Electronics

"The [Iranian] government has put a wholesale ban on imports of home appliances from South Korea, and is gearing up to apply bans on other foreign products. On September 29, Supreme Leader Ayatollah Ali Khamenei instructed President Ebrahim Raisi to ban the importation of home appliances, specifically from “two South Korean firms” which he didn’t name, reportedly to stave off the insolvency of domestic manufacturers. Yet there is no certainty that by ejecting Samsung and LG, it will be the South Korean corporations that will be at a loss. Instead, Iranian consumers are already peeved that the government has stripped them of credible options for their choice of domestic appliances, and they are now discovering that low-quality, inefficient homemade products are an inevitability for the foreseeable future." (Asia Times, "Iran bans goods from South Korea’s Samsung and LG," 11/29/21).

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According to the Republic of Korea Embassy in Iran's website, "Representatives from Samsung Electronics, LG Electronics, SK Networks and DL E&C, among others, attended [a] meeting [in Iran], and discussed the outcome of the recent visit of the Korean Prime Minister to Tehran, and shared the companies’ business activities as well as ways to promote the bilateral economic relationship between Korea and Iran." (4/18/21).

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On Friday, referring to the two Korean giants Samsung and LG that have left the Iranian market under the pressure of the U.S. sanctions, Iran's Foreign Ministry Spokesman said it would be much more difficult to return later for those who were "strong-armed by the United States to leave". Iran was a key market for the products of the two South Korean companies including TV and audio sets, home appliances, air conditioners and mobile phones....Both companies assembled some of their products in Iran but cut down on providing products and parts to Iran and have now completely stopped. In his tweet on Friday which came with a photo of workers pulling down a Samsung banner, Mousavi said that Iranians will "not forget friends who stand by their side at times of hardship". The two companies which stopped selling to Iran two years ago under the pressure of sanctions had not stopped their advertising in Iran. 

Samsung, like most other leading brands, stopped directly selling smartphones to Iran when the sanctions began. Samsung was officially represented in Iran and used to run after-sales service centers in major cities.

However, illegally imported smartphones of various brands such as Samsung and Apple are still quite abundant in the market." (Radio Farda, "Iran Warns Korean Giants Forced By Sanctions Not To Leave Market," 2/15/2020).

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LG Engineering is listed by the Iranian firm, Sazeh Consultants, as a “Participant” in the Borzooyeh Petrochemical Company project. (Sazeh Consultants Website, “About”).

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"Among Asian businesses rethinking their dealings with Iran are banks, oil companies and technology giants including Huawei Technologies Co., Lenovo Group, LG Electronics Inc. and Samsung Electronics Co. South Korean consumer-electronics giants Samsung and LG already have reduced exposure to Iran and are consulting with government officials in Seoul to determine whether they must withdraw from the nation entirely following the end of U.S. oil waivers, according to business people in Tehran who work with the companies. Iran had been financing purchases from both companies with funds generated from the sale of oil and crude-based products." (Wall Street Journal, "Asian Companies Pull Back From Iran Amid U.S. Pressure," 4/24/2019).

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Lists three sales subsidiary offices in Tehran, Iran on its company website. 

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In 2017 the U.S. state of Minnesota listed LG on its Iran restricted companies list rendering LG ineligible for investment and/or state contracting.

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"Iran Khodro Co., an automaker in Tehran, is in talks with LG International Corp. to develop electric vehicles for the Iranian market. 'Negotiations are under way,' said Hashem Yeke Zare, managing director of Khodro. The companies may clinch the deal in autumn, he said in an interview in Tehran. LG International, which is based in Seoul, would supply batteries and other components to the automaker and install charging stations. Khodro would make the cars. The partners aim to manufacture 60,000 vehicles by 2023. 'We are currently carrying out the plans to developing electric vehicles and to setting up charging infrastructure in Iran,' said an LG spokesman. The company declined to give further details before the deal closes." (Bloomberg, "Iranian Automaker in Talks with LG to Make Electric Vehicles," 6/29/2016)

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LG has a company website for Iran in Farsi.

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"Iran is in talks with three Japanese and South Korean oil and gas companies to invest in its oil and gas projects, Head of Investment Committee of the National Iranian Gas Company (NIGC) Asghar Soheilipour said. He said that Japan's Mitsubishi and South Korea's LG and Samsung are negotiating with NIGC to design, establish, and install gas refineries and pipelines, Iran's Mehr news agency reported on Jan. 13. Some Japanese and Italian companies have announced readiness to implement projects even before lifting the international sanctions, he noted." (Trend, "Iran in Talks with Japanese, Korean Oil and Gas Companies," 1/13/15)

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"Head of the investment committee of the Iran National Gas Company (INGC) Asghar Soheilipour said that his company was offering information about Iran's top priority gas projects to potential foreign and domestic investors... The official referred to Mitsubishi, LG and Samsung as corporations having announced readiness for making investments in Iran gas projects." (IRNA, "Official: Foreign firms eying investment in Iran gas industry," 1/3/15)

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In 2014, LG was removed from Pennsylvania Treasury's List of Scrutinized Companies Determined as Having Involvement in Iran due to a change in ownership.
 

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"In the electronics and home appliances sections, sales of LG and Sony flat-screen televisions come with attractive service plans and free home installations. Local brands, such as Pars, go mostly ignored." (The Washington Post, "Iran hopes to resist sanctions by boosting production," 10/27/2012) 

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"After being hit by European and U.S. sanctions, Iran's oil sales are stabilizing as the country entices buyers with attractive prices and a form of barter. But proposed new U.S. restrictions could further bite into its crude exports later this year . . . A form of barter set up by Iran provides an incentive to keep—or in the case of Seoul, to resume—its crude purchases. Faced with banking sanctions that impede its ability to receive crude proceeds and settle its bills for imported goods, the Islamic Republic increasingly gets paid into accounts based in the Asian countries where it sells the oil and in their local currency. Iranian traders then draw on the reserves to purchase goods exported to Iran. South Korean products are ubiquitous in Tehran—from smartphones made by Samsung Electronics Co. Ltd. to LG Electronics Inc. televisions and even costume dramas on local televisions; Iranian imports from the country amounted to $6 billion last year." (Wall Street Journal, "Iran Barters and Bargains to Help Oil Sales," 8/7/12)

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LG maintains a partnership with Fariran, an iranian security comapny. According to its website, Fariran has over fifty retailers in Iran, “and was founded with the purpose of importing, distributing and installing LG CCTV security systems in Iran.”  (Fariran Website, “About Us,” Accessed 8/6/2012) 

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LG surveillance equipment, including the LT903N(P) Speed Dome Camera, is clearly advertised for sale on the website of IRANCCTV. (IRANCCTV Website, “PTZ Speed Dome Camera,” Accessed: 8/6/2012) IRANCCTV is a regime entity that operates under the auspices of Iran’s Ministry of Culture, which has been described in the Iranian media as “a censorship agency” and “all-out mechanism of control and repression” that violently interrogates journalists and activists in Iran. (Reporters Without Borders, “While pointing finger at Bahrain, Iran uses culture ministry to interrogate journalists,” 5/24/2012)

"Samsung Electronics and LG Electronics accounted for a combined 30 percent of Iran's mobile phone market, Korean major newspaper Dong-a Ilbo reported in January." (Reuters, "South Korea may limit exports to Iran on payment concerns: sources," 5/17/2012)

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In 2011, LG was added to the Pennsylvania Treasury's List of Scrutinized Companies Determined as Having Involvement in Iran because of oil-related investment of US $20 million since 1996.
 

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"The lawmakers underlined a finding by the Congressional Research Service that 20 non-US firms may be in violation of the Iran Sanctions Act. They include Totalfina Elf of France; Italy's ENI; Bow Valley of Canada; the Netherlands' Royal Dutch Shell; Norsk Hydro of Norway; Russia's Lukoil; GVA Consultants of Sweden; Sheer Energy of Canada; LG of South Korea; Norway's Statoil; and Inpex of Japan." (AFP, “US lawmakers urge Obama to use Iran sanctions powers,” 10/21/09)

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"LG Electronics Inc. said Tuesday it has started producing handsets in Iran with a local partner. Production started this month, and the facility can make 1 million phones a year, LG spokeswoman Judy Pae said. Pae said she could not identify the Iranian partner or provide other details of the production arrangement or even the facility's location in Iran. Maadiran Group, which describes itself as Iran's leading technology and office automation company, said on its Web site in a Feb. 17 press release that it began producing five models of handsets under license from LG Electronics, the world's fifth-largest manufacturer of mobile phones . . . Pae said LG wants to be more competitive in the Middle East market, and the company plans to export the handsets to other countries in the region. In addition, by manufacturing in Iran, LG can avoid Iran's steep tax on imported handsets." (NBC News, "LG begins making mobile phones in Iran," 3/13/07)

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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)

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"According to "Tehran Times", Iranian authorized dealers of the audio-visual, air conditioning systems and cellular phones affiliated to the Goldiran Co. got together in the Islamic Republic of Iran's Broadcasting (IRIB) Hall of Conferences in Tehran. The party was thrown in honor of S.S. Kim, chief executive officer and Vice President of the LG Electronics. Kim who is also the chief executive officer of Korean LG Electronics Company and among the 20 top economic managers in the world has received many awards in different managerial fields." (InfoProd, “Iran: Senior Managers of LG Electronics Hold Meeting in Tehran,” 11/18/04)

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"Iran signed a $1.6 billion contract with South Korea's LG Construction Co. Ltd. to further develop its huge South Pars offshore gas field in the Gulf. With the signing on Sunday, LG took a 42 percent stake in the project. The remaining 58 percent is held by the state-owned energy firms connected to the National Iranian Oil Company." (Associated Press, “Iran, LG of South Korea sign $1.6 billion gas deal,” 9/16/02)

SonyIran has a website here. 

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According to its Annual Report filed with the SEC for fiscal year 2019: "Sony is aware that certain transactions during the fiscal year ended March 31, 2019, as described below, may be disclosable pursuant to Section 13(r) of the Exchange Act.

Sony does not customarily allocate net profit on a country-by-country or activity-by-activity basis, other than as set forth in Sony’s consolidated financial statements prepared in accordance with U.S. GAAP; thus, the net profit and loss described below are non-U.S. GAAP figures and are estimated solely for the purpose of preparing this disclosure pursuant to Section 13(r) of the Exchange Act. The information below is to the best of Sony’s knowledge, and in particular Sony may not be aware of all potentially reportable sales by third-party-owned dealers and distributors.

• During the fiscal year ended March 31, 2019, a non-U.S. subsidiary of Sony sold medical instruments, including medical printers, print media and monitors, to a third-party-owned dealer in Dubai, which, to the best of Sony’s knowledge, planned to resell those products to hospitals and health organizations in Iran, some of which are under the control of the Iranian Ministry of Health. Sony’s gross revenue from these sales was approximately 1.4 million U.S. dollars, and Sony has estimated that its net profit from such sales was 0.2 million U.S. dollars.
• Sony’s representative office in Tehran, Iran, which was established in 1992, has been closed and has been under liquidation processes since before the beginning of the fiscal year ended March 31, 2014. In the course of liquidation, Sony engages in certain incidental transactions (for example, permits, taxes, and similar matters incidental to the wind-down of the office in Iran) with Iranian government-owned entities. No material revenues or profits are associated with these transactions with the Iranian government-owned entities.

Sony is not aware of any other activity, transaction or dealing by Sony Corporation or any of its affiliates during the fiscal year ended March 31, 2019 that is disclosable in this report under Section 13(r) of the Exchange Act. As of the date of this report, Sony does not anticipate that any activity, transaction or dealing that may be disclosable will be conducted during the fiscal year ending March 31, 2020, except as described above in connection with the wind-down of its representative office in Iran. Nevertheless, Sony has continued to monitor developments in this area, especially in the light of the United States’ decision that was implemented in its entirety on November 5, 2018 to cease its participation in the Joint Comprehensive Plan of Action of July 14, 2015, among the United States, the United Kingdom, China, France, Russia, Germany, the European Union and Iran and re-impose certain secondary sanctions (i.e., laws and regulations that threaten to impose U.S. economic sanctions on non-U.S. companies engaging in specified transactions with Iran outside U.S. jurisdiction). Sony will determine whether and to what extent they affect Sony’s business with Iranian customers as currently conducted and may additionally be conducted. Such business activities may require disclosure pursuant to Section 13(r) of the Exchange Act. Sony intends to conduct any such business activities in accordance with applicable laws and regulations.

Sony believes, and maintains policies and procedures designed to ensure that, its transactions with Iran and elsewhere have been conducted in accordance with applicable economic sanctions laws and regulations and do not involve transactions likely to result in the imposition of sanctions or other penalties on Sony. However, there can be no assurance that Sony’s policies and procedures will be effective, and if the relevant authorities were to impose penalties or sanctions against Sony, the impact of such sanctions could be material."

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During the fiscal year ended March 31, 2017, a non-U.S. subsidiary of Sony sold medical instruments, including medical printers, print media and monitors, to a third-party-owned dealer in Dubai, which, to the best of Sony’s knowledge, planned to resell those products to hospitals and health organizations in Iran, some of which are under the control of the Iranian Ministry of Health. Sony’s gross revenue from these sales was approximately 5.7 million U.S. dollars, and Sony has estimated that its net profit from such sales was 0.4 million U.S. dollars.

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According to its Annual Report filed with the SEC for fiscal year 2016: "   

• During the fiscal year ended March 31, 2016, a non-U.S. subsidiary of Sony sold medical instruments, including medical printers, print media and monitors, to a third-party-owned dealer in Dubai, which, to the best of Sony’s knowledge, planned to resell those products to hospitals and health organizations in Iran, some of which are under the control of the Iranian Ministry of Health. Sony’s gross revenue from these sales was approximately 4.8 million U.S. dollars, and Sony has estimated that its net profit from such sales was 0.3 million U.S. dollars.
• Sony’s representative office in Tehran, Iran, which was established in 1992, has been closed and has been under liquidation processes since before the beginning of the fiscal year ended March 31, 2014. In the course of liquidation, Sony engages in certain incidental transactions (for example, permits, taxes, and similar matters incidental to the wind-down of the office in Iran) with Iranian government-owned entities. No material revenues or profits are associated with these transactions with the Iranian government-owned entities."

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According to its Annual Report filed with the SEC for fiscal year 2015: "Sony is aware that certain transactions during the fiscal year ended March 31, 2015, as described below, may be disclosable pursuant to Section 13(r) of the Exchange Act.

Sony does not customarily allocate net profit on a country-by-country or activity-by-activity basis, other than as set forth in Sony’s consolidated financial statements prepared in accordance with U.S. GAAP; thus, the net profit and loss described below are non-U.S. GAAP figures and are estimated solely for the purpose of preparing this disclosure pursuant to Section 13(r) of the Exchange Act. The information below is to the best of Sony’s knowledge, and in particular Sony may not be aware of all potentially reportable sales by third-party-owned dealers and distributors.

• During the fiscal year ended March 31, 2015, a non-U.S. subsidiary of Sony sold medical instruments, including medical printers and paper, to a third-party-owned dealer in Dubai, which, to the best of Sony’s knowledge, planned to resell those products to hospitals and health organizations in Iran, some of which are under the control of the Iranian Ministry of Health. Sony’s gross revenue from these sales was approximately 2.9 million U.S. dollars, and Sony has estimated that its net profit from such sales was 0.1 million U.S. dollars.       
• Sony’s representative office in Tehran, Iran, has been under liquidation processes and no longer engaged in any operation or activities other than the matters necessary for liquidation since before the beginning of the fiscal year ended March 31, 2014. In the course of liquidation, the office would engage in certain incidental transactions (for example, permits, taxes, and other similar matters incidental to the wind-down of the office in Iran) with Iranian government-owned entities. No material revenues or profits are associated with these transactions with the Iranian government.

Sony is not aware of any other activity, transaction or dealing by Sony Corporation or any of its affiliates during the fiscal year ended March 31, 2015 that is disclosable in this report under Section 13(r) of the Exchange Act. As of the date of this report, Sony does not anticipate that any activity, transaction or dealing that may be disclosable will be conducted during the fiscal year ending March 31, 2016, except as described above in connection with the wind-down of its representative office or for certain transactions through third-party-owned dealers that Sony believes to be intended for hospitals and health organizations in Iran. Nevertheless, in the future, Sony may conduct additional sales activities in Iran through third-party-owned dealers/distributors, which may require disclosure pursuant to Section 13(r) of the Exchange Act. Sony intends to conduct any such sales in accordance with applicable law."

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According to its Annual Report filed with the SEC for fiscal year 2014: "Sony is aware that certain transactions during the fiscal year ended March 31, 2014, as described below, may be disclosable pursuant to Section 13(r) of the Exchange Act.

Sony does not customarily allocate net profit on a country-by-country or activity-by-activity basis, other than as set forth in Sony’s consolidated financial statements prepared in accordance with U.S. GAAP; thus, the net profit and loss described below are non-U.S. GAAP figures and are estimated solely for the purpose of preparing this disclosure pursuant to Section 13(r) of the Exchange Act. The information below is to the best of Sony’s knowledge, and Sony in particular may not be aware of all potentially reportable sales by third-party-owned dealers and distributors.

• Before the beginning of the fiscal year ended March 31, 2014, Sony ceased its sales of professional equipment for use in television broadcasting to a third-party-owned dealer in Dubai, except for selling after-sales service parts and providing after-sales service training for such equipment, which were also ceased by the end of May 2013. The third-party-owned dealer in Dubai, to the best of Sony’s knowledge, may have resold such after-sales service parts and provided relevant after-sales services to the Islamic Republic of Iran Broadcasting, which we believe is a parent company of such dealer. During the fiscal year ended March 31, 2014, Sony’s gross revenue from these sales and training was approximately 14,000 U.S. dollars, and Sony has estimated that its net profit from such sales and training was approximately 11,000 U.S. dollars.
• During the fiscal year ended March 31, 2014, a non-U.S. subsidiary of Sony sold medical instruments, including medical printers, paper and monitors to a third-party-owned dealer in Dubai, which, to the best of Sony’s knowledge, planned to resell those products to the Iranian Ministry of Health. Sony’s gross revenue from these sales was approximately 2.5 million U.S. dollars, and Sony has estimated that its net profit from such sales was less than 0.5 million U.S. dollars.
• During the fiscal year ended March 31, 2014, a non-U.S. subsidiary of Sony closed a dormant bank account at Future Bank B.S.C. in Bahrain. Sony’s non-U.S. subsidiary closed the account in March 2014 and withdrew the remaining balance of the equivalent of 26,000 U.S. dollars, less de minimis fees.
• Sony’s representative office in Tehran, Iran, has been under liquidation processes and no longer engaged in any operation or activities other than the matters necessary for liquidation during the fiscal year ended March 31, 2014. In the course of liquidation, the office may engage in certain incidental transactions (for example, permits, taxes, and other similar matters incidental to the wind-down of the office in Iran) with Iranian government-owned entities. No material revenues or profits are associated with these transactions with the Iranian government.

Sony is not aware of any other activity, transaction or dealing by Sony Corporation or any of its affiliates during the fiscal year ended March 31, 2014 that is disclosable in this report under Section 13(r) of the Exchange Act. As of the date of this report, Sony does not anticipate that transactions that may be disclosable, as discussed above, will continue during the fiscal year ending March 31, 2015, except as described above in connection with the wind-down of its representative office or for certain transactions through third-party-owned dealers that Sony believes to be intended for the Iranian Ministry of Health. Nevertheless, in the future, Sony may conduct additional sales activities in Iran through third-party-owned dealers/distributors, which may require disclosure pursuant to Section 13(r) of the Exchange Act. Sony intends to conduct any such sales in accordance with applicable law.

Sony believes that, and maintains policies and procedures designed to ensure that, its transactions with Iran and elsewhere have been conducted in accordance with applicable economic sanctions laws and regulations and do not involve transactions likely to result in the imposition of sanctions or other penalties on Sony. However, there can be no assurance that Sony’s policies and procedures will be effective, and if the relevant authorities were to impose penalties or sanctions against Sony, the impact of such sanctions could be material."

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Company website lists numerous outlet and retail shops in Iran. (Company Website)

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“Sony Corp. (6758) sold almost $13 million in video and medical equipment to dealers in Dubai that resold the gear in Iran, the company said. The recipients included groups under U.S. sanctions. In a U.S. filing yesterday, Sony said it sold broadcast equipment, security cameras and video-conferencing gear to dealers who planned to resell or resold the products to groups including the Information Technology Department of the Iranian Police and the Islamic Republic of Iran Broadcasting… Sony ‘believes that, and maintains policies and procedures designed to ensure that, its transactions with Iran and elsewhere have been conducted in accordance with applicable economic sanctions laws and regulations,’ according to the filing. Penalties or sanctions taken against the company could be material if any government disagrees, Sony said... One dealer was a subsidiary of the Islamic Republic of Iran Broadcasting, Sony said in the filing. The company also reported sales of medical instruments -- including printers, paper and monitors -- it said were intended for the Ministry of Health.  Sony said it made the disclosure under the Iran Threat Reduction and Syria Human Rights Act of 2012 and related amendments to the Securities Exchange Act of 1934.  The company said it registered a profit of about $500,000 from the sale.” (Bloomberg, “Sony Reports Tech Sales to Iran that May Violate Sanctions,” 6/27/13)

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According to its Annual Report filed with the SEC for fiscal year 2013: "Sony is aware that certain transactions during the fiscal year ended March 31, 2013, as described below, may be disclosable pursuant to Section 13(r) of the Exchange Act.

Sony does not customarily allocate net profit on a country-by-country or activity-by-activity basis, other than as set forth in Sony’s consolidated financial statements prepared in accordance with U.S. GAAP; thus, the net profit and loss described below are non-U.S. GAAP figures and are estimated solely for the purpose of preparing this disclosure pursuant to Section 13(r) of the Exchange Act. The information below is to the best of Sony’s knowledge, and Sony in particular may not be aware of all potentially reportable sales by third-party-owned dealers and distributors.

• During the fiscal year ended March 31, 2013, Sony sold professional broadcast equipment, including cameras, switchers, VTRs, monitors and other associated broadcast equipment and media products for use in television broadcasting, to a third-party-owned dealer in Dubai, which, to the best of Sony’s knowledge, resold that equipment to the Islamic Republic of Iran Broadcasting, which we believe is a parent company of such dealer. Sony’s gross revenue from these sales was approximately 5.2 million U.S. dollars, and Sony has estimated that its net profit from such sales was less than 0.3 million U.S. dollars.
• During the fiscal year ended March 31, 2013, Sony sold medical instruments, including medical printers, paper and monitors to a third-party-owned dealer in Dubai, which, to the best of Sony’s knowledge, planned to resell those products to the Iranian Ministry of Health. Sony’s gross revenue from these sales was approximately 4.9 million U.S. dollars, and Sony has estimated that its net profit from such sales was less than 0.1 million U.S. dollars.
• During the fiscal year ended March 31, 2013, Sony sold video security cameras and hard disk products to a third-party-owned dealer in Dubai, which, to the best of Sony’s knowledge, planned to resell those products to the judiciary, Ferdowsi University, Iran Railway, Bank Sepah and Bank Melli in Iran. Such equipment is generally used by purchasers for the purposes of standard building/premises security in fixed locations. During the fiscal year ended March 31, 2013, Sony’s gross revenue from these sales was approximately 2.2 million U.S. dollars, and Sony has estimated that its net profit from such sales was less than 0.1 million U.S. dollars.
• During the fiscal year ended March 31, 2013, Sony sold video conference equipment to third-party-owned dealers in Dubai, which, to the best of Sony’s knowledge, planned to resell that equipment to the Information Technology Department of the Iranian Police. Sony’s gross revenue from these sales was approximately 0.5 million U.S. dollars, and Sony estimates that it recorded a net loss from such sales.

Sony’s small representative office in Tehran, Iran, may engage in certain incidental transactions (for example, permits, utilities, and other similar matters incidental to operating an office in Iran) with Iranian government-owned entities. No material revenues or profits are associated with these transactions with the Iranian government.

Sony is not aware of any other activity, transaction or dealing by Sony Corporation or any of its affiliates during the fiscal year ended March 31, 2013 that is disclosable in this report under Section 13(r) of the Exchange Act. As of the date of this report, Sony does not anticipate that transactions that may be disclosable, as discussed above, will continue during the fiscal year ending March 31, 2014, except for the operation of its representative office and certain transactions through third-party-owned dealers that Sony believes to be intended for the Islamic Republic of Iran Broadcasting and the Iranian Ministry of Health. Nevertheless, in the future, Sony may conduct additional sales activities in Iran through third-party-owned dealers/distributors, which may require disclosure pursuant to Section 13(r) of the Exchange Act. Sony intends to conduct any such sales in accordance with applicable law.

Sony believes that, and maintains policies and procedures designed to ensure that, its transactions with Iran and elsewhere have been conducted in accordance with applicable economic sanctions laws and regulations and do not involve transactions likely to result in the imposition of sanctions or other penalties on Sony. However, there can be no assurance that Sony’s policies and procedures will be effective, and if the relevant authorities were to impose penalties or sanctions against Sony, the impact of such sanctions could be material."

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"In the electronics and home appliances sections, sales of LG and Sony flat-screen televisions come with attractive service plans and free home installations. Local brands, such as Pars, go mostly ignored." (The Washington Post, "Iran hopes to resist sanctions by boosting production," 10/27/2012) 

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"But its population of about 75 million includes a sizeable urban middle class who have been avid consumers of foreign-made goods, including Samsung and Sony electronics and Peugeot cars." (Reuters, "Iran says it will cut imports of non-essential goods," 10/14/2012)

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"Sony has been in Iran since at least 2000 and currently has an office in the country."  From 2000-2009, the company was the recipient of $103.3 million US federal funds.  The company's business in Iran is currently active.  (The New York Times, "Profiting from Iran, and the US," 3/6/2010)

"Bain Capital, the venture capital firm that Romney started and made him a multimillionaire, teamed up with the Haier Group, a Chinese appliance maker that has a factory in Iran, in an unsuccessful 2005 buyout effort." (Associated Press, "Iran Links Undercut Romneys Recent Plea," 2/24/07)

According to its 2019 Annual Report filed with the SEC: "CMSC, a wholly-owned Japanese subsidiary of Canon Inc., had indirect sales transactions through independent distributors in Istanbul, Turkey, Sharjah, United Arab Emirates and Tehran, Iran for computed tomography, diagnostic ultrasound systems and service parts for those products with hospitals in Iran. It is our understanding that Iranian hospitals are owned or controlled by the Government of Iran (central or local government) and that their purchases are controlled through an agency of the Iranian Ministry of Health and Medical Education. Total gross sales under these contracts during the year 2019 were approximately ¥142,431 thousand. The net profit was substantially less than that."

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

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According to its Annual Report filed with the SEC in 2017: "After considering recent changes in the international situation and economic sanctions relating to Iran, Canon has restarted business with certain Iranian counterparties. Canon maintains policies and procedures designed to ensure that transactions, including transactions with Iranian counterparties, are conducted in accordance with applicable economic sanction laws and regulations."

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According to Canon’s 2016 SEC disclosure, Canon has contracts with the Iranian embassies in Tokyo, Japan, Iran Air in Kuala, Malaysia, CSPL in Thailand and India, the Iranian embassy in Australia, Consulate General of Iran in Germany, CENV Iranian embassy in Denmark. Canon has restarted business with certain Iranian counterparties. 

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"Canon Middle East manages sales, marketing and technical activities across 36 countries, including Iran, where Canon has been selling products since at least 2000, according to the company Web site."  The company received $503.2 million in revenue and benefits from the US for their business 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)

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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," 7/09/08)