Medical*

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

"Varian tells NPR that it does sell cancer care systems to Iran. It's an example of a disconnect between what U.S. companies and the government say they are doing and what medical care providers in Iran are experiencing." (NPR, 8/24/2019).

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Over the last three presidential administrations, the United States government has granted Varian Medical Systems 15 special licenses to do business in Iran. (New York Times, "Companies with Permission to Bypass Sanctions," 12/24/10)

"According to Draeger's regional manager for oil, gas and chemical, Ian White, their business in Iran is to provide safety products, including protection equipment such as breathing apparatus, respiratory protection and face masks to protect people in potentially toxic and poisonous environments. Also, they produce detection equipment which will detect anything explosive in oil, gas, chemical and petrochemical industries.

Draeger Safety has been developing advanced technical devices and solutions trusted by users all over the world. Its broad range of products from safety and protection systems, respiratory protective equipment, air filter to detection technology, warning systems are used in hospitals, for firefighting, for mining, in the oil and gas industry, in the chemical industry and etc.

In industrial spaces, detection and protection devices are essential part of safety systems. Draeger has combined both detection and protection products, to make sure people are safe before and after toxic gases detection.

Draeger has activated in Iran's market for more than 30 years in co-operation with Lab Tech Co., equipment supplier and service provider for healthcare and industrial areas." (Financial Tribune, 6/12/2017)

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Lists Lab Tech Ltd. as its distributor in Tehran, Iran.

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Over the last three presidential administrations, the United States government has granted Draeger Medical Systems 18 special licenses to do business in Iran. (New York Times, "Companies with Permission to Bypass Sanctions," 12/24/10)

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Draeger was involved in a scandel for supplying dual-use technology to Iran through its Iranian partner Irasco.  (DW, "US eyes German Firm Over Software Sale to Iran," 5/8/09)

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)

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

Lists Iran Negar – Planetarium, Marestan Co. Ltd, Optical Trading Center, Pishgaman Sanate Taimaz Co. and Valatec Engineering Company as distributors in Tehran, Iran.

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Over the last three presidential administrations, the United States government has granted Carl Zeiss Meditec 22 special licenses to do business in Iran. (New York Times, "Companies with Permission to Bypass Sanctions," 12/24/10)

KBC Trading Co in Iran "acts as a manufacturers representative firm for large and reowned pharmaceutical companies in the world including Eli Lilly and Sanofi Pasteur…"

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According to its 2016 SEC Disclosure: "Our activities have included supplying medicines for patient use in Iran. We ship our products to Iran and conduct related activities in accordance with our corporate policies and licenses issued by the U.S. Department of the Treasury's Office of Foreign Assets Control. We recently completed a review in which we determined that between the last quarter of 2013 and the first half of 2015, some of these shipments, which were arranged by a third-party logistics company, were sent to Iran on aircraft owned or operated by Iran Air, which is a designated air carrier under Executive Order 13382."

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Over the last three presidential administrations, the United States government has granted Eli Lilly and Company 19 special licenses to do business in Iran. (New York Times, "Companies with Permission to Bypass Sanctions," 12/24/10)

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

Stryker lists an office in Dubai as for it business in Iran.

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Over the last three presidential administrations, the United States government has granted Stryker Corporation 30 special licenses to do business in Iran. (New York Times, "Companies with Permission to Bypass Sanctions," 12/24/10)

According to its Annual Report filed with the SEC in 2015: "As part of its ongoing compliance program, the Company identified certain sales of medical devices made during fiscal year 2015 by one of its non-U.S. affiliated entities to parties in Iran that were not covered by a general license issued by the U.S. Treasury Department's Office of Foreign Assets Controls ("OFAC"). Those sales, which were generally conducted through distributors, whose customers include public hospitals which may be owned or controlled directly or indirectly by the Iranian government, resulted in approximately $4 million in gross revenues and approximately $3 million in net profits (excluding selling, general, and administrative expenses and allocations) in fiscal year 2015. At the time of these sales, the Company believed, based on correspondence received from OFAC in response to a request to renew the specific licenses the Company had to cover these sales, that the sales were eligible for an OFAC general license. The Company subsequently obtained the specific licenses required for these continued sales. The Company has also submitted an initial notification of voluntary self-disclosure regarding this matter to OFAC."

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According to its Annual Report filed with the SEC in 2013: "As of October 9, 2012, all of Medtronic's business dealings with Iran (including business conducted by non-U.S. affiliates) have been conducted pursuant to general or specific licenses issued by the U.S. Treasury Department's Office of Foreign Assets Controls (OFAC). Medtronic and its affiliates plan to continue their existing activities and operations with Iran in accordance with such general or specific licenses.

In October 2012, the U.S. sanctions against Iran were extended to entities owned or controlled by U.S. persons. Prior to such time, it was permissible under U.S. law for independent non-U.S. subsidiaries of U.S. companies to engage in sales to Iranian customers under certain limited circumstances without the need for OFAC authorization. In accordance with these requirements, and without the involvement of U.S. persons, certain of Medtronic's non‑U.S. subsidiaries engaged in lawful sales to Iran during the first two quarters of fiscal year 2013 from its CRDM, Coronary, Structural Heart, Endovascular, Spine, Neuromodulation, Diabetes, and Surgical Technologies businesses. Other sales to or for Iranian customers during the first two quarters of fiscal year 2013 wereundertaken pursuant to specific licenses issued by OFAC. The Iranian sales were generally conducted through distributors, some of whose customers included public hospitals which may be owned or controlled directly or indirectly by the Iranian government. Certain of these sales were also made to a non-governmental entity which sells to the Iranian Ministry of Health. All activities by the Company and its non-U.S. subsidiaries with entities in Iran, including certain governmental entities, in the first two quarters of fiscal year 2013 resulted in approximately $25 million in gross revenue and approximately $16 million in net profits (excluding selling, general, and administrative expenses and allocations)."

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Over the last three presidential administrations, the United States government has granted Medtronic Inc. 28 special licenses to do business in Iran. (New York Times, "Companies with Permission to Bypass Sanctions," 12/24/10)