Flowserve

According to its Annual Report filed with the SEC for fiscal year 2013: "Section 219 of the Iran Threat Reduction and Syria Human Rights Act of 2012 (TRA) added subsection (r) to Section 13 of the Exchange Act.  That subsection requires issuers to disclose whether affiliates engaged in specified activities or transactions relating to Iran. The reporting requirement extends to activities that were permissible under U.S. law at the time they occurred.  As previously reported, in 2007, Flowserve implemented a phased withdrawal from Iran, Syria and Sudan. During the phased withdrawal, Company policy permitted foreign subsidiaries to engage in certain limited business with those countries, including the provision of spare parts for previously supplied equipment so long as those shipments complied with U.S. and other applicable law. In 2010, Flowserve France S.A.S., a Flowserve affiliate, made one shipment of spare parts valued at approximately €25,843 to Kala Naft in Iran. The 2010 shipment complied with U.S. law at the time, as it did not involve U.S. persons and did not involve any U.S.-origin content. Pursuant to Company policy, the shipment was reviewed by internal compliance personnel in Europe at the time to ensure compliance with U.S. and other applicable law.

Effective December 31, 2011, our foreign subsidiaries were directed to complete their withdrawal from Iran, Syria, and Sudan. At that time, no payment had been received from Kala Naft for the 2010 shipment of spare parts.  In the course of a compliance review in the first quarter of 2013, the Company discovered that our foreign affiliate received a final payment of €10,000 on March 15, 2013 associated with the 2010 shipment. The Company requested specific authorization from the Office of Foreign Assets Controls  (“OFAC”) at the U.S. Department of the Treasury to process that payment, as it was received one week after the expiration of the OFAC general license described at 31 C.F.R. 560.555. Additionally, through a subsequent compliance review, the Company discovered that two earlier payments of approximately €5,000 and €8,845 were received on March 22, 2012 and October 3, 2012, respectively, in connection with the 2010 shipment. Receipt and processing of those earlier payments were permissible under U.S. and other applicable law at the time.  Net profit associated with the 2010 shipment was approximately €18,000.  Flowserve and all of the Company's affiliates have withdrawn from the Iranian market.  Flowserve does not intend or expect to continue any activity related to those countries other than foreign government-mandated inspections, which we plan to conclude as soon as possible."

--

"Flowserve, which makes flow control equipment used in the oil and gas industry and has sold power and hand pumps to the Department of Defense, said in 2009 filings with the SEC that due to 'growing political uncertainties' its foreign subsidiaries had in 2006 begun a voluntary phased withdrawal from conducting new business in countries designated as state sponsors of terrorism, including Iran, Syria and Sudan. 'The aggregate amount of all business done by our foreign subsidiaries for customers in Iran, Syria and Sudan accounted for less than 1 percent of our consolidated global revenue in 2008,' the company said, adding that while it was voluntarily phasing out new business with those countries, "our foreign subsidiaries may independently continue to honor certain existing contracts, commitments and warranty obligations in compliance with U.S. and other applicable laws and regulations."

From 2000 through March 2010, Flowserve has been the recipient of $71.1 million in federal funds. (The New York Times, "Profiting from Iran, and the U.S.", 3/6/10)