UK

Grimley Smith Associates

Industry
Chemicals, Energy, Engineering
Country
UK
Sources

In 2018 the U.S. state of New Jersey listed Grimley Smith Associates on its list of entities determined to be engaged in prohibited activities in Iran rendering Grimley Smith Associates ineligible for investment and/or state contracting.

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Grimley Smith Associates is a British engineering firm that "offers services that encompass virtually every aspect of process engineering" (Company Website). 

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Grimley Smith's website describes contract work it performed on three crude oil facilities in Iran for the National Iranian Oil Company. This work constituted "70,000 man-hours of design work" which rendered the facilities "capable of meeting the processing capacity of 400,000 barrels a day for the next 25 years" (Company Website). 

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Grimley Smith's website lists its key values as "integrity, openness, competence, trust, quality, enjoyment, loyalty, accountability, and responsibility" (Company Website). 

 

Remet UK Ltd

Industry
Chemicals, Industrial Metals
States
NY
Country
UK
Contact Information

Phone: 44 (0) 1 634 226 240

Sources

Remet is accused of selling Cobalt aluminate to Iranian engineering firm Mavadkaran, which manufactures equipment for Iran’s energy sector.

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"Jarrad Beddow, 43 the former sales manager of Remet UK, is alleged to have played a 'leading role' in the shipment of cobalt aluminate to the Islamic Republic via Slovakia...  Remet applied for a licence to export the chemicals in the summer of 2008 but was told it had been rejected in September... Mr Hewitt said the authorities were alerted after Remet's managing director discovered the export had gone through." (Daily Telegraph, "Businessman 'exported WMD chemicals to Iran'," 6/6/2012)

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"Although the company’s former sales manager, Jarrad Beddow, claims that there was no law prohibiting the export of the cobalt when it occurred in 2009, it is well know that cobalt aluminate can be used to produce the lethal radioactive isotope cobalt 60. Experts says this material is most likely to be used in a 'dirty bomb.' And, Since 2005, there have been reports that Tehran may be attempting to procure dirty bomb materials." (Global Security Newswire, "U.K Firm Investigated Over Sale of Dirty Bomb Material to Iran," 5/17/2010)

Invensys

Industry
Energy, Engineering, Industrial Services, Transport Infrastructure
Value of USG Contracts
3
Value of USG Contract Source
http://usaspending.gov/explore?fromfiscal=yes&tab=By+Prime+Awardee&fiscal_year=2000&contractorid=2185657&fiscal_year=&tab=By+Prime+Awardee&fromfiscal=yes&carryfilters=on&Submit=Go
Symbol
LON:ISYS
States
TX
VA
Country
UK
Contact Information
Sources

Invensys is a multinational corporation which consists of Invensys Operations Management, Invensys Rail, and Invensys Controls. Invensys Operations Management, the largest division, is “a global technology, software and consulting organization” with over $2 billion in sales (Company Brochure).

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Invensys Operations Management houses the Eurotherm brand of products, which are used in “life sciences, glass manufacturing, plastics, renewable energy and the heat treatment of metals” (Company Brochure). Eurotherm is represented in Iran (Eurotherm Brochure) and is listed as a past exhibitor for the 2009 Iran Oil Show (Iran Oil Show Website).

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In its Code of Conduct, Invensys says, “We are committed to upholding human rights such as those enshrined in the UN Global Compact and the European Convention on Human Rights”, and instructs employees not to “seek to benefit from human rights abuses committed by someone else” (Invensys Code of Conduct).

Orient Freight Group

Industry
Shipping
Country
UK
Contact Information
Sources

According to its website: "We are the right partner for your transports to Turkey, to Iran, to Iraq and the other countries in the Near and Middle East as well as to the Caucasus region and the CIS states. With an experience of many decades we are the "experts" for these regions."
 

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Orient provides shipping services to Iran ("Sea Freight") as well as land transportation ("Overland Services").

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Additionally, Orient provides exhibition services for Iran. "For the past 14 years, Orient have represented and arranged the participation of an average of 700 companies per year" to the Iran Oil Show. The Iran Oil Show is "one of the top three oil exhibitions in the world" ("Exhibition Services").

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See "Destinations" for the full map of Orient's destination within in Iran.

Millennium & Copthorne Hotels

Industry
Hotels
Symbol
LSE: MLC
States
AK
AZ
CA
CO
IL
MA
MN
MO
NY
NC
OH
TN
Country
UK
Sources

"Even now, in the era of happy Hassan Rouhani, questions about the recent prominent Iranian guest triggered palpable discomfort this week among staff at the four-star ONE UN hotel — located on 44th Street, right across from UN headquarters. It turns out Rouhani’s “smiling never hurts” tactic (as it was described by Netanyahu in his withering UN speech on Tuesday) had worked a charm not only with President Barack Obama but with staff at the ONE UN, as well...News that ONE UN would be hosting Rouhani had sparked protests back in August, when a group called United Against A Nuclear Iran (UANI) urged the hotel to turn the Iranians away. ;Certainly the ONE UN is aware that President Rouhani is the public face of a brutal regime that is a sworn enemy of the United States, and which is under strict sanctions by the US government and the international community,' the group’s CEO, Mark Wallace, wrote in a letter to the hotel. No American entity 'should be doing business with the Iranian regime and its delegation, until the regime has seriously and verifiably altered its dangerous and threatening behavior.' While UANI does not intend to 'harm legitimate businesses,' the group will 'publicly highlight' the hotel’s 'irresponsible decision' if it indeed hosts the Iranians, Wallace threatened. (Times of Israel, "A peek into Rouhani’s NY hotel room? No sir, we’d get in trouble," 10/4/13)

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"Iran has found a new home for its delegation during this month’s UN General Assembly in New York City. According to United Against a Nuclear Iran (UANI), which describes itself as a non-partisan, broad-based coalition committed to preventing Iran from acquiring nuclear weapons, the ONE UN New York hotel (formerly known as the Millennium UN Plaza Hotel) plans to house Rouhani and other Iranian officials during their visit to New York City the week of September 22. In a letter to ONE UN General Manager Paul Wong and Wong Hong Ren, CEO of Millennium & Copthorne Hotels, which owns the hotel, UANI CEO, Ambassador Mark D. Wallace warned, 'UANI will publicly highlight [the]… irresponsible decision if you do not take action to refuse accommodation to the Iranian delegation'… This isn’t the first time the hotel has hosted an Iranian delegation. During the May 2010 Nuclear Non Proliferation Treaty (NPT) Review Conference in New York, the Millennium UN Plaza, as it was known at the time, hosted Ahmadinejad and his entourage." (Algemeiner, "Iranian Delegation Finds New Home in New York for UN General Assembly at ONE UN Hotel," 9/15/13)

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"United Against Nuclear Iran (UANI) today called on the Millennium hotel to immediately clarify and reconsider its decision to serve as the official host hotel to President Ahmadinejad during his stay in New York and instead decline to host President Ahmadinejad. In a letter to the Richard Hartman, the CEO of Millennium & Copthorne Hotels Plc and Wanda Chan the General Manager to the Millennium, UANI President Ambassador Mark D. Wallace wrote: 'President Ahmadinejad is the leader of a criminal regime that flouts international law in developing an illegal nuclear weapon, and brutally represses its own people. President Ahmadinejad leads a regime that is the world’s leading state sponsor of terrorism. Just recently President Ahmadinejad called the tragic events of September 11, 2001 a 'big lie'. Simply put it is an outrageous affront to the people of New York City that you would host this man and his delegation. All New Yorkers should reject your hotel if you host this illegitimate 9/11 denying regime...The Millennium’s decision to potentially host President Ahmadinejad is directly contrary to the other New York Hotels and venues that have refused to host this regime including The Helmsley Hotel, Gotham Hall, and The Essex House. If it continues with its decision to host the Iranian regime, the Millennium Hotel will be putting its short-term profit ahead of its responsible role in the New York hotel community." (Business Wire, "UANI Calls on The Millennium Hotel to Refuse to Host President Ahmadinejad," 5/2/10)

Costain

Industry
Construction, Energy
Symbol
LON: COST
Country
UK
Contact Information
Sources

In 2015 Costain was removed from Pennsylvania Treasury's List of Scrutinized Companies Determined as Having Involvement In Iran after the company confirmed that neither it nor any of its subsidiaries have business activities in Iran.
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In 2014, Costain was added to the Pennsylvania Treasury's List of Scrutinized Companies Determined as Having Involvement in Iran because of oil-related investment of US $20 million since 1996.

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Firm/country[A]: Costain Oil, Gas & Process Ltd./United Kingdom;

Status: Gas refinery/processing plant at Bid Boland II;

Commercial activity: Expected completion 2009; Part of consortium whose contract is valued at $1.7 billion;

Firm comment: Contacted on January 14, 2010; no response as of March 22, 2010.

(GAO Report 2010 - "Firms Reported in Open Sources as Having Commercial Activity in Iran’s Oil, Gas, and Petrochemical Sectors")

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"In Iran, Costain led a consortium of four companies in the bidding and ultimate award by the National Iranian Gas Company of the Bid Boland II Gas Treatment Plant Project, valued at $1.67bn and financial negotiations are continuing." (Costain Company Press Release, June 2005)

 

Lloyd's Register

Industry
Financial Services, Shipping
Value of USG Contracts
1
Value of USG Contract Source
http://usaspending.gov/explore?fromfiscal=yes&tab=By+Prime+Awardee&fiscal_year=2006&contractorid=243959&fiscal_year=&tab=By+Prime+Awardee&fromfiscal=yes&carryfilters=on&Submit=Go
States
CA
FL
LA
NJ
TX
WA
Country
UK
Sources

Lists an office in Tehran, Iran on its company website.

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"The Health, Safety and Environment Association of Oil Industry Companies of Iran on Friday signed a memorandum of understanding in Tehran with a British corporation on expanding cooperation in the HSE department. Based on the agreement, Lloyd’s Register, a global engineering, technical and business services organization, will provide HSEAOIC with advanced HSE services and training programs, Shana reported." (November 26, 2016)

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"After coming under pressure from the United States, the ship classification society Lloyd’s Register said in late April that it would close its office in Iran and stop certifying the safety of Iran’s ships." (The Washington Post, "Iran, unable to sell oil, stores it on tankers," 5/14/2012)
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"Lloyd's Register, a leading maritime risk management firm, has shut its operations in Iran and can no longer vouch for the safety of the OPEC member's fleet due to Western sanctions, the head of the company told Reuters. Lloyd's Register, a classification society that verifies the safety and environmental standards of vessels, has stopped assessing around 60 tankers and container ships owned by Iran's NITC and Islamic Republic of Iran Shipping Lines following pressure from the United States... 'The Americans came to us and said that if we continued to work for the Iranians we would be blacklisted in America,' Richard Sadler, the London-based chief executive of Lloyd's Register, said on the sidelines of a conference in Singapore. 'There was a lot of confusion about the sanctions and actually the recommendations was that it was better for British classification societies within Europe not to be dealing directly with NITC,' he said." (Reuters, "Lloyd's Register withdraws from Iran due to sanctions," 4/26/12)

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"However, other firms — notably Lloyd’s Register, Bureau Veritas and Germanischer Lloyd — continue to provide services to Iranian and other vessels working in Iranian ports or waters." (Washington Post, "Congress sees shipping-certification firms as tool to tighten Iran noose," 12/5/2011)

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Lloyd's Register has offices in the Iranian cities of Bandar Abbas, Mahshahr and Tehran. (Lloyd's Register website "List of Offices by Country," February 2010)

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In 2008, Lloyd's Register America, Inc. acquired Martec, which has performed business in Iran's energy sector. (Martec Press Release)

Response

"Our investigation, following receipt of your letter, indicates the vessel transferred to operate under the Djibouti flag from mid-December 2020 which appears to have coincided with a change in the vessel’s name, reported ownership and management which transferred to Indian interests at Peridot Ship Management in Mumbai, and without that having been reported to LR, as required by our published classification Rules and Regulations. A change in management, name and flag of the vessel without informing and involving LR means the vessel did not have valid LR classification and statutory certificates in January 2021." (February 3, 2021)

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“The Lloyd’s Register group has a policy of compliance with all applicable sanctions’ laws and regulations. The SEA GLORIA mentioned in your letter as a Lloyd’s Register classed vessel transferred out of Lloyd’s Register class in January 2020. We are investigating further the matters you have raised with flag State and registered owner’s representatives.” (December 23, 2020)

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Response: “Thank you for your letter dated 8 April 2020 referencing the International Association of Classification Societies (IACS) and the Polish Register of Shipping and acknowledging Lloyd’s Register’s ongoing commitment to conducting its business activities lawfully. Since receiving your letter, Lloyd’s Register has contacted the Secretariat of IACS and is aware that you have written in similar terms to the Chairman of the IACS Council, and other IACS members, and that your correspondence is being considered by IACS members in accordance with IACS procedures.” (April 15, 2020)

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“I would like to confirm that Lloyd’s Register (LR) has an ongoing commitment to comply with all applicable laws, including economic sanctions, and that all our business activities will continue to be entirely lawful.” (August 10, 2016).

CNH Global

Industry
Agriculture, Construction
Value of USG Contracts
89
Value of USG Contract Source
http://www.usaspending.gov/explore?fromfiscal=yes&fiscal_year=2009&contractorid=796329&fiscal_year=&tab=By+Prime+Awardee&fromfiscal=yes&carryfilters=on&Submit=Go
Symbol
NYSE: CNHI
States
IL
Country
UK
Sources

According to its Annual Report filed with the SEC for fiscal year 2018: "In 2018, CNH Industrial suspended business activities in Iran, other than those activities required to fulfill binding orders. Prior to the suspension of business activities in Iran, CNH Industrial had limited commercial activity in Iran conducted by non-US subsidiaries. In 2018, sales in Iran were significantly less than one percent of CNH Industrial’s revenues. In 2018, one of our non-US subsidiaries generated net revenues of approximately $4.6 million attributable to the sale of on and off-road trucks and spare parts to an entity that is indirectly owned or controlled by the Government of Iran. The Iran-related activity was negligible to our overall revenues and profits. Our activities in Iran comply in all material respects with applicable laws and regulations, including U.S. and other international trade sanctions."

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According to its Annual Report filed with the SEC for fiscal year 2017: "CNH Industrial has limited commercial activity in Iran, which is conducted by non-US subsidiaries. In 2017, sales in Iran were significantly less than one percent of CNH Industrial’s revenues.  In 2017, one of our non-US subsidiaries generated net revenues of approximately $11.3 million attributable to the sale of on and off-road trucks and spare parts to an entity that is indirectly owned or controlled by the Government of Iran."

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On February 24, 2016, a delegation of CNH officials met with Iran’s Arak HEPCO Company in Iran. (IRNA, “Arak HEPCO capacities introduced to Italian investors,” 2/24/2016)

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CNH Industrial, reportedly was part of a 370-member Italian trade delegation to Iran in late November 2015. (Press TV, “Fiat in talks for car manufacturing in Iran,” 11/29/2015).

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"Fiat and its sister companies, Fiat Industrial and CNH Global N.V. (CNH), said they will cease business activities in Iran in support of diplomatic efforts to convince the leaders of Iran to abandon its nuclear program, which is widely suspected of developing nuclear weapons. Iran has denied that it is making nuclear weapons... Fiat Industrial and CNH issued statements with the same wording. Fiat exports cars to Iran while Fiat Industrial exports buses and trucks under its Iveco brand. CNH Global builds farm and construction machinery that is sold in Iran." (Dow Jones, "Fiat Ban On Sales To Iran Seen As Victory In Sanctions Campaign," 5/25/2012)
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In a correspondance with the SEC in December of 2009, CNH disclosed details of its sales in Iran.

"CNH’s foreign subsidiaries’ total sales into Iran: $27.8 million in 2006, $42.9 million in 2007, $36.8 million in 2008, and $6.2 million in 2009.  In Iran, CNH’s foreign subsidiaries sell equipment to independent distributors or with the assistance of a commission agent."

(CORRESP for CNH GLOBAL N V, 12/7/2009)

Ernst & Young

Industry
Professional Services
Value of USG Contracts
273
Value of USG Contract Source
http://usaspending.gov/explore?fromfiscal=yes&tab=By+Prime+Awardee&fiscal_year=2010&contractorid=85231&fiscal_year=&tab=By+Prime+Awardee&fromfiscal=yes&carryfilters=on&Submit=Go
States
NY
Country
UK
Sources

Persis Consult has designed the offices for professional services giant, EY, located in Tehran, Iran. (2017)

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EY has agreed to be a Speaker at the 4th Europe-Iran Forum (“EIF4”) in Zürich on October 3-4, 2017.  According to its official website, EY is participating at EIF4 for the purpose of “bringing business leaders, policymakers, and members of the international press into direct conversation about the challenges, opportunities, and broader social responsibilities of commercial activity in Iran.”  (EIF4 Website, “An Unparalleled Project in ‘Business Diplomacy’”).  

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Ernst & Young was listed as a participant at the FT Iran Summit 2016 (the “Summit”) in London on March 9, 2016.

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On its website, Ernst & Young lists that it has an affiliate office, Tadvin Co./Tadvin Management Consultants, in Iran (Company Website, "Members of EYG and Its Affiliates," 7/31/09).

Response

"...welcomes dialogue with elected officials, business leaders and other stakeholders about the issues you raise in your letter, which we agree are important and warrant regular reexamination in the rapidly changing global environment." (September 29, 2017 - response to EIF letter)"

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April 2010: EY has ended its business relationships in Iran. (The New York Times. "Companies Feeling More Pressure to Cut Iran Ties," 4/24/10)

Balli Group

Industry
Airline
Country
UK
Contact Information
Sources

The Balli Group, a holding entity of trading companies, maintains an office in Tehran, Iran. (Company Website)

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“Balli Aviation Ltd., a subsidiary of the United Kingdom-based Balli Group PLC, pleaded guilty today in the U.S. District Court for the District of Columbia to a two-count criminal information in connection with its illegal export of commercial Boeing 747 aircraft from the United States to Iran, announced David Kris, Assistant Attorney General for National Security; Channing D. Phillips, U.S. Attorney for the District of Columbia; Thomas Madigan, Acting Deputy Assistant Secretary of Commerce for Export Enforcement; and Adam J. Szubin, Director of the Department of Treasury's Office of Foreign Assets Control.

Under the plea agreement, Balli Aviation Ltd. agreed to pay a $2 million criminal fine and be placed on corporate probation for five years. The $2 million fine, combined with a related $15 million civil settlement among Balli Group PLC, Balli Aviation Ltd., the U.S. Department of Commerce’s Bureau of Industry and Security (BIS), and the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC), that was also announced today, represents one of the largest fines for an export violation in BIS history. Under the terms of the related civil settlement, Balli Group PLC and Balli Aviation Ltd. have agreed to pay a civil penalty of $15 million of which $2 million will be suspended if there are no further export control violations. In addition, Balli Aviation Ltd. and Balli Group PLC are denied export privileges for five years, although this penalty will be suspended provided that neither Balli Aviation nor Balli Group commits any export violations and pays the civil penalty.  Under the terms of the settlement, Balli Group PLC and Balli Aviation, Ltd. will also have to submit the results of an independent audit of its export compliance program to BIS and OFAC for each of the next five years.” (U.S. Department of Justice, “U.K. Firm Pleads Guilty to Illegally Exporting Boeing 747 Aircraft to Iran,” 2/5/10)