UK

According to its 2021 annual report, Astra Zeneca has a subsidiary, AstraZeneca Pars Company, based in Tehran at Suite 1, 1st Floor No. 39, Alvand Ave., Argantin Sq., Tehran 1516673114, Iran.

--

According to its Annual Report filed with the SEC for fiscal year 2019: "AstraZeneca is a global, innovation-driven biopharmaceutical business with operations in over 100 countries and its innovative medicines are used by millions of patients worldwide. AstraZeneca has a legal entity based in Iran, AstraZeneca Pars Company (“AstraZeneca Pars”), which has no employees, and is owned by non-U.S. Group companies. In July 2017, AstraZeneca Pars submitted regulatory applications to the Iranian Food and Drug Administration and subsequently received marketing authorizations for several products. AstraZeneca Pars has not entered into any commercial transaction since its incorporation; products registered under AstraZeneca Pars are exclusively sold by a third-party distributor.

AstraZeneca, through one of its non-U.S. Group companies that is neither a U.S. person nor a foreign subsidiary of a U.S. person, currently has sales of prescription pharmaceuticals in Iran solely through a single third-party distributor, which uses three known entities in the Iranian distribution chain. At this time, none of AstraZeneca’s U.S. entities are involved in any business activities in Iran, or with the Iranian government. To the best knowledge of the management of AstraZeneca, the third-party distributor used by AstraZeneca is not owned or controlled by the Iranian government and AstraZeneca does not have any agreements, commercial arrangements, or other contracts with the Iranian government. However, AstraZeneca understands that one of the independent sub-distributors of AstraZeneca’s third-party distributor is likely to be indirectly controlled by the Iranian government. Further, AstraZeneca’s third-party distributor may initiate payments using banks associated with the government of Iran for the purchase of AstraZeneca products. Finally, Government agencies, hospitals and institutions may purchase AstraZeneca products from the third party distributor or the sub-distributors.

On February 11, 2017, a non-U.S. Group company that is neither a U.S. person nor a foreign subsidiary of a U.S. person entered into a memorandum of understanding with the Iranian Ministry of Health, whereby AstraZeneca committed to improving the overall quality of healthcare and ensuring that Iranian patients have access to the latest innovative and cost-effective medicines. The memorandum of understanding is still in effect. During 2017, 2018, AstraZeneca, through a distributor, conducted health care provider education programs in Iran, including for employees of hospitals owned or controlled by the Iranian Ministry of Health. In this context, AstraZeneca may make additional products available in Iran in the future; where required, relevant U.S. licenses will be sought.

For the year ended December 31, 2019, the Company’s gross revenues and net profits attributable to the above-mentioned Iranian activities were $16.9 million and $5.2 million respectively. For the same period, AstraZeneca’s gross revenues and net profits were $24.4 billion and $1.2 billion, respectively. Accordingly, the gross revenues and net profits attributable to the above-mentioned Iranian activities amounted to approximately 0.069% of AstraZeneca’s gross revenues and approximately 0.43% of its net profits.

At the time of publication, the management of AstraZeneca does not anticipate any change in its activities in Iran that would result in a material impact on AstraZeneca."

--

AZ Iran will add to this footprint following the signing of a comprehensive “Memorandum of Understanding” (MoU) with the Iranian Food and Drug Authority. This MoU includes several strategic projects that will further accelerate access to innovative medicines for Iranian patients, and will strengthen local research and advance scientific collaboration.

--

AstraZeneca PLC has a U.S. website. 

--

"While Western powers have identified a small group of sectors for Iranian sanction relief, a much wider set of European and U.S. companies—from pharmaceutical firms and medical-equipment makers to food companies and traders—also stands to regain lost Iranian trade as soon as relief measures are formally adopted next month. Western governments singled out Iran's automotive and aviation sectors for temporary sanction relief, while allowing petrochemical exports and trade in gold and other precious metals. But the fine print of the deal also clears the way for GlaxoSmithKline PLC and Sanofi SA, for example, to restart selling many of the drugs they had been forced to cut back on because of increasingly stiff financial sanctions…Pharmaceutical companies Glaxo and AstraZeneca PLC of the U.K. and Sanofi of France reported annual Iranian sales of roughly $32.2 million, $14 million and $13.9 million, respectively, according to their annual SEC reports…A spokeswoman for AstraZeneca said it works in Iran in 'full compliance with the laws and regulations.'" (Wall Street Journal, "Iran Deal Opens Door for Businesses," 12/1/13)

Subsidiary of Bogazzi Fimpar SpA

--

"On Monday, United Against Nuclear Iran (UANI) called on shipping firm NAVALMAR UK LTD (NAVALMAR) to immediately stop making port calls in Iran. In a letter sent to NAVALMAR General Director Roy Terence Ware, UANI CEO, Ambassador Mark D. Wallace, wrote:UANI is specifically raising its concerns with the activities of NAVALMAR’s vessel, the BSLE VENUS, which UANI believes is visiting Iranian ports and interacting with port authorities closely affiliated with Tidewater Middle East Co., a U.S. and EU sanctioned entity."… I am again writing on behalf of United Against Nuclear Iran (“UANI”) to express our concerns about the apparent calling of NAVALMAR UK LTD’s (NAVALMAR) vessel BSLE VENUS at Iranian ports operated by entities sanctioned under recent European and U.S. legislation. Specifically, we would like to express our concerns about the apparently ongoing interaction between your vessel BSLE VENUS and port authorities closely affiliated with Tidewater Middle East Co., a U.S. and EU sanctioned Iranian entity.The general cargo vessel BSLE VENUS, of which NAVALMAR is the registered owner, appears to have visited ports reportedly operated by Tidewater Middle East Co. Tidewater Middle East Co. was sanctioned by the EU and U.S. due to its connection to the Iranian Islamic Revolutionary Guard Corps (“IRGC”). The IRGC itself is sanctioned by the EU and is designated as an entity of proliferation concern by the U.S. Thus by continuing its interaction with this Iranian port management authority, NAVALMAR could be in danger of inadvertently violating EU sanctions. Any payments to Tidewater Middle East Co. are prohibited under the aforementioned sanctions. UANI encourages NAVALMAR to consider abandoning its alleged interaction with sanctioned Iranian entities in order to avoid any further reputational damage derived from its ostensible commercial activities there. …"(BusinessWire, "UANI Calls on UK’s NAVALMAR to Cease Port Calls in Iran," 3/4/13)

"Three foreign currency printing companies have decided to discontinue their businesses in Iran, UANI (United Against Nuclear Iran U.S. group) Communications Director Nathan Carleton told Trend. Earlier this month, UANI has launched a 'Iran Rial Currency Printing Campaign', which targeted companies that print Rial for the Islamic Republic.According to Nathan Carleton, three such companies have stopped their businesses there, as a result of UANI's campaign.'All three of the firms we contacted, 'KBA', 'Flint', and 'DLR', have informed us that they are no longer involved in currency printing in Iran,' Carleton said, noting that UANI applauds the companies for their decisions . . . UANI has also contacted DLR, a British firm whose machines have printed rials for the regime in the past, for clarification about any current ties to Iran . . . Nathan Carleton noted that no one should be helping the Iranian regime print more currency during this critical time.'We will continue to observe the rial's value, but we do not expect it to improve unless the regime changes course.'" (Bloomberg, "Three currency printing companies stop their businesses in Iran," 10/20/12)

AGN International's LinkedIn page lists four employees in Iran.

--

AGN’s website cites Azmoudekaran Certified Public Accountants (“Azmoudekaran”), located in Tehran, Iran, as a member firm, lists several Iranian partners, and notes that the firm employs an additional 100 people.  (AGN website, “AGN Member Firms,”).

--

AGN International confirmed its status as a "Corresponding Member" in Iran in the April 2010 issue of the International Accounting Bulletin.  

--

AGN lists a partner firm in Iran on its company website. ("AGN Members by country," Company website)

RSM International confirmed its status as a "Corresponding Member" in Iran in the April 2010 issue of the International Accounting Bulletin.  

--

RSM lists a corresponding firm in Iran on its company website. ("Contact Us," Company Website)

--

"Advocacy group United Against Nuclear Iran (UANI) said it has succeeded in getting global accounting firm network RSM International to cut ties with an Iranian firm. Washington, D.C.-based UANI said RSM agreed to end its relationship with Dayarayan Auditing & Financial Services Firm in Tehran as of April 30. Chicago-based McGladrey, formerly headquartered in Minneapolis, is RSM's only member firm in the United States. UANI CEO Mark Wallace, a former ambassador to the United Nations, asked RSM and McGladrey to sever the network's relationship with Dayarayan in March. He applauded RSM's decision Friday." (Minneapolis/St.Paul Business Journal, "McGladrey's accounting network will drop Iranian firm," 4/26/2013) 

--

"RSM, a UK-based firm, and Crowe Horwath of the US have joined Grant Thornton, one of the second-tier international accountancy firms, in leaving Iran after coming under US political pressure... RSM said it would cease working with Dayarayan Auditing & Financial Services, while Crowe Horwath said it would cut ties with Hoshiyar/Behmand & Co." (Financial Times, "Three accounting firms pull out of Iran," 4/26/2013) 

--

"Accounting firm McGladrey and global network RSM International are under pressure from a group that has successfully urged major companies to cut ties with Iranian partners. Washington, D.C.-based United Against Nuclear Iran asked RSM International CEO Jeans Stephens and McGladrey CEO Joe Adams to sever their business relationship with Dayarayan Auditing & Financial Services Firm in Tehran. RSM is an international network of accounting firms. McGladrey is RSM's sole United States member firm, and Dayarayan is RSM's the sole Iranian correspondent firm (RSM explains the difference between member and correspondent firms here.)... 'RSM should not enable the provision of such vital professional and financial services to the Iranian government, sanctioned entities and foreign companies in Iran at a time when the international community is working to economically isolate the regime in response to its nuclear program, support for terrorism and gross human rights violations,' wrote UANI CEO Mark Wallace, a former ambassador to the United Nations, in a letter to the chief executives at RSM and McGladrey. 'RSM should also consider how its Iran business dealings could affect its extensive business in the United States,' he continued, in reference to Chicago-based McGladrey, which until recently was headquartered in Minneapolis. I've asked McGladrey for the firm's take but have yet to get a comment. RSM couldn't be reached before publication. UANI spokesman Nathan Carleton said his group has been in contact with the accounting firms. 'We look forward to discussing this matter with RSM and McGladrey, and we are hopeful they will take the responsible action of ending their Iran exposure,' he said." (Minneapolis St. Paul Business Journal, "McGladrey, RSM urged to cut ties with Iranian accounting firm," 3/29/13)

--

"The not-for-profit, non-partisan, advocacy group has written to the CEOs of Grant Thornton and RSM International and their counterparts in the US expressing concern about their 'apparent business dealings' with the country... In RSM’s case, he points out that the 2010 client list of its Iranian correspondent firm, Dayarayan Auditing and Financial Services Firm, included Iranian government bodies, energy firms and foreign companies. 'Among these clients are many sanctioned entities, such as the Islamic Republic of Iran Shipping Lines, the National Iranian Tanker Company, and Datak Telecom,' he says. 'UANI strongly believes that RSM should not enable the provision of such vital professional and financial services to the Iranian government, sanctioned entities and foreign companies in Iran at a time when the international community is working to economically isolate the regime in response to its nuclear program, support for terrorism and gross human rights violations.'" (Economia, "RSM and GT taken to task over Iran," 3/28/13) 

HLB International confirmed its status as a "Full Member" in Iran in the April 2010 issue of the International Accounting Bulletin.  

--

HLB lists a partner in Iran on its company website. ("Member Firms," Company Website)

Moore Stephens confirmed its status as a "Full Member" in Iran in the April 2010 issue of the International Accounting Bulletin.  

--

Moore Stephens lists an office in Iran on its company website. ("Locations," Company Website)

Nexia confirmed its status as a "Full Member" in Iran in the April 2010 issue of the International Accounting Bulletin.  

--

Nexia lists an office in Iran on its website.  ("Global Directory," Company website)

"A Tel Aviv-based civil rights group accused UK satellite operator Inmarsat Plc over the weekend of admitting it provides its technology to Iranian oil tankers. Shurat HaDin (Israel Law Center) warned Inmarsat last month that the company could risk civil as well as criminal proceedings in US courts if it did not stop supplying its guidance services to Iranian military vessels and tankers. Rich Harris, Inmarsat’s senior vice president told Shurat HaDin that the group’s allegations had no basis, and that Inmarsat is not violating sanctions. According to Harris, after the British government privatized Inmarsat in 1999, the company was obliged to continue its 'public service obligations' to 'ensure the continuity of maritime satellite distress and safety communications services' for the UN’s Global Maritime Distress and Safety System. Inmarsat was obliged to provide all ships with distress communications systems 'without discrimination on the basis of nationality,' Harris noted. In response, Shurat HaDin director and civil rights activist Nitsana Darshan-Leitner said that Inmarsat could still be in violation of sanctions, despite its UN obligations . . . The warning letter came in the wake of recent US Treasury Department sanctions against Iranian vessels, imposed last month . . . In a July 26 interview with Space News, Inmarsat spokesman Christopher McLaughlin had said that 'some of these ships [on the Treasury Department list] nonetheless appear to be using older Inmarsat gear,' while noting that the company is not informed as to the identity of its customers, because of its history as an international treaty organization. In that interview, McLaughlin said that these were 'heritage services' installed before its distribution partners had to inform it of its customers’ exact identities." (Jerusalem Post, "Shurat HaDin: UK company servicing Iran tankers," 8/5/12)

--

"A Tel Aviv-based civil rights group warned on Wednesday that satellite operator Inmarsat could face criminal prosecution if it continues providing its technology to Iranian oil tankers. In a letter to Inmarsat, Shurat HaDin (Israel Law Center) said the company could risk civil as well as criminal proceedings in US courts if it did not stop supplying its guidance services to Iranian military vessels and tankers. Shurat HaDin's director, and civil rights activist, Nitsana Darshan-Leitner said the warning letter came in the wake of recent US Treasury Department sanctions against Iranian  The sanctions, imposed earlier this month, identify by name 58 National Iranian Tanker Company (NITC) vessels. The US Treasury Department said that identifying the vessels would help companies and individuals comply with sanctions against Iran and undermine Iran's attempts to use NITC front companies to evade sanctions. Twenty-eight of the vessels named by the US Treasury Department appear on Inmarsat's shipping directory as being in receipt of the company's services . . . According to Jane's Intelligence Weekly,  the Telecommunications Company of Iran (TCI), is the Islamic Republic's national signatory to Inmarsat.  Iran's Revolutionary Guards have effectively taken over Iran’s telecommunications company, TCI, after the Mobin Trust Consortium, a company partially owned by the Guards, won a 2009 tender. Meanwhile, other documents available on Inmarsat's website list TCI as a Point of Service Activation (PSA), the company's term for an entity that has concluded a contract with Inmarsat for its C or Mini C satellite system, used by vessels for two-way communication. In its letter to Inmarsat, Shurat HaDin say that providing aid to Iran is illegal." (Jerusalem Post, "Shurat HaDin warns UK operator over Iran deals," 7/25/12)

"Less than a month after this column queried this column queried Grant Thornton's continued business dealings in Iran, the accountant announces it has terminated relations with Rymand & Co, its Iranian correspondent company, and will 'do no future business in Iran until the regime stops sponsoring terrorists and ends its pursuit of nuclear weapons'. Grant Thornton says it 'appreciates'the matter being brought to its attention. Just put the cheque in the post." (The Telegraph, "City Diary: Mehmet Dalman to write chapter and verse on miner ENRC," 4/30/2013) 

--

"Grant Thornton and two other accounting firms are pulling out of Iran, creating further difficulties for foreign companies still operating in the country. RSM, a UK-based firm, and Crowe Horwath of the US have joined Grant Thornton, one of the second-tier international accountancy firms, in leaving Iran after coming under US political pressure... 'It sends an important message when accountancy firms decide that it is too risky to do business in Iran,' said Mark Wallace, the head of United Against Nuclear Iran, a lobby group. 'Without respected auditors, it makes it much harder for other international companies to continue doing business there.'" (Financial Times, "Three accounting firms pull out of Iran," 4/26/2013)  

Grant Thornton, the UK-based firm, said that it was terminating its relationship with Rymand & Co, an Iranian accounting firm, and said it would not conduct further business in Iran. RSM said it would cease working with Dayarayan Auditing & Financial Services, while Crowe Horwath said it would cut ties with Hoshiyar/Behmand & Co.

--

"Alarm bells are ringing at a lofty diplomatic level over Grant Thornton's continued business dealings in Iran through correspondent firm Rymand & Co. Mark Wallace, a former US ambassador to the United Nations, has written to Grant Thornton global chiefs Edward Nusbaum and Stephen Chipman to question the 'financial and reputational harm' of the accountant's Iranian affiliation. 'As you know,' writes Wallace on behalf of United Against Nuclear Iran (UANI), 'the international community is ... increasingly alarmed by Iran's refusal to alleviate concerns that it may be pursuing nuclear weapons. As one of the world's leading professional networks, Grant Thornton's ongoing business activities in Iran raise serious questions and concerns.' So will Grant Thornton follow KPMG, PwC and Ernst & Young's lead in cutting their Iranian ties? 'We are investigating the matter and will respond to [UANI] directly,' said a spokesman. By UANI's deadline on Monday, Diary hopes." (The Telegraph, "City Diary: Grant Thornton rapped for 'reputational harm' over Iranian business," 3/29/13)

--

Grant Thorton confirmed its status as a "Corresponding Member" in Iran in the April 2010 issue of the International Accounting Bulletin.  

--

On its website, Grant Thornton lists a "Correspondent Firm" in Iran called Rymand & Co. (Grant Thornton Website, "Global Reach," Input: "Iran")