Sweden

Ludden Inc. is a Sweden-based consulting firm offering "senior consultancy services for projects involving HD engines and vehicles, alternative fuels, and diesel (Company Website). 

Ludden's website advertises various management projects in Iran, including bus and truck engine installations and natural gas engine conversions. 

The AF Group is an engineering consultancy firm, with over $708 million in net sales in 2009. The AF Group advertises its services for "industrial processes, infrastructure projects and the development of products and IT systems." It has approximately 4,000 employees and its business base is in Europe (Company Website). 

In 2007, the AF Group acquired Swiss energy consulting company Colenco, establishing a strong foothold in the energy industry. Colenco maintains a strong presence in Iran, establishing a representative office in 2004 to construct a power plant in Iran. This project is detailed on the company's website, where Colenco also notes that it "anticipates a long term commitment to the development challenges of Iran."

"This license authorized Ekman & Company, which manufactures a paper product used in goods like diapers and sanitary napkins, to sell its products in Iran." (New York Times, "Licenses Granted to U.S. Companies Run the Gamut," 12/24/10)

• Conducts business with U.S. banks and Iranian banks ("Iran's Dirty Banking", Avi Jorisch)

Noted for conducting business in Iran with U.S banks. (Avi Jorisch, "Iran's dirty banking," 2010)

Skanska is a large Swedish construction and property development company. It is one of the world's ten largest construction companies, with revenue of $18.69 billion in 2009 (Annual Report). 

In 2002, the company issued a press release with the headline, "Cementation Skanska gets green light on Iranian mine contract." 

"As part of the settlement [with US Treasury Department], Alfa Laval Middle East agreed to implement sanctions compliance measures for five years and provide annual certification to OFAC that the measures have been implemented." (Compliance Week, "Alfa Laval subsidiaries fined $430K for Iran sanctions violations," 7/20/21)

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According to a Settlement Agreement with the US Treasury Department signed April 28, 2021, the "OFAC determined that AL [Alfa Laval] Middle East [a subsidiary of Alfa Laval AB] committed one apparent violation of § 560.203(a) of the Iranian Transactions and Sanctions Regulations, 31 C.F.R. part 560 (“ITSR”) by causing a U.S. person, Alfa Laval Inc. (“AL U.S.”), to violate § 560.204 of the ITSR by exporting $18,585 worth of U.S.-origin goods indirectly to Iran on or about March 26, 2016. 

Additionally, AL Middle East committed one apparent violation of § 560.203(b) of the ITSR in forming a conspiracy with two Iran-based firms and one Dubai-based company to cause a U.S. person to violate § 560.204. This conspiracy took place from on or about August 8, 2015 to on or about May 5, 2016 and involved conduct relating to an export worth $18,585 described above, an incomplete export transaction worth $5,170, and future contemplated transactions worth $181,453.

[Alfa Laval agreed to] pay or arrange for the payment to the U.S. Department of the Treasury the amount of $415,695."

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Alfa Laval website lists a head office in Tehran, Iran.

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Alfa Laval is a Swedish technology company that provides industrial equipment for the energy, chemical, metal, food, and beverage industries. It has a strong US presence and had over $3.3 billion in revenue in 2009 (Company Annual Report). 

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Alfa Laval sells its products in Iran through an Iranian website, in addition to maintaing an office in Tehran (Iranian Website). Through this site, Alfa Laval makes available many products that have a known application in the nuclear energy industry. For example, Alfa Laval advertises the benefits of installing its plate heat exchangers in nuclear power plants.

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The company discloses in its annual report that it has paid at least $632,911 in salary to employees in Iran since 2007 (Company Annual Report)

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Alfa Laval's has deep commercial ties with the U.S. government. Since 2000, Alfa Laval has received over $40.4 million in US government contracts. $35.8 million of these contracts were awarded by the Department of Defense (USA Spending). 

"The company has been identified as potentially providing telecommunications services in Iran. Summary of Status Change from 2019 report - CalPERS has commenced the review process to determine whether the company meets the threshold criteria for consideration under the Act."

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Ericsson appears as a customer on the website of the Iranian telecommunications firm Paya Communications Industries. 

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According to its Annual Report filed with the SEC for fiscal year 2019: "Due to its operations in Iran, and having staff permanently in the country, Ericsson has contacts with its local customers and retains certain local suppliers, including banks, and service providers. In addition, Ericsson has other dealings incidental to its local activities, such as making payments for taxes, salaries, rents, utilities and office and similar supplies as well for local accommodation and transportation and customs related services. As a result, Ericsson has contact with companies and public functions that may be owned or controlled by the government of Iran. While Ericsson seeks to obtain information regarding the actual business names and ownership of customers and other counterparties in Iran through its policies and procedures designed to ensure that Ericsson “knows its customers”, it is challenging to determine ownership and control with certainty, particularly with respect to determining whether an entity engaged in commercial activities is owned or controlled by the government.

During 2019, Ericsson sold communications infrastructure related products and services in Iran to the following telecommunications companies operating in the country: Mobile Communication Company of Iran (“MCCI”), and MTN Irancell. During 2019, Ericsson’s gross revenue (reported as net sales) related to sales to MCCI and MTN Irancell in Iran was approximately SEK 908 million.

In some instances, Ericsson has had to arrange performance bonds or similar financial guarantees to secure Ericsson’s performance of obligations under the commercial agreements Ericsson has entered into relating to the business in Iran. In such instances, Ericsson usually engages its banks outside Iran, who in turn engage local banks in the country. These local banks include Tejarat Bank, Melli Bank, Parsian Bank and Saderat Bank. Although some bonds and guarantees are still in place, no new performance bonds or similar guarantees involving these four banks with respect to Ericsson’s business activities in Iran were issued during 2019.

During 2019, existing bank guarantees issued by Maskan Bank, Parsian Bank, Post Bank of Iran and Tejarat Bank (local banks in Iran) to secure Iranian customer payment obligations to Ericsson were renewed. Further, some payments made to Ericsson’s local subsidiary and payments required to be made by the local subsidiary to suppliers involve banks that may be controlled by the government of Iran."

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According to its Annual report filed with the SEC for fiscal year 2018:"Ericsson has conducted business in Iran/Persia since the late nineteenth century, opened an office in Iran in 1973 and later established a local subsidiary in the country. Ericsson strongly believes in enabling communication for all and believes that access to communications can enable the right to health, education and freedom of expression. Ericsson’s business activities in Iran principally involve the sale of communications infrastructure related products and services, including support, installation and maintenance services. Ericsson’s exports from the European Union (the “EU”) to Iran are performed under export licenses from the Swedish Agency for Non-Proliferation and Export Controls and in compliance with applicable economic sanctions and export controls. Ericsson has conducted business in Iran/Persia since the late nineteenth century, opened an office in Iran in 1973 and later established a local subsidiary in the country. Ericsson strongly believes in enabling communication for all and believes that access to communications can enable the right to health, education and freedom of expression. Ericsson’s business activities in Iran principally involve the sale of communications infrastructure related products and services, including support, installation and maintenance services. Ericsson’s exports from the European Union (the “EU”) to Iran are performed under export licenses from the Swedish Agency for Non-Proliferation and Export Controls and in compliance with applicable economic sanctions and export controls.During 2018, Ericsson sold communications infrastructure related products and services in Iran to the following telecommunications companies operating in the country: Farabord Dadehavare Iranian (“Farabord”) (relating to purchase orders received before May 2018), Mobile Communication Company of Iran (“MCCI”), and MTN Irancell. During 2018, Ericsson’s gross revenue (reported as net sales) related to sales to Farabord, MCCI and MTNIrancell in Iran was approximately SEK 990 million. Since the US withdrawal from the JCPOA, Ericsson is winding down its business and organization significantly but still continues to provide the two main mobile carriers, MCCI and MTN Irancell with support critical for the network to function and to fulfill engagements with these carriers entered into before May 8, 2018." (SEC Disclosure,  3/29/2019)

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Since the United States has withdrawn from the Joint Comprehensive Plan of Action (“JCPOA”), it is generally more difficult to do business in Iran. Ericsson is exploring, including with EU and US authorities, whether and how the disruptive impact on our ability to maintain and support existing networks of our customers can be minimized. (Ericsson Annual Report 2018).

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Ericsson's business in Iran is detailed in its 2017 Annual Report filed with the SEC. 

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"Iran’s second largest mobile operator, MTN Irancell, and Sweden’s Ericsson jointly conducted a test of 5G connection in Tehran over the weekend." (9/23/2017)

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Ericsson's business in Iran is detailed in its 2016 Annual report filed with the SEC. 

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Listed as an approved vendor in Iran by NPC, POGC, NIGCENG, NISOC and NIGC.

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Ericssons business in Iran is detailed in its 2015 Annual Report filed with the SEC. 

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"Sweden’s biggest companies and banks, including telecommunications firm Ericsson AB and truck and bus producer Scania AB, want to invest in Iran if economic sanctions are lifted following its nuclear agreement with world powers.Ericsson spokeswoman Karin Hallstan said in an e-mail that the company has had customers in Iran “for over 100 years” and plans to “explore opportunities” with new ones as it monitors developments following the nuclear deal." (Bloomberg, "Ericsson, Scania Head Sweden's Interest in Post-Sanctions Iran," 10/21/2015).

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Ericsson explains its business in Iran in its 2013 Annual Report filed with the SEC.

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The Ericsson website lists an office in Tehran. (Company website)

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“Ericsson has published its 21(st) Sustainability and Corporate Responsibility report summarizing its performance during 2013…In light of recent international developments related to Iran, Ericsson has decided not to phase out equipment deliveries. The intention is to engage with customers. At the same time the Sales Compliance Board decided to conduct a new Human Rights Impact Assessment based on this foundation.” (Wall Street Journal, “Ericsson Emphasizes Responsible business, energy and Technology for Good in 2013,” 4/11/14)

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"Susan Rice, the U.S. Ambassador to the United Nations, has been under fire recently for, among other things, her investments in energy companies doing business in Iran, per a Washington Post story last week (http://bit.ly/121UkWg). But Rice also has had a stake in Ericsson, the Swedish mobile network equipment maker that has itself been in the spotlight for its growing business dealings in Iran. According to a Reuters report, Ericsson has been helping Iranian mobile telecom operators as part of long-term contracts, including one that involves an expansion project for Mobile Communications Inc. of Iran, the country’s largest mobile network provider (http://reut.rs/WhGryD). Iranian human rights groups say the Iranian mobile phone network is used to track and monitor dissidents and United Against Nuclear Iran has called for Ericsson to end its business relations with MTN Irancell, the country’s second-largest mobile network firm." (Politico, "Rice Investments In Businesses Working With Iran," 12/7/12)

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"The Swedish firm Ericsson is working with Iran's largest mobile telecom operator to expand its network and has promised to support another Iranian mobile carrier until 2021, according to interviews and an internal company document. The involvement of Ericsson, the world's largest mobile network equipment maker, comes at a time when many Western companies have stopped doing business in Iran because of international sanctions or concerns about damage to their reputations. While Ericsson argues in the internal document that telecommunications are a "basic humanitarian service," Iranian human rights groups say Iran's regime has used the country's mobile-phone networks to track and monitor dissidents. Though standard telecommunications equipment does not fall under sanctions, four major equipment makers, including Ericsson, have all said they plan to reduce their Iranian business... Fredrik Hallstan, a spokesman for Ericsson, confirmed the company is currently working on a new expansion project for Mobile Communication Co of Iran (MCCI), but said the venture, which the carrier calls Phase V, is covered under a contract Ericsson signed in 2008... He declined to discuss the nature of the work Ericsson is undertaking, its value or how the company will be paid... Hallstan said Ericsson's promise to continue supporting a second Iranian mobile operator, MTN Irancell, for many years falls under a 2006 contract. MTN Irancell is Iran's second largest mobile carrier. The sensitivity of Ericsson's work in Iran is made clear in a letter written by an executive of the company. On January 19, an Ericsson vice president wrote to MTN Group, a South African company that holds a 49 percent stake in MTN Irancell. In a letter marked confidential, the executive stated that Ericsson undertakes 'to not take actions that could unnecessarily bring any extra press scrutiny and that could potentially destabilize the working arrangements in Iran,' according to a copy reviewed by Reuters. The letter confirmed that Ericsson intends to 'continue supporting the MTN Irancell operation and future network expansions ... based on Ericsson's existing supply contracts ... as long as it is feasibly possible to do business in Iran.'... And it stated Ericsson would continue working with 'relevant international organizations to argue that telephony is a basic humanitarian service.' The letter concluded: 'Ericsson is looking forward to supporting MTN and strengthening our relationship by working closely together to resolve any practical obstacles and challenges facing the MTN Irancell business.' The executive, who at the time of the letter was in charge of Ericsson's business with MTN, did not respond to a request for comment. MTN declined to comment. Hallstan said the letter 'is correct' in that Ericsson will continue to support MTN Irancell under an agreement it signed in 2006 when the mobile operator launched." (Reuters, "Ericsson helps Iran telecoms, letter reveals long-term deal," 11/20/2011)

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Ericsson details its business in Iran in its 2012 Annual Report filed with the SEC. 

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"The Swedish government is trying to prevent the European Union from imposing further sanctions on Iran for fear of losing a lucrative deal for Swedish communications company Ericsson, according to a Foreign Ministry official in Jerusalem... 'We know that in Sweden they fear that if the deal between Ericsson and Iran is canceled this could have implications for the company's other deals,' the Foreign Ministry official said. 'The Swedes fear that other countries with problematic human rights records such as China will hear about the cancellation and worry about their ties with Ericsson.'" (Haaretz, "Fearing loss of lucrative deal, Sweden opposes new Iran sanctions," 10/14/2012)

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"Stockholm-based Ericsson AB, Creativity Software Ltd. of the U.K. and Dublin-based AdaptiveMobile Security Ltd. marketed or provided gear over the past two years that Iran's law enforcement or state security agencies would have access to, according to more than 100 documents and interviews with more than two dozen technicians and managers who worked on the systems... Ericsson and Creativity Software offered technology expressly for law enforcement use -- including a location- monitoring product proposed by Ericsson in early 2009 and one sold this year by Creativity, according to the interviews... Ericsson, the world’s largest maker of wireless networks, confirmed that in the fourth quarter of 2009 it sold a mobile- positioning center for customer billing purposes to MTN Irancell Telecommunications Services Co., Iran’s second-largest mobile provider... When Iranian security officers needed to locate a target one night in late 2009, one former Ericsson employee says he got an emergency call to come into the office to fix a glitch in an Ericsson positioning center... Ericsson says it will continue to maintain the system, but that it decided in October 2010 it would no longer sell any products into Iran due to recent efforts to tighten sanctions... AdaptiveMobile, backed by the investment arm of Intel Corp. (INTC), proposed a system in partnership with Ericsson for Iran’s largest mobile provider in 2010 that would filter, block and store cell phone text messages, according to two people familiar with the discussions. An Ericsson spokesman confirmed the proposal... Ericsson, which bid on the system, was told by MCI, the country’s largest wireless operator, to partner with AdaptiveMobile for monitoring and filtering technology, according to Ericsson spokesman Fredrik Hallstan. Ericsson didn’t win the contract, he says... Ericsson, the telecommunications giant with $28 billion in sales last year, in 2008 supplied Irancell with its Mobile Positioning System 9.0 for locating subscribers -- a test system that Ericsson says Irancell didn’t buy and could use only on a limited scale... Ericsson later sold Irancell the positioning-data component of the test system, says Richard Carter, Ericsson’s Istanbul- based head of commercial, sourcing and partnering in the Middle East and the country manager for Iran. It was sold in late 2009, the company confirmed. Known as a Serving Mobile Positioning Centre, the box calculates a person’s position and logs the data... The former Ericsson employee urgently called in to fix the system in late 2009 says he was told that Iranian intelligence officers were attempting to pinpoint the location of someone in the Zahedan area of southeast Iran... A former Irancell manager said that all such systems supplied to the mobile operator, including technology from Ericsson, were accessible by law enforcement agencies... The former Ericsson employee urgently called in to fix the system in late 2009 says he was told that Iranian intelligence officers were attempting to pinpoint the location of someone in the Zahedan area of southeast Iran... Before the election, on January 24, 2009, Ericsson officials pitched a tracking system specifically for Iran’s security agencies to MCI, according to a seven-page agenda and another document describing the Tehran meeting... Law enforcement agents would be able to track subscribers with 'easy and friendly' identification of geographic positions on a map, according to Ericsson’s 51-page proposal to MCI, which serves 44 million subscribers... The system Ericsson proposed offered capabilities for law enforcement referred to as “PoLIS” that would allow the interception of all phone calls occurring in a specific area, among other features, according to a copy of the proposal... Ericsson would have partnered with an Estonian software firm, Reach-U, whose tracking software 'is designed for state security agencies,' according to one of the documents in the proposal... Ericsson’s Carter says the discussions with MCI were preliminary and came to a halt as turmoil swept the country in 2009. He couldn’t find any reference to PoLIS features, he says... Everything supplied by Ericsson to Iran complied with international trade embargoes, Carter says, adding that their products have been a positive force in the Middle East by promoting communications and commerce. 'Ultimately, telecom is a force for good in society,' he says... Siavash Fahimi, an Ericsson employee, saw up close how these systems can be abused. The 27-year-old Iranian worked for Ericsson in Tehran until 2010, installing several different systems. Police arrested him on the outskirts of a rally that December, beating him with fists and a baton and jailing him for 52 days. Security agents interrogated him 14 times, presenting transcripts of text messages plus an elaborate diagram showing all the people he’d called -- and then everyone they’d called... Fahimi, who fled to Turkey after receiving a two-year prison sentence for his role in the protests, can’t be sure that Ericsson technology aided his interrogators, but he is familiar with the capabilities of these types of systems... As recently as 2010, AdaptiveMobile attempted to sell a similar product to MCI, the one on which it partnered with Ericsson... According to data compiled by Bloomberg, Ericsson signed at least 27 contracts worth $5.25 million with the U.S. government from the start of 2009 to the end of 2010. The data showed no U.S. government business with AdaptiveMobile or Creativity Software." (Bloomberg, "Iranian Police Seizing Dissidents Get Aid Of Western Companies" 10/30/2011)

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"Prior to Iran's political unrest in 2009, Huawei was already a major supplier to Iran's mobile-phone networks, along with Telefon AB L.M. Ericsson and Nokia Siemens Networks, a joint venture between Nokia Corp. and Siemens AG, according to MTN Irancell documents... A spokesman for Ericsson said it delivered 'standard' equipment to Iranian telecom companies until 2008, which included built-in lawful-interception capabilities. 'Products can be used in a way that was not the intention of the manufacturer,' the spokesman said. He said Ericsson began decreasing its business in Iran as a result of the 2009 political upheaval and now doesn't seek any new contracts." (The Wall Street Journal. “Chinese Tech Giant Aids Iran,” 10/27/11)

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"Nobel Peace laureate Shirin Ebadi on Monday accused Swedish telecoms giant Ericsson of aiding monitoring in Iran, and encouraged members of the Iranian diaspora in Sweden to protest to the company.

"I am urging you Iranians in Sweden to please email Ericsson and object and say, 'Why are you selling the Iranian government software with which it can control its people'," the lawyer and human rights activists said.

Ebadi, who was speaking at Stockholm University, said Ericsson had entered dealings with the Iranian government similar to those Nokia Siemens previously had, alleging the company sold Iran software that allowed it to monitor text messages and mobile phone calls." (AFP, "Nobel laureate accuses Ericsson of aiding monitoring in Iran," 11/22/10)

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"Ericsson's Web site lists an office in Tehran. Among other things, it has sold communications equipment to the Department of Defense." From 2000-2009 the company has been the recipient of $119 million US federal funds.  Their activity in Iran is currently active. (The New York Times, "Profiting from Iran, and the US," 3/6/2010)

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"Saber Feyzi, managing director of TCI said sanctions havent stopped IT providers from selling to Iran as contracts for equipment such as switches and transmission and radio systems show. Companies including Siemens, Nokia , Eriksson, Alcatel-Lucent, Cisco Systems, Telaps, NEC, ZTE, Huawei Technologies Co and Wuhan Research Institute have all supplied the Islamic republic. Iranian officials have dismissed US sanctions as inefficient, saying that they are finding Asian partners instead. Several Asian firms are negotiating or signing up to deals with Iran." (Gulf Times, "IRAN TELECOM CO TO OFFER 50% STAKE BY MARCH," 1/14/09)

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"While U.S. companies have long been barred from operating in Iran, more than 200 multinationals have investments there, from British-Dutch oil giant Royal Dutch Shell PLC and French telecommunications-equipment company Alcatel SA to Swedens electronics company Telefon AB L.M. Ericsson." (The Wall Street Journal, "Should states sell stocks to protest links to Iran," 6/14/07)

"We have banned sales to and have no operational sites or employees in Iran. Previous to May 2018, certain limited sales were made in accordance with international agreements and sanctions." (Atlas Copco website)

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Atlas Copco is listed on the March 1, 2022 report to the New Jersey Legislature Iran Divestment as a prohibited company.

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Atlas Copco, headquartered in Nacka, interrupts its business with Iran. 
This, according to President Trump's message that the United States imposes sanctions on the country. "We have been following developments continuously and have made this decision," said Sara Liljedal, Press Manager at Atlas Copco. (Nackajätte bryter med Iran (Trump Effect – Nacka giant breaks with Iran),” Mitti (Sweden), August 7, 2018.) 

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In 2017, the U.S. state of Iowa listed Atlas Copco on its state lists of Companies Doing Business with the Iranian Petroleum/Natural Gas, Nuclear and Military Sectors, rendering Atlas Copco ineligible for investment and/or state contracting.

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According to the Atlas Copco website, “Atlas Copco has appointed a distributor and will use this company as a vehicle for expansion on the Iranian market.”  Atlas Copco Website, “Complex markets: Iran”

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"Atlas Copco has had a branch in Iran for the past 30 years, according to Senior Vice President Hans Sandberg. The company primarily sells compressors, mining and construction equipment and services there, with sales of about $15 million to $20 million a year, he said. The company has received contracts from several United States federal agencies, including the Fish and Wildlife Service to the Department of Defense."  The company received $9.2 million in benefits and revenue from the US government for their investments in Iran, during 2000-2009.  Their business in Iran is currently active. (The New York Times, "Profiting from Iran, and the US," 3/6/2010)

The Iranian Tamkar Gas Equipment Company states on its website that it and a consortium of foreign companies, including Swiss GreenField and German MAN group, signed a contract in 2003 to provide equipment for 57 compressed natural gas refueling stations. According to Tamkar's website, the company is manufacturing the CNG refueling stations under GreenField's license. GreenField notes on its website that it was purchased by Atlas Copco in March 2007 and continues to operate within the Atlas Copco family.

In 2005, another company, Intermech Ltd. was acquired by Atlas Copco South Pacific Holdings Pty Limited of Australia. Through its relationship with Atlas Copco, the company lists an office in Tehran on its website.

According to the government of New Zealand, Intermech Ltd. and Iranian Pars Compressor Co. won a $20 million joint contract in August 2003 from the Iran Fuel Consumption Optimization Organization to build CNG refueling stations throughout Iran. According to a company press release, Intermech shipped 25 packages of equipment to Iran in April 2009; the "order was a follow up after the first successful shipment of 50 packages in 2008."

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Atlas Copco has an Iran portal and lists that it has an office in Tehran, Iran on its company website.