to process funds from EB-5 Iranian visa applicants. The EB-5 visa program authorizes the United States to grant up to 10,000 immigrant visas per year establishing permanent residence in the country to foreign citizens who make an investment of $500,000 or more in a new business in the United States that creates at least 10 full-time jobs for American workers. 'American Life believes that the receipt and investment of funds in the U.S. does serve the sanctions policy goal of depriving Iran and the Iranian banks of economic resources and reducing the amount of funds at their disposal,' the company wrote." (New York Times, "Licenses Granted to U.S. Companies Run the Gamut," 12/24/10)

"Senator Christopher S. Bond, Republican of Missouri, wrote to OFAC in 2004 on this company's behalf, asking that it expedite its review. The company was seeking to export Vitamin and Mineral Premix and a volumetric feeder to the Ministry of Health in Iran and said it was under a 'strict time schedule to receive our license from OFAC or we will not be able to participate in this important project.' The license was issued the following month." (New York Times, "Licenses Granted to U.S. Companies Run the Gamut," 12/24/10)