USA

According to its Annual Report filed with the SEC for fiscal year 2015: "During the reporting period, C.C.D. Cogent Communications Deutschland GmbH (“Cogent Germany”), an indirect, wholly-owned subsidiary of the Company, provided on-net internet access and point-to-point connectivity services to PMS Press+Media Services GmbH, which the Company understands is affiliated with the Islamic Republic of Iran Broadcasting Company (“IRIB”), an Iranian state-owned entity. Cogent Germany received $10,008 in gross revenue during the reporting period. Cogent Germany did not have net profits during the reporting period. The Company has determined that these services were provided starting in June 2012.  The Company has determined that the amount of gross revenues for these services during prior reporting periods were $224,587.  Cogent Germany did not have any net profits during the prior reporting periods. Cogent Germany has terminated these services, and the matter has been voluntarily disclosed to the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”)."

According to its Annual Report filed with the SEC for fiscal year 2012: "In 2012, notifications from one of our market data distributors made in accordance with the requirements of our market data license agreement included disclosures that such distributor had disseminated our market data to the Government Trading Corporation (GTC) and to a European subsidiary of the National Iranian Oil Company (NIOC). In 2012, the gross revenues attributable to these indirect subscriptions made through the distributor were $3,150. The terms and conditions on which the market data was disseminated by the distributor to GTC and NIOC are the same as would be provided to any other indirect subscriber. Other than the execution of a uniform subscriber addendum that is made available to all of our distributors for use with their subscribers, we do not have any contractual or other relationship with GTC or NIOC. We believe that the distribution of our market data, which is otherwise publicly available in other forms on our Web site on a real-time and delayed basis, is exempt from applicable U.S. sanctions programs pursuant to a statutory and regulatory exemption for exports of information and informational materials. Nevertheless, we are in the process of requesting that our market data distributors refrain from providing our market data to their subscribers that are located in sanctioned countries or identified on the U.S. Treasury Department's Specially Designated Nationals and Blocked Persons List. The distribution of our market data to GTC and NIOC is subject to disclosure pursuant to Section 219 of the Iran Threat Reduction and Syria Human Rights Act of 2012 (ITRSHR Act) and Section 13(r) of the Securities Exchange Act of 1934 (Exchange Act), which requires an issuer to disclose in its annual or quarterly reports, as applicable, whether it or any of its affiliates knowingly engaged in certain activities, transactions or dealings relating to Iran or with designated natural persons or entities involved in terrorism or the proliferation of weapons of mass destruction."

According to its Annual Report filed with the SEC for fiscal year 2013: "From November 2012 to January 2013 one of our UK subsidiaries performed an assignment for Melli Bank PLC, a bank incorporated in the UK, consisting of assessing the refurbishment costs for two London properties leased by the bank. To carry out this assessment, our UK subsidiary inspected and measured the two properties and reported its assessments. Melli Bank PLC had been identified on the Specially Designated Nationals and Blocked Persons List (the “SDN List”) pursuant to Executive Order No. 13628. Our gross revenue attributable to this assignment was £7,500 (exclusive of VAT), which was paid to us in February 2013, and our net profits related thereto were approximately £3,375.

On November 6, 2013, one of our UK subsidiaries entered into a contract (the “Contract”) with Melli Bank PLC under which it agreed to provide advice on tax rates for leased commercial property in London. To our knowledge, our UK subsidiary did not perform any services under the Contract nor was it paid a fee. Under the Contract, our UK subsidiary had agreed to conduct inspections of the property, negotiate with UK authorities regarding the applicable rates, calculate tax rate liability, and advise on actions to reduce rate liability. Upon discovering through an internal review that Melli Bank PLC was on the SDN List, we placed a hold on all activity relating to Melli Bank PLC pending further guidance from the U.S. Treasury Department’s Office of Foreign Assets Control. We do not otherwise intend to enter into any Iran-related activity."

According to its Annual Report filed with the SEC for fiscal year 2012: "On October 17, 2012, Costa Crociere S.p.A. (“Costa”), an Italian subsidiary of Carnival plc, entered into a general sales agent agreement with Boutimar Travel Co. Ltd (“Boutimar”), an Iranian corporation. The agreement with Boutimar, which was entered into contrary to our compliance policy, was terminated on January 27, 2014 immediately upon discovery. None of the guests who purchased Costa’s cruises through Boutimar were on the Specially Designated Nationals and Blocked Persons List maintained by the U.S. Office of Foreign Assets Control. The aggregate cruise ticket payments received by Costa from these Iranian guests were approximately $215,000, net of $31,000 of retained commissions."

According to its quarterly report filed with the SEC in 2016: "During the period covered by this report, we learned from the credit card network that processed these transactions that, between November 2013 and June 2015, COBNA authorized three credit card transactions with Iran Air, which was designated pursuant to Executive Order 13382, for three customers in France, Austria and Malaysia totaling $1,460.22. COBNA had negligible gross revenues and net profits attributable to these transactions. We believe that these transactions were not prohibited under applicable U.S. law. Iran Air is no longer designated pursuant to Order 13382 as of January 16, 2016 and we are not required to provide this disclosure regarding transactions with Iran Air after such date; however, we may in the future engage in similar transactions for our credit card customers to the extent permitted by U.S. law."

According to its quarterly report filed with the SEC in 2016: "We are making the following disclosures under Section 13(r) of the Exchange Act because our management recently became aware that one of our foreign subsidiaries made sales through a third-party distributor to customers in Iran that include or may include parties (the “Iran Parties”) that meet the definition of the “Government of Iran” under Section 560.304 of 31 C.F.R. Part 560. Based upon currently known information, total revenues to our subsidiary from sales to the Iran Parties, which took place from June 2013 through November 2015, were approximately $45,000, and the total net income attributable to those sales was approximately $2,500.

Our subsidiary has stopped all shipments to the Iran Parties, and the subsidiary does not intend to continue sales to, or engage in other dealings with, the Iran Parties. On May 6, 2016, we submitted initial notifications of voluntary self-disclosures to the U.S. Department of the Treasury, Office of Foreign Assets Control (“OFAC”), and the U.S. Department of Commerce, Bureau of Industry and Security (“BIS”). We will submit further information to OFAC and BIS after completing an internal investigation, which we are conducting with the assistance of outside counsel, and we intend to cooperate fully with both agencies."

According to a settlement with the US Treasury signed August 21, 2020, "From approximately December 2012 to Janumy 2016, Iscm Turkey [a Turkish subsidiary] appears to have violated§ 560.215 of the ITSR when it engaged in al least 144 transactions involving Iran valued at $383,443 that would have been prohibited by§§ 560.203, 560.204, 560.206, and 560.208 of the ITSR if engaged in by a U.S. person (the "Apparent Violations"). The Apprent Violations constitute an egregious case and were voluntarily self-disclosed.

[Berkshire Hathaway aggreed to] pay or arrange for the payment to the U.S. Department of the Treasury the amount of $4,144,651." 

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"Berkshire Hathaway Inc. has agreed to pay roughly $4.1 million to settle allegations that a Turkish subsidiary violated U.S. sanctions on Iran. The U.S. Treasury Department on Tuesday alleged that Berkshire’s indirect subsidiary—Iscar Kesici Takim Ticareti ve Imalati Limited Sirket—sold cutting tools and related inserts to two third-party Turkish distributors between 2012 and 2016, knowing that the goods would be shipped to a distributor in Iran for resale to end-users there." (Wall Street Journal, "Berkshire To Pay $4.1 Million To Settle Allegations Of Violating U.S. Sanctions On Iran," 10/21/2020). 

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According to its Quarterly report filed with the SEC for fiscal year 2016: "We are making the following disclosures under Section 13(r) of the Exchange Act because our management recently became aware that one of our foreign subsidiaries made sales through a third-party distributor to customers in Iran that include or may include parties (the "Iran Parties") that meet the definition of the "Government of Iran" under Section 560.304 of 31 C.F.R. Part 560. Based upon currently known information, total revenues to our subsidiary from sales to the Iran Parties, which took place from June 2013 through November 2015, were approximately $45,000, and the total net income attributable to those sales was approximately $2,500.

Our subsidiary has stopped all shipments to the Iran Parties, and the subsidiary does not intend to continue sales to, or engage in other dealings with, the Iran Parties. On May 6, 2016, we submitted initial notifications of voluntary self-disclosures to the U.S. Department of the Treasury, Office of Foreign Assets Control ("OFAC"), and the U.S. Department of Commerce, Bureau of Industry and Security ("BIS"). We will submit further information to OFAC and BIS after completing an internal investigation, which we are conducting with the assistance of outside counsel, and we intend to cooperate fully with both agencies."

According to its Annual Report filed with the SEC for fiscal year 2017: "During the year ending December 31, 2017, we sold, in a single sales transaction, 765 twenty-five kilogram bags of ReaShure® encapsulated choline, at a sales price of $82,238 to Imex Gulf, Inc., a privately held US corporation headquartered in Plano, Texas. Imex Gulf, Inc. exported this product to Pishgaman Taghzieh DTI Co.in Tehran, Iran, for subsequent sale and distribution in Iran. We conducted this product sale in compliance with applicable laws. The sale of ReaShure®, an animal feed ingredient, is permissible pursuant to certain statutory and regulatory exemptions from U.S. sanctions applicable to food products."

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According to its Annual report filed with the SEC for fiscal year 2016: "During the year ending December 31, 2016, we sold, in a single sales transaction, 400 twenty-five kilogram bags of ReaShure® encapsulated choline, at a sales price of $46,500 to Imex Gulf, Inc., a privately held US corporation headquartered in Plano, Texas. Imex Gulf, Inc. exported this product to Pishgaman Taghzieh DTI Co.in Tehran, Iran, for subsequent sale and distribution in Iran. We conducted this product sale in compliance with applicable laws. The sale of ReaShure®, an animal feed ingredient, is permissible pursuant to certain statutory and regulatory exemptions from U.S. sanctions applicable to food products."

Avaya disclosed in its Annual Report filed with the SEC for fiscal year 2018: "During Avaya’s recent review of its compliance practices in regards to sanctions regulations administered by the Office of Foreign Assets Control (“OFAC”) of the U.S. Department of the Treasury, Avaya determined that AISL processed a sales order received through HKT for an end user identified as MelliBank PLc Hong Kong Branch (“MBHK”). Though this entity is not specifically identified on OFAC’s Specially Designated Nationals and Blocked Persons List, it is designated as a Specially Designated National and Blocked Persons (“SDN”) as a result of the SDN designation of its ultimate parent company in 2016 pursuant to Executive Order 13599. The gross revenues Avaya received from the sale were $4,954.01 and the net profits from the sale were $2,031.15. Once the sale to MBHK was discovered, Avaya terminated all agreements and dealings with MBHK, including a sales and maintenance agreement. Avaya does not intend to engage in any future activities, transactions or dealings with MBHK.

Avaya filed a voluntary disclosure with OFAC on April 4, 2018 regarding the matter described above. Avaya remains committed to complying fully with U.S. sanctions laws and regulations and has devoted significant resources to its global trade compliance program. Avaya is in the process of implementing various enhancements to strengthen its existing global trade compliance procedures and plans to work with HKT on implementation of other remedial measures, including an improvement plan designed to prevent future exposure to persons targeted under U.S. sanctions."

According to its Annual Report filed with the SEC for fiscal year 2019: " During the third quarter ended September 28, 2019, the company determined that a limited number of non-executive employees in subsidiaries with offices located in the People's Republic of China had initiated fifteen (15) unauthorized shipments of general purpose electronic components to resellers for re-export to customers located in the Islamic Republic of Iran between January 2017 and December 2018. These shipments require disclosure pursuant to Section 219 of the Iran Threat Reduction and Syria Human Rights Act of 2012 and Section 13(r) of the Exchange Act.
The aggregate gross revenue for these shipments was approximately sixty-five thousand six hundred and eighty-nine dollars, $66, the aggregate gross profit was three thousand nine hundred and five dollars, $4, and the aggregate net profit was de minimus. Promptly upon learning of these shipments, the company notified OFAC and BIS of the activities, conducted an internal investigation and terminated or disciplined the employees involved.
These shipments were not made in accordance with the company's internal policies and procedures and the company does not intend to continue this activity and has been improving and will continue to improve procedural protections designed to prevent similar transactions from occurring in the future."