Withdrawn

Air Astana JSC

Industry
Airline
Country
Kazakhstan
Sources

"Air Astana next week is cancelling service to Iran, where it currently operates Almaty – Tehran Imam Khomeini route. Last flight for this 2 weekly flights is scheduled on 31JUL18." (Routes Online, "Air Astana ends Tehran service in late-July," 7/23/2018).
 

Response

“After careful consideration of your letter [and other factors]… it was decided to stop operation to Iran as of August 1, 2018…” (7/26/2018)

Suisse Atlantique

Industry
Shipping
Country
Switzerland
Response

"Since President Trump unilaterally decided to leave the Iran Nuclear Deal and impose new sanction to Iran, we have given clear instruction to our chartering department to stop every future business with Iran and to exclude Iran as destination from our charter party, even if EU is still promoting the Iran Nuclear Deal and we are a Swiss and European company, and therefore shall not be oblige to follow the US sanction." (7/3/2018) 

Nike, Inc.

Industry
Retail
Symbol
NYSE: NKE
States
OR
Country
USA
Sources

“The sanctions mean that, as a U.S. company, we cannot provide shoes to players in the Iran national team at this time,” Nike said in a statement on Friday to NBC News....The reason Nike won't be providing the shoes is that there is "no general license permitting the transfer of U.S.-origin / owned clothing to Iran," Richard Nephew, a former director for Iran at the National Security Council and a sanctions expert, told NBC News via email. "We have such licenses for humanitarian goods and shoes usually don't count," Nephew said. The Treasury issues some licenses in order to authorize activities that would otherwise be prohibited with regard to Iran, but Nephew said that Nike's shoes are likely not covered by these licenses." (6/10/2018).

Torm A/S

Industry
Shipping
Country
Denmark
Sources

"Danish oil product tanker operator Torm (TRMDa.CO) on Tuesday said it has stopped taking new orders in Iran as a consequence of U.S. plans to reimpose sanctions on Tehran.

“We follow the situation closely and always follow the rules. Therefore, we have also stopped taking new orders in Iran,” a spokeswoman told Reuters." (5/15/2018)

Temet Oy

Industry
Technology
Country
Finland
Sources

"During the exhibition, TEMET performed a quality audit to the AMAD factory in Tehran. We are now happy to announce that AMAD Design & Procurement Co. is now a certified manufacturer of TEMET PV-KK-S blast valves in Iran. The certificate was handed over by Mr. Konsta Hölttä, Development Engineer of Temet Oy, and was received by             Mr. Saeed Shafazand, CEO of Amad Design & Procurement Co."
 

Response

Response: “Before starting this business we presented our proposal to the United States Embassy in Helsinki and requested their approval for the same. Their advice was that if Temet provides products only the Oil & Gas market, this is Ok and will not affect Temet´s relations with the United States of America.” (June 13, 2017)

Sika AG

Industry
Chemicals
Symbol
VTX: SIK
States
NJ
Country
Switzerland
Sources

"The company was reported as potentially providing building products and automotive services in Iran In 2018 CalPERS designated the company as under review. In 2019 CalPERS changed the designation to “being monitored” because CalPERS’ initial screening has not identified the company as having involvement in the regions and/or activities targeted by the Act. CalPERS has maintained the company in “monitor” status for 2020. CalPERS continues to monitor the company for possible changes in status relevant to the Act."

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In 2017, CalSTRS designated Sika AG as “Under Review” for potentially having ties to Iran. In 2018, CalSTRS removed Sika AG after reviewing the company’s internal controls and confirming it ceased business related to sanctioned industries.
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In 2017 the U.S. state of California listed Sika AG as a company under review for reportedly providing their building products and automotive services in Iran.

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To insure that Sika is supporting Sustainable and Ecological projects worldwide especially in Emerging Markets, we as Sika’s subsidiary in Iran with permission of Sika AG have sponsored myclimate’s 1st “YES” program in Iran, which was held in December 2016. (12/17/2016)

PartnerRe

Industry
Insurance
Symbol
NYSE: PRE-F
Country
USA
Sources

According to its Annual Report filed with the SEC for fiscal year 2018: "On January 16, 2016, the United States and the EU eased sanctions against Iran pursuant to the Joint Comprehensive Plan of Action ("JCPOA"). On May 8, 2018, the United States announced their withdrawal from the JCPOA (the "U.S. Decision"), thus re-imposing sanctions against Iran after the expiry of the permitted 90 and 180 day wind-down periods, i.e. respectively August 6, 2018 and November 4, 2018. The assessment of the economic situation resulting from the U.S. Decision had led PartnerRe to decide not to pursue business in Iran. Accordingly, contracts entered into by our non-U.S. reinsurance subsidiaries with Iranian entities prior to the U.S. Decision were either not renewed or terminated in a timely manner.

In respect of transactions to be disclosed pursuant to Section 219, carried out in 2018 prior to the U.S. Decision, we can comment as follows:

Through the intermediary of non-Iranian brokers, a non-U.S. subsidiary of PartnerRe Bermuda, entered into a four layer property excess of loss reinsurance treaty with Bimeh Iran which is an entity that has been identified as owned or controlled by the Government of Iran and appears on the List of Persons Identified as Blocked Solely Pursuant to Executive Order 13599. The agreement was executed in 2018 and coverage began January 1, 2018; however, the coverage was terminated by the non-U.S. subsidiary of PartnerRe Bermuda with an effective date of November 4, 2018. Gross revenue was €183 thousand and net profit attributable to the contract was €35 thousand during 2018. This entity was also exposed to a loss pursuant to a marine (cargo and hull) excess of loss reinsurance treaty (the “Treaty”) in respect of a collision in January 2018 of two vessels one of which, covered by the Treaty, caught fire and sank. The sunk vessel was owned or controlled by the Government of Iran, appears on the List of Persons Identified as Blocked Solely Pursuant to Executive Order 13599 and was operated by National Iranian Tanker Company. In addition, the sunk vessel was used to transport condensate from Iran to South Korea. To date and to our knowledge, our exposure amounts to €144 thousand. This claim was notified to PartnerRe in early November 2018 and we have blocked payment of this claim due to the position of our financial institution who refuses to settle payments relating to Iran."

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According to its Annual report filed with the SEC for fiscal year 2017: "On January 16, 2016, the United States and the EU eased sanctions against Iran pursuant to the Joint Comprehensive Plan of Action, and many of the reportable activities, transactions and dealings under Section 13(r) are no longer subject to U.S. sanctions and no longer prohibited by applicable local law.

Certain of our non-U.S. reinsurance operations provide reinsurance treaty coverage to non-U.S. insurers of marine & energy risks as well as mutual associations of ship owners that provide their members with protection and liability coverage. As a result of the recent lifting of European sanctions on Iran, some of these insurers have informed us that they have begun shipping, or will begin to ship, cargo to and from Iran, including transporting crude oil, petrochemicals and refined petroleum products.  Because these non-U.S. subsidiaries insure or reinsure multiple voyages and fleets containing multiple ships, we are unable to attribute gross revenues and net profits from such policies to activities with Iran. As the activities of our insureds are permitted under applicable laws and regulations, the Company intends for its non-U.S. subsidiaries to continue providing such coverage to its insureds and reinsureds.

Though the intermediary of non-Iranian brokers, a non-U.S. subsidiary of the Company, entered into:

  • A four layers property excess of loss reinsurance treaty with Bimeh Iran which is an entity that has been identified as owned or controlled by the Government of Iran and appears on the List of Persons Identified as Blocked Solely Pursuant to Executive Order 13599. The agreement was executed in 2017 and coverage began on January 1, 2017 for one year. Expected gross revenue is €177 thousand (approximately $218 thousand) and expected net profit attributable to the contract is €47 thousand (approximately $58 thousand). The subsidiary intends to continue providing such coverage in accordance with applicable law.
  • A three layers marine excess of loss reinsurance treaty with Bimeh Iran. The agreement was executed in 2017 and coverage began on July 1, 2017 for one year. Expected gross revenue is €129 thousand (approximately $160 thousand) and expected net profit attributable to the contract is €23 thousand (approximately $28 thousand). The subsidiary intends to continue providing such coverage in accordance with applicable law.
  • A three layers property catastrophe excess of loss reinsurance treaty with an Iranian pool of insurers of which one member is Bimeh Iran. The agreement was executed in 2017 and coverage began on September 23, 2017 for one year. Expected gross revenue is IRR 4,635 million (approximately $124 thousand) and expected net loss attributable to the contract is IRR 4,947 million ($132 thousand). The subsidiary intends to continue providing such coverage in accordance with applicable law."

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Seyyed Mohammad Asoudeh, chief executive of Iranian Reinsurance Co., said that the reinsurer is in talks with several foreign reinsurers for coverage, Financial Tribune reported. The foreign reinsurers Iranian Re is talking to include France-based Scor S.E., Bermuda-based PartnerRe Ltd. and Lebanon-based Nasco Insurance Group. "We had a round of successful negotiations regarding mutual insurance cooperation and reinsurance coverage in addition to cooperation in offering modern insurance and reinsurance coverage,” Mr. Asoudeh said. IranianRe is looking to transfer a portion of the country's risk to foreign reinsurers. (December 11, 2017).

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According to its Annual Report filed with the SEC for fiscal year 2016: "On January 16, 2016, the United States and the EU eased sanctions against Iran pursuant to the Joint Comprehensive Plan of Action, and many of the reportable activities, transactions and dealings under Section 13(r) are no longer subject to U.S. sanctions and no longer prohibited by applicable local law.
Certain of our non-U.S. reinsurance operations provide reinsurance treaty coverage to non-U.S. insurers of marine & energy risks as well as mutual associations of ship owners that provide their members with protection and liability coverage. As a result of the recent lifting of European sanctions on Iran, some of these insurers have informed us that they have begun shipping, or will begin to ship, cargo to and from Iran, including transporting crude oil, petrochemicals and refined petroleum products.  Because these non-U.S. subsidiaries insure or reinsure multiple voyages and fleets containing multiple ships, we are unable to attribute gross revenues and net profits from such policies to activities with Iran. As the activities of our insureds are permitted under applicable laws and regulations, the Company intends for its non-U.S. subsidiaries to continue providing such coverage to its insureds and reinsureds.
A non-U.S. subsidiary provides a property catastrophe excess of loss reinsurance to an Iranian pool of insurers of which one member is Bimeh Iran. Bimeh Iran is an entity that has been identified as owned or controlled by the Government of Iran and appears on the List of Persons Identified as Blocked Solely Pursuant to Executive Order 13599. The agreement was executed in 2017 and coverage began on September 23, 2016 for one year. Expected gross revenue is €100,000 and expected net profits attributable to this contract are €10,000. The subsidiary intends to continue providing such coverage in accordance with applicable law."

Response

"PartnerRe Group maintains a robust risk-based compliance program through which the Group evaluates its business opportunities – including participation in global conferences." (February 2, 2018)