Dresser-Rand

Listed as an approved vendor by NIOEC, NPC, POGC, NIGCENG, NISOC, SADAF, NIGC and IOOC.

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According to its Annual Report filed with the SEC for fiscal year 2012: "Subsequently, in October 2012, the Company adopted a policy prohibiting all business with the government of Iran or any person subject to the jurisdiction of Iran. This recently adopted policy is consistent with the Iran Threat Reduction and Syria Human Rights Act of 2012 (“ITRSHRA”), which expanded sanctions against Iran effective in October 2012 and instituted disclosure requirements in annual and quarterly reports for public companies engaged in, or affiliated with an entity engaged in, specified activities under the ITRSHRA. This policy was effective immediately and applied to all contracts, including those in existence on the effective date of the policy.

During 2012, Guascor received payments from a customer in Iran pursuant to a contract for the sale of gas-powered generators. Guascor entered into this contract in January 2011, prior to it being acquired by the Company, and the shipments to the customer pursuant to this contract were not in violation of the U.S. sanctions on Iran or the Company’s policies in place at the time. Payments under the contract were received through a letter of credit issued in June 2011 by Bank Tejarat, an Iranian bank (the “Bank”). Guascor has not engaged in any direct dealings with the Bank, which was selected solely by the Iranian customer. However, Guascor was designated by the customer as the beneficiary under the letter of credit. On January 23, 2012, after the letter of credit was issued, the Bank was designated by the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) as subject to sanctions pursuant to Executive Order 13382. During 2012, Guascor received a total of three payments from the customer via the Bank-issued letter of credit totaling €1.2 (approximately $1.6), two of which, totaling €0.9 ($1.2) were received in November 2012 after the expanded sanctions against Iran were in effect. There were no net profits associated with the receipt of these payments under the letter of credit. Guascor is in the process of winding down all transactions with Iran in accordance with a general license from OFAC and, with the exception of one final payment of €0.1 (approximately $0.1) that is scheduled to be received on or before March 4, 2013, under the Bank-issued letter of credit, no additional dealings with or involving the Bank are contemplated. The Company has fully disclosed the receipt of these payments to OFAC, requesting a finding that no violation has occurred, and has requested from OFAC a license with respect to the final payment scheduled to be received in March 2013. Although there is a risk of sanctions associated with the November 2012 payments, under the particular facts and circumstances described above, the Company believes that sanctions, if any, would not have a material adverse effect on our financial condition.

The Company’s foreign subsidiaries’ aggregate 2012 sales into countries that are subject to these policies was less than 1% of the Company’s total sales in 2012 and only included sales to Iran before the new expanded sanctions against Iran went into effect in October 2012. We did not make any sales to Iran after these new sanctions were effective.

Although such sales are not material in magnitude to our overall business, certain investors may view even this level of business in such countries adversely. This could have an adverse impact on the market price of our common stock and our Senior Subordinated Notes." 

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Several days after coverage in the New York Times (below), Dresser-Rand issued a press release explaining that it had barred its subsidiaries from entering into new business contracts with Iran. 

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"Dresser-Rand, a Texas-based oil and gas equipment supplier, said in multiple filings with the SEC, including as recently as last month, that 'from time to time, certain of our foreign subsidiaries operate in countries that are or have previously been subject to sanctions and embargoes imposed by the U.S. government and the United Nations, including in Iran, Sudan and Syria.'"

As of March 2010, Dresser-Rand is classified as being "Active" in Iran. From 2000 through March 2010, Dresser-Rand has been the recipient of $215.1 million in federal funds. (The New York Times, "Profiting from Iran, and the U.S.", 3/6/10)