Withdrawn

According to its Annual Report filed with the SEC for fiscal year 2019: "During the reporting period, the Company sold access to information and informational materials, which are generally exempt from U.S. economic sanctions, to 3 entities that are part of, or may be owned or controlled by, the Government of Iran.  We were advised by counsel that these transactions were permissible under U.S. sanctions pursuant to certain statutory and regulatory exemptions for the exportation of information and informational materials.  The Company terminated this activity in October 2019 and does not intend to resume it."

According to its Annual Report filed with the SEC for fiscal year 2019: 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 wind-down periods. The assessment of the economic situation resulting from the U.S. Decision led the Company to decide not to pursue business in Iran. Accordingly, contracts entered into by our non-U.S. (re)insurance subsidiaries with Iranian entities prior to the U.S. Decision were either not renewed or terminated in a timely manner.

Certain of our operations located outside the United States, however, underwrite marine and energy treaties on a worldwide basis and, as a result, the underlying insurance and reinsurance portfolios may have exposure to the Iranian petroleum resources, refined petroleum, and petrochemical industries. For example, certain of our operations underwrite global marine hull and cargo policies that provide coverage for vessels navigating into and out of ports worldwide, which could include Iran. We do not believe that any coverage we have provided has directly or significantly facilitated or contributed to the Iranian petroleum resources, refined petroleum, or petrochemical industry.

For the year ended December 31, 2019, we are not aware of any direct premium apportionment with respect to underwriting insurance or reinsurance sanctioned activities reportable under Section 13(r). Should any such risks have entered into the stream of commerce covered by the insurance and reinsurance portfolios underlying our treaties, we believe that the premiums associated with such business would be immaterial.

According to its Form 20-F for the year 2019, filed with the SEC on April 9, 2020:

As previously reported, Tenaris ceased all deliveries of products and services to Iran by the end of October 2018, that is, during the wind-down period and before the full reinstatement of U.S. secondary sanctions on November 5, 2018. Tenaris has not, directly or indirectly, delivered any goods or services to Iran or Iranian companies during 2019 and does not intend to explore any commercial opportunities in Iran, nor does it intend to participate in tender offers by, or issue offers to provide products or services to, Iranian companies or their subsidiaries.

In May 2016, TGS was awarded by Toos Payvand Co., a Tehran-based company, a spot purchase order for carbon steel pipes for the Esfahan Oil Refinery Project (end user National Iranian Oil Company or “NIOC”), for a total value of EUR3.5 million (approximately $4.0 million). TGS delivered most of the items requested under such purchase order, for which the customer made advance payments, during 2017 and during the wind-down period associated with the reinstatement of U.S. secondary sanctions. Shipments under this purchase order were suspended as of October 2018. As of December 31, 2019, TGS recorded an advance payment from Toos Payvand Co. for undelivered goods for approximately EUR 0.04 million (approximately $0.04 million).

During 2018, Dalmine was awarded spot orders from Mapna International FZE for a total value of EUR4.1 million (approximately $4.7 million) of which EUR 4.0 million (approximately $4.5 million) were collected as of December 31, 2018. By October 2018, Dalmine had delivered all ordered items. On April 18, 2019, Dalmine collected the outstanding balance of approximately EUR0.1 million (approximately $0.1 million) in compliance with OFAC regulations. No obligations are outstanding, and no amounts are due to Dalmine in connection with these purchase orders.

During 2018, Dalmine received an order from U.K.-based company BP Exploration Operating Co. Ltd. for EUR0.2 million (approximately $0.2 million) for the provision of casing and coupling to be used in the Rhum Gas Oilfield (located in the U.K.). At the time of the order, the partners in the Rhum Gas Oilfield are BP Exploration Operating Co Ltd. (50%) and Iranian Oil Co UK Ltd (50%), a subsidiary of NIOC. All items were delivered by October 2018. On May 21, 2019, Dalmine collected the outstanding balance of approximately EUR0.2 million (approximately $0.2 million) from BP Exploration Operating Co. Ltd. in compliance with OFAC regulations. No obligations are outstanding, and no amounts are due to Dalmine in connection with this purchase order.

The Iranian company, Novin Niroo Procurement Co. (“Novin Niroo”), cites HPP as a small hydro power plant supplier on its company website. (Novin Niroo Website, “Small Hydro Power Plant”).

Iranian machinery company Partia advertises Achilli as a company on its website. (Partia Website, “Companies”).

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Achilli attended the 2018 Iran Stone Exhibition, according to the exhibitors list. (Iron Stone Exhibition, “Exhibition Book”).

In its report, “Evolution of UAVs Employed By Houthi Forces In Yemen,” CAR concludes, “A significant number of Houthi UAV components either originated in Iran, or match those used by factions in the region that are linked to Iran.” The report contains the following notable excerpt: "All of the Qasef-1s documented by CAR employed circuit boards attached with microcontrollers bearing an Atmel label. A CAR field investigation team also documented an identical Microchip Atmel microcontroller in a receiver for an RCIED which Bahraini security forces had seized in March 2015 from a passenger bus that had travelled from Iraq, through Saudi Arabia, and into Bahrain." CAR, “Evolution Of UAVs Employed By Houthi Forces In Yemen,” February 2020.

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According to its website, Iranian company Fatehin Sanat supplies various products made by Microchip.

Taiwan’s Mega International Commercial Bank will immediately terminate its payment clearing mechanism between Taiwan and Iran in a response to the United States’ sanctions on Iran, a senior bank official told Reuters on Monday. (Reuters, "Taiwan's Mega Int'l Commercial bank to end Taiwan-Iran clearing mechanism," 10/21/2018). 

According to publicly accessible ship-monitoring data, since January 1, 2016, vessels for which MBC is the Group Owner have called at Iranian ports.

MAIT S.p.A. (“MAIT”) was listed as an exhibitor at the 14th Int’l Exhibition of Mine, Mining, Construction Machinery & Related Industry & Equipment (“Iran Conmin 2018”), which took place at the Tehran International Permanent Fairground from November 2-5, 2018. (Iran Conmin 2018, “Exhibition Profile”).

According to publicly accessible ship-monitoring data, since January 1, 2016, vessels for which LAUGFS is the Operator and Group Owner have called at Iranian ports.