Will exit its distribution partnership in Iran before November 4, 2018; had previously predicted a profit of 16 million euros from its business in Iran. (“France’s Ingenico cuts core profit outlook on Iran exit, currency headwinds,” Reuters, July 25, 2018.)
S&P Global is formerly known as McGraw Hill Financial
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According to its Quarterly Report filed with the SEC for the quarterly period ending March 31, 2020: "During the first quarter of 2020, Platts, a division of the Company that provides energy-related information in over 150 countries, sold information and informational materials, which are generally exempt from U.S. economic sanctions, to subscribers that are owned or controlled, or appear to be owned or controlled, by the Government of Iran. Platts provided such subscribers access to proprietary data, analytics, and industry information that enable commodities markets to perform with greater transparency and efficiency, generating revenue that was a de minimis portion of both the division's and the Company’s revenue. The Company will continue to monitor its provision of products and services to such subscribers."
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According to a Quarterly Report filed with the SEC in 2019: "During the third quarter of 2019, Platts, a division of the Company that provides energy-related information in over 150 countries, sold information and informational materials, which are generally exempt from U.S. economic sanctions, to subscribers that are owned or controlled, or appear to be owned or controlled, by the Government of Iran. Platts provided such subscribers access to proprietary data, analytics, and industry information that enable commodities markets to perform with greater transparency and efficiency, generating revenue that was a de minimis portion of both the division's and the Company’s revenue. The Company will continue to monitor its provision of products and services to such subscribers. In addition, S&P Global Market Intelligence had a commercial relationship with an entity that became designated pursuant to Executive Order 13224 during the third quarter. The Company has terminated its relationship with such entity and will not collect revenue relating to this relationship."
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In a letter to CalPERs dated December 1, 2017, the company confirmed it is not engaged in the business targeted by the California Divest from Iran Act.
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In 2017 the U.S. state of California listed S and P Global as a company under review for potentially having sold energy-related information and information materials to Iran-linked subscribers that are subject to U.S. sanctions with links to the Iranian government.
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According to a Quarterly Report filed with the SEC in 2017: "During the third quarter of 2017, Platts, a division of the Company that provides energy-related information in over 150 countries, sold information and informational materials, which are generally exempt from U.S. economic sanctions, to fourteen subscribers that are owned or controlled, or appear to be owned or controlled, by the Government of Iran (the “GOI”). The Company, among other things, offers customers that subscribe to its publications access to proprietary data, analytics, and industry information that enable commodities markets to perform with greater transparency and efficiency. This division provided such data related to the energy and petrochemicals markets to the subscribers referenced above, generating revenue that was a de minimis portion of both the division's and the Company’s revenue. Seven of the subscribers are designated by OFAC as GOI entities; and seven appear, based on publicly available information, to be owned or controlled by GOI entities. In addition, during the third quarter of 2017, this division entered into a contract to sell information and informational materials to another subscriber that is owned or controlled by the Government of Iran, but no revenues were received under this contract during the third quarter. We believe 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 will continue to monitor its provision of products and services to these Iranian customers so that such activity continues to be permissible under U.S. sanctions."
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According to a Quarterly Report filed with the SEC in 2016: "During the third quarter of 2016, one of the Company’s divisions, a provider of energy-related information in over 150 countries, sold information and informational materials, which are generally exempt from U.S. economic sanctions, to fourteen subscribers that are owned or controlled, or appear to be owned or controlled, by the Government of Iran (the “GOI”). The Company, among other things, offers customers that subscribe to its publications access to proprietary data, analytics, and industry information that enable commodities markets to perform with greater transparency and efficiency. This division provided such data related to the energy and petrochemicals markets to the subscribers referenced above, generating revenue that was a de minimis portion of both the division's and the Company’s revenue. Eight of the subscribers are designated by the U.S. Treasury Department’s Office of Foreign Assets Control as GOI entities and six appear, based on publicly available information, to be owned or controlled by GOI entities. We believe 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 will continue to monitor its provision of products and services to these Iranian customers so that such activity continues to be permissible under U.S. sanctions."
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According to a Quarterly Report filed with the SEC in 2015: "During the first quarter of 2015, one of the Company’s divisions, a provider of energy-related information in over 150 countries, sold information and informational materials, which are generally exempt from U.S. economic sanctions, to twelve Iran-linked subscribers that are designated by the Treasury Department’s Office of Foreign Assets Control (“OFAC”) pursuant to Executive Order 13382 and/or are owned or controlled, or appear to be owned or controlled, by the Government of Iran (the “GOI”). The Company, among other things, offers customers that subscribe to its publications access to proprietary data, analytics, and industry information that enable commodities markets to perform with greater transparency and efficiency. This division provided such data related to the energy and petrochemicals markets to the Iran-linked subscribers referenced above, generating revenue that was a de minimis portion of both the division's and the Company’s revenue. One of the twelve Iran-linked customers is designated by OFAC pursuant to Executive Order 13382; one is designated by OFAC both pursuant to Executive Order 13382 and as a GOI entity; five are designated by OFAC as GOI entities; and five appear, based on publicly available information, to be owned or controlled by GOI entities. We believe 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 is reviewing whether to continue to provide these products to these Iranian customers in the future."
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According to a Quarterly Report filed with the SEC in 2014: "During the third quarter of 2014, one of the Company’s divisions, a provider of energy-related information in over 150 countries, sold information and informational materials, which are generally exempt from U.S. economic sanctions, to twelve subscribers in Iran that are designated by the Treasury Department’s Office of Foreign Assets Control (“OFAC”) pursuant to Executive Order 13382 and/or are owned or controlled, or appear to be owned or controlled, by the Government of Iran (the “GOI”). The Company, among other things, offers customers that subscribe to its publications access to proprietary data, analytics, and industry information that enable commodities markets to perform with greater transparency and efficiency. This division provided such data related to the energy and petrochemicals markets to the subscribers in Iran referenced above, generating revenue that was a deminimis portion of both division's and the Company’s revenue. One of the twelve Iran-linked customers is designated by OFAC pursuant to Executive Order 13382; one is designated by OFAC pursuant to Executive Order 13382 and as a GOI entity; five are designated by OFAC as GOI entities; and five appear, based on publicly available information, to be owned or controlled by GOI entities. We believe 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 is reviewing whether to continue to provide these products to these Iranian customers in the future."
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S&P Global has filed Iran Notices with the SEC from 2014-2020.
According to its Annual Report filed with the SEC for fiscal year 2018: "During the fiscal year ended March 31, 2018, Nomura Research Institute, Ltd. (“NRI”), an affiliate in which we hold, directly and indirectly, 38.5 % of the outstanding share capital, has engaged in meetings and discussions on potential business development with entities that are or may be owned or controlled by the Government of Iran. There were no revenues or profits arising directly from these meetings and discussions.
In addition, NRI entered into several contracts with an investment and development company and a governmental organization, both of which are owned or controlled by the Government of Iran, pursuant to which NRI agreed to perform benchmark investigations, conduct comparative analyses and provide other consulting services to facilitate development projects. During the period covered by this report, these contracts and related activities generated gross revenues of ¥8,579,814. Due to costs of providing services, there were no profits attributable to these contracts.
Further, NRI entered into contracts with another entity pursuant to which NRI receives certain services related to the work that NRI is performing for the aforementioned investment and development company and governmental organization. These contracts did not, on their own, generate any revenues or profits for NRI. After consultation with NRI and on the basis of information publicly available to us, we believe that this other entity is a private entity that is not owned or controlled by the Government of Iran.
NRI also made payments to the Government of Iran to obtain entry visas to travel to Iran in connection with the activities described above.
Sanctions relief regarding Iran was implemented in 2016 in accordance with the Joint Comprehensive Plan of Action (“JCPOA”) reached by the permanent members of the United Nations Security Council (China, France, Russia, the United Kingdom and the United States), Germany, the EU, and Iran to ensure that Iran’s nuclear program is used for peaceful purposes. Despite the JCPOA, certain activities, including transactions involving targeted Iran-related persons and entities and transactions that implicate U.S. jurisdiction, remain subject to sanctions. However, on May 8, 2018, President Trump announced his decision to cease the United States’ participation in the JCPOA and to re-impose the U.S. nuclear-related sanctions targeting Iran that were lifted under the JCPOA. In conjunction with this announcement, President Trump issued a National Security Presidential Memorandum (“NSPM”) directing the Secretary of State and the Secretary of the Treasury to prepare immediately for the re-imposition of all of the U.S. sanctions lifted or waived in connection with the JCPOA, to be accomplished as expeditiously as possible and in no case later than 180 days from the date of the NSPM. As a result, new business that is contrary to the re-imposed sanctions will be sanctionable immediately upon re-imposition, and business that pre-dates May 8, 2018 will be subject to wind-down periods of 90 days or 180 days, as applicable, following which parties will be exposed to the risk of sanctions or an enforcement action under U.S. law.
In light of the above, NRI intends to discontinue the activities described above."
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During the fiscal year ended March 31, 2017, certain non-U.S. affiliates of the Company engaged in the following activities with entities that are or may be owned or controlled by the Government of Iran:
• Nomura Research Institute, Ltd. (“NRI”), an affiliate in which we hold, directly and indirectly, 37.2% of the outstanding share capital, has engaged in meetings and discussions on potential business development with entities that are or may be owned or controlled by the Government of Iran. There were no revenues or profits arising directly from these meetings and discussions.In addition, NRI entered into several contracts with an investment and development company, which is owned or controlled by the Government of Iran, pursuant to which NRI agreed to perform benchmark investigations, conduct comparative analyses and provide other consulting services to facilitate development projects. Performance under these contracts is ongoing. During the period covered by this report, these contracts and related activities generated gross revenues of $1,743,500 and estimated net profits of $261,525. Further, NRI entered into a contract with another entity pursuant to which NRI receives certain services related to the work that NRI is performing for the aforementioned investment and development company, and performance under this contract is also ongoing. This contract did not, on its own, generate any revenues or profits for NRI. After consultation with NRI and on the basis of information publicly available to us, we believe that this other entity is a private entity that is not owned or controlled by the Government of Iran.
NRI also entered into a contract with an entity pursuant to which NRI receives certain services related to the exploration of business opportunities in Iran in the cardiovascular treatment field, and performance under this contract is ongoing.
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According to its Annual report filed with the SEC for fiscal year 2016: "During the fiscal year ended March 31, 2016, certain non-U.S. affiliates of ours engaged in the following transactions or dealings with entities that are or may be owned or controlled by the Government of Iran.
These activities were conducted in accordance with applicable law, and we do not believe that the activities were sanctionable under applicable law. We have not generated any revenues from these activities during the period covered by this report.
In light of recent changes in the international economic sanctions regime relating to Iran, we intend to continue to engage in the activities described above and may engage in similar activities in future periods; however, any such activities will be conducted in accordance with all applicable laws, and we do not intend to engage in any activities that are sanctionable under applicable law."
Response: "We do not believe that a blanket boycott of everything remotely associated with Iran is in anyone’s interests" (January 16, 2017)
Response: “…do not intend to do business in Iran or with the Iranian Government in the future.” (July 20, 2017)
Ahwaz, June 24, IRNA -- Managing Director of Khuzestan Regional Electricity Company (KREC) Mahmoud Dasht-e-Bozorg said on Saturday that KREC has signed memorandum of understanding (MoU) with French investing company of “ Green Coast Solution’.
"The Central Bank of Iran (CBI) and Export Insurance Agency of Russia (EXIAR) have signed a memorandum of understanding (MoU) to finance joint projects between the two countries." (October 16, 2017)
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" Russian Agency for Export Credit and Investment Insurance, known as Exiar, signed a memorandum of understanding (MOU) with the Islamic Republic of Iran Railways, known as RAI, to provide €3 billion finance on the joint manufacturing of railway wagons and locomotives." (December 18, 2017)
Official representation in Iran webpage.
"Iran has been cut off from paying for South Korean imports with the United States re-imposing sanctions, and South Korea is concerned that the Korea Trade Insurance Corporation (KTIC) may be on the hook for compensation payouts for the losses sustained by South Korean companies." (October 23, 2018)
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"Minister of Economic Affairs and Finance has confirmed local media reports of an imminent South Korean $13 billion credit line to support Iranian projects–a measure, which if finalized, will mark the biggest instance of foreign finance for the country since the implementation of the nuclear accord in January 2016,...Almost all the key details of the credit line have been reportedly agreed upon, and the Korean government has given the green light, based on which $8 billion will be provided by Export–Import Bank of Korea (KEXIM) while the Korea Trade Insurance Corporation (K-SURE) will account for the rest." (June 2017)
On April 14, 2009, Bank of KLCC 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, KLCC remains on the SBA list of prohibited investments.
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In 2020, the U.S. state of Mississippi listed KLCC 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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As of May 28, 2020, the Florida State Board of Administration (“SBA”) continues to list KLCC on its list of “Scrutinized companies with Activities in the Iran Petroleum Energy Sector.”
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On January 13, 2020, the South Dakota Investment Council submitted a report to the Executive Board of the Legislative Research Council regarding compliance with SDCL 4-5-48 to 4-5-60, Iran Divestiture. Included in this report is an Iran Scrutinized Companies list of all prohibited investments for which the internal managers and direct external managers are instructed not to purchase any company on the list. KLCC is included on this list.
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As of December 31, 2019, the Alaska Retirement Management Board lists KLCC as a company doing material business with Iran.
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On March 13, 2019, the Mississippi Department of Finance & Administration identified KLCC 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.”
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KLCC is listed on the June 4, 2019 and July 12, 2019 Florida State Board of Administration list of prohibited investments (Scrutinized companies) for Iran related business.
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KLCC is listed on the June 2019 Alaska Retirement Management Board, Companies Doing Material Business with Iran list.
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KLCC is listed on the March 2019 Alaska Retirement Management Board, Companies Doing Material Business with Iran list.
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In 2018 the U.S. state of Ohio listed KLCC on its list of entities determined to be engaged in prohibited activities in Iran rendering KLCC ineligible for investment and/or state contracting. / Subsidiary of PETRONAS
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In 2017 the U.S. state of Alaska, Florida, and Mississippi, listed KLCC on its list of companies doing material business with Iran rendering KLCC ineligible for investment and/or state contracting.
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In 2013, 2014, 2015, 2016 and 2017 KLCC was listed on the Texas Pension Review Board List of Scrutinized Companies doing business in Iran pursuant to Chapter 807.054, Government Code.
Eye on Iran is a news summary from United Against Nuclear Iran (UANI), a section 501(c)(3) organization. Eye on Iran is available to subscribers on a daily basis or weekly basis.