USA

According to its Quarterly Report filed with the SEC in 2017, 2018 and 2019: "Certain of the Company’s subsidiaries located outside the United States subscribe to insurance policies that provide insurance coverage to vessels owned by international shipping and marine entities with vessels that travel worldwide. As a result, the insurance policies may be called upon to respond to claims involving or that have exposure to Iranian petroleum resources, refined petroleum, and petrochemical industries. For example, certain of the Company’s non-U.S. subsidiaries participate in global marine hull and war policies that provide coverage for damage to vessels navigating into and out of ports worldwide, which could include Iran."

According to its Quarterly Report filed with the SEC in 2018: "During the reporting period, Bibby Transmissions Limited, a subsidiary of Altra organized and existing under the laws of England (“Bibby”), sold couplings to a customer in the United Kingdom, for ultimate re-sale to an Iranian end user for use in a gas treating plant.  Gross revenues received by Bibby in connection with this transaction were approximately GBP 60.6 thousand and net profits were approximately GBP 12.9 thousand." 

--

According to its Annual Report filed with the SEC for fiscal year 2017: "During the three months ended December 31, 2017, Bibby Transmissions Limited, a subsidiary of Altra organized and existing under the laws of England (“Bibby”), sold couplings to a customer in the United Kingdom, for ultimate re-sale to an Iranian end user for use in a gas treating plant.  Total gross revenues received by Bibby in connection with these transactions were approximately GBP 57.3 thousand and net profits were approximately GBP 21.1 thousand.  Bibby intends to continue pursuing opportunities with this direct customer and end user, to the extent compliant with applicable law."

According to its Annual Report filed with the SEC in 2017: "During our first quarter of fiscal year 2016, we determined that a representative of the Paris branch of Bank Melli purchased a year-long subscription to Adobe Export PDF, a software service we provide. On January 16, 2016, Bank Melli was removed from the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) Specially Designated National List; however, it remains an entity whose property and interests in property must be blocked by U.S. persons pursuant to Executive Order 13599. Upon further investigation and verification of the identity of the entity, we promptly deactivated the account."

According to its Annual Report filed with the SEC in 2018, Enerpac (f/k/a Actuant): "In March 2018, the Company filed an Initial Notice of Voluntary Self-Disclosure ("VSD") with the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) regarding transactions related to otherwise authorized sales of tools and other products by certain of its foreign subsidiaries to two Iranian distributors totaling approximately $0.5 million. While the Company undertook efforts to ensure that those sales were conducted entirely consistent with General License H under the Iranian Transaction and Sanctions Regulations, 31 C.F.R. Part 560, it is possible that certain limited transactions relating to the authorized sales in question fell outside the scope of General License H. The Company immediately determined to cease doing business in Iran and continues not to transact there. With the assistance of its external counsel, the Company undertook an investigation of those Iran-related transactions and, more generally, the adequacy and effectiveness of its procedures to ensure compliance with trade and export requirements. The investigation was completed in October 2018 and resulted in the filing of a final VSD with OFAC on October 26, 2018. The final VSD also included information about additional transactions by certain of the Company's Dutch subsidiaries, with a counterparty in Estonia that may have been in violation of E.O. 13685." 

According to the website of Iranian company, Fatehin Sanat, Fatehin Sanat supplies various products made by Microstrain.

In its report, “Evolution of UAVs Employed By Houthi Forces In Yemen,” CAR concludes, “A significant number of Houthi UAV components either originated in Iran, or match those used by factions in the region that are linked to Iran.” The report contains the following notable excerpt: "All of the Qasef-1s documented by CAR employed circuit boards attached with microcontrollers bearing an Atmel label. A CAR field investigation team also documented an identical Microchip Atmel microcontroller in a receiver for an RCIED which Bahraini security forces had seized in March 2015 from a passenger bus that had travelled from Iraq, through Saudi Arabia, and into Bahrain." CAR, “Evolution Of UAVs Employed By Houthi Forces In Yemen,” February 2020.

--

According to its website, Iranian company Fatehin Sanat supplies various products made by Microchip.

McQuay products are sold on the the website of Iranian company Hirbodan Co.

In April 2014, Liberty Mutual was subpoenaed by the New York Department of Financial Services (“NYDFS”) “as part of a probe of potential sanctions violations involving Iran … demanding information related to their dealings with Swiss-based commodities giant Glencore Xstrata and its Iranian metals trade.” (Reuters, “New York regulator subpoenas four insurers in Iran sanctions probe-source,” 4/9/2014).

Booking Holdings Inc. brand KAYAK features Iran’s Mahan Air on a dedicated web-page. Mahan Air has been subject to two United States Executive Orders (“E.O.”) and is banned from landing in airports in Germany, France and Italy.