Chemicals

According to its Annual Report filed with the SEC for fiscal year 2017: "During the year ending December 31, 2017, we sold, in a single sales transaction, 765 twenty-five kilogram bags of ReaShure® encapsulated choline, at a sales price of $82,238 to Imex Gulf, Inc., a privately held US corporation headquartered in Plano, Texas. Imex Gulf, Inc. exported this product to Pishgaman Taghzieh DTI Co.in Tehran, Iran, for subsequent sale and distribution in Iran. We conducted this product sale in compliance with applicable laws. The sale of ReaShure®, an animal feed ingredient, is permissible pursuant to certain statutory and regulatory exemptions from U.S. sanctions applicable to food products."

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According to its Annual report filed with the SEC for fiscal year 2016: "During the year ending December 31, 2016, we sold, in a single sales transaction, 400 twenty-five kilogram bags of ReaShure® encapsulated choline, at a sales price of $46,500 to Imex Gulf, Inc., a privately held US corporation headquartered in Plano, Texas. Imex Gulf, Inc. exported this product to Pishgaman Taghzieh DTI Co.in Tehran, Iran, for subsequent sale and distribution in Iran. We conducted this product sale in compliance with applicable laws. The sale of ReaShure®, an animal feed ingredient, is permissible pursuant to certain statutory and regulatory exemptions from U.S. sanctions applicable to food products."

On September 19, 2007, Sinopec Shanghai 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, Sinopec Shanghai remains on the SBA list of prohibited investments. 

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Sinopec Shanghai is listed on the 4Q 2020 Minnesota State Board of Investment List of Unauthorized (Scrutinized) Iran Companies.

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In 2020, the U.S. state of Mississippi listed Sinopec Shanghai 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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According to its Annual Report filed with the SEC for fiscal year 2019: "We have sourced a small portion of our crude oil from Iran in the past through Sinopec Corp., our current controlling shareholder, and independent third parties, and Iran may continue to be the ultimate source of a small portion of our crude oil. In addition, Sinopec Corp. and Sinopec Group, the controlling shareholder of Sinopec Corp., have engaged in operations in or purchasing crude oil sourced from Iran and may continue to do so in the future. We have no control over the activities of Sinopec Group or Sinopec Corp. in connection with any activities that they may conduct in Iran."

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According to its 2018 Annual Report filed with the SEC in April 2019: "We have sourced a small portion of our crude oil from Iran in the past through Sinopec Corp., our current controlling shareholder, and independent third parties, and we may continue to purchase crude oil from Iran. In addition, Sinopec Corp. and Sinopec Group, the controlling shareholder of Sinopec Corp., have engaged in operations in or purchasing crude oil sourced from Iran and may continue to do so in the future. We have no control over the activities of Sinopec Group or Sinopec Corp. in connection with any activities that they may conduct in Iran...In addition, purchase of crude oil by Sinopec Corp. subsidiaries that supply us with raw materials may from time to time be sourced from National Iranian Oil Company. This entity has been identified by the U.S. government as an SDN and sanctioned under various laws, including for assisting the government of Iran to avoid sanction and for engaging in activities related to nuclear proliferation. Under Executive Order 13846, the U.S. President can sanction non-U.S. companies that engage in transactions with SDNs such as the National Iranian Oil Company.... It is possible that Sinopec Group or its affiliates engage in activities that are targeted for sanction purposes by the ISA or other U.S. laws. Based on feedback to our inquiries to Sinopec Group, the controlling shareholder of Sinopec Corp., Sinopec Group engaged in limited business activities in Iran such as providing engineering services and designs. We have no performance obligations under any contract to continue to purchase crude oil sourced from Iran in 2019."

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According to its Annual Report filed with the SEC for fiscal year 2013: "In 2013, we sourced a small amount of crude oil from Iran through a wholly-owned subsidiary of Sinopec Corp., our controlling shareholder, and such amount represented 7.04% of our total purchase volume of crude oil. Details of the purchase volume and purchase expenses are provided below. 

In addition, based on feedback to our inquiries to Sinopec Group, the controlling shareholder of Sinopec Corp., Sinopec Group, directly or indirectly, engaged in a small amount of business activities in Iran such as providing engineering support and designs. Sales revenue from these business activities accounted for 0.0015% of Sinopec Group’s total unaudited sales revenue in 2013. No profits were generated from these business activities in 2013.

We have no performance obligations under any contract to continue to purchase crude oil sourced from Iran in 2014."

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Sinopec Shanghai has filed Iran Notices with the SEC from 2013 - 2020. 

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According to its Annual Report filed with the SEC for fiscal year 2012: "In 2012, we sourced a small amount of crude oil from Iran through a wholly-owned subsidiary of Sinopec Corp., our controlling shareholder, and such amount represented 6.3% of our total purchase volume of crude oil in 2012. Details of our 2012 purchase volume and purchase expenses are provided below. In addition, based on feedback to our inquiries to Sinopec Group, the controlling shareholder of Sinopec Corp., Sinopec Group, directly or indirectly, engaged in a small amount of business activities in Iran such as providing engineering support and designs. Sales revenue from these business activities accounted for 0.08% of Sinopec Group’s total unaudited sales revenue in 2012. No profits were generated from these business activities in 2012. We have no performance obligations under any contract to continue to purchase crude oil sourced from Iran in 2013."

In 2014 Nagarjuna was removed from Pennsylvania Treasury's List of Scrutinized Companies Determined as Having Involvement In Iran because the company is now privately held. 

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In 2011, Nagarjuna was added to the Pennsylvania Treasury's List of Scrutinized Companies Determined as Having Involvement in Iran because of oil-related investment of US $20 million since 1996.

"In 2019, Alwaneo Trade DMCC falsified the origin of Iranian petroleum products shipped to the UAE.

Petro Grand FZE, Alphabet International DMCC, Swissol Trade DMCC, Alam Althrwa General Trading LLC, and Alwaneo LLC Co. are all designated pursuant to E.O. 13846 for on or after November 5, 2018, having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services in support of, NIOC, a person included on the List of Specially Designated Nationals and Blocked Persons whose property and interests in property are blocked pursuant to E.O. 13599." (U.S. Department of Treasury, "Treasury Targets Companies Facilitating Iran’s Petroleum Sales," 3/19/2020). 

Petro Grand FZE, Alphabet International DMCC, Swissol Trade DMCC, Alam Althrwa General Trading LLC, and Alwaneo LLC Co. are all designated pursuant to E.O. 13846 for on or after November 5, 2018, having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services in support of, NIOC, a person included on the List of Specially Designated Nationals and Blocked Persons whose property and interests in property are blocked pursuant to E.O. 13599. (U.S. Treasury Department, "Treasury Targets Companies Facilitating Iran’s Petroleum Sales," 3/19/2020). 

On March 18, the U.S. Department of State imposed sanctions, pursuant to Executive Order (E.O.) 13846, on SPI International Proprietary Limited for knowingly engaging in a significant transaction for the purchase, acquisition, sale, transport, or marketing of petrochemical products from Iran. (U.S. Department of State, "Sanctions on Entities Trading in or Transporting Iranian Petrochemicals," 3/18/2020). 

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"The Mokran petrochemical complex, located at the south eastern Chabahar coastal area, will be the third-largest petrochemical base in Iran, after Bandar Imam and Asaluyeh.

“We have developed several scenarios in investment, partnership and financing. Foreigners can own up to 100% of the plants or can join Iranian investors as their local partner,” Reza Ebadzadeh, CEO of SPI International Proprietary Ltd (SPII), a subsidiary of SHASTAN, which owns nearly one quarter of petrochemical sector of Iran, said in an email interview.

SHASTAN is the master developer of the Mokran Petrochemical Hub, as well as the owner of three plants plus utility (nine different packages) within the Mokran Area, while SPII is in charge of funding arrangement for SHASTAN’s mega projects." (ICIS, "Iran building third-biggest petchem complex in Mokran," 1/24/2017).

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"On 16 August 2013, Sasol Investment Company (Pty) Limited, a wholly owned subsidiary of Sasol, entered into a definitive sale and share purchase agreement pursuant to which Main Street 1095 (Pty) Limited, a South African subsidiary of an Iranian investor, completed and effected the acquisition of 100% of the shares of SPI International (Pty) Limited (“SPII”)(“Transaction”).  SPII is the indirect owner of a 50% interest in Arya. 

As described in our most recent trading statement of 1 August 2013, the fair value of Sasol’s investment in Arya was written down to R2,3 billion.  This was based on our assessment of the fair value of Arya as well as the accounting requirement to recognise operating profits of approximately R1,6 billion for the second half of the 2013 financial year. 

As a result of this Transaction, Sasol has no on-going investment in Iran." (Sasol, "SASOL DISPOSES OF ITS INVESTMENT IN THE IRANIAN JOINT VENTURE ARYA SASOL POLYMER COMPANY (“ARYA”)," 8/19/2013). 

According to its website, LOPGAS’s “partners in Iran with who we work very closely as their client include Persian Gulf Petrochemical Industries Company, PCC, NPC, BIPC, Pars, Zagros, Fanavaran, Bouali Sina, Amir Kabir, Noori, Shazand, Isfahan Petrochemical, Tondgooyan and many others.” (LOPGAS Website, “Global Network”).

"In 2019, Triliance ordered the transfer of the equivalent of millions of dollars to NIOC as payment for Iranian petrochemicals, crude oil, and petroleum products shipped to the United Arab Emirates and China after the expiration of any applicable significant reduction exceptions.  In facilitating these shipments, Triliance worked to conceal the Iranian origin of these products.  Triliance has also facilitated the sale of millions of dollars’ worth of petroleum products involving Naftiran Intertrade Company, a subsidiary of NIOC, to companies in China. 

Additionally, Triliance Kish Petrochemical Company, which is the Iran-based branch of Triliance, recently changed its name and operates as Tiba Parsian Kish Petrochemical." (Treasury, "Treasury Targets International Network Supporting Iran’s Petrochemical and Petroleum Industries," 1/23/2020).

According to publicly accessible ship-monitoring data, since January 1, 2016, Harpain ships have called at Iranian ports on at least 14 occasions.