USA

Alltech lists Andishan Terjarat Asia as its distributor in Tehran, Iran.

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The US Government granted animal nutrition company Alltech Inc. a license to sell animal feed to Iran. (New York Times, "Licenses Granted to U.S. Companies Run the Gamut," 12/24/10)

"'U.S. government officials with intelligence and border security responsibilities' contacted Alcoa in January 2006 to advise the company of a continuing investigation stemming from the belief that one of its customers in Turkey was acting as a purchasing agent on behalf of the government of Iran, records show. The investigation was never publicly reported, but as a result of this notification, Libby Archell, an Alcoa spokeswoman, said scheduled deliveries to that customer were halted and the customer was notified that no additional shipments would be forthcoming. A license was needed, however, so that Alcoa could refund the customer for goods that had been paid for but not yet shipped "in order to avoid litigation and attendant discovery," the license application states.

It is unclear what product Alcoa had been shipping to the Turkish customer; OFAC redacted that information, and Ms. Archell declined to say. She said that Alcoa was 'completely unaware' and had no way of knowing that its customer was acting as a front for the Iranian government until the United States government informed the company of its investigation. The company uses an 'extremely thorough due dilligence process' to vet potential customers, she said, adding that the customer in question was not at the time on the government's blacklist of sanctioned parties." (New York Times, "Licenses Granted to U.S. Companies Run the Gamut," 12/24/10)

According to its February 28, 2018 SEC disclosure, Albemarle said, "We do not intent to continue doing such business in Iran." (SEC, "Form 10-K," 2/28/2018).

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The US Government granted Albemarle Corporation a license to sell ibuprofin in Iran. (New York Times, "Licenses Granted to U.S. Companies Run the Gamut," 12/24/10)

"Atlasin is the exclusive representative of Airsep in Iran territory since 1991 and has already sold more than 5000 oxygen concentrators for patients in all around Iran.”

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Over the last three presidential administrations, the United States government has granted AirSep Corporation 27 special licenses to do business in Iran. (New York Times, "Companies with Permission to Bypass Sanctions," 12/24/10)

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"Helen Ying and Larry Hughes, who head AirSep's medical and industrial divisions, said the company had received licenses to sell products like an oxygen machine that effectively turns a room into an oxygen tent and central oxygen systems that supply entire hospitals. The company uses a middleman in Iran, whom Mr. Hughes declined to name for competitive reasons, to make the sales, and another company to do the installations. 'It's a hard way to do business,' he said." (New York Times, "Licenses Granted to U.S. Companies Run the Gamut," 12/24/10)

"This license authorized 540 Sports and Entertainment to place American basketball players on Iranian teams. When 540's owner, John Spencer, first received a phone call from an Iranian sports agent inquiring about such placements, he thought that the man was joking. But since then, he said, he has placed a number of professional players on teams in Iran. On average, the men were paid $7,000 to $40,000 per month, Mr. Spencer said. The United States has long supported such 'sports diplomacy,' and while relations between the United States and Iran are testy, Mr. Spencer said he found that everyday Iranians 'are fascinated with our culture, just as we should be fascinated with theirs.'" (New York Times, "Licenses Granted to U.S. Companies Run the Gamut," 12/24/10)

According to its Annual Report filed with the SEC for fiscal year 2021: "The Company is making the following disclosure under Section 13(r) of the Exchange Act: Protection of Intellectual Property Rights in Iran Pursuant to Specific License As part of its intellectual property (“IP”) protection efforts, 3M has obtained and maintains patents and trademarks in Iran. Periodically, 3M pays renewal fees, through IP service providers/counsel located in Germany, Dubai and Iran, to the Iran Intellectual Property Office (“IIPO”) for these patents and trademarks and has sought to prosecute and defend such trademarks. On January 15, 2020, OFAC granted 3M a specific license to make payments to IIPO at its account in Bank Melli, which was designated on November 5, 2018 by OFAC under its counter terrorism authority pursuant to Executive Order 13224. As authorized by OFAC’s specific license, in the period ended December 31, 2021, 3M paid $307 to IIPO as part of its intellectual property protection efforts in Iran. 3M plans to continue these activities, as authorized under the specific license."

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According to its Annual Report filed with the SEC for fiscal year 2019: "As part of its intellectual property protection efforts, 3M has obtained and maintains patents and trademarks in Iran. Periodically, 3M pays renewal fees, through local counsel located in Dubai and Iran, to the Iran Intellectual Property Office (“IIPO”) for these patents and trademarks and has sought to prosecute and defend such trademarks. On January 15, 2020, OFAC granted 3M a specific license to make payments to IIPO at its account in Bank Melli, which was designated on November 5, 2018 by OFAC under its counter terrorism authority pursuant to Executive Order 13224. As authorized by OFAC’s specific license, in the quarter ended March 31, 2020, 3M paid $109 to IIPO as part of its intellectual property protection efforts in Iran. 3M plans to continue these activities, as authorized under the specific license."

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According to its Annual Report filed with the SEC for fiscal year 2018: "Disclosures Under Iran Threat Reduction and Syria Human Rights Act of 2012

The Company is making the following disclosure under Section 13(r) of the Exchange Act because the Company’s management recently became aware that the ultimate customer in Iran, which meets the definition of the “Government of Iran” under Section 560.304 of 31 C.F.R. Part 560 (the “Iran Party”), was not eligible to receive non-U.S. origin products sold by our foreign subsidiary through a third-party distributor under General License H issued by the U.S. Department of the Treasury, Office of Foreign Assets Control (“OFAC”). Based upon currently known information, total revenues to our foreign subsidiary from indirect sales to the Iran Party, which took place from September 2016 through September 2018, were approximately $8.4 million, and the total net income attributable to those sales was approximately $1.6 million.

Upon expiration of OFAC’s authorization in November 2018, our foreign subsidiary stopped all shipments to the distributor for resale to the Iran Party, and, accordingly, the foreign subsidiary does not intend to continue sales to, or engage in other dealings with the Iran Party. On April 8, 2019, the Company submitted initial notifications of voluntary self-disclosures to OFAC regarding these historic activities, and the Company intends to cooperate fully with OFAC." (U.S. Securities and Exchange Commission, "Form 10-Q," 4/26/2019).

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"Jacqueline Berry, a spokeswoman for 3M, said the company received this license to sell certain medical and dental products to civilian populations in Iran. It separately received another license to sell specialized window film to a United Nations building in Sudan." (New York Times, "Licenses Granted to U.S. Companies Run the Gamut," 12/24/10)

Transammonia actively does business in Iran via a Swiss subsidiary. (CNBC. "Transammonia:A Story of American Business in Iran," 12/7/10)

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Transammonia has performed business dealings with the Iran Petrochemical Commercial Company (IPCC), which is the subsidiary and international trading arm of the National Petrochemical Company (NPC). NPC is wholly owned by the Iranian government. It is responsible for the development and operation of the country's petrochemicals sector and is the second largest producer and exporter of petrochemicals in the Middle East after Saudi Arabia's Sabic.

On June 16, 2010, the U.S. Treasury Department added NPC and its subsidiary IPCC to the Iranian Transactions Regulations (ITR), which “prohibit transactions between U.S. persons and the Government of Iran. These identifications allow U.S. persons and others to identify Iranian Government entities and protect themselves against the risks posed by such entities.” (U.S. Department of Treasury, “Fact Sheet: U.S. Treasury Department Targets Iran’s Nuclear and Missile Programs,” 6/16/10)
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February 2010: “Transammonia purchased 23,000 tonnes from IPCC at $370/tonne FOB for late March loading from BIK [(Bandard Imam Khomeinei)].” (Chemical News & Intelligence, 2/24/10)

July 2009: “This price was $18/tonne lower than last done spot business in the Middle East, [1]which was concluded at $200/tonne FOB following a sale by Iran's Petrochemical Commercial Co (PCC) to trader Transammonia.” (Chemical News & Intelligence, 7/3/09)

May 2009: “Trader Transammonia confirmed it had purchased 23,400 tonnes from Iran Petrochemical Commercial Co (IPCC) at $200/tonne FOB (free on board) with 30 days' credit… Transammonia will ship 15,000 tonnes on 18-21 May on the Marycam Swan for shipment to the southeast Asia. The balance of the purchase will be lifted later, it said.” (Chemical News & Intelligence, 5/14/09).

May 2006: The Agricultural Support Services Company of Iran (ASSC) “received nine offers from traders and purchased urea from Transammonia at Euro212/tonne cost and freight (CFR) southern Iranian ports.” (Chemical news & Intelligence, 5/8/06)

"Marriott International, the US-listed hotel operator, said it was “very keen” to enter the Iranian market pending the removal of legal barriers, with a spokesman from the hotel chain saying there is strong demand in Iran for hotels. Alex Kyriakidis, president and managing director for the Middle East and Africa at Marriott, said that Iran represents a “substantial market” to be responded to in terms of demand for hotels. “Today, Marriott International, being a United States publicly-floated company, is precluded from doing business in Iran. Depending on what happens in the future and what agreements are reached between the United States and Iran, if the doors open legally to do business in Iran, we would be very keen to pursue that opportunity,” he said..." (Gulf News,  "Marriott 'very keen' to pursue opportunities in Iran," 12/7/2016).

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"A Hamburg hotel’s decision on Monday to hold a controversial conference with an alleged violator of human rights to promote German-Iranian trade prompted protest by New York–based United Against Nuclear Iran (UANI) and the German chapter of Stop the Bomb.... The day-long event addressed 'investment possibilities in the northwestern provinces of Iran' and the program listed Iran’s ambassador to Germany, Ali Reza Sheikh Attar, as the keynote speaker. Iranian Kurds and human rights groups say Attar sanctioned a massacre of Iranian Kurds during his tenure as governor of the Kurdistan and West Azarbaijan provinces from 1980 to 1985. In a letter faxed to Marriott’s CEO, J.W. Marriott Jr., UANI President Mark D. Wallace wrote, 'Ambassador Attar represents a criminal regime that flouts international law in developing an illegal nuclear weapon, brutally represses its own people, and is the world’s leading state sponsor of terrorism.' UANI called on Marriott to cancel the pro-Iran trade event. 'If the Marriott continues with its plans to serve as a host to the Iran Business Forum and Ambassador Attar, UANI will take action against the Marriott hotel chain worldwide. UANI will call on its activists to peacefully protest your properties, and will call for a general public boycott of all Marriott properties,' wrote Wallace." (Jerusalem Post, "NGOs slam Marriott for hosting German-Iranian event," 11/23/10)

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On November 22, 2010, the Marriott Courtyard Airport Hotel in Hamburg was scheduled to host the "Iran Business Forum." UANI released a letter on November 19, 2010, calling on Marriott not to host the Iranian trade delegation.

"Luxembourg-based software company Skype, which is in registration for an initial public offering, has answered a subpoena from the Treasury Department seeking information about transactions involving Iran.

Silver Lake Partners, the tech-centric private equity firm that bought the majority share in Skype in 2009, was served an administrative subpoena in July, Skype said in a Nov. 2 filing with the Securities and Exchange commission. The little-noticed subpoena was first disclosed by the company in its August registration statement.

The Treasury’s Office of Foreign Assets Control, which enforces U.S. sanctions, requested information on transactions since 2005, including those related to call termination fees to an unnamed Iranian telecommunications provider, the company said." (Wall Street Journal, "Skype Answers Subpoena On Sanctions Investigation," 11/3/2010)

Lists Farir Asa Teb as its distributor in Iran.

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Sweet'n Low lists an office in Tehran on its website.

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Sweet'n Low is owned by Cumberland Packing Corporation.