Energy

"While identified by CalPERS in 2015 as not meeting threshold criteria for consideration under the Act, in 2017 the company was reported as potentially having operational trade business in Iran helping coordinate various types of businesses between Japanese and Iranian companies. In 2018 CalPERS designated the company as under review. In 2019 CalPERS changed the designation to “being monitored” because CalPERS’ initial screening has not identified the company as having involvement in the regions and/or activities targeted by the Act. CalPERS has maintained the company in “monitor” status for 2020. CalPERS continues to monitor the company for possible changes in status relevant to the Act."

--

In 2020, the U.S. state of Mississippi listed Toyota Tsusho 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 Toyota Tsusho as a scrutinized investment. The managers are explicitly instructed to refrain from purchasing securities on this list.

--

On March 13, 2019, the Mississippi Department of Finance & Administration identified Toyota Tsusho 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 2018, the California State Public Employees Retirement System (“CalPERS”) designated Toyota Tsusho “Under Review.” In 2019, CalPERS designated Toyota Tsusho as “Being Monitored” because CalPERS “initial screening has not identified the company as having involvement in the [activities] targeted by the [2019 California Public Divest from Iran] Act.

--

In 2017, CalSTRS designated Toyota Tsusho Corp. as “Under Review” for reportedly having an operational trade business in Iran which helps coordinate various types of businesses between Japanese and Iranian companies. CalSTRS maintained the “Under Review” designation in 2018.In 2019, CalSTRS removed Toyota Tsusho from its list.

--

In 2017 the U.S. state of California listed Toyota Tusho Corp as a company under review for reportedly having an operational trade business in Iran which helps coordinate various types of businesses between Japanese and Iranian companies.

--

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

--

Subsidiary of Toyota Group.

--

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. Toyota Tusho 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."

--

According to Reuters, Toyota Tsusho maintains its business relations with Iran. (Reuters, “Japan's JX renews Iran term crude contracts for 2016 – sources,” 1/5/2016).

--

In 2015 Toyota Tsusho 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."
 

--

"Besides Mitsubishi, another trading house, Toyota Tsusho has been also lifting Iranian crude since April for the top two buyers, the sources added."a href="http://www.reuters.com/article/2012/06/22/japan-iran-mitsubishi-idUSL3E8HM3VC20120622">Japan's Mitsubishi renews Iran oil imports deal," 6/22/12)

--

In 2011, Toyota Tsusho 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 2009, Iran exported about 421,000 bpd of crude to Japan. It was overtaken by Qatar, however, as Japan's third-largest crude supplier.  Many of Japan's top refiners buy Iranian crude, including Showa Shell Sekiyu (5002.T), Nippon Oil (5001.T), Japan Energy, Cosmo Oil (5007.T). Trading house Toyota Tsusho (8105.T) also has a deal to buy crude from the Islamic republic." (Reuters, "Iran's crude export and fuel import customers," 4/13/2010)

"Japanese refiner Cosmo Oil will load around 900,000 barrels of Iranian Heavy crude oil in early March." (Tehran Times, 2/26/2019).

--

"Japan's Cosmo Oil loads first Iran crude cargo after US sanctions waiver: source." (1/28/2019)

--

Japanese refiner Cosmo Oil has replaced its Iranian crude oil imports with supplies from other Middle Eastern producers ahead of U.S. sanctions on Iran in November, top company executives said. (Reuters, 9/23/2018).

--

According to publicly accessible ship-monitoring data, since January 1, 2016, Cosmo-operated vessels have called at Iranian ports on several occasions.

--

In 2015 CosmoOil 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 uner the waivers granted by the U.S. government that meet Section (a)(2) of Act 44's expiration clause."
 

--

“Two Japanese buyers of Iranian crude, Idemitsu Kosan and Cosmo Oil, are unlikely to raise imports from the Middle Eastern country even after sanctions were eased as part of an initial deal on Tehran's disputed nuclear programme. Executives with the two refiners said on Tuesday they have no plans to increase their contract volumes following the November deal between world powers and Iran that allowed Tehran to keep oil exports at around 1 million barrels per day (bpd), about half of pre-sanction levels…At the same event, Cosmo Oil President Keizo Morikawa also said his company is unlikely to increase purchases from Iran. ‘It is unlikely we can raise volumes now because (domestic) demand is declining,’ he said, adding that it remains unclear how much it would be allowed to import under U.S. sanctions. Cosmo Oil will slightly reduce its Iranian oil imports from April, after its current annual contract expires, an industry source familiar with the matter told Reuters in November. Cosmo has cut its Iranian imports to 15,000 bpd or less in the business year through March 2014, from 40,000 bpd two years ago, industry officials have said.” (Reuters, “Japan's Idemitsu, Cosmo unlikely to raise Iranian crude imports,” 1/7/14)

--

In 2013, CosmoOil was added to the Pennsylvania Treasury's List of Scrutinized Companies Determined as Having Involvement in Iran because government related oil activity. 

--

"Besides JX Nippon, Japan's top buyer of Iranian crude, Showa Shell Sekiyu KK, and Cosmo Oil have already renewed term deals to lift Iranian crude from April, industry sources have said." (The New York Times, "Japan's JX: No Problem With Paying Iran for Oil Now," 5/17/2012)

--

"Iran is poised to lose at least 192,000 barrels a day of crude-supply contracts, or about 9.5 percent of its global exports, as Asian buyers curb purchases amid western sanctions targeting the nation's oil trade. Mangalore Refinery & Petrochemicals Ltd. (MRPL) and Essar Oil Ltd., India's biggest buyers of Iranian crude, and China International United Petroleum & Chemical Co. have reduced or plan to cut purchases from the Islamic Republic by as much as 15 percent. China and India are Iran's largest customers. In Japan, the only Asian country to get an exemption from U.S. sanctions after it demonstrated reductions in purchases, Cosmo Oil Co. plans to cut imports by 25 percent, while JX Nippon Oil & Energy Corp. suspended talks with the Persian Gulf nation over a 10,000 barrel-a-day contract." (Bloomberg, "Iran May Lose 9.5% of Oil Contracts as Asian Buyers Cut Imports," 5/3/12)

--

"Japan's Cosmo Oil Co has renewed its annual oil purchase deal with Iran and cut the volume to comply with U.S. sanctions against the Islamic nation, trade sources said on Friday. A company spokesman declined to comment. Cosmo's new contractual volume from April onwards remained unclear. The company had already lowered its Iran crude imports to a little below 30,000 bpd from about 40,000 bpd since January, and was set to cut further from April, the sources said. Japan's top buyer of Iranian crude, Showa Shell Sekiyu KK , has already renewed its deal, industry sources have said. The contract renewal came after Iran agreed to include a clause in contract terms that released Japanese buyers from any penalty if international sanctions prevent them from taking delivery of Iranian oil, sources said." (Reuters,"Japan's Cosmo Oil renews Iran imports deal," 4/20/2012)

--

"Japanese refiners will cut Iranian crude imports yet again in April as they shy away from renewing annual contracts, showing continued commitment to U.S.-led sanctions over Tehran's nuclear programme.  Japan, the world's third largest oil consumer, has strongly backed calls to cut Iranian oil imports and earlier reductions were hailed by its top business and military ally, the United States, as an example to other countries...JX Nippon Oil & Energy Corp, Japan's biggest oil refiner, has not renewed a contract to buy 10,000 barrels per day (bpd) of Iranian crude, which expired in March, the sources said, declining to be identified as they are not authorised to talk to the media.  Apart from JX, at least three other Japanese firms, including Idemitsu Kosan Co and Cosmo Oil Co, which together buy around 40,000 barrels per day, will not lift any Iranian crude in April, industry sources said. These three do not lift Iranian oil every month."  (Reuters, "Japan refiners deepen Iran crude import cuts,"  4/4/12)

-- 

"JAPAN - In 2009, Iran exported about 421,000 bpd of crude to Japan. It was overtaken by Qatar, however, as Japan's third-largest crude supplier.  Many of Japan's top refiners buy Iranian crude, including Showa Shell Sekiyu (5002.T), Nippon Oil (5001.T), Japan Energy, Cosmo Oil (5007.T). Trading house Toyota Tsusho (8105.T) also has a deal to buy crude from the Islamic republic."  (Reuters, "Iran's Crude export and fuel import customers," 4/13/2010)

Subsidiary of JXTG Holdings.

"According to the official, talks are underway with multinationals, namely Italy's Tecnimont, China's Sinopec, Japan's Marubeni, JGC Corporation, JX Nippon Oil & Energy and South Korea's Daelim, to fund the ventures." (October 2017)

--

During the fiscal year ended March 31, 2017, JXTG Nippon Oil & Energy, a wholly-owned subsidiary of JXTG Holdings, purchased 31 million barrels of crude oil from National Iranian Oil Company for a total purchase price of ¥144,046 million, out of a total of 415 million barrels of crude oil that it purchased during the same period, constituting approximately 7% of the total amount of crude oil that it purchased during the same period. (2017)

v

--

In 2016, JX Nippon’s intentions vis-à-vis the Iranian market are unclear.  According to reports, “JX had a contract to buy 53,000 barrels per day (bpd) of Iranian crude in 2015….the refiner's annual term crude contract with Iran had been renewed, although he [Chairman Yasushi Kimura] could not confirm the volumes.” Chairman Kimura stated that whether JX would increase its Iranian volumes following implementation of the JCPOA “would depend on the economics.” (Reuters, “Japan's JX renews Iran term crude contracts for 2016 –sources,” 1/5/2016).   
--

"Two of Japan's biggest buyers of Iranian crude, JX Nippon Oil & Energy Corp and Showa Shell Sekiyu KK, are set to keep their purchases from Tehran largely steady in 2015, their top officials said on Tuesday. JX, which sources said imported 53,000 barrels per day (bpd) of Iranian crude in 2014, will keep its volumes steady in the new term contract starting this month, Chairman Yasushi Kimura said on the sidelines of an industry gathering. 'Iranian sanctions have been unchanged, so we will not increase or reduce volumes,' Kimura told Reuters." (Reuters, "Japan's JX, Showa Shell to keep Iran crude volumes steady to last year," 1/6/15)

--

“Japan's biggest refiner JX Nippon Oil & Energy has cut its annual crude contract with Iran by 27 percent, an industry source said, a move that will likely keep at bay any potential U.S. pressure over oil shipments from the Islamic republic…JX Nippon Oil & Energy, a unit of JX Holdings Inc, opted to cut its 2014 contract for crude from Iran to 53,000 bpd, from 73,000 bpd last year, said a source familiar with the matter who declined to be identified. The cut was in keeping with reductions to contracts from other crude suppliers such as Saudi Arabia that come as Japan's domestic demand weakens and refiners close down crude units, said the source. JX has cut its refining capacity nearly 600,000 bpd over the last five years due to Japan's shrinking home market and a government efficiency mandate…The reduction amounts to an annual loss of around $800 million for Iran at current prices, according to Reuters calculations. The cuts of 20,000 bpd were slightly more than expected, with the source saying in September that JX would cuts its 2014 imports from Iran to around 60,000 bpd. JX spokesmen declined to comment, citing confidentiality agreements with Iran. Japan reduced Iranian imports by 6.2 percent to 177,414 bpd last year, compared with a 0.9 percent decline in total oil imports. Even if other Japanese buyers lifted the same volumes from Iran this year as last year, the nation's imports would fall to 157,414 bpd, down 11 percent on year.” (Reuters, “Japan's JX cuts 2014 Iran term crude import 27 pct -source,” 3/14/14)

--

"Japan's biggest oil refiner JX Holdings has renewed its annual contract for importing crude oil from Iran for 2014, with volumes steady to slightly lower compared to this year. Steady progress in talks between world powers and Iran over Tehran's decade-old disputed nuclear programme is raising hopes shipments from the OPEC member will stabilise next year at the current reduced levels, prompting JX, and potentially, other buyers to renew their contracts…JX will import quantities of Iranian crude that are permitted under the Western sanctions, chairman Yasushi Kimura told reporters on Thursday, but declined to comment on the volumes…An official at JX Nippon Oil & Energy Corp, the downstream oil unit of JX Holdings, said import volumes for 2014 from Iran have not been set formally but have been mostly decided, with steady or slightly lower quantities to be imported compared to 2013 levels. 'Volumes are not rising,' in 2014, the official said. JX Nippon is likely to cut its Iran import volumes to around 60,000 bpd in 2014 from an estimated 73,000 bpd this year, an industry source familiar with the matter said in September." (Reuters, "Japan's JX renews annual Iranian crude import contract for 2014," 12/19/13)

--

"Japan's top buyer of Iranian crude JX Nippon Oil & Energy Corp is set to cut the oil it takes from the Middle Eastern producer in an annual contract for next year by nearly 20 percent, an industry source familiar with the matter said. Japan, Iran's third biggest oil client, has been cutting its purchases sharply since 2012, under pressure from U.S. and EU sanctions targeting Tehran's nuclear programme…JX is braced for the cuts even though Iran has proposed an agreement to address concerns about its nuclear programme within a year at talks with major powers. 'JX is set to cut close to 20 percent, or by more than 10,000 bpd,' the source told Reuters on condition of anonymity. JX Nippon, a downstream unit of JX Holdings, is expected to cut its Iran import volumes to around 60,000 bpd in 2014, down from an estimated 73,000 bpd this year. That would cost Iran around $390 million next year at current OPEC basket prices, according to Reuters calculations…JX until recently had two annual contracts with Iran, one with a larger volume running from January-December and a smaller one running over the April-March fiscal period. The company only renewed the bigger contract this year, cutting the volume by 10,000 bpd from a year earlier to 73,000 bpd. The second contract, for 10,000 bpd, was allowed to expire at the end of March 2012 and was not renewed." (Reuters, "Japan's JX set to cut 2014 Iran crude buys by nearly 20 pcta," 9/27/13)

--

"JX Nippon Oil & Energy Corp., the country’s biggest refiner, will cut its imports from the current contract of about 80,000 barrels a day, Kimura Yasushi, who serves as chairman for both JX and the Petroleum Association of Japan, said at a press conference today...  'Maintaining that 160,000 barrels a day as a ceiling, refiners will look into reducing more, as JX cuts its own imports,' said Kimura, who declined to comment on how much purchases would be cut. 'We will tackle this while keeping a close eye on the U.S.’s policy on Iran'" (Bloomberg, "Japan to Extend Cuts in Iran Oil Imports in 2013, JX Chief Says," 12/19/12)

--

"Japanese refiners have yet to decide on their crude import volumes from Iran for 2013 as they are looking at various factors including US sanctions, Petroleum Association of Japan President Yasushi Kimura told reporters Monday.'At present, we have not decided on our direction of Iran crude imports,' Kimura said at a press conference in Tokyo. 'We will consider our options from now on to see such factors as various alternative crude options as well as situations over the US sanctions to decide whether we will cut our imports further or maintain the current reduction pace' . . . Kimura, who is the chairman of JX Nippon Oil & Energy, said the company is scheduled to renew its annual crude import contract in January 2013. JX Nippon Oil & Energy would decide its annual import contract next year by considering various factors at the time of its renewal, he added, declining to elaborate further. Platts reported October 17 that JX Nippon Oil & Energy has started talks with the National Iranian Oil Company for the renewal of its contract beyond January 2013. The company might finalize its 2013 contract with NIOC later this month, sources familiar with the matter had said then. JX Nippon Oil & Energy confirmed earlier that it has a contract to import 80,000 b/d of Iranian crude for January-December 2012. A second contract for 10,000 b/d expired at the end of March 2012. JX declined to comment on the fate of the 10,000 b/d import contract that NIOC had allowed it to keep pending for renewal. t was also not immediately clear whether JX Nippon Oil & Energy would reduce significantly its Iranian crude purchase volumes in 2013 compared with 2012 as Japan has already cut a significant volume of its imports this year from a year ago, according to industry sources . . . Japan's imports of crude from Iran have been falling in recent years and are set to fall further following its agreement with the US that allows Japanese banks continued access to the US financial system in return for a pledge to reduce the country's purchases of Iranian crude." (Platts, "Japan yet to decide on Iran crude import volumes for 2013 -- PAJ chief," 10/22/12)

--

"Japanese shippers will start loading on Friday their first cargo of Iranian oil in a month and a half, after the government provided insurance guarantees to replace EU coverage which was suspended due to sanctions against Iran, sources said…Japan's top refiner, JX Nippon Oil & Energy, which has a contracted volume with Iran of 83,000 bpd, has emerged as the country's biggest buyer of Iranian crude, taking the top spot from Showa Shell Sekiyu." (Reuters, "Japan shippers to resume loading Iranian oil on Friday," 7/20/12)

--

"Japan will load its first Iranian crude cargo backed by sovereign guarantees since sanctions disrupted coverage in the international reinsurance market.

JX Nippon Oil & Energy Corp. and Idemitsu Kosan Co. will load about 1.7 million barrels of Iranian crude on the very large crude carrier Ryuho Maru on about July 20 at Kharg Island, the country’s biggest oil-export terminal, according to three officials from the refiners and Japan’s trade ministry. The tanker, owned by Iino Kaiun Kaisha Ltd. , will be backed by the Japanese state, they said, asking not to be identified because the information is confidential.

Japan’s Iranian crude imports will fall in July because refiners were unsure whether the sovereign insurance would be available when they planned July-loading schedules last month, the officials said. Japan’s parliament passed a bill on June 20 to provide $7.6 billion of guarantees to tanker owners that carry Iranian oil. European Union sanctions, introduced as an attempt to persuade Iran to halt its nuclear program, took effect July 1." (Bloomberg, "Japan Set To Load First Iran Crude With Sovereign Insurance," 7/13/12)

--

"Japan will not import any Iranian crude in July as buyers held back to avoid any risk of running foul of EU sanctions targeting insurance, which have severely disrupted the OPEC member's supplies, industry and government sources said on Wednesday.

Japan will join South Korea among top Asian buyers in halting all Iranian imports this month due to sanctions imposed by Brussels on Sunday that aim to cut Iran's oil revenues and force Tehran to curb its nuclear program. The measure will cost Iran dearly in July, as Japan and South Korea imported a combined 256,000 barrels per day (bpd) of Iran's crude in May, worth over $750 million at current oil prices…The EU oil embargo has stopped European insurers, who dominate the maritime sector, from offering cover on Iranian crude. Industry watchers say the EU step has proven to be the hardest hitting measure in the West's arsenal of sanctions aimed at Iran.

Japan's government agreed last month to step in and provide insurance cover of up to $7.6 billion for shipments to keep oil trade with Tehran going…The country's next shipments will be loaded in Iran in late July. Allowing for journey time, they will arrive in Japan after mid-August, sources said…Japan has already scaled back its purchases of Iranian crude to ensure an exemption from U.S. sanctions, which target financial institutions dealing with Iran's central bank. The U.S. measures came into effect last week.

The United States gave Japan a waiver to those sanctions earlier this year after the Asian country reduced its import volumes of Iranian crude…Japan is the only country to date to offer sovereign guarantees on shipments…Japan's biggest buyers of Iranian oil are Showa Shell Sekiyu KK and JX Nippon Oil & Energy Corp.." (Reuters, "Exclusive: Japan to import no Iranian oil in July," 7/4/2012)

--

"Japan has been able to continue with the imports as the country's parliament on Wednesday approved an unprecedented law that allows Tokyo to provide cover of up to $7.6 billion for incidents involving tankers bringing Iranian oil to the country . . . Japan's biggest buyers of Iranian oil, Showa Shell Sekiyu KK (5002.T) and JX Nippon Oil & Energy Corp (5020.T), are to load a total of four vessels in June, steady from May, with shipments arriving this month and next, traders said on Wednesday . . ."(Reuters, "Japan, China to import Iran oil after EU Ban," 6/20/12)

--

"Japan's top oil refiner, JX Nippon Oil & Energy Corp, is not facing a problem paying Iran for crude imports, the company said on Thursday, after a major Japanese bank froze transactions with Iranian banks on the order of a U.S. court... A JX Nippon Oil spokesman said there was no problem with payment to Iran at the moment, but declined to discuss other details, including whether it was considering an alternative payment mechanism... Besides JX Nippon, Japan's top buyer of Iranian crude, Showa Shell Sekiyu KK, and Cosmo Oil have already renewed term deals to lift Iranian crude from April, industry sources have said. Only JX and Showa Shell have plans to lift Iranian oil in April and May among the Japanese oil firms, industry sources have said." (The New York Times, "Japan's JX: No Problem With Paying Iran for Oil Now," 5/17/2012)

--

"Iran is poised to lose at least 192,000 barrels a day of crude-supply contracts, or about 9.5 percent of its global exports, as Asian buyers curb purchases amid western sanctions targeting the nation's oil trade. Mangalore Refinery & Petrochemicals Ltd. (MRPL) and Essar Oil Ltd., India's biggest buyers of Iranian crude, and China International United Petroleum & Chemical Co. have reduced or plan to cut purchases from the Islamic Republic by as much as 15 percent. China and India are Iran's largest customers. In Japan, the only Asian country to get an exemption from U.S. sanctions after it demonstrated reductions in purchases, Cosmo Oil Co. plans to cut imports by 25 percent, while JX Nippon Oil & Energy Corp. suspended talks with the Persian Gulf nation over a 10,000 barrel-a-day contract." (Bloomberg, "Iran May Lose 9.5% of Oil Contracts as Asian Buyers Cut Imports," 5/3/12)

--

 "Japan's top refiner JX Nippon Oil & Energy Corp will not be able to continue importing oil from Iran as tightening global sanctions against the Islamic Republic make it tough to pay for, ship and insure the oil, the company's senior executive said. Japan has already drastically cut loading of Iranian crude since April as its refiners cannot rely on the European reinsurance market to cover tankers. Industry sources have said Japanese buyers can no longer import Iran crude from July if the European Union does not grant an exemption from its planned ban on all European reinsurance, including the cover for pollution." (Reuters, "Japan's JX: Iran crude import may stop due to sanction," 4/26/12)

--

"Japanese refiners will cut Iranian crude imports yet again in April as they shy away from renewing annual contracts, showing continued commitment to U.S.-led sanctions over Tehran's nuclear programme.  Japan, the world's third largest oil consumer, has strongly backed calls to cut Iranian oil imports and earlier reductions were hailed by its top business and military ally, the United States, as an example to other countries...JX Nippon Oil & Energy Corp, Japan's biggest oil refiner, has not renewed a contract to buy 10,000 barrels per day (bpd) of Iranian crude, which expired in March, the sources said, declining to be identified as they are not authorised to talk to the media.  Apart from JX, at least three other Japanese firms, including Idemitsu Kosan Co and Cosmo Oil Co, which together buy around 40,000 barrels per day, will not lift any Iranian crude in April, industry sources said. These three do not lift Iranian oil every month."  (Reuters, "Japan refiners deepen Iran crude import cuts,"  4/4/12)

--

"Japan's biggest refiner JX Nippon Oil & Energy Corp is talking with top exporter Saudi Arabia and other oil producers to source crude to replace any disruption to its imports from Iran, the company's president said on Thursday... 'We've been talking to Saudi Arabia and others on possible scenarios in the case of an import ban (from Iran),' Yasushi Kimura, president of JX Nippon, the wholly-owned downstream oil subsidiary of JX Holdings Inc, told a group of reporters... JX Nippon buys around 70,000 to 80,000 bpd from Iran, industry sources said." (Reuters, "Japan's JX looks to Saudi for oil on Iran worries," 1/5/2012)

--

"JAPAN - In 2009, Iran exported about 421,000 bpd of crude to Japan. It was overtaken by Qatar, however, as Japan's third-largest crude supplier.  Many of Japan's top refiners buy Iranian crude, including Showa Shell Sekiyu (5002.T), Nippon Oil (5001.T), Japan Energy, Cosmo Oil (5007.T). Trading house Toyota Tsusho (8105.T) also has a deal to buy crude from the Islamic republic." (Reuters, Iran's crude export and fuel import customers, 4/13/2010)

Major crude oil wholesaler Showa Shell Sekiyu K.K. has resumed imports of Iranian oil after Tokyo received a temporary waiver in November from reinstated U.S. sanctions, an industry source said Tuesday. (1/22/2019).

--

In 2017 the U.S. State of South Carolina listed Showa Shell Sekiyu as an entity ineligible to contract with the state of South Carolina or any political subdivision of the state per the Iran Divestment Act of 2014. 

--

In 2016 and 2017 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. Showa Shell was included on this list in 2016 and 2017. "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."

--

"Oil refiner Showa Shell Sekiyu bought 55 percent of Japan's crude imports from Iran in January-June, said Chief Executive Officer Tsuyoshi Kameoka. Japan imported 205,871 barrels per day (bpd) of Iranian oil in the first half of 2016, trade ministry data showed, meaning Showa Shell's imports during the period would be around 113,000 bpd." (Reuters, "Showa Shell says buys 55 percent of Japan's Iran crude imports in H1," 10/13/2016). 

-- 

Showa Shell Sekiyu is a subsidiary of Royal Dutch Shell plc.

--

 
Shana (Iran): "Iran's Petroleum Minister Bijan Zangeneh and visiting Japanese Foreign Minister Fumio Kishida met here class="aBn"> class="aQJ">on Monday discussing oil, gas, and petrochemical joint ventures following removal of sanctions. Kishida, who is heading a 23-member delegation of Japanese businessmen and officials, met his counterpart Mohammad-Javad Zarif in the morning... Also class="aBn"> class="aQJ">on Sunday, Director of International Affairs in Iranian Petroleum Ministry said the giant Japanese refiner Showa Shell is in negotiations with Iran over volume of buying crude oil from Iran after sanctions are lifted. 'Showa Shell's senior officials are accompanying the Japanese foreign minister during his visit to Iran with the sale of crude to the major Asian refiner on the agenda of the talks,' Mohsen Qamsari told Shana." (Shana, "Iran, Japan to Improve Energy Ties in Post-Sanction Era," 10/12/15) 

--

"Two of Japan's biggest buyers of Iranian crude, JX Nippon Oil & Energy Corp and Showa Shell Sekiyu KK, are set to keep their purchases from Tehran largely steady in 2015, their top officials said on Tuesday. JX, which sources said imported 53,000 barrels per day (bpd) of Iranian crude in 2014, will keep its volumes steady in the new term contract starting this month, Chairman Yasushi Kimura said on the sidelines of an industry gathering. 'Iranian sanctions have been unchanged, so we will not increase or reduce volumes,' Kimura told Reuters. Showa Shell Sekiyu also indicated its intention to keep its Iranian crude volumes steady at about 70,000 bpd in the fiscal year starting on April 1... Cosmo in 2014 was lifting a little below 15,000 bpd, while Idemitsu has a contract for 2,000 to 3,000 bpd, sources said." (Reuters, "Japan's JX, Showa Shell to keep Iran crude volumes steady to last year," 1/6/15)

--

In 2015 Show Shell 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 uner the waivers granted by the U.S. government that meet Section (a)(2) of Act 44's expiration clause."

--

In 2013, Showa Shell was added to the Pennsylvania Treasury's List of Scrutinized Companies Determined as Having Involvement in Iran because of Government oil-related activity. 

--

"Japanese shippers will start loading on Friday their first cargo of Iranian oil in a month and a half, after the government provided insurance guarantees to replace EU coverage which was suspended due to sanctions against Iran, sources said…Japan's top refiner, JX Nippon Oil & Energy, which has a contracted volume with Iran of 83,000 bpd, has emerged as the country's biggest buyer of Iranian crude, taking the top spot from Showa Shell Sekiyu.

Showa Shell is likely to have reduced its contracted volumes to around 60,000-70,000 bpd, from last year's import average of 100,000 bpd, one of the sources said." (Reuters, "Japan shippers to resume loading Iranian oil on Friday," 7/20/12)

--

"Japan will not import any Iranian crude in July as buyers held back to avoid any risk of running foul of EU sanctions targeting insurance, which have severely disrupted the OPEC member's supplies, industry and government sources said on Wednesday.

Japan will join South Korea among top Asian buyers in halting all Iranian imports this month due to sanctions imposed by Brussels on Sunday that aim to cut Iran's oil revenues and force Tehran to curb its nuclear program. The measure will cost Iran dearly in July, as Japan and South Korea imported a combined 256,000 barrels per day (bpd) of Iran's crude in May, worth over $750 million at current oil prices…The EU oil embargo has stopped European insurers, who dominate the maritime sector, from offering cover on Iranian crude. Industry watchers say the EU step has proven to be the hardest hitting measure in the West's arsenal of sanctions aimed at Iran.

Japan's government agreed last month to step in and provide insurance cover of up to $7.6 billion for shipments to keep oil trade with Tehran going…The country's next shipments will be loaded in Iran in late July. Allowing for journey time, they will arrive in Japan after mid-August, sources said…Japan has already scaled back its purchases of Iranian crude to ensure an exemption from U.S. sanctions, which target financial institutions dealing with Iran's central bank. The U.S. measures came into effect last week.

The United States gave Japan a waiver to those sanctions earlier this year after the Asian country reduced its import volumes of Iranian crude…Japan is the only country to date to offer sovereign guarantees on shipments…Japan's biggest buyers of Iranian oil are Showa Shell Sekiyu KK and JX Nippon Oil & Energy Corp.." (Reuters, "Exclusive: Japan to import no Iranian oil in July," 7/4/2012)

--

"Japan has been able to continue with the imports as the country's parliament on Wednesday approved an unprecedented law that allows Tokyo to provide cover of up to $7.6 billion for incidents involving tankers bringing Iranian oil to the country . . . Japan's biggest buyers of Iranian oil, Showa Shell Sekiyu KK (5002.T) and JX Nippon Oil & Energy Corp (5020.T), are to load a total of four vessels in June, steady from May, with shipments arriving this month and next, traders said on Wednesday, Showa Shell is Japan's top buyer of Iran oil this month, they added." (Reuters, "Japan, China to import Iran oil after EU Ban," 6/20/12)

--

"Besides JX Nippon, Japan's top buyer of Iranian crude, Showa Shell Sekiyu KK, and Cosmo Oil have already renewed term deals to lift Iranian crude from April, industry sources have said. Only JX and Showa Shell have plans to lift Iranian oil in April and May among the Japanese oil firms, industry sources have said. Showa Shell was not immediately available for comment." (The New York Times, "Japan's JX: No Problem With Paying Iran for Oil Now," 5/17/2012)

--

class="form-text">"Japan's Cosmo Oil Co has renewed its annual oil purchase deal with Iran and cut the volume to comply with U.S. sanctions against the Islamic nation, trade sources said on Friday. A company spokesman declined to comment. Cosmo's new contractual volume from April onwards remained unclear. The company had already lowered its Iran crude imports to a little below 30,000 bpd from about 40,000 bpd since January, and was set to cut further from April, the sources said. Japan's top buyer of Iranian crude, Showa Shell Sekiyu KK , has already renewed its deal, industry sources have said. The contract renewal came after Iran agreed to include a clause in contract terms that released Japanese buyers from any penalty if international sanctions prevent them from taking delivery of Iranian oil, sources said." (Reuters,"Japan's Cosmo Oil renews Iran imports deal," 4/20/2012)

--

"Japan will slash its crude purchases from Iran by almost 80 percent in April compared to the first two months of the year as buyers comply with Western sanctions, trade sources said. The cuts, amounting to 250,000 barrels per day, are the steepest yet by the four Asian nations who buy most of Iran's 2.2 million bpd of exports, as tightening sanctions make it tough to pay, ship and insure the oil... Sources said top importer Showa Shell had reduced the volume of oil it will import from Iran under an annual deal the company renewed in April. One source said the cuts may range between 15 percent to 20 percent from last year's 100,000 bpd contract, but exact details were not available. JX Nippon Oil & Energy Corp, Japan's biggest oil refiner, has not renewed a contract to buy 10,000 barrels per day (bpd) of Iranian crude, which expired in March. JX has another contract for 80,000 bpd of crude from Iran, which was renewed in January." (Reuters, "Japan cuts April Iran oil purchases 77 percent," 4/18/12)

--

"In 2009, Iran exported about 421,000 bpd of crude to Japan. It was overtaken by Qatar, however, as Japan's third-largest crude supplier.  Many of Japan's top refiners buy Iranian crude, including Showa Shell Sekiyu (5002.T), Nippon Oil (5001.T), Japan Energy, Cosmo Oil (5007.T)." (Reuters, Iran's Crude export and fuel import customers, 4/13/2010)

--

"Due to economic considerations, Japanese refining companies have become increasingly dependent on the Middle East for oil. Showa Shell relies more heavily on Iran than other companies for oil imports. As Iranian oil is best processed at the second refining unit at the Yokkaichi Refinery, this has contributed to the construction of a state-of- the-art refining facility and the development of technology for more efficient processing of white oil." (Company Website, 2001 Business Review)

"Hyundai Oilbank Co., a major South Korean refiner, plans to import 2 million barrels of Iranian condensate this month, a person familiar with the issue said Monday.

It would be Hyundai Oilbank’s first imports of ultralight crude since September, two months before the United States imposed the most biting sanctions ever on Iran. US President Donald Trump abandoned a landmark 2015 nuclear deal with Iran in May." (Korea Herald, 2/14/2019).

--

In June 2016 Hyundai Oilbank markedly increased imports of Iranian oil. (Mehr News, “S Korea’s Iranian crude imports double in Jan-April period,” 6/7/2016).

--

MOPCIO is the exclusive agent of Hyundai OIL BANK South Korea in IRAN.

-- 

Hyundai Oil Bank is a subsidiary of Hyundai Heavy Industries.

--

“South Korea's crude imports from Iran surged 104 percent in February from a year earlier as refiners hiked purchases ahead of maintenance shutdown starting from March, according to the country's customs data and a refining source. South Korea imported 1.1 million tonnes of Iranian crude last month, or 294,069 barrels per day (bpd), up 4.5 times from January and double from a year earlier, preliminary customs data showed on Saturday…’The two refiners had to hike the imports ahead of maintenance shutdown starting from March. Before and after the maintenance, refiners usually import more to meet annual import contracts,’ a Seoul-based refining source told Reuters. Of four South Korean refiners, SK Energy and Hyundai Oilbank are the only ones that buy Iranian oil on a regular basis. Their Iranian crude imports can vary from month to month as one of the two refiners that buy from the OPEC receives the oil only every other month. SK Energy will shut a 260,000 bpd No. 5 crude distillation unit (CDU) and a 57,000-bpd No.1 gasoline-making unit in the second quarter for maintenance, a spokesman at parent SK Innovation Co Ltd said. Hyundai Oilbank will shut its No.1 110,000-bpd CDU in April for maintenance, it said last month.” (Reuters, “S.Korea Feb Iran oil imports soar ahead of shutdown," 3/15/14)

--

"South Korea's Iranian crude imports fell in October from September, meeting a targetted 15 percent cut in its shipments from the OPEC member for the June-November period to secure an extension of its six-month U.S. sanctions waiver…outh Korea imported 420,402 tonnes of Iranian crude last month, or 99,405 barrels per day (bpd), down more than a quarter compared with September and down nearly a half from a year earlier, preliminary customs data showed on Friday…The total means South Korea met the 125,814 bpd it aims to achieve in its imports from Iran in the six months through November…South Korea's Iranian crude imports vary from month to month as one of the two Korean refiners that buys from Iran receives oil only every other month, according to industry sources. The imports unexpectedly jumped in July from the year-earlier period before dropping off again in August. SK Energy and Hyundai Oilbank are the only South Korean refiners that take Iranian oil on a regular basis. South Korea, the world's fifth-largest crude buyer, imported a total of 10.7 million tonnes of crude last month against 11.1 million tonnes in October 2012, data from the Korea Customs Service also showed on Friday." (Reuters, "S.Korea's Oct Iran oil imports drop, meet target," 11/15/13)

--

"South Korean refiners SK Energy and Hyundai Oilbank are the only two in the country to import Iranian crude. Spokesmen at both refiners declined to comment". (Reuters, "South Korea Pledges 15 Percent Cut to Iran Oil Imports," 06/24/13)

--

"Its two buyers of Iranian crude, refiners SK Energy and Hyundai Oilbank, are shutting a combined 560,000 bpd of refinery capacity for planned maintenance between March and June." (Reuters, "UPDATE 1-S.Korea's Iran crude imports for March down 16.2 pct y/y," 4/22/2013) 

--
"South Korean refiners SK Innovation Co. and Hyundai Oilbank Co. resumed shipments after Iran offered its own vessels." (Bloomberg, "South Korea’s Oil Imports From Iran Rise 24% From a Year Earlier," 1/14/2013)

--

"South Korean refiners will cut imports of Iranian crude during the six months to May by about a fifth from a year earlier, to avoid sanctions by Washington, government and industry sources told Reuters on Monday. Last week the United States granted 180-day waivers on Iran sanctions to China, India, South Korea and some other countries after they cut oil purchases from the Islamic Republic . . . South Korea, the world's fifth largest importer of crude, and one of Iran's biggest oil customers, gave the assurance on the size of the cuts in talks with the United States following discussions with Korean refiners, the sources said. Such a cut would imply South Korean imports of about 147,814 barrels per day (bpd) over the period to next May, since the country imported 184,767 bpd of Iranian crude from December 2011 to May 2012. Two refiners, SK Energy and Hyundai Oilbank, now import about 200,000 barrels per day of crude from Iran." (Reuters, "South Korea to cut Iran crude imports 20 percent," 12/10/12)

--

"Hyundai Oilbank Co. operates a 395,000 barrel-a-day refinery in Daesan." (Bloomberg, "Iran Oil Tanker Signals for Daesan as Korea Continues Importing," 11/6/2012)

--

"An Iranian supertanker is heading to South Korea with a cargo of oil, according to shipping data, as the Islamic republic uses state-owned tankers to make deliveries in response to sanctions over its nuclear program. The Brawny, a very large crude carrier that can take on 2 million barrels of oil, left the Iranian port of Kharg Island yesterday and is provisionally scheduled to discharge its cargo at Daesan in South Korea, according to transmissions captured by IHS Inc. (IHS) on Bloomberg. National Iranian Tanker Co. owns the vessel. Hyundai Oilbank Co. operates a 395,000 barrel-a-day refinery in Daesan." (Bloomberg, "Iran Seen Sending Own Supertanker to Deliver Oil to South Korea," 10/5/12)

--

"Another refiner, Hyundai Oilbank, will lift two million barrels in Iran by the end of the month, the government source said." (Reuters, "S.Korea's SK Energy lifts 2nd Iran crude cargo-source," 9/26/2012)

--

"South Korean refiners will resume imports of up to 200,000 barrels per day of Iranian crude from September, economy ministry sources said on Monday, ending a two-month gap due to a European Union ban on insurance cover for Iranian oil . . . Total imports envisaged at resumption will be six million barrels per month, or 200,000 bpd. SK Energy will import four million barrels per month and Hyundai Oilbank will import two million barrels per month, the economy ministry source added. This is the volume refiners agreed in term contracts with Iran for this year." (Reuters, "S.Korea to resume Iran oil imports from Sept -econ min sources," 8/20/12)

--

"South Korean refiners plan to resume buying crude from Iran in September after a two-month hiatus due to a European Union embargo that made shipping the oil difficult, government and refining sources said on Wednesday. The refiners have, like their Chinese and Indian counterparts, asked Iran to deliver crude on Iranian tankers, government and industry sources said. This shifts the responsibility to Iran for insurance, sidestepping a ban in the EU on insurers from covering Iranian shipments . . . . South Korean refiners and the National Iranian Tanker Company (NITC) are close to finalising a deal that would allow loading to resume from September, sources said.'Refiners have requested Iran to deliver crude, and the deal is almost reached,' a government source with direct knowledge of the matter said . . . Two refining sources confirmed the request had been made to NITC. SK Energy and Hyundai Oilbank are the only two South Korean refiners that import Iranian crude. The refiners would buy a similar quantity of oil as they had prior to the July stoppage, sources said. There may be some variance month by month due to the size of vessels available for imports from NITC, one refining source said." (Reuters, "S.Korea to resume buying Iranian crude in Sept," 8/8/12)

--

"There's a 'high chance' that South Korea will resume importing Iranian crude oil in the near future, Minister of Knowledge Economy Hong Sukwoo said Thursday…Iranian officials have since offered accident insurance coverage worth a maximum of $1 billion on Iranian tankers shipping crude oil to South Korea, a Hyundai Oilbank official said earlier this month.

Hyundai Oilbank and SK Energy, the two South Korean refiners that imported Iranian crude, are considering Iran's offer to provide shipping services, officials from both companies have said…South Korea usually imports around 10% of its crude-oil requirements from Iran, but that percentage declined to 7.4% in the first six months of this year." (Dow Jones, "S Korea Oil Imports to Iran Seen Restarting," 7/26/12)

--

"Iranian officials have offered accident insurance coverage worth a maximum of $1 billion for Iranian tankers shipping Iranian crude oil to South Korea, a Hyundai Oilbank official, who declined to be named, said Wednesday. Hyundai Oilbank and SK Innovation (096770.SE), which fully owns the nation's other refiner, SK Energy, are considering Iran's offer, officials from both companies said. Both companies imported crude oil from Iran until European Union sanctions that took effect July 1 effectively cut off insurance on Iranian crude shipments July 1 . . . The South Korean refiners are considering using the ships of NITC, or National Iranian Tanker Co., they said. Hyundai Oilbank is negotiating the details--including the offer of insurance and the number of monthly shipments--with Iranian officials, the Hyundai Oilbank official said. An agreement may be reached by the end of the month, he said. Meanwhile, Hyundai Oilbank is waiting for the government, which apparently finds the Iranian proposal 'acceptable,' to give it its official blessing, he said. A government official who asked not to be identified told Dow Jones Newswires earlier this week that government officials were leaning toward accepting the Iranian insurance proposal but that it was 'too early to say' whether it would be approved." (Nasdaq, "Iran Offers $1 Billion Insurance on Tankers to S Korea," 7/18/12)

-- 

"South Korea became the first major Asian consumer of Iranian crude to announce a halt to imports after the government said they would be suspended from July 1 due to a European Union ban on insuring tankers carrying Iranian oil . . . Of South Korea's four refiners, only SK Energy and Hyundai Oilbank import Iranian crude. Sources said both refiners will stop importing from Iran when the EU insurance embargo takes effect from July 1." (Reuters, "South Korea to halt Iran oil imports as EU ban bites," 6/25/12)

--

 "South Korean refiner Hyundai Oilbank, a heavy user of Iranian crude, postponed its planned $2 billion initial public offering on Friday due to the euro zone crisis, and ahead of a pending suspension of Iran crude imports on western sanctions…'The withdrawal has been widely expected in the market. Hyundai will be dealt the biggest blow should Iran oil imports be suspended because it has the highest portion of Iranian oil imports among local peers,' said Lee Jeong-heon, an analyst at Hana Daetoo Securities…Hyundai Oilbank is South Korea's biggest Iran oil buyer, sourcing around 20 percent of its total imports from Iran, higher than the country's 2011 average of 10 percent." (Reuters, "Iran crude buyer Hyundai Oilbank drops $2 billion IPO plan," 6/15/12)

--

"Last month, industry sources said the only other South Korean refinery that buys Iranian crude, Hyundai Oil Bank, would stop imports from June... SK Energy had agreed to import 130,000 barrels per day (bpd) of Iranian crude this year under a long-term supply deal, while Hyundai Oilbank had agreed to import 70,000 bpd." (Reuters, "Exclusive: South Korea poised to halt Iran oil imports from July: sources," 5/21/2012)
--
"SEOUL, March 29 (Reuters) - South Korean refiner Hyundai Oilbank is delaying plans for an initial public offer worth up to $2 billion, partly on investor concerns over its links to Iran, sources said, the second big Asian IPO to be snagged by Western sanctions against Tehran.  Hyundai Oilbank, a heavy user of Iranian crude, is controlled by Hyundai Heavy Industries which initially aimed to list it in South Korea as early as May but is now looking at the second half of the year, three sources with knowledge of the matter told Reuters on Thursday.  The delay follows the postponement of another Iran-linked IPO planned for Hong Kong and reflects widening fallout from the U.S.-led sanctions against Iran." (Reuters, "Hyundai Oilbank to delay $2bln IPO amid Iran sanctions - sources" 3/29/12)
--
"Hyundai Oilbank, the only other South Korean refiner that buys Iranian crude, will import 70,000 bpd in 2012, unchanged from 2011, a Hyundai spokesman said on Wednesday... Hyundai is making contingency plans for any disruption in the flow, the spokesman said." (Reuters, "S.Korea buys more Iran oil but eyes alternatives," 1/4/2012)
--
"In 2009 Iran exported 81,446 bpd of crude to South Korea, 12 percent up versus the previous year, while maintaining its rank as South Korea's fourth-largest crude supplier after Saudi Arabia, the UAE and Kuwait, according to the data from Korea National Oil Corp.  South Korea's top refiners which buy Iranian crude include SK Energy (096770.KS) and Hyundai Oilbank." (Reuters, Iran's crude export and fuel import customers, 4/13/2010)

As of July 2021, the U.S. state of Mississippi did not list Mangalore 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.

--

"Indian refiners and at least one European refiner are re-evaluating their crude purchases to make room for Iranian oil in the second half of this year, anticipating that US sanctions will be lifted, company officials and trading sources said.

An official at Mangalore Refinery and Petrochemicals Ltd said his company would also cut spot purchases and buy Iranian oil." (Mint, "Indian, European refiners get ready to buy Iranian oil," 5/19/21)

--

On September 19, 2007, Mangalore Refinery was added to the Florida State Board of Administration List of Prohibited Investments (Scrutinized Companies) due to its involvement in Iran. As of March 9, 2021, Mangalore Refinery remains on the SBA list of prohibited investments. 

--

In 2020, the U.S. state of Mississippi listed Mangalore 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.

--

In 2019 Mangalore Refinery was listed on the Texas Comptroller List of Companies Engaging in Scrutinized Business Operations in Iran.  

--

Mangalore Refinery is listed on the June 4, 2019 and July 12, 2019 Florida State Board of Administration list of prohibited investments (Scrutinized companies) for Iran related business.

--

"Mangalore Refinery and Petrochemicals Ltd (MRPL) has said that the sanction on Iran (a major crude supplier) is an immediate threat to profitability." (Hindu Business Line, "Sanctions on Iran ‘impose supply and price risk on MRPL’," 7/5/2019).

--

Mangalore Refinery & Petrochemicals is listed on the June 2019 Alaska Retirement Management Board, Companies Doing Material Business with Iran list.

--

Mangalore Refinery and Petrochemicals (MRPL), which imports a fourth of its annual crude oil requirement from Iran, is exploring the option of long-term contract with the US apart from increased sourcing from Saudi Arabia, Iraq, UAE, Kuwait and west African countries, given imports from the sanction-hit country will have to be stopped starting May 2. (Financial Express, "Oil imports: Mangalore refinery to explore US oil for supplies beyond Iran," 4/25/2019).

--

Mangalore Refinery & Petrochemicals is listed on the March 2019 Alaska Retirement Management Board, Companies Doing Material Business with Iran list.

--

"India’s Mangalore Refinery and Petrochemicals Ltd (MRPL) expects India to get a waiver from U.S. sanctions on Iranian oil exports this month, a company official said on Tuesday." (Reuters, "UPDATE 1-MRPL expects India to get waiver from U.S. sanctions on Iran this month - official," 10/16/2018).

--

In 2017 the U.S. state of Alaska, Florida, Pennsylvania, Mississippi, South Carolina, Tennessee, Texas listed Mangalore Refinery & Petrochemicals on its list of companies doing material business with Iran rendering Mangalore Refinery & Petrochemical ineligible for investment and/or state contracting.

--

In 2018 the U.S. state of Ohio listed Mangalore Refinery & Petrochemicals as an Iran restricted company rendering Mangalore Refinery & Petrochemicals  ineligible for investment and/or state contracting. Subsidiary of India's Oil and Natural Gas Corporation.

--

"The drop in volumes follows India's threat to order state refiners—Hindustan Petroleum, Bharat Petroleum, Mangalore Refinery and Petrochemicals Ltd, and Indian Oil Corp—to reduce purchases from Iran if an Indian consortium is not awarded the rights to develop Iran's huge Farzad B natural gas field, Reuters reported." (May 2017)

--

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. Mangalore Refinery 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."

--

"India's purchases of Iranian oil fell 4.1 percent in September, slipping from August when imports from Tehran hit their highest in at least 15 years, according to ship tracking data and a report compiled by Thomson Reuters Oil Research and Forecasts... State-run Mangalore Refinery and Petrochemicals Ltd was the biggest importer of Iranian oil in September buying about 150,200 barrels per day, the data showed." (Reuters, "India's Sept Iran oil imports fall 4.1 percent on Aug - shipping data," 10/12/2016).

--

India is set to buy 6 million barrels of Iranian crude for its strategic oil reserves as negotiations with the United Arab Emirates' national oil company for supplies are stuck over commercial terms, industry sources said... Three industry sources with direct knowledge of the matter said India would buy 6 million barrels of Iranian Mix crude from the National Iranian Oil Co in October and November to fill half the Mangalore storage facility in the southwestern state of Karnataka... State firm Bharat Petroleum Corp will buy 4 million barrels in two very large crude carriers (VLCCs) and Mangalore Refineries and Petrochemicals Ltd will import 2 million barrels, the three sources said. (Reuters, "India set to buy Iran oil for emergency reserves: sources," 9/20/2016).

  --

"Indian media say the country's major oil companies have paid the first installment of outstanding oil dues to Iran. The payment of the installment at a total value of $700 million was made by Essar Oil, Mangalore Refinery and Petrochemicals (MRPL) and other Indian refiners on Wednesday. Essar Oil paid $335 million while MRPL paid about $300 million. The remainder of the payments was made by HPCL-Mittal Energy (HMEL) and Hindustan Petroleum Corp (HPCL)... According to what Iran and the P5+1 agreed in July, the US Treasury's Office of Foreign Assets Control (OFAC) would approve the banking mechanism for payment of $1.4 billion by Indian refiners in two equal installments to Tehran. The Indian media say the refiners had deposited the rupee equivalent of $700 million in Kolkata-based UCO Bank which transmitted the money to the Reserve Bank of India (RBI). The RBI will accordingly make arrangements for its onward remittance to Iran." (Press TV, "India pays first batch of Iran oil dues," 10/1/15)

--

"An Indian delegation will visit Iran this week to scout for investment opportunities ahead of an anticipated nuclear deal between the OPEC-member and world powers that would soften sanctions against the country, sources privy to the plan said. Officials from India's finance and oil ministries and executives from ONGC Videsh and Mangalore Refinery and Petrochemicals Ltd are part of the delegation that will hold meeting with their Iranian counterparts on Saturday, the sources said. India is Iran's biggest oil client after China although its imports from Tehran have declined under pressure from western sanctions." (Reuters, "Indian delegation to visit Iran to discuss oil deals- sources," 4/16/15)

--

In 2015 Mangalore Refinery 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 uner the waivers granted by the U.S. government that meet Section (a)(2) of Act 44's expiration clause."

--

"Private-refiner Essar Oil was the biggest Indian client of Iran in 2014, followed by Mangalore Refinery and Petrochemicals Ltd and Indian Oil Corp." (Reuters, "India oil imports from Iran jump sharply in 2014," 1/16/15)

--

“India spent the past five years cutting its Iranian oil imports to comply with international sanctions. Now, Asia’s second-largest energy user needs the curbs to ease as fighting threatens its supply from Iraq. Tougher U.S. sanctions on Iran meant India was obliged to halve purchases from the Persian Gulf nation since 2009. Indian refiners, which get 85 percent of their crude from overseas, say they expect the restrictions to soften. ‘We may be exempted from cutting imports from Iran this year,’ P.P. Upadhya, managing director of Mangalore Refinery and Petrochemicals Ltd., the second-biggest Indian buyer of Iranian crude, said by phone on June 18. ‘We expect the U.S. will be softer on Iran as the conflict deepens in Iraq.’” (Bloomberg, India Bets on Easing Iran Oil Curbs as Fighting Engulfs Iraq, 6/20/14)

--

“Essar Oil and Mangalore Refinery and Petrochemicals Ltd were the only two Indian refiners that purchased oil from Iran in April.” (Reuters, “India's April Iran oil imports drop as buying spree cools,” 5/14/14)

--

“Mangalore Refinery & Petrochemicals Ltd. (MRPL) plans to spend $1.4 billion to expand crude processing at its facility in western India to meet growing fuel demand in Asia’s third-largest economy…’With the new units, we can buy 10 million tons of heavier grades out of 13 million tons of our annual imports,’ Upadhya said. ‘We are planning about 2 million metric tons of Latin American crude in 2014-15 and 4 million tons of Iran Heavy and Norooz and Soroosh grades, as well as heavier grades of Iraqi crude.’” (Bloomberg, “MRPL Plans $1.4 Billion Expansion as Margins Set to Rise,” 4/29/14)

--

"Private refiner Essar Oil and Mangalore Refinery and Petrochemicals Ltd had a deal to buy 80,000 bpd each from Iran in the last fiscal year. State-owned Indian Oil Corp signed for the other contracted term volumes of 25,000 bpd. Essar bought about 105,400 bpd, 32 percent higher than its contract, while MRPL shipped in 83,800 bpd, said the official. 'Essar took almost half of our overall imports from Iran (in 2013/14). They (Iran) are offering better deals than others in the Gulf,’ the official said. Essar Oil officials did not respond to an e-mailed request for further details.Iran has been offering free shipping and discounts on crude sales to Indian refiners to boost its exports.” (Reuters, “India cuts Iran oil imports nearly a fifth in 2013/14,” 4/17/14)

--

“Private refiner Essar Oil will be the biggest Indian buyer of Iran's oil this financial year, replacing state-owned Mangalore Refinery and Petrochemical. Essar will have lifted about 30 percent higher than its contract volume of 80,000 bpd, said another government source. A jump in Essar's Iran oil imports comes as Iran is giving India a discount on crude and offering free delivery. Essar has offered to take about 5.36 million barrels in March from Iran, taking its annual purchases to 105,000 bpd. MRPL's oil imports from Iran will average about 84,000 bpd this fiscal year versus contract levels of 80,000 bpd, the third government source said.” (Reuters, “Exclusive: India to slash Iran oil imports to meet nuclear deal parameters - sources,” 3/11/14)

--

"State-controlled Indian refiners halted Iranian purchases in May after insurers denied coverage to plants using Iranian crude following growing pressure of sanctions against the Islamic republic from the U.S. and Europe. Mangalore Refinery & Petrochemicals Ltd. (MRPL), which gets more than a quarter of its crude requirement from the country, resumed purchases in August using tankers underwritten by two Iranian insurers with sovereign guarantees from India.’We’ve no option but to continue with Iran imports by taking this calculated risk,’ Mangalore Refinery Managing Director P.P. Upadhya said in a phone interview. Mangalore Refinery is operating its 300,000 barrels-a-day plant without any cover, Upadhya said. The company plans to buy 4 million tons from Iran this financial year and increase purchases next year, he said. Moallem Insurance and Kish P&I Club, the two Iranian insurers, were given a six-month extension effective Dec. 28 to cover foreign ships arriving at Indian ports, Deepak Kapoor, India’s deputy nautical adviser, said in a phone interview. India has yet to roll out a proposed 20 billion rupee ($314 million) insurance fund to cover imports from Iran.” (Bloomberg, “India Refiners Delay Iran Imports on Failure to Get Reinsurance,” 1/7/14)

--

"India's oil imports from Iran fell 34.8 percent in April-November from a year ago despite a jump last month, giving New Delhi room to import more till March and still win another waiver of U.S. sanctions…India's oil shipments from Iran rose 13 percent in November from October to 219,700 bpd triggered by higher imports at Mangalore Refinery and Petrochemicals Ltd (MRPL), the data shows. MRPL began receiving fully loaded suezmax vessels at its recently commissioned single point mooring after getting full cover from a local insurer. Last month, MRPL received two suezmaxes of Iranian oil at its crude handling facility. It is not clear which company reinsured the facility." (Reuters, "India poised to boost oil imports from Iran after April-November shipments slide," 12/18/13)

--

In 2013, 2014, 2015, 2016 and 2017 Mangalore Refinery was listed on the Texas Pension Review Board List of Scrutinized Companies doing business in Iran pursuant to Chapter 807.054, Government Code.  
 

--

In 2013, Mangalore Refinery was added to the Pennsylvania Treasury's List of Scrutinized Companies Determined as Having Involvement in Iran because of government oil-related activity. 

--

"India could step up imports from Iran next month and start transferring billions of dollars owed it for oil as early as next week following a deal to curb Tehran's nuclear programme…'Next week if it is possible, we will start making our payments,' said P.P. Upadhya, managing director of Mangalore Refinery and Petrochemicals Ltd, one of the Indian buyers of Iranian crude. A government official also said that payments would be expedited once the payment mechanism via Turkey opens up. 'If that Halkbank route opens up ... rather than pushing this to a later date, perhaps this money will go to the Iranians sooner rather than later,' the official with direct knowledge of the matter said." (Reuters, "India ready to start Iran oil cash transfer after deal," 11/25/13)

--

"Indian refiners have asked the government to clarify if they can pay Iran for crude in euros after the National Iranian Oil Company (NIOC) requested settlement of some debts through a Turkish bank, Indian officials said on Wednesday…India now owes Iran about $5.3 billion for oil imports, government and refining sources said last week. In mid-October, NIOC informed Indian refiners that Halkbank was ready to restart channelling the payments to Iran, the sources told Reuters, declining to be named due to the sensitivity of the matter. NIOC said it had been informed that Halkbank could be used again by Iran's central bank. It was unclear from the communication from NIOC what had changed that would allow the payments to restart without contravening U.S. sanctions, the sources said…Indian refiners have yet to restart payments via Halkbank and have asked the government for guidance, the sources said…Indian refiners Essar Oil, Mangalore Refinery and Petrochemicals Ltd, Hindustan Petroleum and Indian Oil Corp have all bought crude from Iran and owe payment, sources said." (Reuters, "Indian refiners puzzle over Iran request for euro oil payment-sources," 11/13/13)

--

"Bharat Petroleum Corp. Ltd. (BPCL) and Hindustan Petroleum Corp. Ltd. (HPCL) will forego buying Iranian crude even as Mangalore Refinery & Petrochemicals Ltd. (MRPL) accepts an offer from the Persian Gulf nation to waive shipping charges. Refiners want to import crude in rupees amid a 13% slump against the dollar this year while Iran doesn’t want to accept the Indian currency, according to the government in New Delhi. While MRPL has accepted an offer for free shipping, BPCL and HPCL haven’t brought oil from the Islamic Republic since April…Iran, a member of the Organization of Petroleum Exporting Countries (Opec), has been shipping crude cargoes for free to MRPL since August, according to a company official who asked not to be identified because he isn’t authorized to speak to the media. The free shipping will translate into a saving of a little less than a dollar for every barrel of crude, according to the official, who declined to provide further details of MRPL’s purchases.…India plans to purchase 11 million metric tonnes of Iranian crude in the year ending 31 March, according to oil secretary Rae. That would be a drop of more than 15% from the previous year." (Live Mint, "BPCL, HPCL forego Iran oil as rival gets free shipping," 11/8/13)

--

"Iran is offering free delivery of crude to major client India, industry sources said, signalling that tough Western sanctions which have slashed its exports in half are driving Tehran to increasingly desperate measures to keep oil flowing…Iran's remaining Indian clients - Mangalore Refinery and Petrochemicals Ltd, Essar Oil and Indian Oil Corp - could save freight of 70 cents to $1 a barrel on purchases from Iran, said one of the sources…India is one of Iran's few remaining clients along with other Asian buyers China, Japan and South Korea. (Reuters, "Iran offers to ship crude to India for free to boost sales," 11/7/13)

--

"Refiner Mangalore Refinery and Petrochemicals Ltd (MRPL.NS) was the biggest importer of Iranian oil in September, replacing Essar Oil (ESRO.NS) by shipping in 133,000 bpd, the data showed." (Reuters, "India's Iran oil imports drop as refiners await insurance fund," 10/29/13)

--

"Oil and container trade between India and Iran has been disrupted due to uncertainty over insurance cover, leaving some ships stranded outside ports in both countries, industry sources said. The delays had occurred because New Delhi had not yet extended approval for Iranian underwriters to provide insurance for container and tanker vessels calling at Indian ports, they said…A three-month approval by India for Iran's Kish P&I and Moallem Insurance Co to cover container and tanker vessels calling at Indian ports lapsed on September 27…Another aframax, Superior, for Mangalore Refinery and Petrochemical Ltd's (MRPL.NS), was also at anchorage at an Indian port, they said. MRPL, which aimed to get five aframax-size cargoes from Iran this month, had complained to India's oil ministry about the delay in the shipping ministry granting approval to Iranian underwriters, the source said." (Reuters, "Iranian trade with India hit by insurance delay - sources," 10/8/13) 

--

"India aims to cut Iranian crude imports by 15 percent this fiscal year, the oil secretary said on Tuesday, differing from the oil minister who recently said he wanted to hold the shipments at last year's levels. Ahead of Prime Minister Manmohan Singh's visit to the United States last week, Oil Minister M. Veerappa Moily said Iranian imports should be held steady at 260,000 barrels per day (bpd) to save as much as $8.5 billion in foreign exchange as Tehran accepts partial payment in rupees. However, Oil Secretary Vivek Rae, the Petroleum Ministry's top bureaucrat, said on Tuesday that India targets oil imports of around 220,000 bpd from Iran in the year through March 2014…Mangalore Refinery and Petrochemicals and Essar Oil - the only Indian refiners currently importing Iranian crude - will import about 80,000 bpd each this fiscal year." (Reuters, "India aims to cut Iran oil imports by 15 pct - oil secretary," 10/1/13)

--

"India's imports of Iranian oil shot up in August to more than four times the volume taken in July as one refiner resumed purchases after a four-month break, but the average annual pace of shipments is still far below last year's levels . . . Only two refiners - Essar Oil and state-owned Mangalore Refinery and Petrochemical Ltd - bought Iranian oil in August. MRPL, which used to be Iran's top Indian client, bought its first oil from the sanctions-hit nation since April, the data shows. MRPL resumed the imports after securing local reinsurance for claims up to 5 billion rupee ($79 million). In addition, India is planning to provide a 10 billion rupee sovereign guarantee to back local insurance for refineries using Iranian oil, according to government sources. The government guarantee is half of a package that would assure refiners running Iranian oil of about 20 billion rupee in insurance coverage . . . MRPL and another state refiner, Hindustan Petroleum Corp Ltd , had halted Iranian oil imports in April, primarily over the insurance issue. However, as they waited for the government plan to shore up the local insurers, some refiners determined that there are suitable substitutes for Iranian crude." (Reuters, "India's Iran oil imports far below levels last year -trade," 9/20/13)

--

"The government will provide a 10 billion rupee sovereign guarantee to back local insurance for refineries using Iranian oil, two government sources said, as it tries to boost imports paid for in local currency to ease pressure on the rupee . . . 'It was finalised yesterday in a meeting with the petroleum secretary. An energy pool will be set up with a sovereign guarantee,' one of the sources, both of whom have direct knowledge of the matter, said . . . 'The issue has been resolved. GIC (local reinsurer General Insurance Corp) will manage the pool. In case there is any mishap or something, then they will pay,' the second source said. The sources said apart from the 10 billion rupees sovereign backing, GIC and oil companies will provide 5 billion rupees each to the pool . . . Refiner Mangalore Refinery and Petrochemicals Ltd (MRPL.NS) resumed imports from Iran in August after it secured local reinsurance for claims up to 5 billion rupees. MRPL, once Iran's biggest Indian client, halted imports in April due to lack of insurance cover. The sovereign guarantee 'will essentially provide comfort to the insurance companies to the extent that they will provide cover without going to reinsurers abroad,' MRPL's managing director P.P. Upadhya told Reuters.'There will be no change in our strategy to buy Iranian oil,' he added . . . With the start of this re-insurance cover local insurers will delete the sanctions clause from the existing annual policy of Indian refiners processing Iranian oil, two oil industry sources told Reuters." (Reuters, "Government to back up insurance for refiners processing Iranian crude," 9/18/13)

--

"Mangalore Refinery & Petrochemicals Ltd. (MRPL) purchased its first cargo of Iranian crude since April as India prepared a 20 billion-rupee ($314 million) insurance fund to cover future imports. The refiner, India's biggest buyer of Iranian crude, received about 85,000 metric tons on Aug. 17, Managing Director P.P. Upadhya said in a phone interview today from Mangalore. The company has ordered three more shipments of a similar size, he said, without stating delivery schedules. 'This is the first cargo we've got from Iran this financial year and we'll see how many more we can import in the rest of the year,' Upadhya said. 'The same ship has returned to Iran and will bring the additional cargoes.'" (Bloomberg, "Mangalore Refinery Resumes Iran Oil Buying as Insurance Sought," 8/20/13)

--

"Mangalore Refinery and Petrochemicals Ltd said on Monday it expects to receive an Iranian oil cargo by the end of this week, the firm's first purchase from the sanctions-hit nation since April. The resumption of shipments by MRPL, Iran's top Indian client until the firm halted imports in April, will boost India's flagging Iranian oil imports, which more than halved in June from a year ago... 'It (the cargo) was loaded at Kharg (island) on 8th and 9th of this month and is likely to reach Mangalore by the end of this week,' MRPL's managing director P.P. Upadhya said, adding the firm planned to lift four Iranian oil cargoes this month. India is thinking of providing a Rs 20 billion ($327 million) state guarantee to back local insurance for plants using Iranian oil, an industry source said last week. 'Regarding the reinsurance issues, GIC (General Insurance Corp) is working out the plan and we hope it will take care of our interest,' Upadhya said, adding MRPL was finding it difficult to replace Iranian crude. He said Iranian crude was best suited for his refinery but MRPL would also process other crudes once a coker was ready in around two months. MRPL, a subsidiary of oil and gas producer Oil and Natural Gas Corp, operates a 300,000 barrels-per-day refinery in southern Karnataka state." (Economic Times, "MRPL to receive Iranian cargo after four-month gap," 8/12/13)  

--

"India's Mangalore Refinery and Petrochemicals Ltd plans to resume Iranian oil imports from August, after stopping for four months, because it has found no suitable alternatives, an industry source with knowledge of the matter said. Resumption of shipments by MRPL, Iran's top Indian client until it stopped purchases in April, will help to revive the country's Iranian oil imports. India's intake of Iranian crude fell by 40 percent in the April-June quarter, as refiner Essar Oil became Iran's lone Indian client. Hindustan Petroleum Corp and MRPL both halted their Iranian oil buys amid difficulties securing insurance for refineries processing oil from the sanctions-hit country. 'Other crudes are not giving the right price margin. They are not of right type of quality and are not available at the right time,' said the source. 'All these problems are there.' . . . MRPL aims to import about 80,000 bpd of oil from Iran in the current fiscal year, similar to lifting in the year ended March 31, and could ship in up to four aframax cargoes in August. MRPL Managing Director P.P. Upadhya said in a June 29 letter that local reinsurer General Insurance Corp would be able to settle any refinery claim up to 5 billion Indian rupees ($82.83 million) as long as India has a U.S. sanctions waiver that allows it to continue imports of crude oil from Iran. Under its current policy with a local insurer, MRPL is entitle for a permissible maximum loss of 70 billion rupees . . . New Delhi and Tehran are trying to strengthen trade ties, partly to keep Iran's oil flowing and partly so Indian can pay for the crude with exported goods. Iran's oil minister visited India in May and offered to provide insurance for the refineries running Iranian oil, in return for stepped up purchases from the OPEC member. Iran has also made sovereign guarantees to domestic insurance companies that cover vessels carrying oil to India. An Iranian insurance delegation is expected to visit India from Aug. 12 to 16 to explore the feasibility of providing reinsurance cover to refiners." (Reuters, "India's MRPL aims to resume Iran oil imports from Aug," 7/31/12)

--

"Mangalore Refinery and Petrochemicals Ltd plans to resume Iranian oil imports from August, after stopping for four months, because it has found no suitable alternatives, an industry source with knowledge of the matter said. Resumption of shipments by MRPL, Iran's top Indian client until it stopped purchases in April, will help to revive the country's Iranian oil imports. India's intake of Iranian crude fell by 40 percent in the April-June quarter, as refiner Essar Oil became Iran's lone Indian client... MRPL aims to import about 80,000 bpd of oil from Iran in the current fiscal year, similar to lifting in the year ended March 31, and could ship in up to four aframax cargoes in August. MRPL Managing Director P.P. Upadhya said in a June 29 letter that local reinsurer General Insurance Corp would be able to settle any refinery claim up to 5 billion Indian rupees ($82.83 million) as long as India has a U.S. sanctions waiver that allows it to continue imports of crude oil from Iran. Under its current policy with a local insurer, MRPL is entitle for a permissible maximum loss of 70 billion rupees." (The Economic Times, "MRPL Aims to Resume Iran Oil Imports From August: Report," 7/31/13)

--

"Two government-run refiners, Mangalore Refinery and Petrochemicals Ltd and Hindustan Petroleum Corp, stopped importing oil from Iran from April, as local insurers said they could no longer cover plants that process Iranian oil after Europe-based reinsurers backed out." (Reuters, "Table-India Essar's June Iran Oil Imports Up 21.1 pct-trade," 7/24/13)

--

"MRPL is preparing to resume oil imports from Iran, after stopping in April, having secured local reinsurance for claims of up to 5 billion rupees, its managing director said in a letter seen by Reuters. Mangalore Refinery and Petrochemicals (MRPL.NS), which was Iran's top Indian client, halted imports because local insurers said they could no longer cover plants that process Iranian crude. 'MRPL would take all necessary steps for recommencement of import/processing of Iranian crude oil in its refinery,' MRPL P.P. Upadhya wrote in a June 29 letter to Oil Secretary Vivek Rae. Upadhya referred in the letter to meetings with officials from the oil ministry and local reinsurer General Insurance Corp. (GIC) in the letter, copy of which was made available to Reuters, for the plan to resume imports from Iran... GIC would be able to settle any claim up to 5 billion rupees, so far the maximum that has arisen in Indian refining sector, without depending on overseas reinsurers, Upadhya wrote. 'GIC pointed out that in such a scenario, a calculated business risk may be taken by MRPL, similar to what is being taken by Essar, if they desire to recommence processing of Iranian crude oil at their refinery,' Upadhya wrote in the letter... Upadhya, who had earlier said MRPL plans to import 80,000 barrels per day in the current fiscal year, declined to comment on the letter." (Reuters, "MRPL Aims to Resume Iran Oil Imports," 7/1/2013) 

--

"Mangalore Refinery and Petrochemicals Ltd and Essar Oil have said they would halt imports from Iran because of insurance problems, Vivek Rae told reporters... MRPL plans to lift 40 percent less oil under its annual deal with Iran in the fiscal year ending March 31, while Essar Oil aims for a 15 percent reduction. The two companies have a deal to buy 100,000 barrels per day of oil from Iran in 2012/13." (Reuters, "India plans reinsurance fund to cover refiners using Iranian oil," 3/24/2013)

--

"Royal Dutch Shell PLC, sold two high-sulfur oil cargoes to Mangalore Refinery & Petrochemicals (MRPL), the biggest state-run Indian buyer of Iranian crude, as supplies from the Persian Gulf state may be disrupted because of global sanctions. Mangalore, a unit of Oil and Natural Gas Corp., bought 650,000 barrels each of Oman and Banaco Arab Medium crude from Shell for loading next month, according to four traders who asked not to be identified because the information is confidential. The grades are similar to Mangalore’s imports from Iran, the traders said. Indian refiners may halt Iranian crude purchases as local insurers refuse to cover the risks for using the oil, P.P. Upadhya, the managing director at Mangalore, said March 8. The company, known as MRPL, has an contract to buy 5 million metric tons a year from the Islamic Republic... MRPL bought the Oman crude for loading from April 16 to April 30 at a premium of about $1.70 a barrel to Dubai crude on a cost and freight basis, the traders said...  MRPL may import 3.8 million tons of Iranian crude during the year ending March 31, down from its term contract for 5 million, Managing Director Upadhya said on Jan. 31. Shipments of 'even 3.8 million tons in the next financial year may be difficult,' he said." (Bloomberg, "MRPL Said to Buy Oil From Shell on Possible Iran Disruptions," 3/18/2013)

--

"India is set to halt all crude imports from Iran because insurance companies in the country have said refineries processing the oil will no longer be covered due to Western sanctions, the head of refiner MRPL said on Friday. India is Iran's second-largest buyer, taking around a quarter of its oil exports worth around $1 billion a month. 'If cover is not available then all Indian refiners will have to halt imports from Iran or else they will have to take a huge risk,' P.P. Upadhya, managing director of Mangalore Refinery and Petrochemicals Ltd, told Reuters in a telephone interview. MRPL is India's biggest buyer of Iran crude. 'Insurance companies said if I buy Iranian crude my refinery's insurance cover will be canceled ... If we don't get insurance for the refinery then we will stop buying Iranian crude.' It was not immediately clear why this has become an issue now, several months after Europe and the U.S. introduced tough sanctions aimed at Iran's oil trade to force Tehran to the negotiating table over its nuclear program. But in a letter in January seen by Reuters, the General Insurance Corp of India, the national reinsurer, told the General Insurance Council, an industry group, that it had 'dawned' on insurers that cover and losses on processing the crude would not be payable by reinsurers due to existing sanctions." (Reuters,"Exclusive: India set to halt Iran oil imports over insurance - MRPL," 3/8/13)

--

"NITC has chartered the vessel the Omvati Prem, owned by Mumbai-based Indian shipper Mercator Ltd , and used it to carry an oil cargo that sailed from Iran in December for Indian refiner Mangalore Refinery and Petrochemicals Ltd , the sources said. The deal included cost, insurance and freight (CIF), they said... Mercator was the only company to use the scheme. Before NITC chartered the Omvati Prem, MRPL had used the vessel -- which can carry about 635,000 barrels -- to import Iranian crude. MRPL is India's biggest buyer of Iranian crude and did not charter the vessel for this voyage due to commercial and technical reasons, one source said... 'Iran offered Mercator a better rate than MRPL, that's why they have taken the risk of joining hands with NITC,' another shipping source said... MRPL, India's shipping ministry, United India Insurance and The New Indian Assurance Co Ltd all declined to comment for the story." (Reuters, "Iran charters oil ship with Indian insurance: sources," 1/15/2013)

--

"India's oil imports from Iran fell nearly 5 percent in August from July, tanker discharge data made available to Reuters showed on Thursday, in a third straight monthly drop that supports the country's case for renewal of a waiver from U.S. sanctions. Imports rose by about a fifth from a year ago, however, when Iran cut supplies to its second-biggest market as Indian firms had still not found a stable way to pay for oil after New Delhi ended a clearing mechanism under U.S. pressure in December 2010... One of Tehran's biggest Indian clients, MRPL, has not been able to import all its contracted volumes since July, when European sanctions banning shipping and insurance cover for Iranian vessels took effect." (Reuters, "India's Aug Iran imports fall 5 pct on mth; up 19 pct on yr-trade," 9/27/12)

--

"India's oil imports from Iran fell by more than 40 percent in July from June and a year ago, as imports by Tehran's biggest local client MRPL were hit by a shortage of ships and insurance cover caused by European Union sanctions . . . In July Essar emerged as Iran's top Indian client replacing Mangalore Refinery and Petrochemicals, which lifted only a fifth of planned Iran imports in July. MRPL is looking at alternatives to make up for the Iran shortfall . . . Essar's imports rose by a third in July to 154,400 bpd compared with June, the data showed, while MRPL's declined 86 percent to 22,200 bpd." (Reuters, "India cuts July Iran oil imports by over 40 pct y/y-trade data," 8/21/12)

--

"State-run Hindustan Petroleum (HPCL) has made its first payment for Iranian oil in rupees to partially settle its bill for a cargo imported in May, company officials said on Friday, a move that will help New Delhi fix its trade imbalance with Tehran. Another state refiner, Mangalore Refinery and Petrochemicals Ltd, the biggest Indian buyer of Iranian oil, will make a rupee payment on Monday, a company official said . . . India has already won a waiver from tough new U.S. sanctions by cutting imports from Iran. But insurance and shipping difficulties caused by European Union sanctions that started in July are hurting imports from Iran, forcing MRPL to buy only a fifth of planned shipments from Tehran during the month . . . MRPL's first August cargo from Iran is already on its way to Mangalore Port in southern India in the Iranian vessel Gardenia while HPCL is seeking the shipping ministry's permission to lift a cargo from Tehran next week." (Reuters, "India HPCL begins rupee payment for Iran oil," 8/3/23)

--

"India, the third-biggest buyer of Iranian oil, will offer state-backed insurance to tankers, helping the nation’s biggest sea carrier to resume cargoes from the Persian Gulf nation hit by international trade sanctions…The resumption of services will help Mangalore Refinery & Petrochemicals Ltd. (MRPL), India’s biggest buyer of Iranian crude, and other state processors secure supplies after European Union measures disrupted trade…Mangalore Refinery halted purchases from Iran after the sanctions made it impossible to get ships to carry the crude, Managing Director P.P. Upadhya said last week. That prompted the company to buy more of its requirements from the spot market where prices are typically higher." (Bloomberg, "Iran Oil Shipping To Resume As Insurers Step In," 8/2/12)

--

"India has finally agreed to follow U.S. sanctions against Iran and recently banned at least four shipments of crude oil to the country.

India was allowing the local Mangalore Refinery and Petrochemicals Ltd (MRPL) and some other state refineries to import Iranian crude oil on cost, insurance and freight  basis — wherein Tehran was to arrange for ships and insurance, and would receive no profit from the sale.  It was a loophole that New Delhi was apparently comfortable enough jumping through.

But within days, the government revoked the permission and MRPL, the nation’s largest importer of Iranian oil, could only land one out of four July shipments, The Economic Times of India reported on Friday…MRPL had in 2011-12 contracted 7.3 million tons of crude oil from Iran but imported only 6.2 million tons because India reduced its imports from Iran in order to get a waiver from U.S. sanctions. This year, it plans to import just 5 million tons.  Iran is the fourth largest oil supplier in India." (Forbes, "India Bans Iran Oil Tankers From Delivery," 7/27/12)

--

"India's biggest buyer of Iranian oil, MRPL, has bought Azeri, Saudi and Emirati crude to replace imports from Iran in July and it may halt purchases from Tehran altogether as sanctions make shipments more difficult,industry sources said on Monday. Loss of exports to Mangalore Refinery and Petrochemicals(MRPL) would be a blow to Iran, which has seen overseas sales decline by more than half from a year ago due to U.S. and European Union sanctions. 'MRPL has initiated steps to halt its imports from Iran. It is facing problems on a daily basis ... government pressure, sanctions and the latest is Iran's threat to shut the Strait of Hormuz,' said one of the sources . . . The refiner has been forced to restrict its lifting from Iran to a fifth of the planned 3.3 million barrels per day (bpd)in July . . . MRPL has signed a two-month deal with Azerbaijan after shipments from Tehran were hit in July, besides buying an additional cargo each from its existing suppliers United Arab Emirates and Saudi Arabia, to offset Iranian supply cuts . . . MRPL's move highlights the gradual increase in share of non-Iranian supplies in the world's fourth-biggest oil importer's crude basket and the emergence of new trade routes as Tehran's exports decline. MRPL may import only one of its planned five Iran oil cargoes in July after its shippers Great Eastern Shipping Co.(GESCO) refused to carry Iranian crude and New Delhi scrapped an order permitting use of Iranian tankers and insurance." (Reuters, "India's top buyer of Iran oil turns to Azeri, Saudi," 7/16/12)

--

"India's biggest buyer of Iranian oil may only import one-fifth of the 3.3 million barrels of crude it had scheduled for July due to insurance and shipping difficulties caused by European Union sanctions on Tehran, industry sources said.

The possible drop in imports by state-owned refiner Mangalore Refinery and Petrochemicals Ltd (MRPL) underscores the problems the EU sanctions, which ban most of the world's major insurance firms from covering shipments of Iranian oil, have created for Iran's major Asian customers China, India and Japan since coming into effect on July 1.

Along with U.S. sanctions, the EU measures, which include an oil embargo, has so far halved Iran's year-on-year oil sales…India had initially allowed state-owned refiners to use Iranian tankers to ship oil purchases from Iran but swiftly backtracked to benefit its own shipping industry, stipulating that state-run oil firms must use Indian ships and allowing limited coverage by state-run insurers for Iranian cargoes. 

MPRL had planned to import five cargoes of 660,000 barrels each from Iran in July. The shipping ministry gave it approval to ship a single cargo on an Iranian tanker after the blanket approval was withdrawn, two industry sources said.

The company may not be able to transport any more cargoes as its shipping firm, the privately-owned Great Eastern Shipping Company (GESCO), is unwilling to carry Iranian crude due to the limited insurance cover.

'Iran had allocated two aframaxes to MRPL to ensure supply of at least four cargoes in July, but now the shipping ministry is not giving permission to buy on a CIF (delivered) basis and Great Eastern is still keeping MRPL in the dark,' said one of the sources.

'MRPL is talking to Great Eastern, but it looks unlikely that it will use its vessels for Iranian oil imports.'

MRPL has an annual shipping contract with GESCO. Indian insurers will only give shipping firms carrying Iranian oil $50 million per tanker in protection and indemnity cover, a fraction of the typical $1 billion in insurance that Western firms provide for a very large crude carrier…MRPL's first July cargo from Iran is in the NITC (National Iranian Tanker Company) aframax Magnolia, which is scheduled to reach New Mangalore Port next week, one of the sources said." (Reuters, "India's main Iran oil buyer may cut July imports," 6/12/12)

--

"India has given state-run insurers approval to provide limited cover to its ships transporting Iran's oil, allowing refiners to avoid any interruption in supplies because of the constraints of an Iranian fleet struggling with tough Western sanctions . . . India has already cut its Iranian oil purchases by more than a fifth, enough to win a waiver from separate U.S. sanctions, and is expected to load around 300,000 barrels per day this month. But NITC has few of the vessels of the size needed to meet the requirements of at least one Indian refiner, Mangalore Refinery and Petrochemicals Ltd." (Reuters, "India insures Iran oil imports to safeguard flow -sources," 7/10/12)

--

"The Shipping Ministry has said it has 'no objection' to refiners buying oil from Iran on a delivered basis 'for 6 months with effect from July 1, 2012 or until GIC provides P&I/H&M (Hull and Machinery) cover or U.S., EU sanctions are lifted; whichever occurs earlier,' said a source privy to the letter . . . Mangalore Refinery and Petrochemicals (MRPL) had already switched to insuring the oil with Iran Insurance Company, as its policy lapsed and local insurance companies refused to extend the cover, wary of the sanctions." (Reuters, "Exclusive: India allows use of Iran ships for oil imports," 6/25/12)

--

"Indian refiners cut imports from Iran by 38 percent in May from a year ago, tanker discharge data showed, in a second month of steep reductions as they switch suppliers to cushion the impact of new U.S. sanctions on Tehran . . . MRPL nearly halved annual imports from Iran in January-May to about 80,800 bpd. It bought about 52 percent less oil in May from Iran compared with April at 43,000 bpd, the data showed, due to a full shutdown of its refinery during the month . . . MRPL has reduced the size of its [annual deal with Iran] to 100,000 bpd compared with 142,000 bpd in 2011/12." (Reuters, "India cuts May Iran oil imports 38 pct-trade" 6/7/12)

--

"Indian refiner Mangalore Refinery and Petrochemicals Ltd plans to cut its crude purchases from sanctions-hit Iran to 100,000 barrels per day (bpd) in the current fiscal year, its managing director said on Wednesday." (Financial Times, "MRPL to cut Iran oil imports to 100,000 bpd: Executive," 5/24/2012)

--

"Indian refiner MRPL secured coverage from an Iranian insurer for a crude cargo that arrived last week, becoming the first Indian firm known to have taken such action as Western sanctions tighten, sources with knowledge of the matter said... Indian insurers denied coverage to Mangalore Refinery and Petrochemicals for fear the action could fall foul of a pending European oil embargo against Iran... But an Iranian insurer provided cover for MRPL's crude cargo of about 7 07,500 barrels that arrived at India's Mangalore Port last week, the sources said... '(MRPL) recently got a cargo insured by an Iranian firm and other cargoes can also be insured from Iran. The company will do that on a case-by-case basis,' said one of the sources... Another source said MRPL might continue to get Iranian insurance cover for oil imports from Tehran. 'As long as we can avail of Iranian cover we will continue to import cargoes on that basis,' the source said. MRPL is a major Indian buyer of Iranian oil and its insurance policy with New India Assurance Co Ltd for cargoes lapsed this month. State-run insurers were willing to extend cover for crude cargoes except those from Iran under MRPL's new policy, another source said, forcing the refiner to approach Iran. MRPL and other oil firms buy insurance to protect their crude cargo, while ship owners usually arrange cover for the ship and any liability from an oil spill or personal injury... MRPL is buying oil on a free-on-board (FOB) basis with insurance covered by the Iranian firm. MRPL has cut to 100,000 bpd its annual crude import deal with Iran for this fiscal year, about 30 percent lower than last year, the first source said, adding the actual off-take could be less. Some units at MRPL's 300,000 bpd refinery in southern India are shut for maintenance, leading to reduced purchases of Iranian oil in May and June, this source said, adding it bought 124,000 bpd from Iran in 2011/12 versus a deal of 142,000 bpd." (Reuters, "Indian refiner MRPL turns to Iran for oil insurance -sources," 5/21/2012)

--

"Iran is poised to lose at least 192,000 barrels a day of crude-supply contracts, or about 9.5 percent of its global exports, as Asian buyers curb purchases amid western sanctions targeting the nation's oil trade. Mangalore Refinery & Petrochemicals Ltd. (MRPL) and Essar Oil Ltd., India's biggest buyers of Iranian crude, and China International United Petroleum & Chemical Co. have reduced or plan to cut purchases from the Islamic Republic by as much as 15 percent. China and India are Iran's largest customers. In Japan, the only Asian country to get an exemption from U.S. sanctions after it demonstrated reductions in purchases, Cosmo Oil Co. plans to cut imports by 25 percent, while JX Nippon Oil & Energy Corp. suspended talks with the Persian Gulf nation over a 10,000 barrel-a-day contract." (Bloomberg, "Iran May Lose 9.5% of Oil Contracts as Asian Buyers Cut Imports," 5/3/12)

--

"India's top two importers of crude oil from Iran will reduce shipments from the Persian Gulf nation by at least 15% this financial year, the latest sign that New Delhi is playing ball with Washington's efforts to shut-down Iran oil trade despite public pronouncement from Indian officials that they will continue to buy from Tehran. The government has asked state-owned Mangalore Refinery & Petrochemicals Ltd. and Essar Oil Ltd., a private company, to cut their imports in the year through March 2013 due to demands from the U.S., said two people with direct knowledge of the matter. 'Definitely, there is a lot of pressure from the U.S.,' one of the people said. A spokesman for India's oil ministry did not immediately respond to a request for comment." (WSJ, "Under U.S Pressure, India to Cut Iran Imports," 5/2/12)

 --

"State-run Mangalore Refinery and Petrochemicals Ltd has raised further the size of its annual crude import deal with Saudi Arabia by nearly 17 percent, sources said, to make up for planned lower imports from Iran. The Indian refiner, which had almost doubled its Saudi deal from January to 42,000 barrels per day (bpd) will now get an average 49,000 bpd this year, said the sources. MRPL, Iran's biggest Indian oil client, plans to cut its imports from Iran to 80,000-100,000 bpd in 2012/13 (March-April) from 142,000 bpd the previous year, sources had earlier told Reuters." (Reuters, "India MRPL raises Saudi import deal to 49,000 bdp-sources," 4/17/12)

--

"Historically, Iran's biggest Indian oil client was Mangalore Refinery and Petrochemicals Ltd (MRPL), which bought 110,000 in the first quarter, down from 162,0000 bpd in 2011, the data showed." (Reuters, "India replaces China as Iran's top oil client," 4/13/2012)

--

"Another refiner, Mangalore Refinery and Petrochemicals Ltd (MRPL), has begun making contingencies, however, and has floated four tenders for supplies in the short-term from other sources.

MRPL is India's biggest buyer of Iranian crude, with more than half its supply coming from the Islamic republic." (AFP, "Indian oil giant optimistic over Iran supply," 1/6/11)

--

"State-run Mangalore Refinery and Petrochemicals Ltd will reduce term crude imports from Iran by about 8.5 percent to 130,000 barrels per day (bpd) for the 2010/11 fiscal year that began on April 1, a senior company official said on Monday.  MRPL is India's top importer of Iranian crude and buys Iran Mix and Iran Heavy varieties." (Reuters, MRPL trims '10/11 crude import deal with Iran, 4/5/2010)

As of March 9, 2021, Petronet LNG remained on the Florida SBA List of Continued Examination Companies with Petroleum Energy Activities in Iran. 

--

On October 14, 2020, Petronet LNG 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.

--

As of May 28, 2020, the Florida State Board of Administration (“SBA”) continues to list Petronet LNG on its list of “Continued Examination Companies with Petroleum Energy activities in Iran.”  

--

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

--

As of December 31, 2019, the Alaska Retirement Management Board lists Petronas LNG as a company doing material business with Iran.

--

Petronet LNG is listed on the June 2019 Alaska Retirement Management Board, Companies Doing Material Business with Iran list.

--

Petronet LNG is listed on the March 2019 Alaska Retirement Management Board, Companies Doing Material Business with Iran list.

--

On March 13, 2019, the Mississippi Department of Finance & Administration identified Petronet LNG 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 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.” Petronet 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 2017 the U.S. state of Alaska listed Petronet  on its list of companies doing material business with Iran rendering Petronet ineligible for investment and/or state contracting.

--

In 2017 the U.S. state of Florida listed Petronet on its continued examination list of companies with petroleum energy activities in Iran.

--

In 2018 the U.S. state of New York listed Petronet on its list of entities determined to be engaged in prohibited activities in Iran rendering Petronet ineligible for investment and/or state contracting.

--

In 2013 Petronet was removed from Pennsylvania Treasury's List of Scrutinized Companies Determined as Having Involvement In Iran after it was determined its involvement fell outside of three year window. 

--

In 2012, Petronet 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 and it was determined to have new involvement.
 

--

Petronet's Iranian Branch - Petronet Iran 

--

Petronet revised agreements in 2005 to begint he processing of Liquefied Natural Gas (LNG) from Iran.  (Company Website - Press Release, India, Iran to renegotiate LNG prices)

--

“The US Government Accountability Office, in a recently released report, moved ONGC Videsh Ltd, the overseas arm of state explorer Oil and Natural Gas Corp (ONGC), and three others, including Petronet LNG, out of the list [of companies known to have energy ties with Iran]…Previously, IOC, along with OVL, ONGC, OIL and Petronet, were listed as firms that had active ties with Iran…Petronet and Hinduja Group had signed agreements with Iran in 2009 to develop one of the 28 phases of the giant South Pars gas field and convert the fuel into LNG for export at an investment of over $10 billion. The project never took off.“ (Economic Times, “US moves ONGC Videsh out of list of firms with ties to Iran,” 4/10/14) 

--

"The Indian government has asked its public sector oil firms to seek legal opinion on the impact of the latest round of US sanctions on Iran on their investment in the Persian Gulf nation, Oil Secretary S Sundareshan said here. The US administration had in May named Oil and Natural Gas Corporation, ONGC Videsh Ltd, Oil India Ltd, IndianOil, Hinduja Group and Petronet LNG among the 41 firms worldwide having energy ties with Iran, an act for which it may impose sanctions on them." (Indian Express, "Oil PSUs seeking legal opinion on sanctions," 7/22/2010)

In their 2010 10-K forms for the SEC, Fuel System Solutions disclosed details about their business in Iran.

"From time to time, some of our foreign subsidiaries sell fuel delivery systems, related parts and accessories to customers in Iran, a country that is currently subject to sanctions and embargoes imposed by the U.S. government and the United Nations and a country identified by the U.S. government as a terrorist-sponsoring state. 

The constraints on our ability to have U.S. persons, including our senior management, provide managerial oversight and supervision over sales in Iran may negatively affect the financial or operating performance of such business activities. We have procedures in place to conduct these operations in compliance with applicable U.S. laws. However, failure to comply with U.S. laws in our foreign operations could result in material fines and penalties, damage to our reputation and a reduction in the value of our shares of common stock. 

In addition, our foreign subsidiaries’ activities in Iran could reduce demand for our stock among certain of our investors. Certain potential investors may avoid investing in our common stock for political reasons, rather than for business reasons." (10-K for Fuel Systems Solutions Inc, 3/8/2010)

In a 2008 correspondence with Parker Drilling Company, the SEC requested more details to be disclosed regarding their investments in Iran:

“We are aware of various news reports indicating that since 2003 you have been engaged in drilling wells at Korpeje in Turkmenistan, from where natural gas is exported by pipeline to Iran. Your Form 10-K does not include disclosure regarding any contacts with Iran, a country identified by the State Department as a state sponsor of terrorism, and subject to U.S. economic sanctions and export controls. Please describe to us the nature and extent of your past, current, and anticipated contacts with Iran, if any, whether through direct or indirect arrangements. Your response should describe in reasonable detail any components, equipment, technology, or other products or services you have provided into Iran, and any agreements, commercial arrangements, or other contacts you have had with the government of Iran or entities controlled by that government.” (UPLOAD for PARKER DRILLING CO DE, 7/8/2008)

Parker Drilling responded:

"Pursuant to a recent internal review, we (Parker Drilling Co.) have preliminarily identified certain shipments of equipment and supplies that were routed through Iran. In addition, we have engaged in drilling wells in the Korpedje Field in Turkmenistan, from where natural gas may be exported by pipeline to Iran. We are currently reviewing these shipments and drilling activities to determine whether the timing, nature and extent of such shipments or drilling activities may have given rise to violations of these laws and regulations." (10-Q for PARKER DRILLING CO DE, 8/11/2008)

"Yesterday, we disclosed in our Form 10-Q for the quarter ended June 30, 2008, which we timely filed with the Commission, that we are conducting an internal review relating to (a) certain shipments of equipment and supplies that were routed through Iran and (b) the drilling of wells in Korpeje Field in Turkmenistan, from where gas may be exported by pipeline to Iran. As described in our Form 10-Q, concurrent with the filing of our Form 10-Q we voluntarily disclosed the status of our current review of these matters to the Department of Treasury’s Office of Foreign Assets Control. This disclosure, which appears in three separate places in the Form 10-Q, is excerpted below." (CORRESP for PARKER DRILLING CO DE, 8/12/2008)

"Pursuant to an internal review, we have identified certain shipments of equipment and supplies that were routed through Iran as well as other activities that may have violated applicable U.S. laws and regulations. In addition, we have engaged in drilling wells in the Korpedje Field in Turkmenistan, from where natural gas may be exported by pipeline to Iran." (10-K for PARKER DRILLING CO DE, 3/3/2010)

In 2008, the SEC had requested for more details regarding Smith International's business in Iran and the Middle East to be disclosed in their 10-K forms.  The company responded with the following correspondence: 

“The Company has limited historical business involving operations in Iran, Syria and Sudan (the “Listed Countries”) conducted through the offshore operations of certain of its business units. We do not believe that our operations in the Listed Countries and the risks associated therewith present a material investment risk to our security holders from either a quantitative or qualitative perspective based on the analysis in the responses supplementally furnished with this letter and for the reasons included herein.” (CORRESP for SMITH INTERNATIONAL INC, 7/24/2008)

--

 “Smith has limited operations in countries which are subject to trade or economic sanctions or other restrictions imposed by the U.S. government. These countries include Iran, Syria, and Sudan. Smith’s operations in these countries are conducted through non-U.S. wholly and partially owned affiliates. Approximately 1% of Smith’s annual revenue in each of the last three years was derived from these countries. Smith does not believe such to be strategically significant to its worldwide operations as a whole.” (S-4/A for SMITH INTERNATIONAL INC, 8/15/2008)

--

In a correspondance with the SEC in August 2008, Smith International promised to disclose the details of their subsidiaries’ operations in Iran in their 10-K form, however they failed to do so in their 2009 10-k form.

“We are actively pursuing the termination of all business activities in Iran and Sudan. We are conducting a review of the business activities involving Iran and Sudan. While the nature and scope of issues that may emerge from this review are yet to be determined, there is a risk that we could identify violations of U.S. sanctions laws, which if pursued by regulatory authorities, could result in administrative or criminal penalties which in certain circumstances could be material.” (10-K for SMITH INTERNATIONAL INC, 11/16/2009)

--

"Smith International Inc (SII.N), an oilfield services company set to be taken over by industry leader Schlumberger Ltd (SLB.N), said on Monday it was actively pursuing the termination of all its activities in Iran and Sudan." (Reuters, "Smith International to pull out of Iran, Sudan," March 1, 2010)