USA

“The sanctions mean that, as a U.S. company, we cannot provide shoes to players in the Iran national team at this time,” Nike said in a statement on Friday to NBC News....The reason Nike won't be providing the shoes is that there is "no general license permitting the transfer of U.S.-origin / owned clothing to Iran," Richard Nephew, a former director for Iran at the National Security Council and a sanctions expert, told NBC News via email. "We have such licenses for humanitarian goods and shoes usually don't count," Nephew said. The Treasury issues some licenses in order to authorize activities that would otherwise be prohibited with regard to Iran, but Nephew said that Nike's shoes are likely not covered by these licenses." (6/10/2018).

S&P Global is formerly known as McGraw Hill Financial 

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According to its Quarterly Report filed with the SEC for the quarterly period ending March 31, 2020: "During the first quarter of 2020, Platts, a division of the Company that provides energy-related information in over 150 countries, sold information and informational materials, which are generally exempt from U.S. economic sanctions, to subscribers that are owned or controlled, or appear to be owned or controlled, by the Government of Iran. Platts provided such subscribers access to proprietary data, analytics, and industry information that enable commodities markets to perform with greater transparency and efficiency, generating revenue that was a de minimis portion of both the division's and the Company’s revenue. The Company will continue to monitor its provision of products and services to such subscribers."

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According to a Quarterly Report filed with the SEC in 2019: "During the third quarter of 2019, Platts, a division of the Company that provides energy-related information in over 150 countries, sold information and informational materials, which are generally exempt from U.S. economic sanctions, to subscribers that are owned or controlled, or appear to be owned or controlled, by the Government of Iran. Platts provided such subscribers access to proprietary data, analytics, and industry information that enable commodities markets to perform with greater transparency and efficiency, generating revenue that was a de minimis portion of both the division's and the Company’s revenue. The Company will continue to monitor its provision of products and services to such subscribers. In addition, S&P Global Market Intelligence had a commercial relationship with an entity that became designated pursuant to Executive Order 13224 during the third quarter. The Company has terminated its relationship with such entity and will not collect revenue relating to this relationship."

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In a letter to CalPERs dated December 1, 2017, the company confirmed it is not engaged in the business targeted by the California Divest from Iran Act. 

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In 2017 the U.S. state of California listed S and P Global as a company under review for potentially having sold energy-related information and information materials to Iran-linked subscribers that are subject to U.S. sanctions with links to the Iranian government.

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According to a Quarterly Report filed with the SEC in 2017: "During the third quarter of 2017, Platts, a division of the Company that provides energy-related information in over 150 countries, sold information and informational materials, which are generally exempt from U.S. economic sanctions, to fourteen subscribers that are owned or controlled, or appear to be owned or controlled, by the Government of Iran (the “GOI”). The Company, among other things, offers customers that subscribe to its publications access to proprietary data, analytics, and industry information that enable commodities markets to perform with greater transparency and efficiency. This division provided such data related to the energy and petrochemicals markets to the subscribers referenced above, generating revenue that was a de minimis portion of both the division's and the Company’s revenue. Seven of the subscribers are designated by OFAC as GOI entities; and seven appear, based on publicly available information, to be owned or controlled by GOI entities. In addition, during the third quarter of 2017, this division entered into a contract to sell information and informational materials to another subscriber that is owned or controlled by the Government of Iran, but no revenues were received under this contract during the third quarter. We believe that these transactions were permissible under U.S. sanctions pursuant to certain statutory and regulatory exemptions for the exportation of information and informational materials. The Company will continue to monitor its provision of products and services to these Iranian customers so that such activity continues to be permissible under U.S. sanctions." 

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According to a Quarterly Report filed with the SEC in 2016: "During the third quarter of 2016, one of the Company’s divisions, a provider of energy-related information in over 150 countries, sold information and informational materials, which are generally exempt from U.S. economic sanctions, to fourteen subscribers that are owned or controlled, or appear to be owned or controlled, by the Government of Iran (the “GOI”). The Company, among other things, offers customers that subscribe to its publications access to proprietary data, analytics, and industry information that enable commodities markets to perform with greater transparency and efficiency. This division provided such data related to the energy and petrochemicals markets to the subscribers referenced above, generating revenue that was a de minimis portion of both the division's and the Company’s revenue. Eight of the subscribers are designated by the U.S. Treasury Department’s Office of Foreign Assets Control as GOI entities and six appear, based on publicly available information, to be owned or controlled by GOI entities. We believe that these transactions were permissible under U.S. sanctions pursuant to certain statutory and regulatory exemptions for the exportation of information and informational materials. The Company will continue to monitor its provision of products and services to these Iranian customers so that such activity continues to be permissible under U.S. sanctions."

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According to a Quarterly Report filed with the SEC in 2015: "During the first quarter of 2015, one of the Company’s divisions, a provider of energy-related information in over 150 countries, sold information and informational materials, which are generally exempt from U.S. economic sanctions, to twelve Iran-linked subscribers that are designated by the Treasury Department’s Office of Foreign Assets Control (“OFAC”) pursuant to Executive Order 13382 and/or are owned or controlled, or appear to be owned or controlled, by the Government of Iran (the “GOI”). The Company, among other things, offers customers that subscribe to its publications access to proprietary data, analytics, and industry information that enable commodities markets to perform with greater transparency and efficiency. This division provided such data related to the energy and petrochemicals markets to the Iran-linked subscribers referenced above, generating revenue that was a de minimis portion of both the division's and the Company’s revenue. One of the twelve Iran-linked customers is designated by OFAC pursuant to Executive Order 13382; one is designated by OFAC both pursuant to Executive Order 13382 and as a GOI entity; five are designated by OFAC as GOI entities; and five appear, based on publicly available information, to be owned or controlled by GOI entities. We believe that these transactions were permissible under U.S. sanctions pursuant to certain statutory and regulatory exemptions for the exportation of information and informational materials. The Company is reviewing whether to continue to provide these products to these Iranian customers in the future."

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According to a Quarterly Report filed with the SEC in 2014: "During the third quarter of 2014, one of the Company’s divisions, a provider of energy-related information in over 150 countries, sold information and informational materials, which are generally exempt from U.S. economic sanctions, to twelve subscribers in Iran that are designated by the Treasury Department’s Office of Foreign Assets Control (“OFAC”) pursuant to Executive Order 13382 and/or are owned or controlled, or appear to be owned or controlled, by the Government of Iran (the “GOI”). The Company, among other things, offers customers that subscribe to its publications access to proprietary data, analytics, and industry information that enable commodities markets to perform with greater transparency and efficiency. This division provided such data related to the energy and petrochemicals markets to the subscribers in Iran referenced above, generating revenue that was a deminimis portion of both division's and the Company’s revenue. One of the twelve Iran-linked customers is designated by OFAC pursuant to Executive Order 13382; one is designated by OFAC pursuant to Executive Order 13382 and as a GOI entity; five are designated by OFAC as GOI entities; and five appear, based on publicly available information, to be owned or controlled by GOI entities. We believe that these transactions were permissible under U.S. sanctions pursuant to certain statutory and regulatory exemptions for the exportation of information and informational materials. The Company is reviewing whether to continue to provide these products to these Iranian customers in the future."

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S&P Global has filed Iran Notices with the SEC from 2014-2020. 

Reynolds Group Holdings Ltd. (a U.S. company) disclosed in 2016 that a UAE joint venture (of which it owned 50%) sold milk carton sleeves to an Iranian dairy company that was “majority-owned by a pension fund for certain civil servants in Iran and therefore may be indirectly controlled by the Government of Iran.”

According to its Annual Report filed with the SEC for fiscal year 2018: "On January 16, 2016, the United States and the EU eased sanctions against Iran pursuant to the Joint Comprehensive Plan of Action ("JCPOA"). On May 8, 2018, the United States announced their withdrawal from the JCPOA (the "U.S. Decision"), thus re-imposing sanctions against Iran after the expiry of the permitted 90 and 180 day wind-down periods, i.e. respectively August 6, 2018 and November 4, 2018. The assessment of the economic situation resulting from the U.S. Decision had led PartnerRe to decide not to pursue business in Iran. Accordingly, contracts entered into by our non-U.S. reinsurance subsidiaries with Iranian entities prior to the U.S. Decision were either not renewed or terminated in a timely manner.

In respect of transactions to be disclosed pursuant to Section 219, carried out in 2018 prior to the U.S. Decision, we can comment as follows:

Through the intermediary of non-Iranian brokers, a non-U.S. subsidiary of PartnerRe Bermuda, entered into a four layer property excess of loss reinsurance treaty with Bimeh Iran which is an entity that has been identified as owned or controlled by the Government of Iran and appears on the List of Persons Identified as Blocked Solely Pursuant to Executive Order 13599. The agreement was executed in 2018 and coverage began January 1, 2018; however, the coverage was terminated by the non-U.S. subsidiary of PartnerRe Bermuda with an effective date of November 4, 2018. Gross revenue was €183 thousand and net profit attributable to the contract was €35 thousand during 2018. This entity was also exposed to a loss pursuant to a marine (cargo and hull) excess of loss reinsurance treaty (the “Treaty”) in respect of a collision in January 2018 of two vessels one of which, covered by the Treaty, caught fire and sank. The sunk vessel was owned or controlled by the Government of Iran, appears on the List of Persons Identified as Blocked Solely Pursuant to Executive Order 13599 and was operated by National Iranian Tanker Company. In addition, the sunk vessel was used to transport condensate from Iran to South Korea. To date and to our knowledge, our exposure amounts to €144 thousand. This claim was notified to PartnerRe in early November 2018 and we have blocked payment of this claim due to the position of our financial institution who refuses to settle payments relating to Iran."

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According to its Annual report filed with the SEC for fiscal year 2017: "On January 16, 2016, the United States and the EU eased sanctions against Iran pursuant to the Joint Comprehensive Plan of Action, and many of the reportable activities, transactions and dealings under Section 13(r) are no longer subject to U.S. sanctions and no longer prohibited by applicable local law.

Certain of our non-U.S. reinsurance operations provide reinsurance treaty coverage to non-U.S. insurers of marine & energy risks as well as mutual associations of ship owners that provide their members with protection and liability coverage. As a result of the recent lifting of European sanctions on Iran, some of these insurers have informed us that they have begun shipping, or will begin to ship, cargo to and from Iran, including transporting crude oil, petrochemicals and refined petroleum products.  Because these non-U.S. subsidiaries insure or reinsure multiple voyages and fleets containing multiple ships, we are unable to attribute gross revenues and net profits from such policies to activities with Iran. As the activities of our insureds are permitted under applicable laws and regulations, the Company intends for its non-U.S. subsidiaries to continue providing such coverage to its insureds and reinsureds.

Though the intermediary of non-Iranian brokers, a non-U.S. subsidiary of the Company, entered into:

• A four layers property excess of loss reinsurance treaty with Bimeh Iran which is an entity that has been identified as owned or controlled by the Government of Iran and appears on the List of Persons Identified as Blocked Solely Pursuant to Executive Order 13599. The agreement was executed in 2017 and coverage began on January 1, 2017 for one year. Expected gross revenue is €177 thousand (approximately $218 thousand) and expected net profit attributable to the contract is €47 thousand (approximately $58 thousand). The subsidiary intends to continue providing such coverage in accordance with applicable law.
• A three layers marine excess of loss reinsurance treaty with Bimeh Iran. The agreement was executed in 2017 and coverage began on July 1, 2017 for one year. Expected gross revenue is €129 thousand (approximately $160 thousand) and expected net profit attributable to the contract is €23 thousand (approximately $28 thousand). The subsidiary intends to continue providing such coverage in accordance with applicable law.
• A three layers property catastrophe excess of loss reinsurance treaty with an Iranian pool of insurers of which one member is Bimeh Iran. The agreement was executed in 2017 and coverage began on September 23, 2017 for one year. Expected gross revenue is IRR 4,635 million (approximately $124 thousand) and expected net loss attributable to the contract is IRR 4,947 million ($132 thousand). The subsidiary intends to continue providing such coverage in accordance with applicable law."

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Seyyed Mohammad Asoudeh, chief executive of Iranian Reinsurance Co., said that the reinsurer is in talks with several foreign reinsurers for coverage, Financial Tribune reported. The foreign reinsurers Iranian Re is talking to include France-based Scor S.E., Bermuda-based PartnerRe Ltd. and Lebanon-based Nasco Insurance Group. "We had a round of successful negotiations regarding mutual insurance cooperation and reinsurance coverage in addition to cooperation in offering modern insurance and reinsurance coverage,” Mr. Asoudeh said. IranianRe is looking to transfer a portion of the country's risk to foreign reinsurers. (December 11, 2017).

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According to its Annual Report filed with the SEC for fiscal year 2016: "On January 16, 2016, the United States and the EU eased sanctions against Iran pursuant to the Joint Comprehensive Plan of Action, and many of the reportable activities, transactions and dealings under Section 13(r) are no longer subject to U.S. sanctions and no longer prohibited by applicable local law.
Certain of our non-U.S. reinsurance operations provide reinsurance treaty coverage to non-U.S. insurers of marine & energy risks as well as mutual associations of ship owners that provide their members with protection and liability coverage. As a result of the recent lifting of European sanctions on Iran, some of these insurers have informed us that they have begun shipping, or will begin to ship, cargo to and from Iran, including transporting crude oil, petrochemicals and refined petroleum products.  Because these non-U.S. subsidiaries insure or reinsure multiple voyages and fleets containing multiple ships, we are unable to attribute gross revenues and net profits from such policies to activities with Iran. As the activities of our insureds are permitted under applicable laws and regulations, the Company intends for its non-U.S. subsidiaries to continue providing such coverage to its insureds and reinsureds.
A non-U.S. subsidiary provides a property catastrophe excess of loss reinsurance to an Iranian pool of insurers of which one member is Bimeh Iran. Bimeh Iran is an entity that has been identified as owned or controlled by the Government of Iran and appears on the List of Persons Identified as Blocked Solely Pursuant to Executive Order 13599. The agreement was executed in 2017 and coverage began on September 23, 2016 for one year. Expected gross revenue is €100,000 and expected net profits attributable to this contract are €10,000. The subsidiary intends to continue providing such coverage in accordance with applicable law."

Oaktree Capital Group LLC (a U.S. company) recounts a 2015 seizure by the Iran Revolutionary Guard Corps. of its indirectly owned vessel the Maersk Tigris. The vessel was escorted towards the Iranian port of Bandar Abbas and seized. The company noted that, during the seizure, the ship master bought “certain necessary provisions to maintain the health, safety and/or security of the Vessel’s crew,” which generated no revenue for Oaktree.
 

As stated in its 2017 SEC disclosure: "During the quarter ended December 31, 2017, Microsoft provided software services to a person or entity identified under section 560.304 of title 31, Code of Federal Regulations. The services constituted a cloud-based spam and malware filtering service and the cloud-based provision of Office 365 software services provided to two entities associated with the Iranian bank, Bank Sepah – Bank Sepah International PLC and Banque Sepah, respectively. For the former, an annual service fee equivalent to $600 was charged for a one-year period beginning in February 2017, and for the latter, use rights were charged at a price equivalent to approximately $55 per month from September 2016 through November 2017, totaling $770. Microsoft has ceased providing these software services to these entities and has no intention of doing so in the future."

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"Iran’s social media has been falling over itself in the past week over reports about Microsoft’s quiet but real entry into the Iranian technology sector. The twitter account for Shargh newspaper’s Sobhan Hassanvand was first to clock the American giant as having a base in Iran on Monday night (Dec. 15). Hassanvand showed a picture of a building on Bucharest Avenue in central Tehran with a giant Microsoft sticker on the window, with the quote “@Microsoft office in #Iran.” (January 2015)

In 2017 the U.S. state of Michigan listed Mentor Graphics Corp. on its Iran restricted companies list rendering Mentor Graphics ineligible for investment and/or state contracting. 

Subsidiary of Warbug Pincus.

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"in its February 16, 2017 filing, Laredo Petroleum, Inc. (a U.S. company) stated clearly that neither it nor its affiliates knowingly engaged in any activities associated with Iran. However, “because the SEC defines the term ‘affiliate’ broadly,” Laredo disclosed information provided by Warburg Pincus, Laredo’s founding member and whose affiliates own 36.2% of Laredo’s common stock. According to the disclosure, the affiliates of Warburg Pincus beneficially own more than ten percent of the equity interests of another company, Santander Asset Management Investment Holdings Ltd. (SAMIH). Because SAMIH may be deemed to be under common control with Laredo due to the SEC’s broad interpretation of affiliate, Laredo disclosed that a SAMIH affiliate—Santander U.K. plc—held savings accounts for two SDNs during the year, even as it noted that SAMIH’s activity does not relate to any activity conducted by Laredo or Laredo’s affiliates."

Keysight Technologies voluntarily self-disclosed to the US Treasury Department and agreed to a settlement signed June 18th, 2020 of $473,157. The Treasury Department's review of Anite's (a subsidiary of Keysight Technologies at the time of the violations) activities show that they violated Iranian Transactions and Sanctions Regulations in that Anite engaged in "exports of six goods intended for Iran with US origin content."

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According to its website, Iranian company Fatehin Sanat provides Keysight Technologies products.

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From January to May 2016, Anite, a recently acquired subsidiary of Keysight organized and existing under the laws of England and Wales, engaged in transactions involving the sale of wireless network testing and measurement equipment to an end user in Iran. Anite sold the equipment through intermediate companies for ultimate end use by MTN Irancell, located in Tehran, Iran. These sales were completed in violation of Keysight’s trade policies which currently prohibit all sales to Iranian customers. Keysight discovered this activity after the relevant reporting period and has conducted a comprehensive internal investigation and review.  As a result of this investigation and review, disciplinary action has been taken with respect to employees who knowingly violated company policy and Keysight has implemented additional compliance procedures designed to prevent future violations of policy. (2017)