Withdrawn

According to its Annual Report filed with the SEC for fiscal year 2018: "During the fiscal year ended March 31, 2018, Nomura Research Institute, Ltd. (“NRI”), an affiliate in which we hold, directly and indirectly, 38.5 % of the outstanding share capital, has engaged in meetings and discussions on potential business development with entities that are or may be owned or controlled by the Government of Iran. There were no revenues or profits arising directly from these meetings and discussions.

In addition, NRI entered into several contracts with an investment and development company and a governmental organization, both of which are owned or controlled by the Government of Iran, pursuant to which NRI agreed to perform benchmark investigations, conduct comparative analyses and provide other consulting services to facilitate development projects. During the period covered by this report, these contracts and related activities generated gross revenues of ¥8,579,814. Due to costs of providing services, there were no profits attributable to these contracts.

Further, NRI entered into contracts with another entity pursuant to which NRI receives certain services related to the work that NRI is performing for the aforementioned investment and development company and governmental organization. These contracts did not, on their own, generate any revenues or profits for NRI. After consultation with NRI and on the basis of information publicly available to us, we believe that this other entity is a private entity that is not owned or controlled by the Government of Iran.

NRI also made payments to the Government of Iran to obtain entry visas to travel to Iran in connection with the activities described above.

Sanctions relief regarding Iran was implemented in 2016 in accordance with the Joint Comprehensive Plan of Action (“JCPOA”) reached by the permanent members of the United Nations Security Council (China, France, Russia, the United Kingdom and the United States), Germany, the EU, and Iran to ensure that Iran’s nuclear program is used for peaceful purposes. Despite the JCPOA, certain activities, including transactions involving targeted Iran-related persons and entities and transactions that implicate U.S. jurisdiction, remain subject to sanctions. However, on May 8, 2018, President Trump announced his decision to cease the United States’ participation in the JCPOA and to re-impose the U.S. nuclear-related sanctions targeting Iran that were lifted under the JCPOA. In conjunction with this announcement, President Trump issued a National Security Presidential Memorandum (“NSPM”) directing the Secretary of State and the Secretary of the Treasury to prepare immediately for the re-imposition of all of the U.S. sanctions lifted or waived in connection with the JCPOA, to be accomplished as expeditiously as possible and in no case later than 180 days from the date of the NSPM. As a result, new business that is contrary to the re-imposed sanctions will be sanctionable immediately upon re-imposition, and business that pre-dates May 8, 2018 will be subject to wind-down periods of 90 days or 180 days, as applicable, following which parties will be exposed to the risk of sanctions or an enforcement action under U.S. law.

In light of the above, NRI intends to discontinue the activities described above."

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During the fiscal year ended March 31, 2017, certain non-U.S. affiliates of the Company engaged in the following activities with entities that are or may be owned or controlled by the Government of Iran:

  •   Nomura Research Institute, Ltd. (“NRI”), an affiliate in which we hold, directly and indirectly, 37.2% of the outstanding share capital, has engaged in meetings and discussions on potential business development with entities that are or may be owned or controlled by the Government of Iran. There were no revenues or profits arising directly from these meetings and discussions.In addition, NRI entered into several contracts with an investment and development company, which is owned or controlled by the Government of Iran, pursuant to which NRI agreed to perform benchmark investigations, conduct comparative analyses and provide other consulting services to facilitate development projects. Performance under these contracts is ongoing. During the period covered by this report, these contracts and related activities generated gross revenues of $1,743,500 and estimated net profits of $261,525. Further, NRI entered into a contract with another entity pursuant to which NRI receives certain services related to the work that NRI is performing for the aforementioned investment and development company, and performance under this contract is also ongoing. This contract did not, on its own, generate any revenues or profits for NRI. After consultation with NRI and on the basis of information publicly available to us, we believe that this other entity is a private entity that is not owned or controlled by the Government of Iran.

NRI also entered into a contract with an entity pursuant to which NRI receives certain services related to the exploration of business opportunities in Iran in the cardiovascular treatment field, and performance under this contract is ongoing.

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According to its Annual report filed with the SEC for fiscal year 2016: "During the fiscal year ended March 31, 2016, certain non-U.S. affiliates of ours engaged in the following transactions or dealings with entities that are or may be owned or controlled by the Government of Iran.

• Nomura Asset Management Co., Ltd., Nomura Asset Management Malaysia Sdn. Bhd. and the Dubai Branch Office of Nomura Asset Management U.K. Limited, our direct and indirect wholly-owned subsidiaries, have engaged in discussions on business development with entities owned or controlled by the Government of Iran. Certain of our non-U.S. affiliates made payments to the Government of Iran to obtain entry visas to travel to Iran in connection with these discussions.
• Nomura Research Institute, Ltd., an affiliate in which we hold, directly or indirectly, 36.8% of the outstanding share capital, has engaged in discussions on business development with entities that are or may be owned or controlled by the Government of Iran. Certain of our non-U.S. affiliates made payments to the Government of Iran to obtain entry visas to travel to Iran in connection with these discussions.
• Nomura International plc, our indirect wholly-owned subsidiary, has interacted with a multilateral development financial institution that supports the economic development of its member countries, largely in Africa, the Middle East and Southeast Asia, in connection with a potential financing transaction for the client of the institution. The Government of Iran holds a minority ownership interest in this institution. Nomura International plc has had no direct dealings with the Government of Iran and, on the basis of information available to us, we do not believe that the Government of Iran controls this institution.

These activities were conducted in accordance with applicable law, and we do not believe that the activities were sanctionable under applicable law. We have not generated any revenues from these activities during the period covered by this report.

In light of recent changes in the international economic sanctions regime relating to Iran, we intend to continue to engage in the activities described above and may engage in similar activities in future periods; however, any such activities will be conducted in accordance with all applicable laws, and we do not intend to engage in any activities that are sanctionable under applicable law."

According to its Annual Report filed with the SEC for fiscal year 2019: "We had approximately 0.4 million MAUs in Iran in December 2019, and our business with Iran represented approximately 0.002% of our revenues in 2019, which consisted primarily of sales of Stickers and in-game items in the ordinary course of business. In February 2017, LINE PLAY Corporation, which is owned by LINE Plus Corporation, our wholly-owned subsidiary in Korea, established a local branch in Iran, which subsequently ceased all operations and remains closed as of December 31, 2019."

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According to its Annual Report filed with the SEC for fiscal year 2018: "We had approximately 0.8 million MAUs in Iran in December 2018, and our business with Iran represented approximately 0.006% of our revenues in 2018, which consisted primarily of sales of Stickers and in-game items in the ordinary course of business. Our website containing media content directed at users in Iran, which we had launched in May 2016, was closed in November 2018. In February 2017, LINE PLAY Corporation, which is owned by LINE Plus Corporation, our wholly-owned subsidiary in Korea, established a local branch in Iran, which subsequently ceased all operations and remains closed as of December 31, 2018."

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 "On May 5, 2016, we launched a website containing media content directed at users in Iran. In February 2017, LINE PLAY Corporation, which is owned by LINE Plus Corporation, our wholly-owned subsidiary in Korea, established a local branch in Iran, which subsequently ceased all operations and remains closed as of December 31, 2017. LINE Plus Corporation met with officials from a governmental research institute in Iran in conjunction with our market research initiatives in Iran, and in January 2017, entered into a two-month research contract with the Iran Telecommunication Research Center (ITRC) to gain a better understanding of the Iranian mobile market and relevant regulatory considerations. We did not generate any revenue from the contract, which expired in 2017." (2017)

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According to its Annual Report filed with the SEC for fiscal year 2016: "In December 2016, we had approximately four million MAUs in Iran. In addition, LINE provides Official Accounts to local Iranian celebrities and engages in promotional activities directed at users in Iran. On May 5, 2016, we launched a website containing media content directed at users in Iran. LINE Pay is available to users in Iran, Cuba, Sudan and Syria. Our business with Iran represented approximately 0.03% of our revenues for the year ended December 31, 2016. In February 2017, we established a local branch through our subsidiary, LINE PLAY Corporation. Our subsidiary, LINE Plus Corporation, has met with officials from the Government of Iran in conjunction with our business expansion efforts in Iran. In January 2017, LINE Plus Corporation entered into a two month research contract with the Iran Telecommunication Research Center (ITRC). The purpose of the research contract was for LINE to explore business opportunities in Iran and gain a better understanding of the Iranian mobile market and relevant regulatory considerations. We will not generate revenue from the contract, and we do not plan to renew the contract."

According to its Annual Report filed with the SEC for fiscal year 2018: "The vessel Myrto made a call to the port of Bandar Imam Khomeini on April 12, 2018, discharging soybeans, and remained in the port of Bandar Imam Khomeini during 2018 for ten days. During this time the Myrto was on time charter to Cargill at a gross rate of $8,000 per day.

The aggregate gross revenue attributable to these ten days that our vessel remained in the port of Bandar Imam Khomeini was $80,000. As we do not attribute profits to specific voyages under a time charter, we have not attributed any profits to the voyages which included this port call. Our charter party agreements for our vessels restrict the charterers from calling in Iran in violation of U.S. sanctions, or carrying any cargo to Iran which is subject to U.S. sanctions."

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"The vessel Thetis made a call to the port of Bandar Imam Khomeini on February 25, 2017, discharging corn, and remained in the port of Bandar Imam Khomeini during 2017 for seven days. During this time the Thetis was on time charter to Transgrain Shipping B.V., Rotterdam at a gross rate of $5,150 per day." (SEC Disclosure 2017).

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According to its Annual Report filed with the SEC for fiscal year 2016: "Pursuant to Section 13(r) of the Exchange Act, we note that for the period covered by this annual report, four of our vessels made one port call each to Iran in 2016.

• The vessel Amphitrite made a call to the port of Bandar Imam Khomeini on February 24, 2016, discharging corn, and remained in the port of Bandar Imam Khomeini during 2016 for seven days. During this time the Amphitrite was on time charter to Bunge S.A. at a gross rate of $7,700 per day.
• The vessel Artemis made a call to the port of Bandar Imam Khomeini on October 4, 2016, discharging sugar, and remained in the port of Bandar Imam Khomeini for 20 days. During this time the Artemis was on time charter to Bunge S.A. at a gross rate of $5,350 per day.
• The vessel Melite made a call to the port of Bandar Imam Khomeini on March 4, 2016, discharging corn, and remained in the port of Bandar Imam Khomeini for eight days. During this time the Melite was on time charter to Cargill International S.A. at a gross rate of $7,250 per day.
• The vessel Myrto made a call to the port of Bandar Imam Khomeini on March 3, 2016, discharging soya bean meal and pellets, and remained in the port of Bandar Imam Khomeini for 34 days. During this time the Myrto was on time charter to Cargill International S.A. at a gross rate of $6,000 per day."

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According to its Annual Report filed with the SEC for fiscal year 2015: "Pursuant to Section 13(r) of the Exchange Act, we note that for the period covered by this annual report, the vessels Amphitrite and Clio made five port calls to Iran in 2015 for a combined length of 60 days. The vessel Amphitrite made calls to the port of Bandar Imam Khomeini on December 29, 2014 (discharging corn), April 29, 2015 (discharging soya beans), September 6, 2015 (discharging corn) and November 28, 2015 (discharging maize), and remained in the port of Bandar Imam Khomeini during 2015 for 50 days in the aggregate. The vessel Clio made a call to the port of Bandar Imam Khomeini on October 27, 2015, discharging corn, and remained in the port of Bandar Imam Khomeini for 10 days.  During this time the Amphitrite was on time charter to Bunge S.A. at a gross rate of $11,300 per day and the Clio was on time charter to Transgrain Shipping B.V at a gross rate of $6,500 per day. Our aggregate gross revenue attributable to these 60 days of port calls was approximately $3.2 million, less 5% commissions paid to third parties. As we do not attribute profits to specific voyages under a time charter, we have not attributed any profits to the voyages which included these port calls.  Our charter party agreements for the Amphitrite and Clio restrict the charterers from calling in Iran in violation of U.S. sanctions, or carrying any cargo to Iran which is subject to U.S. sanctions. However, there can be no assurance that the Amphitrite, Clio or another of our vessels will not, from time to time in the future on charterer's instructions, perform voyages which would require disclosure pursuant to Exchange Act Section 13(r)."

"Arkas Holding and IRISL, which is a maritime company of Islamic Republic of Iran, dissolved the partnership. Within the scope of developing relationships between Turkey and Iran; the shares of the IRISL Anadolu Shipping Agency, which was established in 2016 by Arkas Holding and IRISL that is a maritime company of Islamic Republic of Iran; were transferred to Iranians." (Maritime, "Arkas Holding and IRISL Dissolve the Partnership," 11/7/2018).

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"Arkas Holding has said it signed a memorandum of understanding with the Islamic Republic of Iran Shipping Lines (IRISL) to establish a Turkey-based joint venture to offer maritime transportation and logistics services across the Mediterranean Sea.

Arkas Chairman Lucien Arkas, and IRISL Executive Board Chairman Dr. Mohammad Saeedi attended the signing ceremony, which was held in IRISL’s head office in Tehran, said the İzmir-based Arkas said in a written statement on April 12." (April 12, 2016).

Keysight Technologies voluntarily self-disclosed to the US Treasury Department and agreed to a settlement signed June 18th, 2020 of $473,157. The Treasury Department's review of Anite's (a subsidiary of Keysight Technologies at the time of the violations) activities show that they violated Iranian Transactions and Sanctions Regulations in that Anite engaged in "exports of six goods intended for Iran with US origin content."

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According to its website, Iranian company Fatehin Sanat provides Keysight Technologies products.

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From January to May 2016, Anite, a recently acquired subsidiary of Keysight organized and existing under the laws of England and Wales, engaged in transactions involving the sale of wireless network testing and measurement equipment to an end user in Iran. Anite sold the equipment through intermediate companies for ultimate end use by MTN Irancell, located in Tehran, Iran. These sales were completed in violation of Keysight’s trade policies which currently prohibit all sales to Iranian customers. Keysight discovered this activity after the relevant reporting period and has conducted a comprehensive internal investigation and review.  As a result of this investigation and review, disciplinary action has been taken with respect to employees who knowingly violated company policy and Keysight has implemented additional compliance procedures designed to prevent future violations of policy. (2017)

In 2019 JXTG was listed on the Texas Comptroller List of Companies Engaging in Scrutinized Business Operations in Iran.  

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In 2019, JXTG was listed as a divested security on the Michigan State Retirement System list for active business operations in Iran. 

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JXTG Holdings, Japan’s biggest oil refinery operator, has secured crude oil supplies from other countries such as Saudi Arabia to replace Iranian oil shipments that have been crimped by U.S. sanctions, its president said on Monday.

“We are not importing Iranian oil from May but there is no major impact,” JXTG Holdings President Tsutomu Sugimori, told an earnings news conference, when asked about the impact of tighter U.S. sanctions on Iranian oil.

“We have already secured supplies to replace Iranian oil from countries such as Saudi Arabia,” he said. (Reuters, "JXTG says gets supplies from Saudi, others to replace Iranian oil," 5/13/2019).

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JXTG Holdings Inc., a refiner, plans to follow government guidance, and if necessary will replace Iranian supplies with supplies from the Middle East, West Africa, and possibly the United States. (June 29, 2018)

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According to its 2017 Annual Report filed with the SEC: "During the fiscal year ended March 31, 2017, JXTG Nippon Oil & Energy, a wholly-owned subsidiary of JXTG Holdings, purchased 31 million barrels of crude oil from National Iranian Oil Company for a total purchase price of ¥144,046 million, out of a total of 415 million barrels of crude oil that it purchased during the same period, constituting approximately 7% of the total amount of crude oil that it purchased during the same period.

JXTG believes that the above transaction does not subject it or its affiliates to U.S. sanctions. JXTG Nippon Oil & Energy does not currently intend to cease purchasing crude oil from National Iranian Oil Company."

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In 2017 the U.S. state of Michigan, South Carolina and Tennessee listed JXTG as an Iran restricted company rendering JXTG ineligible for investment and/or state contracting.

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In 2015 JX Holdings was removed from Pennsylvania Treasury's List of Scrutinized Companies Determined as Having Involvement In Iran because the company's "involvement in purchases of crude oil falls uner the waivers granted by the U.S. government that meet Section (a)(2) of Act 44's expiration clause."
 

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In 2013, JX Holdings was added to the Pennsylvania Treasury's List of Scrutinized Companies Determined as Having Involvement in Iran because of Government oil-related activity.