UK

Debenhams

Industry
Retail
Symbol
LN: DEB
Country
UK
Sources

Locations in Iran.

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"An iconic British department store is about to open the doors of its first location in the Islamic Republic of Iran. Founded in London in 1778, Debenhams now has 145 stores across Britain and Ireland and about 40 franchises in 16 countries worldwide, but opening up in North Tehran may present new challenges." (CBS News, "Designer Duds For Fashion-Starved Iran," 12/29/08)

Response

No response at this time.

Cadbury

Industry
Food and Beverage
Symbol
LN: CBKY
States
KY
Country
UK
Sources

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. (USA Today, "From bull semen to bras, Iran still buys American," 7/9/08)

Response

No response at this time.

British American Tobacco

Industry
Tobacco
Symbol
LSE:BATS
Country
UK
Contact Information
Sources

"Despite recent gains by Iranian Tobacco Co. (ITC), multinationals continue to dominate the Iranian cigarette market, according to a report by PressTV, citing ITC CEO Siavash Afzali.   

Speaking at a press briefing on May 17, Afzali said that Japan Tobacco International (JTI) and British American Tobacco (BAT) control more than 61 percent of sales and some 70 percent of the value of the cigarette market in Iran. Afzali estimated that JTI and BAT supplied 46 billion cigarettes to Iranian consumers in the calendar year to late March." (Tobacco Reporter, "Foreign Firms Dominate Iranian Cigarette Market," 5/18/21)

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According to its Annual Report filed with the SEC for fiscal year 2019: "BAT has a local operation in Iran, established on 18 October 2003, through its wholly-owned non-US subsidiary, B.A.T. Pars Company (Private Joint Stock) (BAT Pars). BAT Pars produces its products, which include Kent, Pall Mall and Montana brands, in its own factory in Eshtehard, which is in the Alborz province of Iran. BAT Pars distributes its product via 75 sub-agents with national and provincial distribution licences, who sell products to wholesalers and retailers with the support of BAT Pars’ sales representatives. BAT Pars has 307 direct employees and an additional 1,159 contract workers supplied by a private company.

Concerning the business of BAT Pars, various elements such as income tax, payroll, social security, other taxes, excise, monopoly fees, duties and other fees, including for utilities, licences and judicial fees to commence litigation, are payable to the Government of Iran and affiliated entities regarding BAT Pars’ operation. BAT Pars maintains bank accounts in Iran with various banks to facilitate its operations in the country and to make any required payments, as described above, to the Government of Iran and affiliated entities regarding its operations.

During the year ended 31 December 2019, BAT did not have any gross revenues or net profits derived from transactions with the Government of Iran or affiliated entities.

BAT believes, and maintains policies and procedures designed to ensure, that its activities in Iran and elsewhere comply in all material aspects with the applicable and relevant trade sanctions laws and regulations, including US and other international trade sanctions and/or embargoes. BAT’s sanctions policies and procedures have been designed to be as robust as possible. However, there can be no absolute assurance that these policies and procedures will be effective. Were they to be ineffective, penalties or sanctions could be imposed against BAT, which could be material. To the extent permitted under applicable law, and as long as it continues to meet BAT’s risk management and operational requirements, BAT Pars’ activities in Iran are expected to continue."

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As of August 27, 2019, British American Tobacco is listed on the Illinois Investment Policy Board list of Iran restricted companies.

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Lists British American Tobacco Pars in Tehran, Iran on its company website.

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Dec 2016 Subsidiary filings with SEC lists B.A.T. Pars Company as its subsidiary.

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"B.A.T. [British American Tobacco] said it now makes cigarettes for export to Iran in Turkey. (USA Today, "From bull semen to bras, Iran still buys American," 7/9/08)

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"GIANTS WITH A FOOT IN TEHRAN: Total, Shell, Statoil, BNP Paribas, Commerzbank, MTN, UPS, Linde, Technip, Nokia, Ericsson, Peugeot, Renault, OMV, Societe Generale, ENI, Mitsubishi, Sumitomo, Siemens, LG, Samsung, Bosch, Valeo, Nestle, Unilever, BAT, Japan Tobacco." (The London Times, "American pressure threatens UK firms," 5/27/06)

Response

No response at this time.

BP

Industry
Energy
Value of USG Contracts
10700
Value of USG Contract Source
http://usaspending.gov/explore?fromfiscal=yes&tab=By+Prime+Awardee&fiscal_year=2008&contractorid=243243&fiscal_year=&tab=By+Prime+Awardee&fromfiscal=yes&carryfilters=on&Submit=Go
Symbol
LN: BP
States
AK
IL
TX
Country
UK
Contact Information
Sources

BP's form 20-F filed with the SEC for fiscal year 2021 states: "To our knowledge, none of BP's activities, transactions or dealings are required to be disclosed pursuant to ITRA Section 219, with the following possible exception. On 17 July 2018, BP Iran Limited terminated its lease of an office in Tehran. The office had been used for administrative activities. In 2021, taxes with an aggregate US dollar equivalent value of approximately $1,600 were paid from a BP trust account held with Tadvin Co. to Iranian public entities. No gross revenues or net profits were attributable to these activities."

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"An oil tanker run by BP Plc is being kept inside the Persian Gulf in fear it could be seized by Iran in a tit-for-tat response to the arrest by Gibraltar last week of a vessel hauling the Islamic Republic’s crude. The British Heritage, able to haul about 1 million barrels of oil, was sailing toward Iraq’s Basrah terminal in the south of country when it made an abrupt u-turn on July 6." (Bloomberg, "BP Oil Tanker Shelters in Persian Gulf on Fear of Iran Retaliation, " 4/8/2019).

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According to its 2019 SEC disclosure, BP reported the following: "To our knowledge, none of BP’s activities, transactions or dealings are required to be disclosed pursuant to ITRA Section 219, with the following possible exceptions:

  • Prior to 30 November 2018, Rhum, located in the UK sector of the North Sea, was operated by BP Exploration Operating Company Limited (BPEOC), a non-US subsidiary of BP, and Rhum was owned under a 50:50 unincorporated joint arrangement between BPEOC and Iranian Oil Company (U.K.) Limited (IOC) which was initially established in 1974. During 2018, BP recorded gross revenues of $177.3 million related to its interests in Rhum. BP had a net profit of $87.7 million for the year ended 31 December 2018.
  • BP has sought to carry out its role as operator of the Rhum joint arrangement in compliance with US sanctions and has obtained a series of specific OFAC licences relating to the ongoing operation of the Rhum field.
  • In November 2017, BPEOC entered into an agreement with IOC for the sale and purchase of an IOC entitlement to Forties blend crude oil. The parties agreed to set off the purchase price - £29.89 million ($39.88 million equivalent) - against IOC’s share of operating costs incurred or to be incurred by BPEOC as operator of the Rhum field under the Rhum joint operating agreement. 604,976 net barrels of Forties blend crude oil was loaded at a North Sea terminal in January 2018 and delivered to BP’s Rotterdam refinery. Upon delivery at BP’s Rotterdam refinery, the Forties blend crude oil was comingled with other products for refining, and therefore BP is unable to ascertain an amount of gross revenue or gross profit attributable to it.
  • During 2018, BPEOC received £223,693 ($298,456 equivalent) (net of tariffs) from BPEOC Forties Pipeline System in respect of monies owed to IOC in relation to the purchase of IOC’s share of Onshore Raw Gas at the Kinneil terminal of the Forties Pipeline System. BP and IOC agreed to set off the £223,693 ($298,456 equivalent) against IOC’s share of operating costs incurred or to be incurred by BPEOC as operator of the Rhum field under the Rhum joint operating agreement.
  • During 2018, BPEOC received £2.79 million ($3.73 million equivalent) (net of tariffs) from a non-US third party in respect of the sale to such non-US third party of certain NGLs redelivered from the St Fergus terminal. These NGLs had been acquired by BPEOC from IOC at the St. Fergus terminal. BP and IOC agreed to set off the £2.79 million ($3.73 million equivalent) against IOC’s share of operating costs incurred by BPEOC as operator of the Rhum field under the Rhum joint operating agreement.
  • As noted above, on 30 November 2018, BP completed the sale of its ownership stake in the Rhum joint arrangement and transferred its role as operator to Serica. Prior to the sale, on 5 October 2018, Serica and BP received a conditional licence from OFAC relating to the ongoing operation of the Rhum field. The licence was valid until 31 October 2019 and was conditional upon arrangements being put in place before 5 November 2018 relating to the interests in Rhum held by IOC. An updated licence from OFAC on substantially the same terms and a letter of comfort permitting all non-US persons to support Rhum activities in compliance with US secondary sanctions were issued on 2 November 2018. On the same date the conditions in such OFAC licence in respect of the interest in Rhum held by IOC were met in full. These conditions were satisfied through arrangements which provide that all benefits accruing from and relating to IOC’s interest in Rhum will be held in escrow, by a trust and management company (Rhum Management Company) set up for this purpose, for such period as US sanctions apply. The arrangements are designed to ensure that neither IOC nor any direct or indirect parent company of IOC (including any member of the Government of Iran) will derive any economic benefit from Rhum, or exercise any decision-making powers in respect of Rhum, during that period. From satisfaction of the OFAC licence conditions on 2 November 2018, BP dealt with the Rhum Management Company in respect of Rhum joint venture matters.
  • In December 2018, BP made a cash transfer of £2.69 million ($3.59 million equivalent) to Rhum Management Company. This transfer represented the net amount of IOC funds in the Rhum joint venture account which had not, to that date, been set off against IOC’s share of operating costs incurred by BPEOC as operator of the Rhum field under the Rhum joint operating agreement.
  • BP does not expect to enter into any further similar arrangements with IOC or any member of the Government of Iran in relation to the Rhum field. BP will continue to purchase from Serica’s liftings from Rhum or provide services to Serica as the operator of Rhum.
  • On 17 July 2018 BP Iran Limited terminated its lease of an office in Tehran. The office had been used for administrative activities. In 2018, taxes, including rental tax payments associated with the Tehran office, with an aggregate US dollar equivalent value of approximately $11,000, were paid from a BP trust account held with Tadvin Co. to Iranian public entities. No gross revenues or net profits were attributable to these activities.
  • During 2018, certain BP employees visited Iran for the purpose of meetings with Iranian government officials and other Iranian nationals and attending conferences. Payments were made to Iranian public entities for visas and taxes in relation to such visits with an aggregate US dollar equivalent value of approximately $3,000. In addition, certain BP employees met with Iranian government officials and other Iranian nationals outside of Iran. No gross revenues or net profits were attributable to these activities, save where otherwise disclosed. BP will continue to monitor and assess business opportunities in Iran which are compliant with EU and US laws applicable to BP including potentially attending meetings in connection with this purpose." (SEC, "20-F," 3/29/2019). 

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"BP has stopped work on the Rhum gas field in the North Sea, which it has a 50-percent stake in, sharing it with the National Iranian Oil Company. The company cited the reintroduction of US sanctions against Tehran as the reason." "BP suspends work on gas field shared with Iran," RT, May 31, 2018.

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“BP has decided to defer some planned work on the Rhum gas field in the North Sea while we seek clarity on the potential impact on the field of recent US government decisions regarding Iran; Rhum is co-owned by an Iranian company. BP always complies with applicable sanctions.” (May 23, 2018).

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European oil companies could be particularly hit - French company Total signed a $5bn deal with Iran after the agreement, while BP has a joint venture to operate the Rhum gas field with Iran's state oil company. (May 11, 2018).

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In 2017, the U.S. states of Iowa and South Carolina listed BP on its state list of Doing Business with the Iranian Petroleum/Natural Gas, Nuclear and Military Sectors, rendering BP ineligible for investment and/or state contracting.

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Nov 2017 – “London-based BP this week agreed to sell to North Sea producer Serica Energy three fields in the aging offshore basin, including the Rhum field which is co-owned by a subsidiary of Iran’s national oil company.”

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"BP and Iran's state-run oil company received a license from the U.S. Treasury last year to operate their joint gas field in the North Sea following the lifting of Western sanctions on Tehran, BP said on Thursday.  Production at the Rhum field was suspended in 2010 when Europe imposed sanctions on Iran over its nuclear program and only resumed four years later after Britain agreed to set up a temporary management scheme whereby all revenue due to Tehran would be held until sanctions were lifted. Following the removal of European Union and United Nations sanctions on Iran in January 2016, the temporary management scheme ceased. Iran regained control of its stake and on Sept. 29, 2016 BP obtained a license from the U.S. Treasury, through its sanctions enforcement arm - the Office of Foreign Asset Control (OFAC), to continue operations at the field, BP said in its 2016 annual report." (Reuters, "U.S. Granted BP License To Operate Joint North Sea Field With Iran," 4/6/2017).

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"BP has opted out of the first wave of agreements to develop oil and gas reserves in Iran after the lifting of international sanctions - setting it apart from its two biggest European rivals Royal Dutch Shell and Total... BP has not applied to take part in a forthcoming tender of exploration and production rights in Iran, according to people briefed on the matter, and has no immediate plans for separate agreements of the kind reached by Shell and Total. These people said the main reason was commercial. "It's a question of where the best returns on investment can be made and BP has plenty of attractive opportunities elsewhere," said one. However, these people acknowledged the continued existence of some US sanctions against Iran - and the prospects of a hardline stance against Tehran by the Trump administration - was a particular deterrent for BP. Although based in the UK, BP has the biggest US exposure of any European oil group; about 40 per cent of its shareholders and 30 per cent of its employees are American, including Bob Dudley, chief executive." (Financial Times, "BP Opts Out of Iran Deals Ahead of Trump Hard Line on Tehran," 1/2/2016).

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"The National Iranian Oil Company has signed new spot oil export contracts with BP and the Anglo-Dutch Royal Dutch Shell to provide them with oil and gas condensates, director for international affairs at NIOC said on Wednesday... A spot contract is a deal for buying or selling a commodity for settlement (payment and delivery) on the spot date, which is normally two business days after the trade date. A spot contract is in contrast with a forward contract where terms are agreed now but delivery and payment will occur at a future date." (Financial Tribune, "Iran Signs Spot Contracts with Shell, BP," 12/29/2016).

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"BP has created a new executive committee to explore business in Iran which will exclude its American chief executive Bob Dudley in a bid to avoid potential violations of U.S. sanctions still in place. The new committee is headed by BP's chief financial officer Brian Gilvary, who is a British national. Gilvary will coordinate the oil major's operations in Iran and any discussions with the country's national oil company, according to industry sources. The move highlights the lengths to which multinationals will go to exploit lucrative new business in Iran, which is only slowly emerging from years of isolation that crippled the OPEC member's energy-reliant economy... BP's new executive committee also includes Bernard Looney, upstream chief executive, who is Irish, Dev Sanyal, chief executive of alternative energy and executive vice president, regions, an Indian national, and General Counsel Rupert Bondy, a Briton. "The separate governance structure does not involve Bob or any other U.S. citizens and was set up for Bob's own protection," one source said... Last month, Dudley said: "Iran is a large oil and gas province "... We're going to have to be very careful. We don't want to violate any sanctions." (Reuters, "Exclusive: BP ring-fences CEO Dudley from Iran decision-making," 11/22/2016).

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"Iran continues its quest for new crude buyers, especially in Europe, but its loyal customer base will continue to hinge on countries like India and China, whose demand for Iranian crude has observed a steady rise this year. Iran has found interest for its crude in some unusual places in the past few months as it continues it diversify its list of buyers. Earlier this month it agreed to sell 1 million barrels of crude oil to Hungary via Croatia as it seeks to widen its post-sanctions customer base, which now includes cargoes sold to oil major BP, France's Total, Greece's Hellenic Petroleum, Spain's Repsol and Cepsa, Russia's Lukoil, Poland's Grupa Lotos, Portugal's Petrogal and Italy's Saras and Iplom. Iran said it has held talks with Bosnia and Herzegovina this week as it hopes to expand its list of crude oil export destinations. However, its shipments to Asia remain the pillar of its export market." (Platts, "Analysis: Iran eyes new crude oil buyers, Asia remains linchpin," 11/1/2016).

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"Iran’s state-owned oil company sold condensate to BP Plc for the first time since sanctions were lifted in January, marking the country’s re-emergence as one of the world’s top suppliers of crude oil and natural gas liquids. National Iranian Oil Co. will supply South Pars condensate to BP for loading between September and October, said an NIOC official, asking not to be identified because of internal policy. The shipment may be used by one of BP’s own refineries or resold to other users, the official said by phone." (Plc for the first time since sanctions were lifted in January, marking the country’s re-emergence as one of the world’s top suppliers of crude oil and natural gas liquids. National Iranian Oil Co. will supply South Pars condensate to BP for loading between September and October, said an NIOC official, asking not to be identified because of internal policy. The shipment may be used by one of BP’s own refineries or resold to other users, the official said by phone." (Bloomberg, "Oil Major BP Buys First Iranian Oil Since Sanctions Eased," 10/5/2016).

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"'A cargo of one million barrels of natural gas condensate was delivered to BP,' Mohsen Ghamsari was quoted as saying by Iran's semi-official Mehr news agency. 'So far NIOC has sold two cargos of crude oil and gas condensate to two British companies,' Ghamsari said, without naming the second company... Ghamsari said negotiations are underway for NIOC to sign long-term contracts with BP and Royal Dutch Shell, Mehr reported." (Retuers, "Iran sells first cargoes of oil, condensate to British companies - Mehr news," 10/3/2016).

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"Iran's oil minister met BP PLC and Total SA on Wednesday, in a sign of renewed interest for the country's oil sector. International sanctions ban Western oil companies from entering Iran's oil fields. Earlier this week, Tehran failed to reach a final nuclear agreement with world powers, which could have eased such restrictions. Speaking to reporters, Iranian oil minister Bijan Zanganeh said he met representatives of BP PLC--the first such reported meeting with the British oil giant--and France's Total SA to discuss a possible entry in the country. Total, which was represented by new Chief Executive Officer Patrick Pouyanne, and BP have both previously said they won't work in Iran unless sanctions are lifted. Separately, Mr Zanganeh also met Vagit Alekperov, president of Russian oil giant Lukoil. Speaking to reporters, Mr. Alekperov said that 'as soon as sanctions [are] lifted, we are hoping [to] enter' the country. He also said Lukoil would like to participate in bidding round for new oil contracts which is due early next year, but which has been postponed several times." (Dow Jones, "Iranian Oil Minister Meets With BP, Total and Lukoil," 11/26/14)

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“Multiple companies currently exploring new business ventures in Iran are also cashing in on highly lucrative contracts with the U.S. Defense Department, raising questions about whether their dealings with Iran could run afoul of U.S. law. At least 13 major international companies have said in recent weeks that they aim to reenter the Iranian marketplace over the next several months. The companies have received Pentagon contracts totaling well over $107 billion, according to a Washington Free Beacon analysis that tracked DoD contracts awarded since fiscal year 2009. Many of the companies, which include carmaker Renault and oil giants such as BP, have already sent high-level trade delegations to Tehran to meet with Iranian officials about striking new business dealsRenault, for instance, resumed shipping car parts to Iran in January of this year. The French automaker has received at least $111,170 from the Pentagon, according to publicly available data. BP representatives reportedly attended an Iran oil investor conference that included Iranian President Hassan Rouhani and the country’s oil minister.” (Washington Free Beacon, “Pentagon Contractors Exploring Business with Iran,” 2/25/14)

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"Iran will have a new, attractive investment model for oil contracts by September, its president and oil minister told some of the world's top oil executives here on Thursday, part of its drive to win back Western business. Iranian President Hassan Rouhani and Oil Minister Bijan Zanganeh said their new administration was keen to open up to Western investments and technology, executives who attended the meeting said. They also stressed the importance of fossil fuel, with global energy demand rising. ‘The fact that the president of Iran came to the meeting today... is clearly a sign that Iran wants to open up to international oil companies,’ said Paolo Scaroni, chief executive of Italy's Eni, who was at the meeting. ’It was an impressive presentation,’ said one of three further oil executives who were at the meeting and spoke with Reuters on condition of anonymity. ’They said they are working on a new model to work with investors and are happy to see us,’ he added. ‘They not only need money but technologies. They are happy to have consultations about how new contracts shall work. They want to decide on the model by September.’ ’The message was - look at us, our geological risks are minimal, reserves are huge, come and we will create competitive terms and you will be happy. Your return on investments will be acceptable,’ another executive said. Along with ENI, France's Total, Britain's BP , LUKoil and GazpromNeft from Russia, and several other companies were present.” (Reuters, “Iran lures oil majors with new contracts pledge,” 1/23/14)

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“For foreign firms, the biggest prize in Iran is undoubtedly its sanctions-crippled oil and gas sector. ’Iran clearly has huge resources. Its production has been curtailed in recent years,’ oil company BP said in a statement. ‘It clearly has a lot of potential.’ It cautioned, however, that ‘this is likely to be a very complicated political process.’” (AP, “European businesses rushing to find Iran bonanza,” 1/22/14)

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"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...'I am talking to some of them,' he said, without saying which...BP's name stands out in this group of European companies because it didn't enter Iranian projects after the Islamic Revolution. BP's predecessor company, Anglo-Iranian Oil, played a controversial role under the previous regime of the Shah." (Wall Street Journal, "Iran Wants U.S. Companies to Develop Oil Fields," 12/4/13)

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"Britain could be close to agreeing a deal to ease sanctions that have stopped gas production from the North Sea's Rhum field, jointly owned by BP (BP.L) and the National Iranian Oil Co., the Mail on Sunday newspaper said.Production from the field, which once supplied 5 percent of Britain's gas output, has been suspended since 2010 as a result of international sanctions against Iran. But with signs of a thaw in relations between Iran and the West, the government now hopes to win agreement from the European Union and the United States for a sanctions waiver in the near future, the newspaper said, citing people close to the talks. One stumbling block to a deal, however, could be concerns from companies involved in financing and servicing the field that any exemption for the producers would not fully protect them from legal action, it added . . . A spokesman for BP declined to comment on the possibility of a waiver being granted. 'As operator of the field our priorities are two-fold - to ensure the field remains safe and that we remain compliant with the law,' he said. 'It is up to the government to decide on the longer-term options.'" (Reuters, "Britain pushing to ease sanctions on BP gas field," 9/22/12)

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"The U.K. government is in talks with the U.S. and the European Union over a possible exemption to Iranian sanctions that would allow BP BP.LN +0.03% PLC to restart a North Sea natural gas field partially owned by a Tehran-controlled companyBP's Rhum field, in the North Sea, is 50% owned by an affiliate of Iran's state oil company. BP closed it in 2010 amid tightening U.S. and EU sanctions aimed at stopping Iran's nuclear program. It is unclear exactly what shape the possible exemption might take, or whether a deal will be reached in the end. But recent efforts stem from newly adopted EU regulations, which allow exemptions under specific conditions. 'The BP gas field could be exempted from sanctions under an EU Council Regulation adopted in December 2012 amending previous regulation on restrictive measures against Iran,' an EU spokeswoman said. The spokeswoman declined to comment on talks over the exemption. 'We are working with the EU to ensure the long-term security of the Rhum North Sea gas field and will be making an announcement on this in due course,' said a spokeswoman for the U.K.'s Department of Energy and Climate Change. A spokeswoman for the U.S. State Department confirmed discussions had been held with the British government on the issue, but declined to provide detailsRhum is 50% owned by IOC UK, which is controlled by the state-owned National Iranian Oil Co., via a Malaysia-based unit. It was producing around 5.4 million cubic meters of gas a day before it was shut down in 2010, according to BP. That is about 5% of current U.K. output. The joint venture was set up in 1973 when Iran was still ruled by the Shah. Gas was discovered in the field in 1977, but because of the technically challenging nature of the reservoir, it only started producing in 2005. EU officials say it is the only Western-Iranian joint venture of its kind in the bloc." (Wall Street Journal, "U.K. Seeks Exemption From Iranian Sanctions for BP Gas Field," 9/16/13)

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"Several western oil companies also supply jet fuel to the airport - Royal Dutch Shell, BP and Chevron - but they say they source it outside the UAE and in full compliance with sanctions on Iran." (Reuters, "Dubai flights rely on fuel refined from Iranian oil," 4/24/2013)

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"Naftiran owns a 10 percent stake in the Shah Deniz project in Azerbaijan which is co-led by BP and Norway's Statoil and which is estimated to contain 1.2 trillion cubic meters of gas." (Reuters, "EU sanctions target Iran oil, gas, tanker companies," 10/16/2012)

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"Reuters has learned that on February 1, [Iranian oil-trading firm] Naftiran Intertrade increased its holding in British oil giant BP Plc by 1.85 million shares. It now holds a stake worth more than $190 million (121 million pounds). In addition to the shareholding, the Iranian company's ties to BP include the Rhum gas field in the North Sea, a venture that's now suspended due to sanctions. It also has active projects like a gas field with BP in Azerbaijan, and an investment with Royal Dutch Shell in fuel distribution in Senegal . . . A spokesman at BP said the company would not comment on individual shareholders. 'However we regularly review and take legal advice to ensure our compliance with sanctions legislation. We remain confident that BP is in full compliance with all applicable sanctions regimes including UN, EU regulations and US law, and will remain in compliance,' he said. 'We continue to monitor the situation closely' . . . Under the European sanctions, if a corporate entity is believed to have reasonable cause to suspect that it may be making funds available - either directly or indirectly - to someone on the sanctions list, British or European authorities could investigate or even prosecute." (Reuters, "Special Report - For Iran oil trader, Western ties run deep," 2/16/12)

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"Refiners in South Africa include Shell, BP, Total, Chevron, petrochemicals group Sasol , and Engen, majority-owned by Malaysian state oil group Petronas. BP, Chevron, Sasol and Engen said earlier this year that they have either stopped or were not sourcing any Iranian crude. Trade data from March showed, however, that imports of Iranian crude had gone up from the previous month." (Reuters, "S.Africa keen to replace Iranian crude with Nigerian," 5/24/2012)

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"While some open sources reported that BP sold gasoline to Iran in 2009 or 2010, other open sources reported that BP stopped selling gasoline to Iran in 2008." (U.S. Government Accountability Office, Report: "Firms Reported in Open Sources to Have Sold Iran Refined Petroleum Products between January 1, 2009 and June," September 3, 2010)

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BP continues to be actively engaged in the Iranian petroleum industry through joint ventures with Iranian oil companies. BP is currently partnering with the Iranian governmental-controlled Naftiran in the North Sea and Azerbaijan; these projects are worth over $2.4 billion per year (Time Magazine, "Sleeping with the Enemy: BP's Deals with Iran", 6/18/2010).

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"Still, given all the controversy over Iran's nuclear program, many companies decline to discuss their Iranian oil purchases. Companies like Shell and BP have said they have stopped selling gasoline to Iran.

But they rarely mention that they continue to buy crude or other Iranian oil products, which generally is a much larger and more lucrative business than gasoline deliveries" (The Wall Street Journal. "Oil Trade with Iran Thrives Discreetly," 5/20/10).

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"BP, in a 2009 filing with the Securities and Exchange Commission, said it had interests in and was the operator of two fields and a pipeline located outside Iran in which the National Iranian Oil company had an interest. The company also said in the filing that it buys small quantities of crude oil from Iran for sale to third parties in Europe and for its own refineries in South Africa and Europe and, through a joint venture, blends small quantities of lubricants for sale there. In addition, BP was one of several companies that provided Iran with gasoline, but Toby Odone, a spokesman for BP in London, said the company decided in 2008 to cease such shipments."  The company was alloted 3.5 million acres from the US government for their business in Iran during 2000-20009.  Their investments in Iran are currently active. (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," July 9, 2008)

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"In recent months, Iran has, according to the respected trade publication International Oil Daily and other sources including the U.S. government, purchased nearly all of this gasoline from just five companies, four of them European: the Swiss firm Vitol; the Swiss/Dutch firm Trafigura; the French firm Total; British Petroleum; and one Indian company, Reliance Industries." (Orde F. Kittrie, Op-Ed, "How To Put The Squeeze On Iran," The Wall Street Journal, November 13, 2008)

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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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"Last Friday, Thyssen-Krupp, a steel-making conglomerate, said a representative of Iran - the company's third biggest shareholder - no longer would hold a seat on its supervisory board. In remarks to shareholders, Thyssen-Krupp supervisory board chairman Gerhard Cromme said he regretted having to remove the Iranian, but failure to do so would have created considerable economic disadvantages for the company. Thyssen-Krupps move came as BP chief executive officer John Browne reiterated that the oil company would refrain from exploring business opportunities in Iran." (The Globe and Mail, "Two big EU firms ease ties with Iran," January 28, 2005)

Response

No response at this time.

Barclays PLC

Industry
Banking
Value of USG Contracts
105
Value of USG Contract Source
http://usaspending.gov/explore?fromfiscal=yes&tab=By+Prime+Awardee&fiscal_year=2008&contractorid=243239&fiscal_year=&tab=By+Prime+Awardee&fromfiscal=yes&carryfilters=on&Submit=Go
Symbol
LN: BARC
States
CA
FL
GA
IL
MA
NY
TX
Country
UK
Sources

According to its Annual Report filed with the SEC for fiscal year 2019: "Between 1993 and 2006, Barclays entered into several guarantees for the benefit of Iranian banks in connection with the supply of goods andservices by Barclays customers to Iranian buyers. These were counter guarantees issued to the Iranian ban ks to support guarantees issued by these banks to the Iranian buyers. The Iranian banks and a number of the Iranian buyers were subsequently designated as Specially Designated Nationalsand Blocked Persons (“SDN”) by the U.S. Department of the Treasury, Office of Foreign Assets Control (“OFAC”). 
Barclays is party to a long - term lease, entered into in 1979, with the National Iranian Oil Company (“NIOC”), pursuant to which Barclays rents partof NIOC House in London for a Barclays bank branch. The lease is for 60 years, contains no early termination clause, and has 20 years remaining.Barclays makes quarterly lease payments in GBP to an entity that is owned by the Government of Iran. The payments are made in accordance with applicable laws and regulations. Barclays attributed no revenue in 2019 in relation to this activity.
A Barclays customer was designated pursuant to the Global Terrorism Sanctions Regulations (“GTSR”) in March 2016. Barclays continues to receive credit card repayments from this customer in accordance with applicable laws and regulations. A block continues to be applied to the card to prevent any further spending. Barclays attributed revenue of approximately GBP 480 in 2019 in relation to this activity. In 2019, Barclays processed three euro payments relating to overflight charges, a portion of which were for the overflight of Iranian airspace. It ispresumed that the ultimate beneficiary of the outbound payments was a Government of Iran owned entity. The payments were made in accordance with applicable laws and regulations. No payments were made directly to Iran or any entity owned or controlled by the Government of Iran. Although OFAC has issued a general license relating to payments for overflights of Iranian airspace, it does not technically apply to aircraft owned by non - U.S. persons, or registered outside of the U.S. Barclays attributed revenue of approximately GBP 30 in 2019 in relation to this activity. Barclays maintains customer relationships with UK - incorporated medical manufacturing companies. In 2018 and 2019, Barclays processed several payments, for the benefit of our customer, relating to the export of medical devices to privately - owned Iranian entities. The end users of these medical devices include hospitals or clinics that may be owned or controlled by the Government of Iran. The payments were made in accordance with applicable laws and regulations. All payments were received from the privately - owned Iranian entities; no payments were received directly from any entity owned or controlled by the Government of Iran. Although OFAC has issued general licenses relating to the sale of medical devices,they do not technically apply to sales of non - U.S. origin items by non - U.S. persons. Barclays attributed revenue of approximately GBP 60 in 2019 in relation to this activity. Barclays maintains customer relationships with several individuals who work for UK - based entities that are ultimately owned by the Government of Iran and are OFAC SDNs." 

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"Barclays Plc, BNP Paribas SA, Commerzbank AG, Credit Agricole SA, Credit Suisse Group AG, Deutsche Bank AG, HSBC Holdings Plc , Royal Bank of Scotland Group Plc and Standard Chartered Plc had been sued by military personnel who survived the attacks, and relatives and estates of those killed.

The plaintiffs accused the banks in a 533-page complaint of concealing their work for Iran through such practices as altering wire transfers, and masking the identities of those transferring funds.

But the judge found the complaint “devoid” of allegations that the banks knew they were enabling attacks in Iraq linked to Hezbollah, al Qaeda and other groups that the U.S. government has designated as foreign terrorist organizations.

Swain found no proof, as required under a 2013 decision from the federal appeals court in Manhattan, that the services were a substantial factor in the attacks, and that the plaintiffs’ injuries were a reasonably foreseeable consequence." (April 1, 2019)

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As of August 27, 2019, Barclays plc is listed on the Illinois Investment Policy Board Iran Restricted Companies list. 

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In 2018, the U.S. state of Michigan listed Barclays on its state lists of Companies Doing Business with Iran rendering Barclays ineligible for investment and/or state contracting.

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"For Syrian and Iranian citizens living in the Gulf, finding a bank to deal with just became a little tougher. Banks like Barclays and HSBC have begun turning away new customers from countries that are facing sanctions. They are closing down some existing accounts, further isolating Syrian and Iranian citizens from the global financial industry... Also under the new measures, Syrian or Iranian customers with bank balances of less than 100,000 dirhams, or $27,225, will be asked to close their accounts within 30 days. Customers with salaries of less than 15,000 dirhams will also be affected. This is because the cost to the bank of making the enquiries necessary to enforce compliance is higher than the benefit or 'profit potential' of keeping a customer with a small bank balance. It is cheaper for HSBC to close an account or not to open a new one with a balance of less than 100,000 dirhams." (The New York Times, "Sanctions Chill Reaches Banking Clients in the Persian Gulf," 2/13/13)

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"Since 2009, the Justice Department, the Treasury Department and the Manhattan district attorney’s office, working largely in concert, have brought charges against five foreign banks, contending they moved billions of dollars through their American subsidiaries on behalf of Iran, Cuba and North Korea, sponsors of terrorism and drug cartels. The cases against the five banks all included deferred prosecution agreements and required the banks — ABN Amro, Barclays, Credit SuisseLloyds and most recently ING — to forfeit a substantial amount of assets. The cases typically have not involved United States banks. Unlike foreign institutions, American banks were prohibited from originating or receiving such transactions from Iran. That enabled them to largely sidestep the conduct that has helped ensnare foreign banks." (New York Times, "Deutsche Bank’s Business With Sanctioned Nations Under Scrutiny," 8/17/12)

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"While operating in Iran, the bank received a small contract from the United States Navy. In 2007, the company disclosed to the Securities and Exchange Commission that it was the subject of a Justice Department  investigation into its operations in countries where the United States maintains sanctions, and a spokesperson said the bank terminated all of its business in Iran and other countries subject to sanctions that year. The company, which said in a 2010 disclosure that it was cooperating with the inquiry, declined to comment on the investigation."  The company received $47,381 in revenue and benefits from the US government for their business in Iran during 2000-2009.  The company has since withdrawn their investments in Iran. (The New York Times, "Profiting from Iran, and the US," 3/6/2010)

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“Evidence of Iran's efforts to acquire sensitive materials also is emerging from investigations by state and federal prosecutors in New York into whether a number of major Western banks illegally handled funds for Iran and deliberately hid Iranian transactions routed through the U.S….Documents detailing Iran's metals acquisition efforts are being reviewed by U.S. law-enforcement and intelligence officials, people involved in the matter said. Manhattan District Attorney Robert Morgenthau said he is conducting a broad inquiry into illegal transactions by Iran. Last week, Lloyds TSB of London agreed to pay $350 million to settle U.S. sanctions-busting charges with Mr. Morgenthau's office and the Justice Department. The bank admitted it violated U.S. law but said the practice has ceased. There are nine other banks that we think were doing this, said Mr. Morgenthau in an interview, including Barclays PLC of the U.K. A Barclays spokesman had no comment beyond a prior disclosure confirming the inquiry. Other banks under scrutiny in the probe include Credit Suisse and Deutsche Bank, people with knowledge of the inquiries said." (The Wall Street Journal, "Fresh Clues of Iranian Nuclear Intrigue," 1/16/09)

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