Telecommunications

According to its Annual Report filed with the SEC for fiscal year 2019: "We or our affiliates, are a party to the international roaming agreements with Mobile Company of Iran, or MCI, and MTN Irancell, or MTN, respectively. In 2019, the estimated gross revenue generated from such inbound international roaming traffic with MCI and MTN was approximately RMB254,500 and RMB28,200, respectively, and the estimated total amount paid to MCI and MTN for the outbound international roaming traffic was approximately RMB45,200 and RMB127,700, respectively. We or our affiliates do not customarily allocate net profit on a country-by-country or activity-by-activity basis, and therefore it is not possible to determine accurately the precise net profits attributable to such transactions with MCI and MTN. We or our affiliate estimate that the net profits attributable to the transactions with MCI and MTN were negligible relevant to our overall net profits. We or our affiliate intend to continue these activities in the future."

According to its Annual Report filed with the SEC for fiscal year 2019: 

VEON’s non-U.S. subsidiaries have roaming agreements with the following GSM mobile network operators in Iran which may be owned, controlled or otherwise affiliated with the government of Iran: Telecommunications Company of Iran (“TCI”), MTN Irancell, Taliya Mobile and RighTel. During 2019, our gross revenue received from roaming arrangements with TCI, MTN Irancell and RighTel was approximately US$95,443, US$24,330 and US$2,091 respectively. We recorded an approximate net profit from roaming arrangements with TCI of US$38,335, and approximate net losses with MTN Irancell and RighTel of US$55,141 and US$145,344, respectively. During 2019, we received no gross revenue from roaming arrangements with Taliya Mobile with no net profits.

VEON’s Russian subsidiary, PJSC VimpelCom, began providing mobile services to Iran Air in 2019. During 2019, the approximate gross revenue and net profits for these services was US$452. VEON may discontinue this activity in compliance with applicable law.

VEON’s non-U.S. subsidiaries have the following agreements with Iranian embassies. During 2003, VEON Armenia began providing mobile and fixed-line telecommunications services to the Embassy of Iran in Yerevan. The approximate gross revenue and net profits for these services in 2019 was US$15,000. During 2001, our Russian subsidiary, PJSC VimpelCom, began providing telecommunications services, including mobile and fixed-line services, to the Embassy of Iran in Moscow. The approximate gross revenue and net profits for these services in 2019 was US$20,127 and US$19,035, respectively. During 2013, our Pakistan subsidiary, Jazz, began providing mobile telecommunications services to the Embassy of Iran in Islamabad. The approximate gross revenue and net profits for these services in 2019 was US$4,272. During 2004, our Kyrgyzstan subsidiary, Sky Mobile LLC, began providing mobile telecommunications services to the Embassy of Iran in Bishkek. The approximate gross revenue and net profits for these services in 2019 was US$499 and US$354, respectively. During 2009, our Algerian subsidiary, OTA, and subsequently its wholly owned subsidiary, Optimum, began providing mobile telecommunications services to the Embassy of Iran in Algiers. The approximate gross revenue and net profits for these services in 2019 was US$479. During 2007, our Bangladesh subsidiary, Banglalink, began providing telecommunications services to the Embassy of Iran in Dhaka. The approximate gross revenue and net profits for these services in 2019 was US$6. During 2018, our Uzbekistan subsidiary, Buzton, began providing telecommunications services to the Embassy of Iran in Tashkent. The approximate gross revenue for these services was US$222 with net profits of US$45.

ATEN lists Raymond Computers Co., Ltd. as its distributor in Tehran, Iran. 

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ATEN International Co., Ltd. (ATEN) is listed as an exhibitor at the 18th International Trade Show on Innovative CIT Solutions (“Iran Telecom Innovations Show;” “Telecoms Show”) took place October 16-19, 2017 in Tehran, Iran. (Iran Telecom Innovations Show, “Exhibitors & Products”):

LinkedIn page for Soheil Yaghoub Mesri states he is the Iran territory sale representative for Alfred Kuhse GmbH. 

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Kuhse participated in the 17th Iran International Electricity Exhibition (“IEE”) – sponsored by the Iranian Ministry of Energy – which took place in Tehran, Iran on November 4-7, 2017. (IEE Website, “The 17th Iran International Electricity Exhibition”).

"According to the defendant’s guilty plea, from 2008 until late 2011, Ghodskani was a Tehran-based employee of Fanavar Moj Khavar (Fana Moj), a company located in Tehran, Iran. In 2009, Ghodskani, along with co-defendant Alireza Jalali and others, established Green Wave Telecommunication, Sdn Bhn, (Green Wave), a company located in Kuala Lumpur, Malaysia, that operated as a front for Fana Moj. As part of the conspiracy, Ghodskani falsely represented herself as an employee of Green Wave to U.S. companies in order to acquire export-controlled technology from the United States. To accomplish these acquisitions, Ghodskani, Jalali and others concealed the ultimate destination and end users of the exported technology." (Iran Watch, "Iranian Citizen pleads Guilty to Conspiring to Facilitate the Illegal Export of Technology to Iran," 8/9/2019).

"A statement issued by the center on Thursday October 10 says rumors on social media about the lifting of the ban on Telegram are not true. Telegram, which had close to 40 million users in Iran was banned in early 2018 after mass anti-government protests nationwide. Messaging apps are used to inform people about protests. Iran has also blocked Facebook and thousands of websites, some for political reasons.During the past week, a post attributed to the Chief of High Council of Cyberspace Abolhassan Firouzabadi said that ban was to be lifted. Firouzabadi has denied posting the tweet that promised ending the ban on Telegram. The rumors on lifting the ban on Telegram started when the Judge who had ruled last year that the social networking service should be banned, was arrested last week on charges of financial corruption. Regardless of the ban, Telegram is still the most popular social networking platform retaining most of its users according to official figures. Iranians routinely use proxies and VPNs to get access to free internet." (Radio Farda, "Ban on Popular Telegram App Not to be Lifted In Iran," 10/10/2019).

“The Yerevan Telecommunication Research Institute” CJSC was founded in 1987. The institute works on computer software, hardware and software for telecommunication systems, Development and Production of nodes, functional elements of microelectronics design & manufacturing of the technological control systems for microcontrollers, specialists in the fields of telecommunications and information technology training in communication;

YETRI CJSC has obtained CCL items that were reexported without the required BIS licenses, and the person who is both Executive Director of YETRI CJSC and President of Markel CJSC has been engaged in a business relationship with a sanctioned Iranian organization; (Source: Federal Register)

Markel has obtained CCL items that were reexported without the required BIS licenses, and the President of Markel CJSC has been engaged in a business relationship with a sanctioned Iranian organization;

According to their official website, official partner of Markel is Yerevan Telecommunications Research Institute; (Source: Federal Register)

"The company has been identified as potentially providing mobile phone services in Iran. In 2019 CalPERS designated the company as under review. In 2020 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 continues to monitor the company for possible changes in status relevant to the Act."

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In 2017, CalSTRS designated Telenor ASA as “Under Review” for reportedly having roaming and service agreements with the Iranian state-owned Mobile Company of Iran. CalSTRS maintained the “Under Review” designation in 2018.

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In 2017 the U.S. state of California listed Telenor as a company under review for reportedly having roaming and service agreements with the Iranian state-owned Mobile Company of Iran.

According to its annual report filed with the SEC in 2020, "Some of our subsidiaries have entered into roaming agreements with Iranian telecommunication companies. Pursuant to such roaming agreements our subsidiaries’ customers are able to roam in the particular Iranian network (outbound roaming) and customers of such Iranian operators are able to roam in our relevant subsidiary’s network (inbound roaming). For outbound roaming, our subsidiaries pay the relevant Iranian operator roaming fees for use of its network by our customers, and for inbound roaming the Iranian operator pays the relevant subsidiary roaming fees for use of the respective network by its customers.

Our subsidiaries were party to the following roaming agreements with Iranian telecommunication companies in 2019:

(1)

Telefónica Móviles España S.A. (“TME”), our Spanish directly wholly-owned subsidiary, has respective roaming agreements with (i) Mobile Telecommunication Company of Iran (“MTCI”), (ii) MTN Irancell (“Irancell”), (iii) Taliya (“Taliya”), and (iv) Telecommunication Kish Co (“TKC”). During 2019 TME recorded the following revenues related to these roaming agreements: (i) 67,273.13 euros from MTCI, (ii) 323.77 euros from Irancell, (iii) no revenues from Taliya, and (iv) no revenues from TKC.

Until December 31, 2019, TME also held a roaming hub through its 55% directly-owned subsidiary, Link2One, a.e.i.e. (“L2O”). Under the related agreement, L2O provided a roaming hub service to Irancell enabling the latter to maintain a relationship with other members of the hub. Some entities of the Telefónica Group were members of the hub. During 2019, L2O recorded revenues of 9,000.00 euros from Irancell. L2O terminated its agreement with Irancell on June 30, 2019. The roaming arrangement between TME and Irancell under the L2O framework was terminated on April 30, 2019.

(2) Telefónica Germany GmbH & Co. OHG (“TG”), our German 69.22% indirectly-owned subsidiary, has respective roaming agreements with (i) MTCI and (ii) Irancell. During 2019 TG recorded the following revenues related to these roaming agreements; (i) no revenues from MTCI and (ii) 7,441.13 euros from Irancell.

(3) Telefónica UK Ltd (“TUK”), our English directly wholly-owned subsidiary, has a roaming agreement with Taliya. During 2019 TUK recorded no revenues from Taliya. Until April 30, 2019, TUK also had a roaming arrangement with Irancell under the L2O framework, which was terminated on such date. TUK recorded 314.54 euros in roaming revenues under such roaming arrangement.

(4) Telefónica Argentina, S.A. and Telefónica Móviles Argentina, S.A. (together “TA”), our Argentinean directly and indirectly wholly-owned subsidiaries, had a roaming arrangement with Irancell under the L2O framework that was terminated on April 30, 2019. During 2019 TA recorded 0.89 euros in roaming revenues under such roaming arrangement.

(5) Telefônica Brasil S.A. (“TB”), our Brazilian 73.68% indirectly-owned subsidiary, has a roaming agreement with Irancell. During 2019, TB recorded 0.68 dollars in roaming revenues and had 169.11 dollars (before taxes and 184.32 dollars after taxes) of expenses payable to Irancell under this agreement.

(6) Pegaso PCS S.A. de C.V. (“PCS”), our Mexican directly wholly-owned subsidiary, has a roaming agreement with Irancell. During 2019 PCS recorded 9.33 euros in roaming revenues under this agreement.

 7) Telefónica del Perú, S.A.A. (“TdP”), our Peruvian 98.57% indirectly-owned subsidiary, had a roaming arrangement with Irancell under the L2O framework that was terminated on April 30, 2019. During 2019 TdP recorded no revenues under such roaming arrangement.

(8) Colombia Telecomunicaciones, S.A. ESP ("ColTel"), our Colombian 67.50% directly and indirectly-owned subsidiary, had a roaming arrangement with Irancell under the L2O framework that was terminated on April 30, 2019. During 2019, ColTel recorded no revenues under such roaming arrangement.

(9)Telefonía Celular de Nicaragua S.A. (“TN”), in respect of which we indirectly held a 60% stake until May 16, 2019 (the date on which we completed the sale of such stake), had a roaming arrangement with Irancell under the L2O framework that was terminated on April 30, 2019. During 2019, TN recorded no revenues under such roaming arrangement.

(10) Telefonica Móviles del Uruguay S.A. (“TMU”), our Uruguayan directly wholly-owned subsidiary, had a roaming arrangement with Irancell under the L2O framework that was terminated on April 30, 2019. During 2019 TMU recorded 0.24 euros in roaming revenues under such roaming arrangement.

(11)Telefónica Móviles Chile S.A. (“TCH”), our Chilean directly wholly-owned subsidiary, had a roaming arrangement with Irancell under the L2O framework that was terminated on April 30, 2019. During 2019 TCH recorded 4.94 euros in roaming revenues under such roaming arrangement.

The net profit recorded by our subsidiaries pursuant to these agreements and arrangements did not exceed the related revenues recorded thereunder.

The purpose of all of these agreements is to provide our customers with coverage in areas where we do not own networks. For this purpose, we intend to continue maintaining those agreements which are still outstanding.

The Group does not currently have any forthcoming plans to enter into new roaming arrangements with Iranian telecommunication companies. However, the Group may consider entering into such arrangements in the future."

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In 2019 Telefonica was removed from the Texas Comptroller List of Companies Engaging in Scrutinized Business Operations in Iran. 

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In 2018 Telefonica was listed on the Texas Pension Review Board List of Scrutinized Companies doing business in Iran pursuant to Chapter 807.054, Government Code.  
 

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In 2018 the U.S. state of Ohio listed Telefonica as an Iran restricted company rendering Telefonica ineligible for investment and/or state contracting.