Conglomerate

"The company was reported as potentially purchasing Iranian crude. 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."

--

Mitsubishi International lists an office in Tehran Iran on its company website. 

--

"Trading house Mitsubishi Corp. said it had asked employees stationed at its operational bases in Iran and Iraq to remain on alert but has not gone as far as to evacuate them." (The Japan Times, "Japan firms pull staff out of Iran and limit Iraq travel amid high tensions," 1/9/2020).

--

Mitsubishi Corp. had previously been removed from the Iran related securities list. In 2017, CalSTRS designated Mitsubishi Corp. as “Under Review” for potentially having new ties to Iran. In 2018, CalSTRS removed Mitsubishi Corp. after reviewing the
company’s business with Iran and internal controls to prevent sanction violations.

--

In 2017 the U.S. state of California listed Mitsubishi as a company under review for reportedly renewing contracts to purchase Iranian crude.

--

"Japan's Mitsubishi Corp bought a naphtha cargo from Iran last month, the Asian country's first such purchase from Iran since October 2016, sources familiar with the matter said. The naphtha cargo, loaded in late January, has arrived in Japan and is from the new Persian Gulf Star Refinery (PGSR), one source added… A Mitsubishi spokesman confirmed it had bought naphtha from Iran recently, but declined to comment on details or which refinery the cargo was from due to company policy." (Reuters, "Japan's Mitsubishi Buys Iran Naphtha Cargo," 2/21/2017).

--

In 2016 and 2017 Tennessee used the South Carolina list of "Entities Ineligible to Contract with the State of South Carolina or any Political Subdivision of the State per the Iran Divestment Act of 2014, S.C. Code Ann." as its list of persons it determines engage in investment activities in Iran. Mitsubishi was included on this list in 2016 and 2017. "Inclusion on this list would make a person ineligible to contract with the state of Tennessee, if a person ceases its engagement in investment activities in Iran, it may be removed from the list."

--

The German economy ministry said several firms from the Mittelstand, the small-to-medium-sized companies that form the backbone of the economy, had also signed deals with Iranian partners. Mitsubishi Germany has signed a contract to modernize a gas-fired plant, while plant constructor Keller HCW wants to build a brickyard in Iran, it said. Both countries' central banks have also agreed to technical co-operation." (Reuters, "Siemens signs Iran rail contract as Germany drums up business," 10/3/2016). 

--

"Iran said on Monday that it welcomes the return of Japan's Mitsubishi and Mitsui to its petrochemical projects. Abbas Sheri-Moqaddam, the managing director of the National Petrochemical Company (NPC), said Mitsubishi and Mitsui had a satisfactory performance in different sections of Iran’s petrochemical industry. Sheri-Moqaddam,  speaking in a meeting with the heads of the two companies who are in Tehran on board a senior Japanese trade delegation, added that they can again participate in Iran’s projects once the sanctions against the country are lifted... The heads of Mitsubishi and Mitsui for their part said they are ready to resume investments in Iran once the sanctions against the country are lifted." (Press TV, "Iran wants Japan’s big petchem firms back," 10/12/15) 

--

"Iran is in talks with three Japanese and South Korean oil and gas companies to invest in its oil and gas projects, Head of Investment Committee of the National Iranian Gas Company (NIGC) Asghar Soheilipour said. He said that Japan's Mitsubishi and South Korea's LG and Samsung are negotiating with NIGC to design, establish, and install gas refineries and pipelines, Iran's Mehr news agency reported on Jan. 13. Some Japanese and Italian companies have announced readiness to implement projects even before lifting the international sanctions, he noted." (Trend, "Iran in Talks with Japanese, Korean Oil and Gas Companies," 1/13/15)

--

"Head of the investment committee of the Iran National Gas Company (INGC) Asghar Soheilipour said that his company was offering information about Iran's top priority gas projects to potential foreign and domestic investors... The official referred to Mitsubishi, LG and Samsung as corporations having announced readiness for making investments in Iran gas projects." (IRNA, "Official: Foreign firms eying investment in Iran gas industry," 1/3/15)

--

In 2015 Mitsubishi 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 under the waivers granted by the U.S. government that meet Section (a)(2) of Act 44's expiration clause."

--

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

"China's CITIC Trust will extend $10 billion credit line for supporting projects in lran, based on an agreement signed between the company and five Iranian banks at CITIC Group headquarters in Beijing on Thursday." (Financial Tribune, 9/14/2017).

--

September 2017 - China has signed an agreement with Iran to provide a credit line of $10 billion for its infrastructure projects – what is seen as the biggest economic deal between the two countries after the removal of sanctions against the Islamic Republic in 2016.

--

The agreement was signed between China’s CITIC Group Corporation and a consortium of Iranian banks that included Bank of Industry and Mine, Refah Bank, Parsian Bank, Bank Pasargad and Export Development Bank of Iran.

--

CITIC Group’s wholly owned subsidiary CITIC Construction Co., Ltd maintains a branch in Iran and includes the Iran Teheran Metro among its “representative projects.” CITIC Construction Co. also features the South Iran Aluminum Plant under “Showcase” projects.

--

“Chinese CITIC Company has signed a memorandum of understanding with the municipality of Iran's Eastern Azerbaijan province's capital city Tabriz for implementation of a tram project, Iranian Donya-e-Eqtesad newspaper reported on March 18. The deputy governor of East Azerbaijan province, Mohammad Sadeq Pour Mahdi, Tabriz mayor, Sadeq Najafi and some members of Tabriz city council as well as top managers of the Chinese party attended the memorandum signing ceremony in Tabriz. Pointing to the achievements of his official trip to China and his meetings with some important Chinese companies, Najafi underlined the establishment of the first tram of the country and city as the most important part of the signed agreement and also highlighted the importance of cooperation with Chinese CITIC company in metro and electric bus projects to reduce the traffic and pollution problems of Tabriz in the near future. The deputy governor of East Azerbaijan province, Pour Mahdi emphasized the importance of attracting foreign investments, expressing hope to increase transportation projects in Tabriz. Tabriz is Iran's second most polluted city. Distribution of low quality gasoline along with older automobiles creates 72 percent of the air pollution in Tabriz, East Azerbaijan Province's Environment Department director Hamid Ghasemi said on Feb. 27.” (Trend, “China to implement tram project in Iran’s Tabriz,” 3/8/14)

Tata Group maintains a strong U.S. presence  and a Tata North America website.

--

Tata's Subsidary, Tata Steel, has engaged in joint ventrue projects with Iranian Mines and Mining Industries.

--

“India's Tata Group has announced readiness to invest in Iran's mine and energy sectors, the Mehr News Agency reported on March 15. Madhu Kannan, Tata's Head of Business Development, and Janaki Chaudhry, the group's head of strategy and business development, met with Mehdi Karbasian, the head of the Board of Directors of Iranian Mines and Mining Industries Development and Renovation, known as IMIDRO, in Tehran. Kannan said Tata is looking for an Iranian trade partner to carry out projects jointly in the long term. Karbasian, for his part, said that Tata can launch joint ventures for establishing steel plants and carrying out mining exploration projects. Tata Group is an Indian multinational conglomerate company headquartered in Mumbai. It encompasses seven business sectors: communications and information technology, engineering, materials, services, energy, consumer products and chemicals. Tata Group was founded in 1868. It has operations in more than 80 countries across six continents.” (Trend, “India’s Tata announces readiness to invest in Iran’s mine, energy sectors,” 3/15/14)

--

According to its Annual Report filed with the SEC for fiscal year 2013: "TCC had a contractual relationship with the Telecommunication Infrastructure Company of Iran (“TIC”). TCL had a contractual relationship with TIC as well. Both TCL and TCC terminated their contractual relationships with TIC via letters dated January 5, 2013 and January 17, 2013 respectively. Both contract terminations were effective on or before February 5, 2013. As such, the Company believes it has satisfied the requirements for the safe harbor under Section 218 of the ITR Act. Prior to the termination of the contractual relationships, both TCC and TCL had been involved in long-term relationships with TIC, and its former parent company the Telecommunications Company of Iran (“TCI”). The history of these relationships dates back decades, as the companies or their predecessors have been primary telephone operators in the international long distance market in their respective countries. On November 20, 2007, the Company was advised, pursuant to a general notification issued by TCI, of its pending reorganization and privatization by the Iranian government and that “since the ownership of Iranian International Switching Center has been transferred to the state-run TIC, all telecommunication activities such as Total Accounting Rate (TAR), Hubbing Services, Signaling Services will be performed by TIC.

Prior to this privatization, TIC was a wholly owned subsidiary of TCI. As of the privatization in 2008, TIC has operated and continues to operate as part of the Iranian Ministry of Information and Communications Technologies.

The contract between TCC and TIC (“the TCC/TIC contract”) involved the provision of fixed and mobile voice services, including IDDD (International Direct Distance Dialing), HCD (Home Country Direct), ITFS (International Toll Free Service), Operator and ISDN (Integrated Services Digital Network) traffic. The contract, a Total Accounting Rate (“TAR”) Agreement, sets out differential rates based on the volume of the bilateral voice termination traffic, i.e., from TCC to TIC and from TIC to TCC, and it covered all countries, except for India. The contract between TCL and TIC (“the TCL/TIC contract”) only pertained to the exchange of international voice traffic between India and Iran.

On November 11, 2011, the Government of Canada issued new sanctions against Iran under its Special Economic Measures Act (the “Canadian Iran Regulations”). Of relevance to the TCC/TIC relationship, the new sanctions contain explicit prohibitions on the provision of financial services: (i) to any person in Iran; (ii) from any person in Iran; (iii) for the benefit of any person in Iran; or (iv) on the direction or order of any person in Iran2 . The Canadian Iran Regulations contain grandfathering provisions that exempt from this prohibition those financial services required to be provided further to contracts “entered into before November 22, 2011”3 . The TAR Agreement at issue with TIC was last amended on August 30, 2011, prior to the grandfathering date of November 22, 2011.

On September 17, 2012, TCC sought permission from the Canadian regulator, the Minister of Foreign Affairs, to be allowed the opportunity to obtain payment from TIC for telecommunications services rendered up to the end of 2012 . TCC stated that while it believed that the contract with TIC, since it was entered into prior to November 21, 2011, was exempt from the restriction on conducting financial services with entities in Iran, it was making this filing out of an “abundance of caution.”"

--

“Tata Steel has planned an equity infusion of around $675 million for its joint venture (JV) project with Iranian Mines and Mining Industries and a 100% subsidiary in Iran by 2009, together with an additional $300 million investment by 2011. The project cost for the first and second JVs would be $1.2 billion and $300 million respectively. Both the projects will have a debt-equity ratio in equal proportion and Tata Steel's equity commitment for these two projects would be around $375 million. The first joint venture would include setting up a project for manufacturing billets and slabs with 49% stake each with its Iranian counterpart with the remaining 2% held by a pension fund of the Iranian government. It would manufacture billets and slabs with a capacity of 1.5 million tonne per annum. The second JV too would have a similar shareholding pattern in its mining of unexplored iron ore mines at the Gol-e-Gohar mines in Kerman province of Iran. Further, Tata Steel will also set up a wholly-owned subsidiary for manufacturing 3 million tonne billets in two phases at a cost of $1.2 billion. The equity infusion in this project would be another $600 million split equally between two phases. Sharing details about its mega foray in Iran, Tata Steel managing director B Muthuraman said, ‘the idea is to manufacture billets at the Iran project at low cost and feed it as raw material to the NatSteel facility in Singapore.’” (Press Release, "Tata Steel equity for Iran foray at $675 million," 6/14/05)

Safran maintains a "Safran North America" website, which highlights Safran's "significant physical presence in the United States, comprised of 32 companies and joint ventures operating across 58 locations in 22 states."

--

According to the Safran North America website, "The company’s largest end-user is the U.S. Department of Defense, with its technologies equipped on such vital military and government platforms as the KC-135R aerial tanker, F-22 Raptor fighter jet, UH-72A Lakota Light Utility Helicopter and Delta IV launch system."

--

“Multiple companies currently exploring new business ventures in Iran are also cashing in on highly lucrative contracts with the U.S. Defense Department, raising questions about whether their dealings with Iran could run afoul of U.S. law. At least 13 major international companies have said in recent weeks that they aim to reenter the Iranian marketplace over the next several months. The companies have received Pentagon contracts totaling well over $107 billion, according to a Washington Free Beacon analysis that tracked DoD contracts awarded since fiscal year 2009. Many of the companies, which include carmaker Renault and oil giants such as BP, have already sent high-level trade delegations to Tehran to meet with Iranian officials about striking new business deals…These companies include Boeing and General Electric—which have DoD contracts worth $87 and $12 billion respectively—as well as the Italian oil company Eni, Merck, Safran, Vitol, Bosch Rexroth, Sanofi Pastuer, and AVL.” (Washington Free Beacon, “Pentagon Contractors Exploring Business with Iran,” 2/25/14)

--

“Iran [welcomes] the most senior French trade delegation in years on Monday, telling more than 100 executives that the farsighted among them stood to win the race for business following an easing of some economic sanctions…'A new chapter has begun in relations between Iran and Europe,' Mohammad Nahavandian, President Hassan Rouhani's chief of staff, was quoted as saying by the official IRNA news agency. ‘You should carry the message back that potential for cooperation with Iran is real and not to be overlooked,’ he told the delegation. ‘Those with longer foresight stand to win this race.’ The delegation of more than 100 executives from Medef, the French employers' association, on a Feb 2-5 trip, met Nahavandian and members of Iran's Chamber of Commerce, Industries, Mines and Agriculture, IRNA said. A source close to the delegation told Reuters it was the most senior group of entrepreneurs and financiers to visit Iran since the 1979 revolution, representing the defence, aviation, petrochemicals, automotive, shipping and cosmetics sectors. Among companies represented were Safran, Airbus , Total, GDF-Suez, Renault, Alcatel, Alstom, Amundi and L'Oréal, the source said. ‘Many of these firms have worked in Iran before and their goal now is to restore links,’ the source said. ‘The very makeup of the delegation shows these people are here to evaluate potential for cooperation.’ A French embassy source in Tehran said the visit was merely exploratory and ‘nothing is to be signed this time around.’” (Reuters, “Iran welcomes French business chiefs after sanctions eased,” 2/3/14)

--

"Executives from some of France's biggest companies…are slated to fly to Tehran next month—signaling a fresh wave of corporate interest in Iran as the West eases sanctions. Details of the high-level business trip are emerging after Iran and Western powers completed the terms of an interim nuclear deal on Sunday, with Tehran agreeing to closer international monitoring of its nuclear program in exchange for limited, temporary sanctions relief. The deal specifically eases restrictions related to Iran's aviation, auto and petrochemicals industries…A spokesperson for Safran SA, which makes propulsion engines and other aircraft spare parts, said that it was considering sending a representative on the trip but that no final decision had been made.” (Wall Street Journal, “French Companies Explore Return to Iran Amid Sanctions Thaw,” 1/13/14)

"Iranian electronics manufacturer Entekhab plans to acquire Dongbu Daewoo Electronics by purchasing a 100 percent stake in the smaller Korean consumer electronics firm, local financial sources said Sunday." (January 2018).

--

According to Korean and Iranian media sources, Korea Development Bank (“KDB”), as a creditor for Dongbu Steel, is considering “putting off the plan … to sell off the cash-strapped company’s [Dongbu Steel] electric furnace used for hot-rolled steel production [at the Dangjin plant] to an Iranian steelmaker amid concerns that the U.S. could walk out a nuclear deal with the Middle Eastern country.”  (Pulse News, “S. Korea’s creditors may call off Dongbu Steel furnace sale to Iranian steelmaker,” 10/23/2017; Financial Tribune, “S. Korean Firm May Call Off Furnace Sale to Iranian Steelmaker,” 10/26/2017).

--

Dongbu Group is a “Global conglomerate corporation which operates through seven business segments with 59 subsidiaries and 40,000 employees.” These segments include steel, chemicals, construction and electronics. Dongbu CNI, a Dongbu Group subsidiary specializing in IT and electronics, lists an office in Tehran. Other Dongbu subsidiaries and major affiliates, including Dongbu Corporation, hold $40 million in contracts with the U.S. government. 

Hanwha Corporation Tehran Representative Office listed on its company website.

--

Hanwha Corporation is a major South Korean Conglomerate composed of  "two major business units: The Explosives Division which makes commercial explosi-ves, technologically advanced defense industry products and aerospace products, and the Trade Division." According to a list of "Achievements" posted on its company website, the "Explosives" unit of Hanwha Corporation has engaged in multiple projects in Iran. Many of these projects have involved other South Korean companies including Sungjin Geotec Co. and POSCO. The same list reveals that Hanwha Corporation has engaged in business with Petrochemical Industries Design and Engineering Company (PIDEC), one of Iran's largest engineering companies.

Hanwha Corporation's subsidiary, Hanwha E&C, holds around $60 million in contracts with the US government. 

On June 30, 2020, the Mississippi Department of Finance & Administration identified Koc Holding as a company “engaged in investment activities in Iran, providing funds, goods or services valued at $20,000,000 or more in the energy sector of Iran.” 

--

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

--

In 2016 Tennessee used the South Carolina list of "Entities Ineligible to Contract with the State of South Carolina or any Political Subdivision of the State per the Iran Divestment Act of 2014, S.C. Code Ann." as its list of persons it determines engage in investment activities in Iran. KOC Holdings was included on this list in 2016. "Inclusion on this list would make a person ineligible to contract with the state of Tennessee, if a person ceases its engagement in investment activities in Iran, it may be removed from the list."

--

In 2015 KOC Holding 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 under the waivers granted by the U.S. government that meet Section (a)(2) of Act 44's expiration clause."
 

--

In 2014, KOC Holding was added to the Pennsylvania Treasury's List of Scrutinized Companies Determined as Having Involvement in Iran because its the parent of a scrutinized company.

-- 

Turkish energy firm Tupras is a subsidiary of Koc Holding.

--

"The United States has pressed Turkey to follow up on a 20 percent cut in oil purchases from Iran with a further cut in six months time to help persuade Iran to quit stalling in talks over its nuclear program, a U.S. diplomat said on Tuesday. The diplomat said Washington granted Turkey a 180-day exception from financial sanctions as a result of the initial cut made by Tupras, Turkey's sole refiner and a unit of Koc Holding." (Reuters,"U.S. presses Turkey to cut more Iranian oil imports," 6/12/12) 

Yamaha's Outboard Engine has been found in the following Houthi weapon system: WBIED. (UN Security Council, "Letter dated 22 January 2021 from the Panel of Experts on Yemen addressed to the President of the Security Council," 1/21). 

--

Yamaha is listed as a participating company at the 14^th International Exhibition of Transportation & Urban Services & Related Industries which takes place October 27-30^th, 2016 in Tehran Iran. (Participating International Companies)  

--

"Yamaha Motor Co., Ltd (YMC) has recently concluded a technical assistance agreement with the nationaly run Iranian motorcycle maker DMI to being the manufacture of motorcylces in Iran...In the past, from 1971 to '81, DMI manufactured three Yamaha brand motorcycle models..."  (Yamaha.  "Yamaha Brand Motorcycle Production Begins Again in Iran."  5/23/2001)

In November 2017, Iran discussed bilateral cooperation in the field of air industries with Antonov company CEO. Iran and Antonov company have been cooperating in the production and operation of aircrafts for two decades.

--

"The Persian Gulf country will buy two Ukrainian-made Antonov-158s, after a test flight of the aircraft earlier this month, Mohammad-Ali Sirati, managing director of the Iranian aircraft company, was cited as saying by the official Islamic Republic News Agency. The countries then will start to jointly build the aircraft next year, Sirati, whose company will be in charge of the project, said in Tehran yesterday. Some 30 percent of each plane will be made in Iran, state-run media reported." (Business Week, "Iran Says Antonov-158 Built With Ukraine May Fly in 2013," 10/6/2011)

--

Antonov lists on its website that their AN-24 turboprop aircraft is serially produced at HESA plant in Isfahan, Iran. (Antonov website)

---

"Reports issued by U.S. researchers attempting to document activity by multinational companies in Iran have named...units of Japan's three largest banks--Mitsubishi UFJ Financial Group Inc, Sumitomo Mitsui Financial Group and Mizuho Financial Group Inc--as doing business that could possibly run afoul of new U.S. rules.A widely circulated report issued this year by a former U.S. Treasury Department official on global banks doing business with Iranian banks named the Big Three Japanese financial institutions. Spokespeople for the three Japanese banks declined to comment on the accuracy of the report, or how the law might affect their operations in Iran." (Wall Street Journal, "New U.S. Law on Iran May Hurt Japanese Firms," 7/1/2010).