Energy

Mobin International is associated with bank accounts also used for IRGC funds. Madanipour, through Mobin International, works closely with NIOC and entities associated with NIOC and the IRGC, and has taken steps to conceal Iranian, IRGC, and NIOC involvement in previous petroleum-product transactions. On or about March 17, 2019, Mobin International confirmed with Naftiran Intertrade Company Ltd.—a Swiss-based Iranian oil trading company designated by OFAC for its connections to NIOC—an agreement for storage in Malaysia and UAE.As part of its role in the scheme described, Mobin International has also altered documents to camouflage the true nature of petroleum-product sales. For example, on or about July 26, 2018, Madanipour discussed Mobin International’s right to issue and switch a bill of lading relating to a NITC shipment, and Madanipour has documented the cost to “[s]witch documents” to be $30,000.00.

On or about May 20, 2019, Madanipour learned that Mobin International was allegedly being sued by NIOC for failing to pay its debts and that Madanipour was being sued by the Persian Gulf Petrochemical Company and others for failing to pay his debts. (Reuters, "U.S. files suit to seize gasoline in four Iran tankers headed to Venezuela," 7/2/2020). 

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

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In June 2020, Lanka Ioc was listed by the Connecticut Office of the Treasurer as a restricted company and therefore prohibits direct investment in the company due to its involvement in Iran. 

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On January 20, 2020, Minnesota SBI listed Lanka Ioc as a scrutinized investment. The managers are explicitly instructed to refrain from purchasing securities on this list.

According to its Annual Report filed with the SEC for fiscal year 2013: "The Iran Threat Reduction and Syria Human Rights Act of 2012, signed into law by President Obama on August 10, 2012, added a new Section 13(r) to the Exchange Act, which requires us to disclose whether the Company or any of its affiliates has engaged in certain Iran-related activities during the reporting period. All of the transactions referenced below involved the supply by our wholly-owned Singaporean subsidiary, Oil States (Asia) Ptd Ltd ("Oil States (Asia)"), of riser pipes and associated material for use in the development of the South Pars Gas Field, development of which is controlled and mandated by Pars Oil & Gas Co, which was designated in December 2010 by the Office of Foreign Assets Control (OFAC) as being owned or controlled by the Government of Iran. Since the completion of the transactions described below, Oil States (Asia) has wound down all of its Iran-related business, and voluntary self-disclosures have been submitted to OFAC and the State Department about these transactions.

Transaction with Petroleum Pipe Middle East (FZE)

This transaction involved the sale of riser pipe and associated material by Oil States (Asia) to Petroleum Pipe Middle East (FZE) ("PPME"). PPME is a company in the United Arab Emirates ("UAE") and a subsidiary of Petroleum Pipe Company, a company incorporated in the Jersey Islands. Oil States (Asia) was aware that PPME was placing the order for an intermediate customer, Dana Kish Drilling Company ("Dana Kish"). Dana Kish ultimately used the products in question for the development of the South Pars Gas Field, which is controlled and mandated by Pars Oil & Gas Co. The PPME transaction began with discussions and quotations to PPME in February 2012 and resulted in Oil States (Asia)'s acceptance of PPME's order on August 20, 2012, which was subsequently revised and ultimately finalized on January 7, 2013. Oil States (Asia) made two shipments to PPME in the UAE, on November 29, 2012 and March 8, 2013. The total value of PPME's order was approximately $4.2 million, for which Oil States (Asia) received an estimated net profit of $0.4 million.

Transactions with Integrated Energy Systems Trading FZC

These transactions involved the sale of riser pipe and associated material by Oil States (Asia) to Integrated Energy Systems Trading FZC ("IEST"). IEST is a company in the UAE and a subsidiary of Integrated Energy Systems Holdings, a Russian company. IEST was placing the orders for an intermediate customer, Petro Karan Shafagh Kish ("PKSK"), an Iranian entity. PKSK ultimately used the products in the development of the South Pars Gas Field.

This transaction consisted of two orders. Oil States (Asia) accepted both orders from IEST on October 10, 2011, which were subsequently revised and ultimately finalized on April 9, 2012. Oil States (Asia) made two shipments to IEST in Iran on May 18, 2012 and December 24, 2012. The total value of IEST's orders were approximately $11.7 million, for which Oil States (Asia) received an estimated net profit of $1.3 million.

Transaction with Petropars International FZE

This transaction involved the sale of riser pipe and associated material by Oil States (Asia) to Petropars International, FZE (“Petropars”). Petropars is a UAE entity that was designated in June 2010 by OFAC as ultimately owned or controlled by the Government of Iran. Oil States (Asia) issued invoices in December of 2011 and received payment of approximately $4.3 million in January of 2012 for an estimated net profit of approximately $0.5 million."

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According to its Quarterly Report filed with the SEC for fiscal year 2012: "The Iran Threat Reduction and Syria Human Rights Act of 2012, signed into law by President Obama on August 10, 2012, added a new Section 13(r) to the Exchange Act, which requires us to disclose whether the Company or any of its affiliates has engaged in certain Iran-related activities during the reporting period. In the second quarter of 2013, our wholly-owned Singaporean subsidiary, Oil States (Asia) Ptd Ltd (Oil States (Asia)), received two payments in connection with a prior transaction for the sale of riser pipe and associated material to a United Arab Emirates company, for ultimate use in the South Pars Gas Field. This field is controlled and mandated by Pars Oil & Gas Co, an entity designated in December 2010 by the Office of Foreign Assets Control (OFAC) as being owned or controlled by the Government of Iran. The transaction that is the subject of this disclosure commenced at a time when Oil States (Asia) was not subject to the Iranian Transactions and Sanctions Regulations, 31 C.F.R. Part 560 (ITSR). The total value of Oil States (Asia)’s transaction was approximately $4.2 million, for which it received an estimated net profit of $0.4 million. The two payments that Oil States (Asia) received during the reporting period totaled approximately $2.2 million. Except for the receipt of these two final payments from its customer during April 2013, Oil States (Asia) completed the transaction in accordance with and during the validity period of the wind-down general license at ITSR Section 560.555, which expired on March 8, 2013. Oil States (Asia) has wound down its Iran-related business, and the Company has submitted voluntary self-disclosures to OFAC and the State Department about this transaction."

According to an Annual Report filed with the SEC in 2012: "In 2012, ITS  through its indirect non-U.S. subsidiaries International Tubulars FZE and International Tubular Services Kish Company may have engaged in transactions or dealings with an entity or entities owned or controlled, directly or indirectly, by the Government of Iran by providing equipment and related services pursuant to contracts in Iran.  Fund V is not aware of gross revenues and net profits, if any, attributable to that activity.  Fund V has been informed by ITS that ITS’ subsidiaries have stopped supplying equipment and related services into Iran and are winding down all operations related to Iran."

According to its Annual Report filed with the SEC for fiscal year 2012: "During the period from January to September, 2012, the company made several fleet sales of motor fuel with an aggregate total sales price of approximately $11,000 to the Iranian Embassy in Canada. The net earnings attributable to these sales were less than $500. These sales were made without the involvement of any U.S. person and were permitted by U.S. laws in effect at the time. No sales occurred after the October 10, 2012, effective date and the company does not expect any such sales to occur in the future."

According to an Annual Report filed with Enterprise Product Partners "M&B owns and controls Oiltanking GmbH, which in turn owns a joint venture interest in the Exir Chemical Terminal (“ECT”) in Iran via its wholly owned affiliates Oiltanking ME Holding GmbH (formerly named Oiltanking Iran GmbH) and OMEA GmbH.  This interest results from an investment dating back to 2002.  Oiltanking GmbH currently has the contractual right to vote for the appointment of two members of ECT’s three-member board.  Oiltanking GmbH provides no goods, services, technology, information or support to ECT and plays no role in the management or day-to-day operations of ECT.

ECT stores chemicals and hydrocarbons, including naphtha, linear alkyl benzene and n-hexane, for distribution in Iran and for export to Asia and Europe.  To our knowledge, ECT’s activities are in compliance with applicable U.S., European Union or United Nations sanctions laws.  ECT pays routine and standard charges (i) to the Petrochemical Special Economic Zone Organization (“Petzone”) for the use of pipelines and (ii) to the National Petrochemical Company (“NPC”), which operates the berth.  Petzone is a subsidiary of NPC, which is owned and controlled by the Government of Iran. As Oiltanking GmbH has no direct involvement in the day-to-day operations of ECT, we have no information regarding ECT’s intent to continue or not continue making the payments described above."

According to its Annual Report filed with the SEC for fiscal year 2013: "Oiltanking GmbH, the ultimate parent company of our general partner, maintains a joint venture interest in Oiltanking Odfjell GmbH, which in turn owns a joint venture interest in the Exir Chemical Terminal (“ECT”) in Iran. This interest results from an investment dating back to 2002. Oiltanking GmbH currently has the contractual right to vote for the appointment of one member of ECT’s three-member board. Oiltanking GmbH provides no goods, services, technology, information or support to ECT and plays no role in the management or day-to-day operations of ECT.

Among other activities, ECT transfers naptha originating in Iraq to Oman for a customer in the United Arab Emirates, and it does not import or handle any Iranian-origin products that are regulated under U.S., European Union or United Nations sanctions laws. ECT pays routine and standard charges (i) to the Petrochemical Special Economic Zone Organization (“Petzone”) for the use of pipelines and (ii) to Terminals and Tanks Petrochemical Co. (“TTPC”), which operates the berth. Petzone and TTPC are subsidiaries of the National Petrochemical Company, which is owned and controlled by the Government of Iran. As Oiltanking GmbH has no direct involvement in the day to day operations of ECT, we have no information regarding ECT’s intent to continue or not continue making the payments described above."

According to its Annual Report filed with the SEC for fiscal year 2017: "During 2017, our French subsidiary CGG Services SAS, generated revenues equivalent to US$31 thousand from software training provided to employees of an Iranian entity involved in the petroleum industry, and our French subsidiary Sercel SAS generated revenues equivalent to US$36 thousand from repair and maintenance work on gauges for Iranian entities involved in the petroleum industry. We do not believe that any net profit is attributable to these activities. These subsidiaries may continue carrying out these activities in the future."

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”).

Mecanicas Bolea, S.A. (“Mecanicas Bolea”) is listed as an exhibitor at the 23rd International Oil, Gas, Refining and Petrochemical Exhibition (“IOGRPE”), which will take place at the Tehran International Permanent Fairground on May 6-9, 2018. (Iran Oil Show 2018 Website, “Exhibition”).

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"Companies from several countries, including Spain, France and China, have expressed readiness to launch joint ventures in Iran's lucrative petrochemical sector.  Spain's Mecanicas Bolea S.A. is helping Iranian experts construct a desalination plant in Kangan Petro Refining Complex—a major petrochemical and refinery project in southern Bushehr Province.

Pedro Saura Cabello, director general of Spanish Mecanicas Bolea S.A., made the statement in Tehran on Monday, NIPNA, the National Petrochemical Company's news agency reported. 

"There are good opportunities to expand collaboration between Iranian and Spanish industrial firms and we are trying to promote cooperation," Cabello said. According to the official, the company has been involved in designing and manufacturing petrochemical equipment for the past 30 years.

"Mecanicas Bolea specializes in designing pressure vessels as well as heat exchangers," Cabello said, adding that Iranian experts can draw on the company's expertise to design petrochemical units." (Reuters, "Foreign Companies Eager to Make Petrochem Investment," 5/7/2018).