Turkey

"A Turkish industrial group has indicated interest in investing in Iran for production of ferrochrome, the Fars news agency said on Friday. Yildirim Holding A.S. says it is ready to purchase Iran's ferrochrome production units or their products and mines to produce chrome ores. Yuksel Yildirim, CEO of Yildirim Holding, met with head of Iranian Mines, Mining Industries Development and Renovation (IMIDRO) Mehdi Karbasian in Tehran and discussed cooperation, Fars said. Yildirim announced readiness to sign a 10-year cooperation agreement, saying his company has a plan for operation in Iran. Ferrochrome is mostly used in stainless steel." (Press TV,  "Turks seek investment in Iran ferrochrome," 6/5/2015)

"The number of foreign airlines active in Iran has dropped in the past few years. Iran's Fars News Agency reported that 27 foreign airlines were active in Iran in the previous Iranian calendar year (which ended March 20, 2014)... Corendon, Shaheen Air, Saudi Arabian Airlines, and Atlasjet were the most active international airlines in Iran in previous year." (Trend, "27 foreign airlines active in Iran," 1/10/15)

"The number of foreign airlines active in Iran has dropped in the past few years. Iran's Fars News Agency reported that 27 foreign airlines were active in Iran in the previous Iranian calendar year (which ended March 20, 2014)... Corendon, Shaheen Air, Saudi Arabian Airlines, and Atlasjet were the most active international airlines in Iran in previous year." (Trend, "27 foreign airlines active in Iran," 1/10/15)

"The U.S. Commerce Department on Monday issued a rare emergency order aimed at blocking the illegal re-export of two large, used U.S.-built commercial jet engines to Iran by a company based in Turkey. Assistant Commerce Secretary David Mills, who oversees export enforcement, signed the order on Friday after learning that Turkish-based 3K Aviation Consulting & Logistics planned to re-export two engines built by General Electric Co to Iran on Tuesday using Pouya Airline, an Iranian cargo airline…The order, which will be in effect for 180 days, includes sweeping consequences for 3K Aviation, Pouya Airline and Adaero International Trade, the Illinois-based company that the department said had shipped the used aircraft engines to Turkey. The order bans all three companies and their key officers from engaging in negotiations, trade, transport or other activities involving any U.S. export-controlled items, not just the aircraft engines in question. The order also applies to banks, insurance companies and other parties that might be involved in financing or otherwise supporting any such transactions. The department issues one or two such orders a year, said one Commerce Department official. Sadettin Ilgin, managing director of Adaero International, denied any wrongdoing, and said he had been in touch with U.S. and Turkish authorities to clear his company's name…We did not sell the engines to 3K,’ said Ilgin, who worked for Turkish Airlines for 40 years. ‘This was all done properly and we have the paperwork to show it.’ Ilgin said Turkish officials had assured him that they had denied permission for Pouya Airline to pick up the engines in Antalya, southwestern Turkey. Officials at 3K told him they planned to send the engines back to Germany, he told Reuters. No comment was immediately available from 3k Aviation or from International Aerospace Group…The Commerce Department official declined comment on whether the U.S. government was investigating possible earlier illegal exports of U.S.-built engines to Iran by 3K Aviation…In signing the order, Mills said the department's Bureau of Industry and Security had presented evidence that two GE CF6 engines were transported to 3K Aviation in Turkey on behalf of Adaero International and that 3K planned to send the engines to Iran using Pouya Airline on Jan. 7. Two sources familiar with the aircraft engine market said the engines were likely intended for use on Airbus planes operated by Iran." (Reuters, “U.S. acts to block Turkish firm from sending GE engines to Iran,” 1/7/14)

"On March 20, 2015, AAG Makina, a Turkish equipment manufacturer, settled one charge of aiding an unauthorized export to Iran with the U.S. Commerce Department’s Bureau of Industry and Security (BIS).  According to the charge, in 2011, Satco Corporation, a Canadian company, ordered $47,334 worth of valve parts and a pressure transmitter, which were shipped from the United States to AAG Makina.  The shipped goods were subject to the Export Administration Regulations.  AAG Makina forwarded the items to two Iranian petrochemical companies without U.S. government authorization.  The Turkish company agreed to pay a civil penalty of $23,000 without either admitting or denying the allegations." (Iran Watch, "Turkish Company in Procurement Ring Settles Charge of Illicit Export of Valve Parts to Iran," 3/21/2015). 

--

"The U.S. Department of Commerce's Bureau of Industry and Security (BIS) today added 36 companies and individuals to the Entity List…for engaging in actions contrary to the national security or foreign policy interests of the United States. BIS's Office of Export Enforcement (OEE) conducted investigations that revealed the companies and individuals engaged in a series of actions involving illicit shipments of U.S-origin goods to Iran and prohibited end-users in China…The second group of entities (Saeed Talebi, Satco, Satco Corporation, Satco GmbH, Kadin Satco FZE, AAG Makina, and Murat Peker) operated as parts of a procurement ring coordinating the sale and supply of items to Iran in violation of OFAC regulations and the EAR. Saeed Talebi purchased items from U.S. companies and shipped them to Iran via Germany and Turkey. Talebi established businesses in the U.A.E., Germany, and Canada to facilitate his scheme. Murat Peker, an employee of AAG Makina in Turkey, worked with Talebi to facilitate shipments by providing false information to the U.S. Government concerning the final destination of the shipments." (Bureau of Industry and Security, "Bureau of Industry and Security Adds 36 Parties to Entity List for Actions Involving Illegal Shipments of Goods to Iran and China," 12/12/13)

On June 30, 2020, the Mississippi Department of Finance & Administration identified Koc Holding as a company “engaged in investment activities in Iran, providing funds, goods or services valued at $20,000,000 or more in the energy sector of Iran.” 

--

In 2017 the U.S. state of Mississippi, South Carolina and Tennessee listed KOC as an Iran restricted company rendering KOC ineligible for investment and/or state contracting.

--

In 2016 Tennessee used the South Carolina list of "Entities Ineligible to Contract with the State of South Carolina or any Political Subdivision of the State per the Iran Divestment Act of 2014, S.C. Code Ann." as its list of persons it determines engage in investment activities in Iran. KOC Holdings was included on this list in 2016. "Inclusion on this list would make a person ineligible to contract with the state of Tennessee, if a person ceases its engagement in investment activities in Iran, it may be removed from the list."

--

In 2015 KOC Holding was removed from Pennsylvania Treasury's List of Scrutinized Companies Determined as Having Involvement In Iran because the company's "involvement in purchases of crude oil falls under the waivers granted by the U.S. government that meet Section (a)(2) of Act 44's expiration clause."
 

--

In 2014, KOC Holding was added to the Pennsylvania Treasury's List of Scrutinized Companies Determined as Having Involvement in Iran because its the parent of a scrutinized company.

-- 

Turkish energy firm Tupras is a subsidiary of Koc Holding.

--

"The United States has pressed Turkey to follow up on a 20 percent cut in oil purchases from Iran with a further cut in six months time to help persuade Iran to quit stalling in talks over its nuclear program, a U.S. diplomat said on Tuesday. The diplomat said Washington granted Turkey a 180-day exception from financial sanctions as a result of the initial cut made by Tupras, Turkey's sole refiner and a unit of Koc Holding." (Reuters,"U.S. presses Turkey to cut more Iranian oil imports," 6/12/12) 

• “Iran stopped exporting natural gas to Turkey after Bootash Natural Gas Co. requested a halt in supply, the Iranian Oil Ministry news website reported, citing the head of public relations for the National Iranian Gas Co. Gas exports from the Bazargan facilities was cut off at 11 p.m on Sep. 22, Majid Bojarzadeh said, according to the website, Shana. Turkey’s Bootash Natural Gas said it wanted to examined the pipeline and repair ‘probable defects’ in the export link, the report cited him as saying.” (Bloomberg, "Iran Stops Gas Exports to Turkey Due to Pipe Repairs" 9/26/2011)

As of December 2020, Rhode Island continues to list Gubretas an Iran scrutinized company for active involvement of at least $50 million in Iran's energy sector. Gubretas maintains a 48.88 percent controlling interest in the Iran-based Razi Petrochemical Co.

--

As of July 2020, Gubre remains on 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. 

--

Gubre Fabrikalari is listed on the 4Q 2020 Minnesota State Board of Investment List of Unauthorized (Scrutinized) Iran Companies.

--

In 2020, the U.S. state of Mississippi listed Gubretas on its state lists of Companies Doing Business with the Iranian Petroleum/Natural Gas, Nuclear and Military Sectors, rendering it ineligible for investment and/or state contracting.

--

On January 20, 2020, Minnesota SBI listed Gubretas as a scrutinized investment. The managers are explicitly instructed to refrain from purchasing securities on this list.

--

As of October 2019, Gubretras remains on 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. 

--

On March 13, 2019, the Mississippi Department of Finance & Administration identified Gubretas as a company “engaged in investment activities in Iran, providing funds, goods or services valued at $20,000,000 or more in the energy sector of Iran.

--

Gübretaş subsidiary RaIntrade Petrochemical Co. (“RaIntrade”)3 – whose “core business segments” are “[a]mmonia, fertilizers, [and] petrochemicals” – apparently trades Iranian-origin petrochemical products, notably from the Razi Petrochemical Complex at the Iranian port of Bandar Imam Khomeini. LPG Tanker GAS CAT (IMO: 8818843) recently transported sanctioned petrochemical products apparently supplied by RaIntrade from the Razi Petrochemical Complex arriving at Port of Dahej, India on January 27, 2019... According to the RaIntrade Website, RaIntrade is the “exclusive global marketer of Razi Petrochemical Co. Products.” Moreover, Razi Petrochemical Co. is itself a subsidiary of Gübretaş, according to the 2015 Annual Report of RaIntrade’s ultimate parent, Gübretaş.

--

According to the GÜBRETAŞ webpage, GÜBRETAŞ also has a big fertilizer production complex in Iran, with rich natural gas resources. Ammonia, urea and phosphoric acid can be produced in the facilities of this complex.

--

In 2017 the U.S. state of Minnesota, Pennsylvania, Mississippi, Rhode Island, South Carolina, and Tennessee listed Iran on its restricted companies list rendering Gubretas ineligible for investment and/or state contracting.

--

In 2016 Tennessee used the South Carolina list of "Entities Ineligible to Contract with the State of South Carolina or any Political Subdivision of the State per the Iran Divestment Act of 2014, S.C. Code Ann." as its list of persons it determines engage in investment activities in Iran. Gubretras was included on this list in 2016. "Inclusion on this list would make a person ineligible to contract with the state of Tennessee, if a person ceases its engagement in investment activities in Iran, it may be removed from the list."

In 2018 Tennessee used the New York list of “Entities determined to be non-responsive bidders/offerers pursuant to the New York State Iran Divestment Act of 2012.” BPCL was included on this ist in 2018. Tennessee states "Inclusion on this list would make a person ineligible to contract with the state of Tennessee, if a person ceases its engagement in investment activities in Iran, it may be removed from the list."

--

Gubretas, full name Gubre Fabrikalari TAS, is a Turkish chemical fertilizer company, and describes itself as "one of the biggest industrial corporations in Turkey." In addition to manufacturing and trading all types of fertilizer, it also provides port service to assist in their transportation and export (Company Website).

--

"Turkish hotels and travel agents reported a sharp jump in bookings from Iranian tourists this week while traders in Istanbul's famed bazaar said more Iranian businessmen have been buying Turkish goods in bulk to sell back home. The pickup in activity immediately after Iran won relief from international sanctions in a nuclear agreement over the weekend signaled that Turkey's slowing economy may be among the first to reap economic benefits from the deal. Companies and merchants anticipate the once-burgeoning trade between the neighboring countries will thrive again…The nuclear agreement also allows Iran to resume exporting and importing some gold and precious metals—an industry that could generate $1.5 billion in government revenues for Tehran, according to the U.S. It also suspends some sanctions on auto and petrochemical exports…For Turkish companies with operations inside Iran, the interim deal is already bringing benefits. Turkish fertilizer producer Gubre Fabrikalari, or Gubretas, which has a 49% stake in the Razi Petrochemical Company, Iran's largest fertilizer production facility, saw its stock rise as much as 7.3% after the deal was announced. 'The deal is definitely positive for us. We used to experience logistical problems when transferring our products due to petrochemical sanctions,' said Huseyin Karakus, investment-relations manager at Gubretas. 'We're already seeing our operation costs decline and we hope money transfers will be easier.'" (Wall Street Journal, "Turkey Expects Boon to Trade With Iran from Nuclear Deal Easing Sanctions," 11/28/13)

--

In 2011, Gubretras 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.

--

In February 2011, Gubretas's chairman revealed that the company had been approached by Iranian companies for advice in evading US banking restrictions. Bloomberg reported that this solicitation concurred with Gubretas's plans to add 1 million tons of production capacity at its Iranian fertilizer plant.

As of August 2021, AK Makina is listed on the US State of New York's list of Entities determined to be non-responsive bidders/offerers pursuant to The New York State Iran Divestment Act of 2012.

--

In January 2021, the State of New Jersey Department of the Treasury listed AK Makina as a company engaged in prohibited activities in Iran pursuant to P.L. 2012, c. 25 ("Chapter 25"). 

--

As of October 14, 2020, AK Makina remained on the Tennesse Department of General Services list of persons it determines engage in investment activities in Iran, as described in 12-12-105.

--

In 2020, the U.S. state of Mississippi listed AK Makina on its state lists of Companies Doing Business with the Iranian Petroleum/Natural Gas, Nuclear and Military Sectors, rendering ADKL ineligible for investment and/or state contracting.

--

As of July 1, 2020, Ak Makina is listed as an entity “determined, based on credible information available to the public, to be engaged in prohibited activities in Iran pursuant to P.L. 2012, c.25 (“Chapter 25”).  

--

As of June 8, 2020, Ak Makina is listed on the Pennsylvania Department of General Services Iran Free Procurement List. Entities included on this list are ineligible to enter into a contract with the Commonwealth of Pennsylvania for goods and services worth at least $1,000,000 per sections 3501-3506 of the Commonwealth Procurement Code, 62 Pa. C.S. §§ 3501-3506.

--

As of April 15, 2020, Ak Makina is included on the Tennessee list of persons it determines engage in investment activities in Iran, as described in § 12-12-105. 

--

As of April 15, 2020, Ak Makina is included as an entity determined to be non-responsive bidders/offerers pursuant to The New York State Iran Divestment Act of 2012.  

--

In 2018 and 2019 Tennessee used the New York list of “Entities determined to be non-responsive bidders/offerers pursuant to the New York State Iran Divestment Act of 2012.” AK Makina was included on this list in 2018 and 2019. Tennessee states "Inclusion on this list would make a person ineligible to contract with the state of Tennessee, if a person ceases its engagement in investment activities in Iran, it may be removed from the list."

-- 

In 2019, the U.S. states of Mississippi, Pennsylvania and New York listed AK Makina on their state lists of Companies Doing Business with the Iranian Petroleum/Natural Gas, Nuclear and Military Sectors, rendering Ak Makina ineligible for investment and/or state contracting.

--

In 2017, the U.S. states of Mississippi, Pennsylvania and New York listed AK Makina on their state lists of Companies Doing Business with the Iranian Petroleum/Natural Gas, Nuclear and Military Sectors, rendering Ak Makina ineligible for investment and/or state contracting.

--

AK Makina is a Turkish mechanical company that trades in machinery from such manufacturers as Hyundai-Kia, Hyundai Heavy Industries, LG, and others (Company Website). 

---

A leaked US diplomatic cable shows that Ak Makina has been attempting to export machinery to an Iranian company, Shahid Hemmat Industrial Group, that has been developing a liquid missile propellant for the Iranian nuclear program. Despite American requests to the Turkish government to stop the transaction, it appears that Ak Makina has not cut their ties with Iran (Aftenposten, Turkish Firm Ak Makina Continued Assistance to Missile-Related Entities in Iran, 6/26/2009). 

Karsan Otomotiv is Turkey’s only multi-branded commercial vehicle producer. Karsan’s website notes that it “makes the production of Peugeot Partner under Peugeot license, Hyundai HD 35/75 under Hyundai license, Renault Trucks Premium Uzunyol, Premium Lander and Kerax under Renault Trucks license, Citroen Berlingo under Citroen license and J9 Premier under its own brand.” Karsan was ranked 267^th in the list of “Turkey’s Top 500 Industrial Organizations” in 2008. (Company Website)

--

On March 9, 2011, following extensive discussions, UANI announced that Karsan had ended its business in Iran. Karsan had demonstrated that it had withdrawn from Iran and committed to foregoing any business in Iran until such time as Iran fulfills its obligations to the international community related to its illegal nuclear program. (UANI, "UANI Applauds Turkish Company Karsan for Ending Its Business in Iran," 3/9/11)

--

Karsan entered into a five-year exclusive distribution agreement in 2007 with Iran’s Sanat Khuodro Kamau to export J9 minibus models to Iran. (Karsan Report, May 10, 2007)

 --

A Karsan company report on February 15, 2008, notes that the company “signed a contract to export J9 Premier to Iran, which will be sold to some Middle East countries via Iran.”

--

A July 2010 press release indicated that the updated J10 model would be sold in Iran, Syria, and African countries. (Press Release)