Advanced Micro Devices (AMD)

AMD's website states that the company is "committed to fully comply with the United States and all applicable export and import laws and regulations governing the export, re-export, or import of AMD products, software, services and technology. AMD's Global Trade Compliance organization is responsible for providing guidance and support of AMD's global export and import compliance obligations... AMD products, services, and technology are prohibited for U.S. export or re-export to Cuba, Iran, North Korea, Sudan, and Syria or to any country or end-use subject to U.S. trade sanctions."

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AMD says it hasn't authorised any product shipments to Iran, directly or indirectly, but somehow the Iranian High Performance Research Center (IHPCRC), which is located at Tehran's Amirkabir University of Technology, says it has assembled a Linux-based system with 216 Opteron processing cores (an AMD product).  There is a connection through Thacker, also known as Sky Electronics, an authorised distributor of AMD products based in the United Arab Emirates. (The Enquirer, "AMD is inside Iran's missiles and supercomputers," 6/17/2009)

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In response to reports that AMD processors had been used to build Iran's most powerful supercomputer, the SEC wrote AMD the following correspondence on May 8, 2009:

"It appears from exhibit 21 to your Form 10-K, exhibit 99.1 to your Form 8-K, and the “AMD Worldwide” section of your website that you have operations in the Middle East and Africa, which are regions that include Iran, Syria, and Sudan. In addition, we are aware of a December 2007 news report that your processors have been used to build Iran’s most powerful supercomputer. Iran, Syria, and Sudan are identified by the State Department as state sponsors of terrorism, and are subject to U.S. economic sanctions and export controls. We note that your Form 10-K does not include disclosure regarding contacts with Iran, Syria, or Sudan. Please describe to us the nature and extent of any past, current, and anticipated contacts with the referenced countries, whether through joint ventures, distributors, resellers, or other direct or indirect arrangements. Your response should describe any products or technology you had provided to the referenced countries, directly or indirectly, and any agreements, commercial agreements, or other contacts you have had with the governments of those countries or entities controlled by those governments."

In a June 19, 2009 response letter to the SEC, AMD wrote:

"In response to the Staff’s comment, the Company advises the Staff that AMD has not had any direct authorized contacts with Iran, Syria or Sudan (collectively, the “Embargoed Countries”). The Company has not provided any products or technology to the Embargoed Countries and has had no agreements, commercial agreements or other business contracts with the governments of the Embargoed Countries or entities controlled by those governments.The Company has an established export management system (“EMS”) which sets forth strict policies relating to its export related activities. The Company has designed these policies to ensure compliance with U.S. export control laws. The EMS governs the review of all sales and shipments to countries which are subject to U.S. economic and export sanctions. In addition, it is the Company’s policy that all authorized distributors of AMD products contractually commit that they will fully comply with all U.S. export control laws with respect to their sales and shipments of AMD products. The Company also periodically requests that its authorized distributors reaffirm these commitments...

Supporting material sent to the Committee on Foreign Investment in the United States (“CFIUS”) in December 2008 corroborated the above findings. The responses detail the controls that AMD has in place, including EMS, to prevent its distributors from selling products to prohibited end-users. These materials also contradict the articles referenced by the Staff that AMD processors were used in the construction of an Iranian supercomputer, showing that there are no records that indicate any improper or illegal shipment of technology to Iran, Syria or Sudan by AMD. Again, we are happy to provide you with copies of these materials.

The Company respectfully advises the Staff that in the rare occasions in the past where the Company has discovered an unauthorized resale by a distributor or direct customer of its product to an Embargoed Country, AMD has immediately terminated the export of its products to such customers or distributors if such customer or distributor does not agree to immediately cease such sales."

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"Chipmaker AMD is red-faced after a bunch of Iranian boffins smuggled 216 Opteron chips into the country and built themselves a supercomputer. Iran has loads of trade embargoes against it as part of a punishment for not liking America much. One of the embargos forbids the import of IT gear so that the Iranians cannot get their paws on a supercomputer.

Scientists at the Iranian High Performance Computing Research Center at the country's Amirkabir University of Technology have said that they have built a supercomputer using 216 AMD Opterons in a Linux cluster. They think that it can manage 860 giga-flops. But the development is extremely embarrassing for AMD which claims it has never shipped its chips to Iran or allowed anyone else to do so. No doubt AMD is expecting a visit from US law enforcement people who want to know how the chips got to Iran.

A spokesAMD said that the company complies with all United States export control laws. Any shipment of AMD products to Iran by any authorised distributor of AMD would be a breach of the specific provisions of their contracts with AMD." (The Inquirer, "AMD probed over Iran supercomputer build," 12/7/09)

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"Despite federal antiterrorism trade sanctions that bar the sale of U.S.-made computer technology to Iran, a computing research center in Tehran claims to have used Advanced Micro Devices Inc.'s Opteron processor to build the Middle Eastern country's most powerful supercomputer. The Iranian High Performance Computing Research Center (IHPCRC), which is located at Tehran's Amirkabir University of Technology, said in an undated announcement on its Web site that it has assembled a Linux-based system with 216 Opteron processing cores. That's a relatively small supercomputer, with a claimed peak performance level of 860 billion floating-point operations per second, or gigaflops. But the research center said that the system, which will be used for weather forecasting and meteorological research, is the fastest built in Iran to date." (Computerworld, "Iranians claim to have built Opteron-based supercomputer," 12/6/07)