USA

Hyatt Hotels is one of the companies listed as a speaker at the HR Trends Summit taking place from October 18-19, 2016 in Tehran, Iran. (Speakers).

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According to its Annual Report filed with the SEC for fiscal year 2012: "Several individuals stayed at the Park Hyatt Hamburg, a property leased by a foreign subsidiary of the Registrant, during 2012, for a total of 33 room nights pursuant to a pre-negotiated standard preferred rate agreement with Europaeisch-Iranische Handelsbank AG, an entity included on the Specially Designated Nationals and Blocked Persons List maintained by the Office of Foreign Assets Control in the U.S. Department of the Treasury. The aggregate revenues received by the hotel for such stays were approximately $9,300 (including F&B and other revenue). The EAME/SW Asia management segment EBITDA profit margin for the year ended December 31, 2012 was 28.3%. Based on this information, the aggregate net profits received by the hotel for such stays were approximately $2,600. The rates for such room nights were paid in accordance with the standard preferred rate agreement with Europaeisch-Iranische Handelsbank AG. The agreement with Europaerisch-Iranische Handelsbank AG was terminated in September 2012, and the Registrant does not intend to continue such activity. The individuals stayed at the Park Hyatt Hamburg before it became subject to the Iranian Transactions and Sanctions Regulations, 31 C.F.R. Part 560 (“ITSR”), on October 9, 2012. Even if the foreign subsidiary had been subject to the ITSR at the time of the stays, the Registrant believes that such hotel stays were exempt from the ITSR and the Weapons of Mass Destruction Proliferators Sanctions Regulations, 31 C.F.R. Part 544, pursuant to the International Emergency Economic Powers Act."

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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…The Hyatt hotel chain said that this year, an individual whom the Treasury Department identified as working for one of the National Iranian Oil Co.’s front companies stayed for five nights at the Grand Hyatt in Malaysia’s capital of Kuala Lumpur, a franchise not owned by the chain. The hotel netted about $400. But Hyatt said there was nothing wrong with that because no American people or products were involved." (Washington Post, "Under new law, companies disclosing even tiniest dealings with Iran," 12/4/13)

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"Billed as a dialogue between American church leaders and President Ahmadinejad of Iran, the Religions for Peace event at the Grand Hyatt Hotel on Thursday is shaping up as the focal point of this week's gathering of world leaders in New York City." (New York Sun, "Ahmadinejad Prepares To Steal the Scene," 9/22/08)

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"The banquet hall of the Grand Hyatt Hotel in mid-town Manhattan had the feel of an extravagant Persian wedding on Wednesday night. A crowd of over one thousand guests, dressed in formal attire, sat around tightly packed tables munching on Iranian delicacies and chit-chatting casually in Farsi. But the occasion was a dinner hosted by Iran's President Mahmoud Ahmadinejad. The guest list, all Iranian-Americans living in the tri-state area, had been drawn up from the database of Iran's mission to the United Nations and consulate in Washington D.C." (Wall Street Journal, "My Dinner with Ahmadinejad," 9/27/08)

"An AP review of corporate SEC filings found dozens of companies that have done business in Iran in recent years or said their products or services may have made it there through other channels. Some are household names: PepsiCo, Tyson Foods, Canon, BP Amoco, Exxon Mobil, GE Healthcare, the Wells Fargo financial services company, Visa, MasterCard and the Cadbury Schweppes candy and beverage maker. (Pioneer Press, "From bull semen to bras, Iran still buys American," July 9, 2008)

"Visa is not able to offer products or services to Iranian banks, merchants or consumers, a source in Visa Inc., US multinational financial services corporation, told Trend. This is due to the ongoing restrictions by the Office of Foreign Assets Control (OFAC) of the US..." (March 14, 2018)

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An AP review of corporate SEC filings found dozens of companies that have done business in Iran in recent years or said their products or services may have made it there through other channels. Some are household names: PepsiCo, Tyson Foods, Canon, BP Amoco, Exxon Mobil, GE Healthcare, the Wells Fargo financial services company, Visa, MasterCard and the Cadbury Schweppes candy and beverage maker. (From bull semen to bras, Iran still buys American, Associated Press, Sharon Theimer, July 9, 2008)

"This license authorized the export of chicken and beef and chicked-based products and beef products to Royal Meat Industry L.L.C. for resale to the Sham Sham Shiraz Protein Industry Complex in Shiraz, Iran." (New York Times, "Licenses Granted to U.S. Companies Run the Gamut," 12/24/10)

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"Since 2005, Tyson has had an indirect wholly-owned subsidiary in Europe that develops and sells chicken breeding stock in what the company called limited sales to Iran.  'No part of Tyson Foods in the U.S. has been party to these sales,' said spokesman Gary Mickelson, adding that sales on average have been less than 2 million annually." 

From 2000-2009, the company was the recipient of $2 billion US federal funds.  Their business in Iran is currently active.  (The New York Times, "Profiting from Iran, and the US," 3/6 2010) 

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An AP review of corporate SEC filings found dozens of companies that have done business in Iran in recent years or said their products or services may have made it there through other channels. Some are household names: PepsiCo, Tyson Foods, Canon, BP Amoco, Exxon Mobil, GE Healthcare, the Wells Fargo financial services company, Visa, MasterCard and the Cadbury Schweppes candy and beverage maker. (Associated Press, From bull semen to bras, Iran still buys American, Associated Press, Sharon Theimer, July 9, 2008)

Listed by U.S. Government as doing business in Iran. (U.S. Securities and Exchange Commission, List of Companies Doing Business With State Sponsors Of Terror, Removed from the internet in July of 2007)

“According to the OpenNet Initiative, a collaboration of Harvard University, the University of Toronto, the University of Cambridge, and Oxford University, Iran ‘uses the commercial filtering package SmartFilter – made by the U.S.-based company, Secure Computing – as the primary technical engine of its filtering system.’” (CBS News, “Iranians Bypass Net-Censors With High-Tech Tools,” 6/17/09)

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Computer security company McAfee Inc plans to buy Secure Computing Corp for $465 million, adding specialized equipment that keeps hackers from breaking into computer networks. (Reuters, “McAfee to pay $465 million for Secure Computing,” 9/22/08)

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SENATOR RICHARD DURBIN (D-IL): Software produced by American companies such as FortNet and Secure Computing has repeatedly been used to censor the Internet in Burma and Iran respectively. 

Secure Computing refused to provide me with a list of the governments that use its filters. However, the OpenNet Initiative, a partnership between the University of Toronto, Cambridge University and Harvard Law School, has compiled data on how such products are used in foreign nations where censorship is easy because the governments control all Internet service providers.

The initiative found that SmartFilter has been used by government-controlled monopoly providers in Kuwait, Oman, Saudi Arabia, Sudan, Tunisia and the United Arab Emirates. It has also been used by state-controlled providers in Iran, even though American companies are banned from selling technology products there. (Secure Computing denies selling products or updates to Iran, which is probably using pirated versions.) According to OpenNet, filtering products from another American company, Websense, have also been used by a state-controlled service provider in Iran. 

(Federal News Service, HEARING OF THE SUBCOMMITTEE ON HUMAN RIGHTS AND THE LAW OF THE SENATE COMMITTEE ON THE JUDICIARY, May 20, 2008)

According to its Annual Report filed with the SEC for fiscal year 2015: "The Iran Threat Reduction and Syria Human Rights Act of 2012 (ITRA) requires disclosure of certain activities relating to Iran by PepsiCo or its affiliates that occurred during our 2015 fiscal year. As previously disclosed, one of our foreign subsidiaries historically maintained a small office in Iran, which provided sales support to independent bottlers in Iran in connection with in-country sales of foreign-owned beverage brands, and which was not in contravention of any applicable U.S. sanctions laws. The office ceased all commercial activity since the enactment of ITRA. During our 2015 fiscal year, our foreign subsidiary received a license from the U.S. Treasury Department’s Office of Foreign Assets Control authorizing it to engage in activities related to the winding down of the office in Iran and completed the process of winding down its office. The foreign subsidiary did not engage in any activities in Iran other than wind-down activities in 2015, or have any revenues or profits attributable to activities in Iran during 2015."

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According to its Annual Report filed with the SEC for fiscal year 2014: "The Iran Threat Reduction and Syria Human Rights Act of 2012 (ITRA) requires disclosure of certain activities relating to Iran by PepsiCo or its affiliates that occurred during our 2014 fiscal year. As previously disclosed, one of our foreign subsidiaries historically maintained a small office in Iran, which provided sales support to independent bottlers in Iran in connection with in-country sales of foreign-owned beverage brands, and which was not in contravention of any applicable U.S. sanctions laws. The office ceased all commercial activity since the enactment of ITRA. In addition, the office of the foreign subsidiary had one local bank account, containing aggregate deposits of approximately $180, with a bank identified on the list of “Specially Designated Nationals” maintained by the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC). During our 2014 fiscal year, our foreign subsidiary received a license from OFAC authorizing it to engage in activities related to the winding down of the office in Iran and to close the bank account. Following receipt of this license, our foreign subsidiary restarted the process of winding down its office and closed the bank account. Subsequent to the end of 2014, this license expired and the foreign subsidiary ceased the process of winding down its office upon expiration of the license. The foreign subsidiary has applied for a license from OFAC to authorize continuation and completion of wind-down activities and intends to continue such activities upon receipt thereof. The foreign subsidiary did not engage in any activities in Iran other than wind-down activities in 2014, or have any revenues or profits attributable to activities in Iran during 2014."
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According to its Annual report filed with the SEC for fiscal year 2013: "The Iran Threat Reduction and Syria Human Rights Act of 2012 (ITRA) requires disclosure of certain activities relating to Iran by PepsiCo or its affiliates that occurred during our 2013 fiscal year.  As previously disclosed, one of our foreign subsidiaries historically maintained a small office in Iran, which provided sales support to independent bottlers in Iran in connection with in-country sales of foreign-owned beverage brands, and which was not in contravention of any applicable U.S. sanctions laws. In 2012, our foreign subsidiary took steps to close its office in Iran, including terminating all three of its employees, and the office has ceased all commercial activity since the enactment of ITRA.  During 2013, our foreign subsidiary continued the process of winding down its office in Iran pursuant to a general license from the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) until the expiration of such license in March 2013. The subsidiary did not engage in any activities in Iran other than wind-down activities in 2013, or have any revenues or profits attributable to activities in Iran during 2013. The office of the subsidiary continues to have one local bank account, containing aggregate deposits of approximately $180, with a bank identified on the list of “Specially Designated Nationals” maintained by OFAC. The subsidiary has applied for a license from OFAC to authorize continuation and completion of wind-down, including closing the bank account, and plans to resume and complete such wind-down activities upon receipt thereof."

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According to its Annual Report filed with the SEC for fiscal year 2012: "The recently enacted Iran Threat Reduction and Syria Human Rights Act of 2012 (TRA) requires disclosure of certain activities relating to Iran by PepsiCo or its affiliates that occurred during the twelve month period covered by this report. One of our foreign subsidiaries had historically maintained a small office in Iran, which provided sales support to independent bottlers in Iran in connection with in-country sales of foreign-owned beverage brands, and which was not in contravention of any applicable U.S. sanctions laws. Starting in early 2012, our foreign subsidiary began to take steps to close this office in Iran, including the termination of all three of its employees, and the office has ceased all commercial activity since enactment of the TRA. Prior to the enactment of the TRA, this foreign subsidiary paid local Iranian governmental authorities taxes associated with the office and with wind-down activities. The office also maintained local bank accounts with two banks identified on the list of “Specially Designated Nationals” (SDN) maintained by the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC). The aggregate amount of transactions or dealings the business office had with the Iranian Government and banks on the SDN list in 2012 was approximately $100,000, and no gross revenue or net profit was attributable to such activity. Our foreign subsidiary is currently in the process of completing the wind-down of the office in Iran pursuant to a general license from OFAC and intends to seek any further specific licenses as may be necessary in order to complete the wind-down of this office."

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Over the last three presidential administrations, the United States government has granted Pepsi 16 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 Pepsi to sell its products in Iran. The company has also been licensed to sell its products in Sudan. A company spokesperson said that the company was abiding by United States law: 'When it comes to politically sensitive markets, we rely on rules set by the U.S. Government, and we're committed to adhering to those rules, however they may evolve.'" (New York Times, "Licenses Granted to U.S. Companies Run the Gamut," 12/24/10)

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An AP review of corporate SEC filings found dozens of companies that have done business in Iran in recent years or said their products or services may have made it there through other channels. Some are household names: PepsiCo, Tyson Foods, Canon, BP Amoco, Exxon Mobil, GE Healthcare, the Wells Fargo financial services company, Visa, MasterCard and the Cadbury Schweppes candy and beverage maker. (Associated Press, "From bull semen to bras, Iran still buys American," 7/9/08)

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"The only visual clues that these lunching ladies aren't dining at some smart New York City eatery but in the heart of Washington's Axis of Evil are the expensive Hermès scarves covering their blond-tipped hair in deference to the mullahs. And the drink of choice? This being revolutionary Iran, where alcohol is banned, the women are making do with Coca-Cola. Coca-Cola? Isn't corporate America prohibited by Washington's sanctions from doing business in Iran? Yes, for the most part, says U.S. Treasury spokeswoman Molly Millerwise. But Treasury has bent the rules for foodstuffs, a loophole through which American drinks giants Coca-Cola (Charts) and PepsiCo (Charts) have been able to pour thousands of gallons of concentrate into Iran via Irish subsidiaries. And that has allowed these brands, so much a symbol of America - and so much an affront to Iran's conservative clerics - to open another front in their global cola war. After just a few years back in Iran, Coke and Pepsi have grabbed about half the national soft drink sales in what is one of the Middle East's biggest drinks market... Coke and Pepsi shrug off the hardliner rhetoric and insist they are aren't breaking any laws - American or Iranian - by licensing products in Iran through their concentrate subsidiaries in Ireland. Says Pepsi spokesman Dick Detwiler: 'PepsiCo has no equity investment in Sasan or any other enterprise in Iran and has no relationship with the government of Iran. We sell in strict accordance with all applicable U.S. laws and restrictions.' Coke spokesman Charles Sutlive echoes Pepsi's line, adding that Coke, which also licenses Fanta, Sprite and Dasani water through Khoshgovar, has 'no tangible assets in Iran'... But the fiercest battle is being fought in the marketplace, where Zamzam is defending its estimated 50 percent share of Iran's $1 billion in annual drinks sales, and Coke seems to have a clear edge over Pepsi. Shopkeeper Shahgholi owns a store in downtown Tehran around the corner from the former U.S. embassy, today a museum displaying 'U.S. atrocities' that draws few visitors. 'Nine of out ten bottles I sell are Coke,' he says. Sasan's Abadi says Pepsi and Coke share about 40 percent of the market, but Khoshgovar commercial manager Fahime Askari puts Coke's market share way ahead of Pepsi's. Reliable sales figures are hard to come by. Coke may be the real thing in Iran, but you won't hear that familiar slogan here. Washington's rules forbid U.S. companies to provide their licensees marketing support in Iran. It wouldn't be welcomed anyway by the mullahs, who regard America-themed advertising as spiritual pollution. 'Because of the relationship between Iran and America,' Abadi says, 'we are not allowed to advertise in public places.'" (Fortune, "Iran's cola war," 2/6/07)

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"Both Pepsi and Coca-Cola have factories in Iran." (Agence France Presse, Iran TV urges boycott of Zionist products," 7/19/06)

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"Both companies send the syrup to independent companies in Sudan and Iran, which then produce the drinks in their own factories, selling them in bottles and cans identical to Coca-Cola and Pepsi containers found elsewhere. A Coca-Cola spokesman, Dana Bolden, said the primary motive for operating in Sudan and Iran was 'to ensure quality control and protect our trademarks with the independent bottler.'" (The International Herald Tribune, "Coveted U.S. products find way past sanctions," 5/27/08)

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“There's also an undercurrent of anti-Americanism that has shaped Germany's Iran policy. Ruprecht Polenz, the top Christian Democrat on the Bundestag's Foreign Affairs Committee, has defended German trade with Iran by evoking the presence of Coca Cola and Pepsi in Iran.” (The New Republic, "Business as Usual: How Europe Will Undermine Obama's Iran Policy," 8/17/08)

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"OSG, based in New York, said Feb. 10 that the pool of 45 supertankers from seven owners in which its carriers trade will no longer go to Iran... Four OSG-owned ships, managed by Tankers International LLC, called at the country's biggest crude-export terminal in the past year, ship tracking data compiled by Bloomberg show...OSG's Overseas Rosalyn, which can carry about 2 million barrels, arrived at Kharg Island on Jan.27 and departed the next day, tracking data compiled by Bloomberg show.  It left abour 16 feet deeper in the water, an indication it loaded cargo...OSG complies with all U.S and European laws and its headquarters in New York doesn't manage charters, OSG Chief Executive Officer Morten Arntzen said in an email Jan. 30."  (Bloomberg, "Iran Sanctions Tighten as OSG to Frontline Halt Crude Cargo," 2/13/12 )

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OSG is "the second largest publicly traded oil tanker company in the world, measured by number of vessels." (Company website. "Corporate Profile")

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"According to marine transport site, Equasis, ships owned by US shipping company, Overseas Shipholding Group Inc. (NYSE: OSG), partly owned [by] Oudi Recanati and Ariel Recanati, have docked in Iran. An examination of Equasis's website found that OSG oil tanker Overseas Tanabe docked at Khark in Iran in September 2009. The ship flies under the Marshall Islands flag." (Globes. "Recanti's OSG ships also docked in Iran," 6/1/11)

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Listed by U.S. Government as doing business in Iran. (U.S. Securities and Exchange Commission, List of Companies Doing Business With State Sponsors Of Terror, Removed from the internet in July of 2007)

According to the website Intravel Card, "You can’t use MasterCard in Iran. Due to sanctions, Iran is forbidden to make any USD/EURO transaction to International banking system So, MasterCard in Iran is not accepted nor Credit card and Visa Card or any other debit cards. You can use Iran debit card like IntravelCard instead of MasterCard in Iran."

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In their Annual Report filed with the SEC for fiscal year 2021, Mastercard stated that "Iran and Syria have been identified by the U.S. State Department as terrorist-sponsoring states, and we [Mastercard] have no offices, subsidiaries or affiliated entities located in these countries and do not license entities domiciled there."

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On March 16, 2016, OFAC issued a Finding of Violation to Mastercard that stated: "The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has issued a Finding of Violation to MasterCard International Incorporated (“MasterCard”) for violations of the Reporting,
Procedures and Penalties Regulations (RPPR), 31 C.F.R. part 501. On October 25, 2007, OFAC designated Bank Melli pursuant to Executive Order 13382 of June 28, 2005, “Blocking Property of Weapons of Mass Destruction Proliferators and Their Supporters,” and Bank Saderat pursuant to Executive Order 13224 of September 23, 2001, “Blocking Property and Prohibiting Transactions with Persons who Commit, Threaten to Commit, or Support Terrorism,” and added both parties to the List of Specially Designated Nationals and Blocked Persons (the “SDN List”).

At the time OFAC designated Bank Melli and Bank Saderat, MasterCard held accounts in which Bank Melli or Bank Saderat had an interest. MasterCard had previously taken steps to restrict the above-referenced accounts following the issuance of Executive Order 12959 of May 6, 1995, “Prohibiting Certain Transactions With Respect to Iran” (“E.O. 12959”), which prohibited the exportation of goods, services (including financial services), or technology from the United States to Iran. In the time between the issuance of E.O. 12959 and the above-referenced designations, the Bank Melli and Bank Saderat accounts became dormant on MasterCard’s books, but the assets in the accounts nonetheless remained with MasterCard. MasterCard, however, failed to report the accounts to OFAC as blocked following OFAC’s designation of the banks. By failing to properly report the abovereferenced accounts in which Bank Melli and Bank Saderat had an interest, MasterCard violated § 501.603(b) of the RPPR."

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According to its Annual Reports filed with the SEC in 2016, 2017, 2018, and 2019: 

We identified through our compliance program that for the period covered by this Report, Mastercard processed transactions resulting from:

•certain European acquirers having acquired transactions for consular services with Iranian embassies located in Austria, France and Spain that accepted Mastercard cards
•certain European and Middle Eastern acquirers having acquired transactions for Iran Air, which accepted Mastercard cards, in Austria, France and Qatar

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In 2017 the U.S. state of Michigan listed Mastercard as an Iran restricted company rendering Mastercard ineligible for investment and/or state contracting./ "MasterCard does not have any direct links with Iran due to the primary sanctions still in place, said the Central Bank of Iran’s head of Communications and Information Technology Department.

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“Although the US-based company provides no services in Iran, negotiations are underway with non-US international companies to offer international credit cards to Iranians, which will come to fruition next year,” Nasser Hakimi was also quoted as saying by ISNA." (March 4, 2017)

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An AP review of corporate SEC filings found dozens of companies that have done business in Iran in recent years or said their products or services may have made it there through other channels. Some are household names: PepsiCo, Tyson Foods, Canon, BP Amoco, Exxon Mobil, GE Healthcare, the Wells Fargo financial services company, Visa, MasterCard and the Cadbury Schweppes candy and beverage maker. (Associated Press, "From bull semen to bras, Iran still buys American," July 9, 2008)

According to a correspondence filed with the SEC in 2011: "We have a distribution agreement with Iran Memco, based in Iran, who operates as our distributor for ophthalmology products in Iran. We have been working with Iran Memco since 2007."

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“In December 2005, we [Iridex] received a purchase order from Hamilens Co., a distributor in Tehran, Iran for two OcuLight SLx Infrared Lasers, 20 Gauge straight Endoprobes and two Dovetail lens filters with an aggregate purchase price equal to $39,040.00. The products related to this order were shipped on December 30, 2005. Iridex received a partial payment of $15,472.00 in June 2006 for this order.” (SEC Correspondence, 2007)

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According to an Annual Report filed with the SEC: "United States export laws permit the sale of medical products to certain countries under embargo by the United States government if the seller of such products obtains a license to do so, which requirements are in place because the United States has designated such countries as state sponsors of terrorism. Certain of our products have been sold in Iran, Sudan and Syria under license through distribution agreements with independent distributors. The aggregate revenue generated by sales of our products into Iran, Sudan and Syria have been immaterial to our business and results of operations. We may continue to supply medical devices to Iran, Sudan and Syria and other countries that are under embargo by the United States government upon obtaining all necessary licenses." 

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Listed by U.S. Government as doing business in Iran. (U.S. Securities and Exchange Commission, List of Companies Doing Business With State Sponsors Of Terror, Removed from the internet in July of 2007)