Technology

On its Company Website, Single lists a representative office in Tehran through Varzidehkar Co.

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Single is headquartered in Charlotte, North Carolina.

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Single is the subsidiary of German Company SINGLE Temperiertechnik GmbH.

On its Company Website, New York General Trading says “We have worked with big companies like Mitsubishi, Daewoo, Toyota, Hyundai & Mazda.

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“Today the U.S. Department of the Treasury announced actions targeting a diverse set of entities and individuals located around the world for evading U.S. sanctions against Iran, aiding Iranian nuclear and missile proliferation, and supporting terrorism.  These actions reflect the United States’ sustained commitment to continue enforcing our existing sanctions as the P5+1 and Iran work toward a comprehensive solution to address the international community’s concerns over Iran’s nuclear program. ’The global targets designated today play key roles in supporting Iran’s nuclear program and active support for terrorism.  The United States has made clear that as it implements the Joint Plan of Action, contingent on Iran satisfying its own commitments, the overwhelming majority of sanctions remain in effect and will continue to be vigorously enforced,’ said Under Secretary for Terrorism and Financial Intelligence David S. Cohen. Today’s actions target entities and individuals located across the world, operating in Turkey, Spain, Germany, Georgia, Afghanistan, Iran, the United Arab Emirates, and Liechtenstein…Pursuant to E.O. 13608, which targets foreign persons engaged in activities intended to evade U.S. economic and financial sanctions with respect to Iran and Syria, the Department of the Treasury sanctioned Georgia-based Pourya Nayebi, Houshang Hosseinpour, and Houshang Farsoudeh and eight companies owned or controlled by these individuals…Treasury is also imposing sanctions on eight companies located in multiple countries that are owned and/or controlled by Nayebi, Hosseinpour, and Farsoudeh (acting individually or together), including: Caucasus Energy (Georgia), Orchidea Gulf Trading (UAE and/or Turkey), Georgian Business Development (Georgia and/or UAE), Great Business Deals (Georgia and/or UAE), KSN Foundation (Liechtenstein), New York General Trading (UAE), New York Money Exchange (UAE and/or Georgia), and European Oil Traders (Switzerland)…On multiple occasions, these front companies deceived the international financial community, including by generating false invoices in connection with transactions involving designated Iranian banks.“ (U.S. Department of Treasury, “Treasury Targets Networks Linked To Iran,” 2/6/14)

"New Jersey-based Lawrenceville Plasma Physics Inc and Tehran's Islamic Azad University will jointly design a fusion machine that 'would be affordable to construct in industrializing nations', according to a contract signed last weekend and seen by The Guardian... Sceptics doubt whether US trade sanctions will permit the collaboration. But LPP claimed in a written statement that the pact qualifies as an official US department of treasury exemption 'which authorizes collaborating with academics and research institutions on the … creation and enhancement of written publications.' LPP is scheduled to notify the president's  council of advisors on science and technology of its Iranian partnership at 2pm ET on Friday in Washington DC... LPP is one of several small companies that believe they can crack fusion far sooner than can ITER or the National Ignition Facility (NIF), another international behemoth, based in Livermore, California. Two months ago, LPP reported a breakthrough when it confined a gas at 1.8bn degrees C, much higher than the industry record of 1.1bn degrees C that had stood since 1978... LPP and Azad University are developing 'aneutronic' fusion, which would not rely on neutrons. It would eliminate turbines by providing electricity directly through charged ions." (The Guardian, "Iranian team to collaborate with US company on nuclear fusion project," 5/25/2012)

According to Ubiquity’s 10-K filed with the SEC in 2019, “In May 2011, we filed a self-disclosure statement with the U.S. Commerce Department, Bureau of Industry and Security’s (“BIS”) Office of Export Enforcement (“OEE”) relating a review conducted by us regarding certain export transactions from 2008 through March 2011 in which products may have been later sold into Iran by third parties. In June 2011, we also filed a self-disclosure statement with the U.S. Department of the Treasury’s Office of Foreign Asset Control (“OFAC”) regarding these compliance issues. We resolved the matters described in our self-disclosures with the BIS and OFAC, and have taken significant steps towards ensuring our compliance with export control regulations and embargoes.”

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"Ubiquiti Networks Inc., a maker of wireless hardware and video surveillance equipment, agreed to pay a $504,225 penalty to settle apparent U.S. sanctions violations for allowing its hardware to be sold in Iran, according to a company filing. The case illustrates how small companies can run afoul of compliance rules as they seek to expand in new markets. Ubiquiti “demonstrated reckless disregard for U.S. sanction” law, and allowed its wireless equipment to be exported into Iran through distributors located in the United Arab Emirates and Greece, according to a release from the U.S. Office of Foreign Assets Control. The firm had no compliance program at the time, according to the release. And even after Ubiquiti learned that the transactions broke U.S. law, the company allowed them to continue for another year, until February 2011, OFAC said. The company said, in a filing released Thursday, that until early 2010 it didn’t prohibit its distributors from selling its products to Iran. After it learned of the potential violations, the company said that it failed to immediately ‘amend all its distribution agreements and to implement more robust compliance controls.’ Ubiquiti first made the issue of possible violations public in 2011, as it prepared for its initial public offering. As part of its IPO prospectus, the company said it hadn’t been sufficiently familiar with export control laws because of its small size and the ‘inexperience of our management team in these matters,’ Reuters reported. As of June 2013, the company had just 111 employees stretched across four countries, according to filiings. The company recorded $320.8 million in revenue for its fiscal year 2013 that ended June. Ubiquiti declined requests for interview through a spokeswoman. In a statement, the spokeswoman said: ‘Since 2011, we have put measures in place designed to prevent this type of issue from happening again.’” (Wall Street Journal, “Ubiquiti Networks Settles Over U.S. Sanctions Violations,” 3/6/14)

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“Wireless equipment maker Ubiquiti Networks Inc broke a two-month drought in the U.S. IPO market on Thursday pricing shares in its initial public offering at the low end of the expected range… Ubiquiti, whose shares will trade on Nasdaq under the stock symbol UBNT.O, makes wireless networking and video surveillance equipment. It said in its prospectus that certain of its products were sold to Iran, Cuba, Syria, the Sudan and North Korea and that some of its encryption components were sold without the appropriate export authorization… A review of Ubiquiti's sales to Iran by the Department of Commerce's Office of Export Enforcement earlier this year resulted in a warning letter, but no criminal or administrative prosecution or other penalties -- but Ubiquiti remains under review by the Department of the Treasury's Office of Foreign Assets Control.” (Reuters, "Ubiquiti breaks US IPO drought amid Iran controversy," 10/13/2011)

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"UBNT believes its products have been sold into Iran by third parties." (Seeking Alpha, "<>IPO Preview: Ubiquiti Networks," 10/7/2011)

Over the last three presidential administrations, the United States government has granted Applied Imaging Corporation 20 special licenses to do business in Iran. (New York Times, "Companies with Permission to Bypass Sanctions," 12/24/10)

In June 2016, the Embassy of the Government of Iran located in the Republic of Ireland placed an order for Dell desktop computers, computer stands, and a server for a total purchase price of approximately 8,816 Euros (approximately $9,941 at the exchange rate for U.S. dollars at the date of such order). We did not accept the order, but such embassy subsequently deposited prepaid funds in the amount of its purchase order in a local bank for our account. These funds remain blocked at the local bank, and we do not intend to engage in future activity with respect to this matter.

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According to its Annual Report filed with the SEC in 2012: "We are disclosing the following information pursuant to Section 13(r) concerning activity by a UK affiliate of Quest Software, Inc. (“Quest Software”), which Dell acquired on September 27, 2012. The disclosure is regarding a maintenance services software renewal transaction with Melli Bank PLC valued at 106.13 British pounds (approximately $169.90 at the exchange rate for U.S. dollars on the renewal date) and marketing activity.

Quest Software specializes in business software. On September 10, 2012, prior to our acquisition of Quest Software, Quest Software (UK) Ltd., then a UK subsidiary of Quest Software, renewed two software maintenance licenses with Melli Bank PLC. The first license, for Quest Recovery Manager for Exchange software, had been in effect for seven years before the renewal, while the second license, for Spotlight on Messaging software, had been in effect for four years before the renewal. Recovery Manager for Exchange software enables users to search and retrieve message-level data and compare contents between different mailboxes. Spotlight on Messaging is a business software program that helps manage messaging and real-time communications and provides troubleshooting solutions. Marketing activity also occurred prior to and after the acquisition with respect to Quest customers generally, including Melli Bank PLC, but no transactions were concluded other than the license renewal transaction.

Melli Bank PLC is a wholly-owned subsidiary of Bank Melli in Iran. Melli Bank PLC is headquartered in London and is listed by the Treasury Department's Office of Foreign Assets Control as a Specially Designated National.

The profit on the license renewal transaction was no more than the annual renewal transaction value indicated above. Following our acquisition of Quest Software and our discovery of the renewal transaction, we terminated all software maintenance activity under the licenses. We will not engage in future activity under the licenses."
 

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"This license authorized a shipment of computers to an embassy in Tehran." (New York Times, "Licenses Granted to U.S. Companies Run the Gamut," 12/24/10)

"This license was issued after Senator Edward M. Kennedy's office called OFAC on behalf of this Massachusetts-based company on July 12, 2006, then wrote a follow-up letter on Nov. 29, 2006. The license authorized the sale of the HUMAC NORM Multi-Joint Evaluation and Exercise System to Sepehran Company for resale in Iran to, among other entities, the National Olympic Academy of Iran, which trains Iran's athletes. The product, which was deemed to be an allowable medical device export, is an exercise machine used in sports rehabilitation. Rob Potash, the vice president of Computer Sports Medicine, said he believed that the sale of American products to Iranians helped to improve the United States' image there." (New York Times, "Licenses Granted to U.S. Companies Run the Gamut," 12/24/10)

"The documents relating to this license have been so heavily redacted by OFAC that it is impossible to tell what was authorized. A company spokeswoman, Karen Gordon Quintal, said Bell Helicopter had received this and another license because it needed 'to store property of Iran and Iraq that Bell had possession of in the United States on the dates, respectively, when the assets of those countries were frozen. These licenses were required to enable Bell to store the assets, consisting principally of spare parts, in Bell’s U.S-based warehouse facility. Bell continues to store that property.'" (New York Times, "Licenses Granted to U.S. Companies Run the Gamut," 12/24/10)

According to its Annual Report filed with the SEC for fiscal year 2021: "The Company is making the following disclosure under Section 13(r) of the Exchange Act: Protection of Intellectual Property Rights in Iran Pursuant to Specific License As part of its intellectual property (“IP”) protection efforts, 3M has obtained and maintains patents and trademarks in Iran. Periodically, 3M pays renewal fees, through IP service providers/counsel located in Germany, Dubai and Iran, to the Iran Intellectual Property Office (“IIPO”) for these patents and trademarks and has sought to prosecute and defend such trademarks. On January 15, 2020, OFAC granted 3M a specific license to make payments to IIPO at its account in Bank Melli, which was designated on November 5, 2018 by OFAC under its counter terrorism authority pursuant to Executive Order 13224. As authorized by OFAC’s specific license, in the period ended December 31, 2021, 3M paid $307 to IIPO as part of its intellectual property protection efforts in Iran. 3M plans to continue these activities, as authorized under the specific license."

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According to its Annual Report filed with the SEC for fiscal year 2019: "As part of its intellectual property protection efforts, 3M has obtained and maintains patents and trademarks in Iran. Periodically, 3M pays renewal fees, through local counsel located in Dubai and Iran, to the Iran Intellectual Property Office (“IIPO”) for these patents and trademarks and has sought to prosecute and defend such trademarks. On January 15, 2020, OFAC granted 3M a specific license to make payments to IIPO at its account in Bank Melli, which was designated on November 5, 2018 by OFAC under its counter terrorism authority pursuant to Executive Order 13224. As authorized by OFAC’s specific license, in the quarter ended March 31, 2020, 3M paid $109 to IIPO as part of its intellectual property protection efforts in Iran. 3M plans to continue these activities, as authorized under the specific license."

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According to its Annual Report filed with the SEC for fiscal year 2018: "Disclosures Under Iran Threat Reduction and Syria Human Rights Act of 2012

The Company is making the following disclosure under Section 13(r) of the Exchange Act because the Company’s management recently became aware that the ultimate customer in Iran, which meets the definition of the “Government of Iran” under Section 560.304 of 31 C.F.R. Part 560 (the “Iran Party”), was not eligible to receive non-U.S. origin products sold by our foreign subsidiary through a third-party distributor under General License H issued by the U.S. Department of the Treasury, Office of Foreign Assets Control (“OFAC”). Based upon currently known information, total revenues to our foreign subsidiary from indirect sales to the Iran Party, which took place from September 2016 through September 2018, were approximately $8.4 million, and the total net income attributable to those sales was approximately $1.6 million.

Upon expiration of OFAC’s authorization in November 2018, our foreign subsidiary stopped all shipments to the distributor for resale to the Iran Party, and, accordingly, the foreign subsidiary does not intend to continue sales to, or engage in other dealings with the Iran Party. On April 8, 2019, the Company submitted initial notifications of voluntary self-disclosures to OFAC regarding these historic activities, and the Company intends to cooperate fully with OFAC." (U.S. Securities and Exchange Commission, "Form 10-Q," 4/26/2019).

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"Jacqueline Berry, a spokeswoman for 3M, said the company received this license to sell certain medical and dental products to civilian populations in Iran. It separately received another license to sell specialized window film to a United Nations building in Sudan." (New York Times, "Licenses Granted to U.S. Companies Run the Gamut," 12/24/10)