Withdrawn

Air Baltic

Industry
Airline
Country
Latvia
Sources

AirBaltic continues to provide flights from Riga to Tehran. 

Response

The tickets you identified in your letter are sold on interline basis with Ukraine International Airlines and to be performed by the said operator. Taken into account the sensitivity of the matter, we have decided to show good will and to stop offering such connecting flight on our website. 

Adriatic Sea Transport Shpk

Industry
Shipping
Country
Albania
Sources

According to publicly accessible ship-monitoring data, since January 1, 2016, AEC ships have called at Iranian ports on thirty-two occasions.

Response

Adriatic Sea Transport confirmed on October 19, 2018 that they suspended all operations with Iran government and from March 2018 are without any collaboration with Iran ports and Iran governments.

Ace Tankers CV

Industry
Shipping
Country
Netherlands
Sources

According to publicly accessible ship-monitoring data, since January 1, 2016, Ace Tanker ships have called at Iranian ports over 25 times.

Response

Response: "Please note that Ace Tankers and any of its affiliated DO not call Iranian Ports nor carrying any Iranian cargo or having any business related to Iran or Iranian individuals." (August 8, 2019)

H.B. Fuller

Industry
Manufacturing
Country
USA
Sources

"H.B. Fuller Co., a U.S. manufacturer of adhesives, said it may have violated U.S. economic sanctions on Iran through the potential resale of its products by some customers of its subsidiaries.

The St. Paul, Minn., company in a regulatory filing said its hygiene products were possibly resold into Iran through customers of its subsidiaries based in Turkey, starting in 2011, and in India, from 2014.

H.B. Fuller, which makes adhesives used in electronics, furniture, construction and disposable baby diapers, said it made a self disclosure of the possible violation to the U.S. Treasury Department's Office of Foreign Assets Control, which enforces U.S. economic sanctions, in January 2018. The company said it stopped sales to these customers in fiscal 2018, adding the company doesn't currently conduct any business in Iran.

Still, this could result in a finding that U.S. sanctions were violated and possible penalties, the company said in its quarterly report filed with the Securities and Exchange Commission last week.

The company discovered the potential violation during a financial review and hasn't received a response from OFAC, according to company spokeswoman Kimberlee Sinclair. The possible violation could result in monetary penalties ranging from zero to $10 million, H.B. Fuller said in the filing.

"H.B. Fuller never sold any products into Iran," Ms. Sinclair said. "A customer in the Middle East diverted a small amount of baby diaper adhesive into Iran. We immediately alerted OFAC when we found out." Ms. Sinclair said the company manufactures baby diaper adhesives in India and has a sales office in Turkey.

The company said in the filing that it retained legal counsel to conduct an internal investigation on the issue in 2018. Ms. Sinclair said the company has concluded its internal investigation and has submitted the results and findings to OFAC.

The Trump administration in September increased sanctions on Iran in response to attacks on critical oil supplies in Saudi Arabia. The U.S. last week blacklisted several Chinese companies for allegedly shipping Iranian oil in violation of U.S. sanctions."

Banco Bilbao Vizcaya Argentaria (BBVA)

Industry
Banking
Symbol
NYSE BBVA
Country
Spain
Sources

According to its Annual Report filed with the SEC for fiscal year 2019: "The BBVA Group discloses the following information pursuant to Section 13(r) of the Exchange Act, which requires an issuer to disclose whether it or any of its affiliates knowingly engaged in certain activities, transactions or dealings relating to Iran or with natural persons or entities designated by the U.S. government under specified executive orders, including activities not prohibited by U.S. law and conducted outside the United States by non-U.S. affiliates in compliance with local law. In order to comply with this requirement, the Company has requested relevant information from its affiliates globally.

The BBVA Group has the following activities, transactions and dealings with Iran requiring disclosure:

Legacy contractual obligations related to counter indemnities. The BBVA Group made a payment of $642 to Bank Melli on July 11, 2019, due to outstanding commissions on the counterindemnity executed on October 16, 2018. Such counterindemnity was issued in April 2000 and has been regulatory reported until its execution in 2018.

Iranian embassy-related activity. The BBVA Group maintains bank accounts in Spain for one employee of the Iranian embassy in Spain. This employee is a Spanish citizen. Estimated gross revenues for the year ended December 31, 2019, from embassy-related activity, which include fees and/or commissions, totaled $2,225. The BBVA Group does not allocate direct costs to fees and commissions and therefore has not disclosed a separate profit measure. 

The BBVA Group is committed to terminating these business relationships as soon as legally possible."

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As of August 27, 2019, Banco Bilbao Vizcaya Argentaria (BBVA) is listed on the Illinois Investment Policy Board Iran Restricted Companies list. 

Response

BBVA closed its Tehran representative office in 2008 (4/16/2018)

Petronas Chemicals Bhd

Industry
Chemicals
Symbol
PCHEM:MK
Country
Malaysia
Sources

On June 16, 2011, Petronas Chemicals was added to the Florida State Board of Administration List of Prohibited Investments (Scrutinized Companies) due to its involvement in Iran. As of March 9, 2021, Petronas Chemicals remains on the SBA list of prohibited investments. 

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In 2020, the U.S. state of Mississippi listed Petronas Chemicals on its state lists of Companies Doing Business with the Iranian Petroleum/Natural Gas, Nuclear and Military Sectors, rendering it ineligible for investment and/or state contracting.

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Petronas Chemicals is listed on the June 4, 2019 and July 12, 2019 Florida State Board of Administration list of prohibited investments (Scrutinized companies) for Iran related business.

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Petronas Chemicals Bhd is listed on the Alaska Retirement Management Board's March 2019 and June 2019 list of companies doing business with Iran.

Response

"We would like to re-iterate that PETRONAS Chemicals Group Berhad does not have business with or in Iran, which was why UANI did not find any mention of Iran on our website or in any other disclosures." (7/29/2020)

Gastec Corporation

Industry
Chemicals
Country
Japan
Sources

On the official website of Zist Tajhiz Pooyesh Company, Gastec Corporation is mentioned as their official business partner. Zist Tajhiz Pooyesh Company is added on February 3, 2017 to the Specially Designated Nationals (SDN) list maintained by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) for suppling goods to Mabrooka Trading, which procures items for Iran-based Navid Composite, a subsidiary of U.N.-sanctioned Sanam Industries Group;

Response

"We used to do business with Pooyesh Enviro before Iran and the company became subject to the OFAC regulation. We believe this is the reason why they still cite us as an international parter on their website. However, we have never executed business with them since the situation was changed." (3/19/2020)

Aviteq

Industry
Construction
Country
Germany
Sources

"According to the official website of Aviteq, Iranian working partner of Aviteq is FITCO;

On the website of FITCO, Aviteq is mentioned as their supplier;

FITCO is involved in purchasing equipment and materials which have direct applications in the Iranian nuclear program;

FITCO is listed by the European Union on December 1, 2011 as an entity linked to Iran’s proliferation-sensitive nuclear activities or Iran’s development of nuclear weapon delivery systems; with some exceptions, European Union member states must freeze all funds and economic resources owned, held or controlled by the listed entity, and prevent funds or economic resources from being made available to it;" (IFMAT, "Despite EU Sanctions Aviteq Continues To Work In Iran," 7/8/2019). 

Response

Indeed we canceled months ago our business relationship to Iranian company. We forgot this entry but we now deleted it.

Odfjell Drilling Ltd

Industry
Drilling
Symbol
NO ODL
Country
Norway
Contact Information

eikn@odfjelldrilling.com

Sources

According to a response sent to Minnesota State Board of Investment in January 2019, "Odfjell Invest Ltd nor any of its affiliates has had any active business operations in Iran after 4 November 2018. Since entering the Iranian oil and gas market in 2016, Odfjell Well Services II Ltd ("OWS"), a company in the Odfjell Drilling group, held two contracts until the end of the wind-down period on 4 November 2019: 

  • Iranian Offshore Engineering and Construction Co
  • Drilling Company INternational

All activities under these two contracts were terminated by OWS prior to the end of the wind-down period. Personnel and equipment demobilizaton was initiated before the end of the wind down period and completed shortly thereafter. 

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Odfjell was removed from the May 15, 2019 Iowa Public Employees' Retirement System Iran Prohibited Companies List.

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In 2019, CalSTRS identified Odfjell Drilling as potentially having ties to Iran. CalSTRS
subsequently removed Odfjell drilling after confirming the winddown of their Iranian involvement and reviewing the company’s internal controls. 

Andritz Hydro AG

Industry
Manufacturing
Country
Austria
Sources

Andritz Hydro AG was identified as potentially providing hydropower equipment in Iran.

In 2017, CalSTRS designated Andritz Hydro AG as “Under Review” for potentially potentially providing hydropower equipment in Iran. CalSTRS maintained the “Under Review” designation in 2018.

Response

On June 2, 2020, Andritz confirmed to UANi that it has refrained from doing business in Iran.