Reed Business Information

Reed Business Information is the subsidiary of Reed Elsevier.

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“UK authorities have been probing past transactions between a division of Anglo-Dutch publisher Reed Elsevier and Iranian banks, to consider whether sanctions may have been breached. Reed Business Information continued to provide services to banks in Iran after those entities had been put on the HM Treasury sanctions list, according to internal documents seen by the Financial Times. In one instance, the company sold a database subscription to a bank a month after it was placed on the list in 2008. Several other banks retained access to the database for months after they were added to the list. Internal emails from Reed Business Information show that its staff had advised several banks on alternative ways to pay for their subscriptions and other services because payments were rejected by the company’s bank. HM Revenue & Customs’ criminal investigation division last month decided to refer a complaint to the UK’s National Crime Agency Economic Crime Command to consider whether financial sanctions were breached, the FT has learnt. The National Crime Agency and HMRC said they could not comment on individual cases. RBI said it had not been contacted by either HMRC or NCA.

The company reviewed its sanctions policy after managers in July 2013 wrote several emails that demonstrate they were unsure about the legality of some proposed and existing transactions and considered them high risk.RBI and US-based Accuity – which its parent Reed Elsevier acquired at the end of 2011 – operate together as Accuity and sell databases such as Bankers Almanac. That database allows clients to find and validate bank payment routing data and share their own payment information. ‘The product does not contain functionality to execute payment transactions,’ a spokesperson for RBI told the FT. Accuity also offers screening tools to help financial institutions comply with sanctions and anti-money laundering compliance programmes. The email trail suggests that the company as at July last year did not have a systematic procedure in place to decide whether to allow banks access to their product in countries under sanctions. However, a spokesperson for RBI said internal procedures had existed, and were implemented by back-office staff before January this year. In January it issued a policy document on how to comply with sanctions and began a training programme for sales staff. The policy directs its sales staff not to seek out business opportunities in countries under sanctions. The company sold Bank Melli Iran a subscription to Bankers Almanac shortly after the UK imposed sanctions on the bank in June 2008, according to subscription data reviewed by the Financial Times. Sales staff attempted to sell a subscription to the Iranian bank, Bank Sepah, more than two years after it was put on the sanctions list in early 2007, the emails show. A spokesperson for RBI did not dispute the timing of the transactions with the banks but said that contracts with entities under sanctions were terminated ‘as soon as they became apparent in our screening process.’ The company acknowledged, in response to questions from the FT, that three banks had retained access to Bankers Almanac ‘beyond the EU’s two-month grace period after they were designated.’ Export Development Bank of Iran retained access for 10 months after designation, Bank Saderat for 11 months, and Sina Bank for five months. ‘It should be noted that many of the regulations allowed for existing contracts to run on until completed,’ a spokesman for RBI said. The company said that the products consist entirely of publicly available information and that the transactions were worth approximately £30,000.‘External legal counsel has informed us that it is unclear whether these products are even subject to sanctions,’ a spokesperson said.” (Financial Times, “Reed Business Information faces scrutiny over sanctions," 5/1/14)

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On its March 2014 20-F form for the U.S. Securities and Exchange Commission, Reed Elsevier stated, “During 2013, Tarbiat Modares University, Urmia University, Masih Daneshvari Hospital, Kharazmi University, Ferdowsi University of Mashad, the Iran Ministry of Science, Research and Technology, the Iran Ministry of Health and Tehran University of Medical Sciences purchased subscription access to our ScienceDirect online platform, and in some cases, also purchased print subscriptions or other publications from our scientific, medical & technical publications business. Petrochemical Commercial Company, National Petrochemical Company, Jam Petrochemical Company, Sepahan Oil Company, Zagros Petrochemical Company, Shazand Petrochemical Co., Bandar Imam Petrochemical Company, Tabriz Petrochemical Company, Arya Sasol Polymer Company, Polynar Corporation, Behran Oil Co., Ghaed Bassir Petrochemical Co., Fanavaran Petrochemical Co. and Farabi Petrochemical Company subscribed to our ICIS price reports relating to the global petrochemical, energy and fertilizer markets. Iran Air subscribed to our Flight Global aviation news and information service. Our exhibitions business provided exhibition space to the Cultural Centre of the Embassy of the Islamic Republic of Iran located in Japan. During 2013, our aggregate revenue from the foregoing activities was approximately £4.45 million. We do not normally allocate net profit on a subscription-by-subscription, individual customer or country-by-country basis. However, we estimate that our net profit from these activities, after internal cost allocations, amounted to less than 0.075% of our net profit reported in our combined income statement for the year ended December 31, 2013. Numerous individuals located in Iran subscribed to or purchased certain of our scientific, medical & technical publications. Many of these individuals are researchers, doctors or other professionals who have obtained subscriptions or purchased publications in their individual capacity, but who may be employed by government agencies in Iran or by hospitals, universities or other entities owned or controlled by the government of Iran. We work with authors, other contributors and journal editorial board members who are located in Iran, many of whom are employed at hospitals, universities or research institutions that are owned or controlled by the government of Iran. During 2013, we did not pay any fees or receive any revenues in connection with this activity. During 2013, numerous attendees at conferences organized by our exhibitions business were Iran nationals. We believe these transactions and dealings were lawful under applicable laws and regulations, and anticipate that similar transactions or dealings may occur in the future." (United States Securities and Exchange Commission, “Form 20-F,” 3/11/14)