Medical*

According to its Annual Report filed with the SEC for fiscal year 2019: "Additionally, the U.S. Department of the Treasury’s Office of Foreign Control and the Bureau of Industry and Security at the U.S. Department of Commerce administer laws and regulations that restrict U.S. persons and, in some instances, non-U.S. persons, in conducting activities, transacting business or making investments in certain countries, or with governments, entities and individuals subject to U.S. economic sanctions. From time to time, certain of our subsidiaries have limited business dealings with countries subject to these sanctions, including Iran, Sudan, Syria, Russia and Cuba. These dealings represent an insignificant amount of our consolidated revenues and income but expose us to an increased risk of operating in these countries, including foreign exchange risks or restrictions or limitations on our ability to access funds generated in these jurisdictions, or the
risk of violating applicable sanctions or regulations, which are complex and subject to frequent change."
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Baxter International acquired Gambro Middle East in Egypt to operate in Iran.

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

According to correspondence filed with the SEC: "Hologic develops and manufactures medical products, including diagnostic products, medical imaging systems, and surgical products primarily focused on serving the healthcare needs of women. The Company has sold small volumes of these products and related components to independent, non-U.S. third party distributors located in Iran and Syria. The Company does not sell its products directly to end users in Iran and Syria. The products sold for use in these countries are medical products, including mammography systems, osteoporosis systems, ThinPrep™ diagnostic kits and related imaging equipment to assist in the diagnosis of cervical cancer, breast biopsy equipment, and related components.

Hologic’s distributors in Iran and Syria are responsible for selling, installing and servicing the Company’s products sold in those jurisdictions. The only service performed by Hologic personnel in those jurisdictions would be a “first-in-country” installation of a particular product. During such first installation, Hologic performs the installation with the distributor, during which the distributor is trained to install and service the equipment. The limited installation, training and technical support provided by Hologic are undertaken, managed and paid for by the Company’s European operations and personnel. None of these personnel are U.S. citizens or permanent residents.

The Company has no subsidiaries, assets or personnel based in Iran or Syria, and to the best of the Company’s knowledge, the Company does not have any agreements, commercial arrangements, or other contacts with the governments of Iran or Syria or entities controlled by those governments, except as such contact may relate to the Company providing its distributors with “first-in-country” installation assistance, as such installation may take place in a government-owned or -controlled hospital or clinic."

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Over the last three presidential administrations, the United States government has granted Hologic Inc 56 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 Abbott Laboratories 46 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 Datascope Corp 71 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 Boston Scientific Corporation 75 special licenses to do business in Iran. (New York Times, "Companies with Permission to Bypass Sanctions," 12/24/10)

"Gary G. Miller, a California Republican, wrote on June 1, 2007, on behalf of this company's application to sell medical equipment to a company in Iran called Jarf Kherad Company Limited, which would distribute the equipment to hospitals under the control of the Iranian Ministry of Health. OFAC explained to Mr. Miller on July 12, 2007, that the company had been informed that its paperwork was incomplete. The application was ultimately approved." (New York Times, "Licenses Granted to U.S. Companies Run the Gamut," 12/24/10)

"ImEx Gulf Inc., which represents over 10 U.S. companies, had the most visitors as it had displayed the U.S. flag in its stand.  As a matter of fact, this happened for the first time for over three decades.

Since the first Kish Island show was a success, VIV and Sunsafa Co. are discussing the possibility of hosting another Kish Island show." (4/21/2014)

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The US Government provided ImEx Gulf with a license to sell medical products to Iran. (New York Times, "Licenses Granted to U.S. Companies Run the Gamut," 12/24/10)

"This license involved a medical-waste disposal plant in Honolulu called Hawaii Medical Vitrification. On July 28, 2003, the plant’s owner, Samuel Liu, ordered 200 graphite electrodes from a Chinese government-owned company, China Precision Machinery Import Export Corporation. In an interview, Mr. Liu said he had chosen the company because the electrodes available in the United States were harder to find and more expensive. Two days later, the Bush administration barred American citizens from doing business with the Chinese company, which had already been penalized repeatedly for providing missile technology to Pakistan and Iran. By the time Customs seized the electrodes on Nov. 5, waste was piling up in the sun. Nor did prospects look good for Mr. Liu’s application to the licensing office seeking to do an end run around the sanctions. On Nov. 21, a State Department official, Ralph Palmiero, recommended that the agency deny the request since the sanctions explicitly mandated the 'termination of existing contracts' like Mr. Liu’s. 'The penalties are clear in this case,' Mr. Palmiero wrote, 'and the responsibility rests with OFAC to implement the import ban.' That is when Senator Daniel K. Inouye’s office stepped in. While his electrodes were at sea, Mr. Liu had made his first political contribution ever, giving the senator’s campaign $2,000. Mr. Liu says the timing was coincidental, that he was simply feeling more politically inclined. Records show that an Inouye aide called the licensing office on Mr. Liu’s behalf the same day that Mr. Palmiero recommended denying the application. The senator himself wrote two days later. Mr. Inouye’s spokesman, Peter Boylan, said the contribution had 'no impact whatsoever' on the senator’s actions, which he said were motivated solely by concern for the community’s health and welfare. The pressure appears to have worked. The following day, the licensing office’s director at the time asked the State Department to reconsider in an e-mail that prominently noted the senator’s interest. A few days later, the State Department found that the purchase qualified for a special 'medical and humanitarian' exception. The license was issued Dec. 10. Two months later, Mr. Liu sent the senator another $2,000 contribution, the maximum allowable. Treasury Under Secretary Stuart Levey said he could not comment on the details of a decision predating his tenure. But he noted that sanctions against the Chinese company had since been toughened, and added, 'Certainly this transaction wouldn’t be authorized today.'" (New York Times, "Licenses Granted to U.S. Companies Run the Gamut," 12/24/10)

In 2018, the U.S. state of Michigan listed Becton, Dickinson & Company on its state lists of Companies Doing Business with Iran, rendering Becton, Dickinson & Company ineligible for investment and/or state contracting.

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"In 2013 and 2014 Michigan divested $45 million from Becton Dickinson and Co., a U.S. medical supplies company that sells to Iran legally under federal regulations.

A Becton Dickinson spokesman said the firm was unaware it was a target of divestment by Michigan until contacted by Reuters. It said in a statement that its trade with Iran is authorized by the U.S. Treasury Department’s Office of Foreign Assets Control, which oversees federal sanctions." (Reuters, 4/13/2015). 

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According to correspondence filed with the SEC in 2010: "The Company’s sales into Iran during fiscal years 2009 and 2010 were $2,932,134 and $4,415,097, respectively, and we estimate fiscal year 2011 sales to be $3,140,758. The Company sold medical products pursuant to U.S. government licenses to Iranian pharmaceutical companies and through independent, third-party distributors that distribute the medical supplies and devices to end-users in Iran. The medical products sold into Iran are eligible for re-export to Iran under the Trade Sanctions Reform and Export Enhancement Act of 2000 (“TSRA”) “Ag/Med” program.

To the Company’s knowledge, the sales into Iran, Sudan and Syria were made in compliance with BD’s Global Trade Management System and complied with applicable laws and regulations.
The Company anticipates continued sales into the Middle East, including into Iran, Sudan, and Syria, and the Company will seek and obtain any required U.S. and other government licenses or authorizations to conduct such activities in full compliance with applicable laws. The Company reviews its export activities on a regular basis to ensure compliance with applicable economic sanctions and export control laws and mandates trade compliance training for all associates involved in the export, re-export or transfer of products, materials or technology originating from any BD location and shipped or transferred to any customer, vendor or distributor worldwide."

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Over the last three presidential administrations, the United States government has granted Becton, Dickinson & Company 49 special licenses to do business in Iran. (New York Times, "Companies with Permission to Bypass Sanctions," 12/24/10)

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"This medical device company and its French subsidiary were licensed to export goods, the precise nature of which OFAC redacted, to Iran." (New York Times, "Licenses Granted to U.S. Companies Run the Gamut," 12/24/10)

"One of the world's leading biotechnology companies, Genzyme is dedicated to making a major positive impact on the lives of people with serious diseases." (Company Website)

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Over the last three presidential administrations, the United States government has granted Genzyme Corporation 14 special licenses to do business in Iran. (New York Times, "Companies with Permission to Bypass Sanctions," 12/24/10)

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Website states that it does business with Iran and other Middle Eastern countries through its Dubai office.
Genzyme Middle East (Company Website)

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The Dubai office will provide regional sales and marketing support to customers and distributors for its enzyme replacement treatments for Gaucher, MPS I, Fabry and Pompe, four Lysosomal Storage Diseases*. It will also support activities for Renagel, a treatment to reduce the phosphorus levels in chronic kidney disease patients on hemodialysis, Thymoglobulin, an immunosuppressant for treating and preventing acute rejection in renal transplant patients, and Thyrogen, an adjunct to thyroid cancer disease management designed to aid in the treatment and earlier detection of recurrence…

The Dubai office will represent Genzyme in Bahrain, Egypt, Iran, Iraq, Jordan, Kuwait, Lebanon, Qatar. Further activities in Yemen, Syria and Sudan could be foreseen.” (AMEinfo.com, “Genzyme inaugurates Middle East office in Dubai,” 11/6/06)