USA

"HP acquired the Apogee group, a U.K. based office equipment dealer, on November 1, 2018.  During the second quarter of 2019, HP discovered that its newly acquired subsidiary had invoiced one payment and accepted two payments from Bank Sepah International plc shortly after the acquisition, under a legacy contract for copier services.  Bank Sepah International plc is subject to U.S. sanctions pursuant to Executive Order 13382. The combined total value of the transactions was £72.49 ($92.78).  We are unable to accurately calculate the net profit attributable to these transactions.  Following HP’s discovery of these transactions and at HP’s direction, Apogee terminated the contract with Bank Sepah International plc.  HP is in the process of disclosing relevant transactions related to the Apogee acquisition to the relevant authorities." (SEC Disclosure, 5/30/2019)

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HP discovered that its newly acquired subsidiary, Apogee group, processed two service calls during November 2018, shortly after the acquisition, for toner replacement on behalf of Bank Saderat plc, with which it had a legacy contract. Following HP’s discovery of these transactions and at HP’s direction, Apogee terminated the contract with Bank Saderat plc. (SEC Disclosure, 12/12/2019).

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The Iranian company, DAYA SERVER, is engaged in the sale and support of HPE products. (DAYA SERVER Website, “Customers”). (DAYA SERVER Website, “Customers”). 

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 "HP has a policy of complete compliance with all US export laws. We don't sell products directly to Iran and we don't have any employees or facilities in that country. Having recently examined the situation, we believe it's important to go beyond the letter of the law. HP is taking further steps with distributors in the Middle East intended to prevent the distribution of our products in Iran by third parties. These actions include tightening distributor contract terms to explicitly prohibit the sale of HP products in Iran, more closely monitoring the activities of our distributors in the Middle East, and conducting even more frequent audits of our distributors in the region." (Company Website)

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“A major infiltration of a military network blamed on Iran was facilitated by a poorly written contract with computer-services provider Hewlett-Packard Co. , said people familiar with the matter. H-P's contract with the military didn't require it to provide specific security for a set of Navy Department databases, and as a result, no one regularly maintained security for them. That eased access for hackers, who used the opening to penetrate deep into the Navy Marine Corps Intranet network, said people familiar with the matter. The findings of the Navy's investigation are being closely watched by lawmakers on Capitol Hill, who next week are set to evaluate the nomination of Vice Adm. Michael Rogers as National Security Agency director. Adm. Rogers was the Navy cyber chief who oversaw the response. The intrusion, which officials said didn't compromise classified information or email, took about four months to clean up. The Navy has been working to address lapses revealed by the hack and other security efforts under what it calls Operation Rolling Tide. The infiltration is the only publicly known penetration of a military network blamed on Iranian hackers…The hacking ‘is a contracting failure and not a technology failure,’ said one cybersecurity specialist familiar with the situation. ‘This is a Dilbert cartoon.’ H-P on its website calls the Navy and Marine Corps network ‘the world's largest and most secure intranet,’ saying that ‘improved security is unquestionably NMCI's greatest value.’ The network's security system detects more than 800 new viruses each month, it says. An H-P spokesman declined to comment on the infiltration.” (Wall Street Journal, “Navy Hacking Blamed on Iran Tied to H-P Contract,” 3/6/14)

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"A major Iranian partner of Huawei Technologies offered to sell at least 1.3 million euros worth of embargoed Hewlett-Packard computer equipment to Iran's largest mobile-phone operator in late 2010, documents show. China's Huawei, the world's second largest telecommunications equipment maker, says neither it nor its partner, a private company registered in Hong Kong, ultimately provided the HP products to the telecom, Mobile Telecommunication Co of Iran, known as MCI... Huawei has a similar partnership with HP. In a statement, the Palo Alto, Calif., company said, 'HP has an extensive control system in place to ensure our partners and resellers comply with all legal and regulatory requirements involving system security, global trade and customer privacy and the company's relationship with Huawei is no different.' The statement added, 'HP's distribution contract terms prohibit the sale of HP products into Iran and require compliance with U.S. and other applicable export laws.'... The proposal makes clear that HP computer servers were an integral part of the 'Hardware Installation Design' of the expansion project. Tables listing equipment for MCI facilities at a new site in Tehran and in the city of Shiraz repeatedly reference HP servers under the heading, 'Minicomputer Model.'... The pages list prices for HP servers, disk arrays and switches, including those that already are 'existing' and others that need to be added. The total proposed project price came to 19.9 million euros, including a 'one time special discount.' The proposed new HP equipment, which totaled 1.3 million euros, included one server, 20 disk arrays, 22 switches and software . The existing HP equipment included 22 servers, 8 disk arrays and 13 switches, with accompanying prices. Asked who had provided the existing HP equipment to MCI, Vic Guyang, a Huawei spokesman, said it wasn't Huawei." (Reuters, "Exclusive: Huawei partner offered embargoed HP gear to Iran," 12/30/12)

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"But because its products are often sold by others through indirect channels without its knowledge or consent 'it is always possible that products may be diverted to Iran or Syria after being sold to channel partners, such as distributors and resellers,' HP said... HP said in both letters that it would continue to work with ZTE, but it had conducted an internal investigation relating to an alleged sale of its products to MTN Irancell, Iran's second largest mobile carrier." (Reuters, "HP says products may have been sold to Syria by others," 11/23/2012)

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"MTN Irancell, a joint venture between MTN Group Ltd of South Africa and an Iranian government-controlled consortium, sourced equipment from Sun Microsystems Inc, Hewlett Packard Co and Cisco Systems Inc, the documents and interviews show. MTN owns 49% of the joint venture but provided the initial funding." (Reuters, "Iranian cell-phone carrier obtained banned U.S. tech," 6/4/2012)

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"Hewlett-Packard formed a partnership in 1997 with a newly formed company in Dubai to sell its products in the Middle East, including to Iran. It also sold services to the U.S. military while operating in Iran. In January 2009, after its sales in that country came under scrutiny, the company said it would cease all business in Iran to go "beyond the letter of the law."  From 2000-2009, the company has been the recipient of $17.6 billion US federal funds.  They have withdrawn their acitivites in Iran.  (The New York Times, "Profiting from Iran, and the US," 3/6/2010)

"Amid rising tensions between Iran and the US, five missiles were fired at an “American oil company,” according to the Iranian Fars News website. The report is based on another Iraqi report that said Monday morning that rockets had been fired at a company linked to Halliburton. How the website knew this is unclear and photos were not available from the scene. It was also unclear who fired the alleged rockets; it could also be blamed on ISIS.

However, the alleged rocket attack fits a pattern of dozens of such attacks on bases housing US troops and against the American Embassy. In 2018, there were also attacks on US facilities in Basra, and the oil fields were largely evacuated of some foreign workers. The US evacuated its consulate in Basra and warned Iran and its proxies against attacks. Social justice protesters in October and November 2019 blocked roads to the oil fields around Basra." (4/6/2020)

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"This license authorized the company's United States personnel to engage in transactions relating to PSL Energy Service's oil drilling equipment. In response to questions from The New York Times, OFAC said that PSL Energy Services, a Scottish oil services company, had removed the equipment from Iran after completing a project there. It was in negotiations for the sale of a majority of its stock to Halliburton. Because the equipment was among the PSL's assets and had been used in Iran, it was deemed 'Iranian-origin goods' under American regulations, and thus a license was needed to allow Halliburton to deal with the equipment in the future. Shortly after OFAC issued the license, Halliburton completed the deal to acquire PSL Energy Services and announced it, records show." (New York Times, "Licenses Granted to U.S. Companies Run the Gamut," 12/24/10)

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"This license authorized the company to engage in transactions that ultimately would allow it to withdraw from Iran. The withdrawal came after the company was criticized for doing business in Iran's lucrative energy sector through a loophole that allows foreign subsidiaries of United States companies to do business in sanctioned countries or with sanctioned entities, activities that would be forbidden for the American parent." (New York Times, "Licenses Granted to U.S. Companies Run the Gamut," 12/24/10)

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"Halliburton, former Vice President Cheney's old company, provided oil and gas drilling services to Iran through foreign subsidies. After a political furor erupted over the work, the company announced it would do no new business in Iran, and it exited the country altogether in 2007. While still operating in Iran, Halliburton won huge contacts from the federal government, including a no-bid contract to restore Iraq's oil sector, as did its subsidiary at the time, Kellogg Brown & Root." From 2000-2009, the company was the recipient of $27.1 billion US federal funds.  The company has withdrawn its investments from Iran. (The New York Times, "Profiting from Iran, and the US," 3/6/2010)

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"More importantly, even the threat of unilateral sanctions has been effective as recently as last year. As state after state has ramped up efforts to divest pension funds from companies invested in Iran, and as S 970, the Smith-Durbin Iran Counter-Proliferation Act, has garnered support in Congress, American companies like General Electric, Halliburton, and Baker Hughes with subsidiaries operating in Iran have rethought the wisdom of doing business with one of our nation's most dangerous enemies. And as the United States has contemplated additional unilateral banking sanctions on Iran, banks across Europe have ratcheted back their exposure to the Islamic Republic, with some pulling out entirely." (AEI, "The Iran Counter-Proliferation Act of 2007," Danielle Pletka, April 21, 2008)

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"A top executive of Halliburton Company told lawmakers here yesterday that the corporation does not intend to resume business in Iran now that it has completed its current contracts. Testifying before a Senate subcommittee investigating American business ties to Iran, a Halliburton vice president and corporate secretary, Sherry Williams, said that when company officials decided to leave Iran in 2005, 'We recognized that we would not be able to go back in' under federal law." (The New York Sun, "Halliburton Says It Has No Plans To Go Back To Iran," Russell Berman, May 1, 2007)

"ExxonMobil did business with Iran, Syria and Sudan through a European subsidiary while President-elect Donald Trump’s nominee for secretary of State was a top executive of the oil giant and those countries were under U.S. sanctions as state sponsors of terrorism, Securities and Exchange Commission filings show. That business connection is likely to surface Wednesday at a confirmation hearing for ExxonMobil CEO Rex Tillerson before the Senate Foreign Relations Committee. The sales were conducted in 2003, 2004 and 2005 by Infineum, in which ExxonMobil owned a 50% share, according to SEC documents unearthed by American Bridge, a Democratic research group. ExxonMobil told USA TODAY the transactions were legal because Infineum, a joint venture with Shell Corporation, was based in Europe and the transactions did not involve any U.S. employees. The filings, from 2006, show that the company had $53.2 million in sales to Iran, $600,000 in sales to Sudan and $1.1 million in sales to Syria during those three years." (USA Today, "ExxonMobil and Iran did business under secretary of State nominee Tillerson," 1/9/2017).

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According to an Iran Notice filed with the SEC in 2013: "The captioned Act was signed by President Obama on August 10, 2012.  Among other things, the Act extended the prohibition against U.S. persons doing business with the Government of Iran to include such persons’ non-U.S. subsidiaries.  Previously, non-U.S. subsidiaries were not covered by this restriction.  Application of the restriction to non-U.S. subsidiaries took effect on October 10, 2012.  The Act also requires registrants to disclose, in their annual and quarterly reports, activities covered by the Act which occurred anytime during the period covered by the report, even if such activities occurred prior to the effective date of the Act and were permitted at the time.

During the period from January to September, 2012, ExxonMobil’s majority-owned Canadian affiliate, Imperial Oil Limited (IOL), made several fleet sales of motor fuel with an aggregate total sales price of approximately 11,000 Canadian dollars to the Iranian Embassy in Canada.  IOL’s net profits attributable to these sales were less than 500 Canadian dollars.  The sales were made without the involvement of any U.S. person and were permitted by U.S. laws in effect at the time.  No sales occurred after the October 10, 2012, effective date, and we do not expect any such sales to occur in the future."

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"Infineum U.K., a joint venture in which ExxonMobil has a 50 percent indirect ownership, sold gasoline additives to Iran, but stopped in 2006, according to Cynthia Bergman White, company spokeswoman. Exxon is a big supplier of fuel to the Department of Defense." From 2000-2009, the company has been the recipient of $4.9 billion in US federal funds.  They have withdrawn their investments from Iran. (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," 7/9/08)

"Chery has a big U.S. partner, too. On July 4 last year Chery signed an agreement to co-produce economy cars with Chrysler, and on Dec. 18, Xinhua, the official Chinese news agency, reported that Chrysler would start selling Chery-made sedans under the Dodge brand in Mexico very soon. The Chrysler alliance is starting small, with Chrysler selling the Chery-made under the Chrysler brand, Dodge. Chery's business outside China more than doubled last year. The company opened a factory in Iran in 2003, a plant in Russia in 2006, and a plant in Egypt in 2006." (Business Week, "China Autos: Chery Keeps Accelerating," 1/07/08)

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The bill, which roped in companies with even small engagements with Iran, affected not only Honda, but Chrysler AG, Bridgestone Corp., Siemens and ThyssenKrupp AG, all of which have factories in Ohio. The pension funds estimated that the targeted companies employed more than 45,000 workers in the state. (The Associated Press, "Should states sell stocks to protest links to Iran," 6/14/07)

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"China's biggest domestic automaker, Chery, is opening a factory in Iran, expanding its fast-growing foreign ties soon after announcing ventures with Chrysler and Fiat." (Associated Press, "China's Chery to open auto factory in Iran," 8/18/07)

"Iran wants U.S. companies such as Chevron Corp. and ConocoPhillips to develop its oil and gas fields, the country's oil minister said Wednesday, signaling the Islamic Republic's readiness to court American business interests amid a thaw in relations with the West. Western companies are still banned by their governments from investing in Iran's oil and gas fields, and this is the first time Iran has named particular U.S. companies it would like to enter the country…Speaking to reporters ahead of a meeting of the Organization of the Petroleum Exporting Countries, Iran's oil minister, Bijan Zanganeh, said, 'We have no limitations for U.S. companies.' Asked who he would like to see return or enter Iran, he named European giants Total SA, Royal Dutch Shell PLC, Eni SpA, Statoil ASA and BP PLC. But he also named 'ConocoPhillips, Chevron.' 'I am talking to some of them,' he said, without saying which. In the 1990s, ConocoPhillips and Chevron tried to enter Iranian oil projects but their efforts were scuttled when Washington banned such investments for American companies. Many European companies, such as Total and Shell, did move in before being forced to completely pull out when the European Union forbid their presence in 2010." (Wall Street Journal, "Iran Wants U.S. Companies to Develop Oil Fields," 12/4/13)

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"ConocoPhillips did business in Iran through its British subsidiary, Conoco LTD, up until 2003, when it left the country. The company said it has no operations, assets or investments in Iran, either directly or indirectly its subsidiaries. But in 2004 it bought a minority stake in Lukoil, which continues to do business with Iran. A spokesperson for Lukoil said in addition to its contract with an Iranian oil company to develop an oil project in Uzbekistan, the company also sells gasoline to Iran. ConocoPhillips said it does not control Lukoil nor does it directly involved in Lukoil's Iran-related business. ConocoPhillips spokesperson John McLemore confirmed that the company profits from it due to its 20 percent investment in the company."  The company has received $1.7 billion from the US government for their investments in Iran during 2000-2009.  The New York Times lists the company's business in Iran as active.  (The New York Times, "Profiting from Iran, and the US," 3/6/2010)

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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)

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"A top executive of Halliburton Company told lawmakers here yesterday that the corporation does not intend to resume business in Iran now that it has completed its current contracts. In addition to Halliburton, those corporations in include General Electric, ConocoPhillips, and Aon." (The New York Sun, "Halliburton Says It Has No Plans To Go Back To Iran," 5/01/07)

"The Wall Street Journal reported Thursday morning that U.S. exports to Iran were increasing despite mounting enmity between both sides, while European Union exports to Tehran were falling. Oral-B mouth wash, made by Procter & Gamble Co. of Cincinnati, Ohio, is still on display at local corner shops in Iran—the company confirms it still sells to Iran legally. Coca-Cola Co.’s Coke soft drink is sold in cafes and supermarkets. The Atlanta-based multinational says its syrup is still being legally exported to Iran and bottled by Khoshgovar Co., whose commercial manager Valid Nejati confirmed the information. 'There have been no issues' with receiving payments, a Coca-Cola spokesman said." (Wall Street Journal, "U.S. Boosts Trade to Iran, Despite Sanctions," 8/16/12)

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

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"Coca-Cola does business in Iran through an Irish subsidiary, which sells concentrate to a bottling company called Khoshgovar based in Mashhad, according to a spokeswoman. The company has also received licenses to sell its products in Sudan." (New York Times, "Licenses Granted to U.S. Companies Run the Gamut," 12/24/10)

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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 New York Times, "Despite Sanctions, US consumer goods are prevalent in Sudan and Iran," 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)

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)

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According to a report filed with the SEC in 2007: "During 2007, we began the process to enter several country markets within the region. We have obtained product approval in Iraq and are actively pursuing registrations in Saudi Arabia, Kuwait, Iran (pending U.S. government clearance), Morocco, Libya and Egypt."

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"Calpyte Biomedical is on the verge of selling into Iran Calpyte is actually awaiting U.S. government clearance to sell an HIV test in Iran." (The Star-Ledger, "Pharmalot," 7/1/07)

GE and Baker Hughes will cease operations in Iran in accordance with U.S. law. The trade licenses that the company had been operating under are expected to be revoked in November. (Forbes, 6/8/2018).

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According to its Annual report filed with the SEC for fiscal year 2018: "In January 2016, the U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) issued General License H authorizing U.S.-owned or controlled foreign entities to engage in transactions with Iran if these entities meet the requirements of the general license. On May 8, 2018, President Trump announced that the United States will cease participation in the Joint Comprehensive Plan of Action (JCPOA) and begin re-imposing the U.S. nuclear-related sanctions. On June 27, 2018, OFAC revoked General License H and added Section 560.537 to the Iranian Transactions and Sanctions Regulations (ITSR), which authorized all transactions and activities that are ordinarily incident and necessary to the winding down of activities previously approved under General License H through November 4, 2018. Prior to May 8, 2018, certain non-U.S. BHGE affiliates conducted limited activities, as described below, in accordance with General License H. As of November 5, 2018, non-U.S. BHGE affiliates have concluded all activity previously conducted under General License H in Iran. These activities were conducted in accordance with all applicable laws and regulations.
During the year ending December 31, 2018, but prior to the expiration of the wind down period for General License H, non-U.S. BHGE affiliates conducted the following reportable activities:
•
A non-U.S. affiliate of BHGE received five purchase orders and attributed €31.4 million ($36.0 million) in gross revenues and €8.6 million ($9.9 million) in net profits related to the sale of valves and parts for industrial machinery and equipment used in gas plants, petrochemical plants and gas production projects in Iran.

• A second non-U.S. affiliate of BHGE received 12 purchase orders and attributed €0.1 million ($0.1 million) in gross revenues and less than €0.1 million ($0.1 million) in net profits to the sale of valves and other spare parts for use in the petrochemical industry in Iran.
• A third non-U.S. affiliate of BHGE attributed €0.3 million ($0.3 million) in gross revenues and €0.1 million ($0.1 million) in net profits to transactions involving the sale of films used in the inspection of pipelines in Iran.

These non-U.S. affiliates do not intend to continue the activities described above. The Company has ended all of these activities in full compliance with U.S. sanctions and at this time does not intend to seek specific U.S. Government authorization to collect revenues associated with previously reported projects.

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According to its Annual Report filed with the SEC for fiscal year 2016: "In January 2016, the U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) issued General License H authorizing U.S.-owned or controlled foreign entities to engage in transactions with Iran if these entities meet the requirements of the general license. Pursuant to this authorization, a non-U.S. BHGE affiliate received seven purchase orders during the fourth quarter of 2017 for the sale of goods pursuant to General License H that could potentially enhance Iran’s ability to develop petroleum resources. The purchase orders cover the sale of valves and parts for industrial machinery and equipment used in gas plants, petrochemical plants and gas production projects in Iran. These purchase orders are valued at less than €0.1 million ($0.1 million), less than €0.1 million ($0.1 million), less than €0.1 million ($0.1 million), €0.3 million ($0.3 million), €0.7 million ($0.8 million), €0.1 million ($0.1 million) and €0.8 million ($1 .0 million). This non-US affiliate also received a cancellation of a previously reported contract for the sale of spare parts for gas turbines. This purchase order cancellation reduces previously reported contract values by €12.3 million ($12.9 million). This non-U.S. affiliate attributed €6.8 million ($8.2 million) in gross revenue and €1.4 million ($1.7 million) in net profits against previously reported transactions during the quarter ending December 31, 2017.
A second non-U.S. BHGE affiliate received three purchase orders during the fourth quarter of 2017 for the sale of spares parts to support the development of offshore petroleum resources. The three purchase orders are individually valued at less than €0.1 million ($0.1 million), less than €0.1 million ($0.1 million), and less than €0.1 million ($0.1 million) each. This non-U.S. affiliate did not recognize any revenue or profit during the quarter ending December 31, 2017.
A third non-U.S. BHGE affiliate received a purchase order pursuant to General License H valued at €0.2 million ($0.2 million) during the fourth quarter of 2017. The non-U.S. affiliate also received a purchase order at the very end of the third quarter valued at €0.3 million ($0.3 million). Both purchase orders cover the sale of films to be used in inspection of pipelines in Iran. This non-U.S. affiliate did not recognize any revenue or profit during the quarter ending December 31, 2017. All of these non-U.S. affiliates intend to continue the activities described above, as permitted by all applicable laws and regulations."

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"Baker Hughes, through its foreign subsidiaries, had done work in Iran's oil and gas sectors, but decided several years ago to get out of both Iran and Sudan. A spokesperson said that the company finished all major warranty work it was contractually obligated to do in 2007."  The company has received $7.6 million in revenue and benefits from the US government for their business in Iran during 2000-2009.  They have since withdrawn their investments in Iran. (The New York Times, "Profiting from Iran, and the US," 3/6/2010)

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"At first, even companies incorporated in the United States - including such Schlumberger rivals as Halliburton, Weatherford, and Baker-Hughes - got around US sanctions by utilizing their overseas subsidiaries to perform work in Iran. Then the Sept. 11, 2001, terrorist attacks sparked federal investigations into whether US personnel were involved in the subsidiaries operating in Iran. Facing tighter scrutiny, negative publicity, and investor anger, all three of Schlumberger's main American competitors pulled out of Iran." (The Boston Globe, "Oil firm sidesteps sanctions on Iran," 12/7/08)

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"More importantly, even the threat of unilateral sanctions has been effective as recently as last year. As state after state has ramped up efforts to divest pension funds from companies invested in Iran, and as S 970, the Smith-Durbin Iran Counter-Proliferation Act, has garnered support in Congress, American companies like General Electric, Halliburton, and Baker Hughes with subsidiaries operating in Iran have rethought the wisdom of doing business with one of our nations most dangerous enemies. And as the United States has contemplated additional unilateral banking sanctions on Iran, banks across Europe have ratcheted back their exposure to the Islamic Republic, with some pulling out entirely." (AEI, The Iran Counter-Proliferation Act of 2007, April 21, 2008)

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"'Baker Hughes left Sudan in December and since then has been only doing warranty work stemming from contracts in Iran,' spokesman Gary Flaharty said. 'Baker Hughes is not starting new work in Iran,' he said." (The Houston Chronicle, "Weatherford to leave sanctioned countries," 9/11/07)

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 Internet in July 2007)