Cabot Specialty Chemicals Inc.

"Cabot received this license after it assisted in a sales transaction of silicon dioxidebetween two non-U.S. parties. The company applied for the exception after learning that the goods would be shipped via the Iranian government-owned shipping line known as Irisl. 'The items in question are already loaded onto containers at the dock and ready to be loaded onto the vessel, which is due to depart the port of Antwerp, Belgium, on Monday,' the company's lawyers, in the firm of Baker & McKenzie, wrote to OFAC on May 11, 2001. OFAC's director, Adam J. Szubin, stressed that the approval came seven years before Irisl was blacklisted by the United States for aiding Iran's nuclear and ballistic missile programs. Up until then, he said, the agency made case-by-case exceptions to a broad prohibition against dealing with Iranian companies in situations like this one in which the company had no prior knowledge that an Iranian entity was involved in the transaction and granting the license did not involve a direct payment from a United States person or company to an Iranian entity." (New York Times, "Licenses Granted to U.S. Companies Run the Gamut," 12/24/10)