Telecommunications

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

"During 2019 we had two activities relating to Iran: (i) our roaming agreement (mobile services) with Mobile Company of Iran (MCI) (formerly TCI), which allows our mobile customers to use their mobile device on a network outside their subscriber’s home network (see “Glossary of Terms—Roaming”) and (ii) our international telecommunications services agreements with international carriers (fixed services), which cover delivery of traffic to Iran through non-Iranian carriers.

On December 28, 2018, Telecom Argentina notified Mobile Company of Iran (MCI) the decision to terminate the IRA agreement signed by both parties related to Voice Roaming Service, in February 1, 2019. Notwithstanding the foregoing, and in order to properly document the termination of the roaming service, on February 1, 2019, a notarial certificate was issued stating the termination at a technical level of said service.

After the date of termination of the agreement, Telecom Argentina will issue and receive invoices for traffic consumptions up to that date.

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We have, to our knowledge, two activities relating to Iran: (i) our roaming agreement (mobile services) with Mobile Company of Iran (MCI) (formerly TCI), which allow our mobile customers to use their mobile device on a network outside their subscriber’s home network (see “Glossary of Terms—Roaming”) and (ii) our international telecommunications services agreements with international carriers (fixed services), which cover delivery of traffic to Iran through non-Iranian carriers.

According to its 2017 SEC 10-K filing: DT, through certain of its non-U.S. subsidiaries, is party to roaming and interconnect agreements with the following mobile and fixed line telecommunication providers in Iran, some of which are or may be government-controlled entities: Gostaresh Ertebatat Taliya, Irancell Telecommunications Services Company (“MTN Irancell”), Telecommunication Kish Company, Mobile Telecommunication Company of Iran, and Telecommunication Infrastructure Company of Iran. For the year ended December 31, 2017, gross revenues of all DT affiliates generated by roaming and interconnection traffic with Iran were less than $4 million and estimated net profits were less than $4 million.

In addition, DT, through certain of its non-U.S. subsidiaries, operating a fixed line network in their respective European home countries (in particular Germany), provides telecommunications services in the ordinary course of business to the Embassy of Iran in those European countries. Gross revenues and net profits recorded from these activities for the year ended December 31, 2017 were less than $0.4 million. We understand that DT intends to continue these activities.

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

Iskratel announced on April 14th that this week the Slovenian-based ICT company has signed the milestone contract with the national operator Telecommunication Company of Iran (TCI) in Tehran. With this project Iskratel will bring modernization of fibre-based broadband access to seven Iranian territories.The project basis was last year’s official tender of TCI, where Iskratel was chosen as one of the four major vendors and solution providers. The multimillion euro project has been trusted to Iskratel - being the only European vendor in this tender - and global vendors Huawei, FiberHome and Zyxel." (April 2017) 

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Iskratel, D.o.o., Kranj (“Iskratel”) is listed as an exhibitor at the 18th International Trade Show on Innovative CIT Solutions (“Iran Telecom Innovations Show;” “Telecoms Show”) taking place on October 16-19, 2017 in Tehran, Iran. (Iran Telecom Innovations Show, “Exhibitors & Products”).

 In 2018 the U.S. state of Ohio listed Global Telecom Holding on its Iran prohibited companies list rendering GTH ineligible for investment and/or state contracting.

Attended the 18th International Trade Show on Innovative CIT Solutions which took place in Tehran, Iran on October 16-19, 2017  and reported business operations with the Iranian companies AKTIS and Gostarsh Salem Iranian Telecom (Iran Telecom Innovations Show, “Exhibitors & Products”; AKTIS Website, “Brands [Coriant])”; GSI Website [cached], “Our Partners”).

According to its Annual Report filed with the SEC for fiscal year 2018: "Prior to our fourth quarter 2018 acquisition of Sky, a non-U.S. subsidiary of Sky entered into two licensing agreements that licensed some of Sky’s owned programming content to a broadcasting company that is owned and controlled by the Government of Iran. The first agreement was entered into in June 2012, and was amended in July 2016, to license 150 hours of programming content for various three-year license terms for a one-time fee of €86,250. The last remaining programming license under this agreement expires in January 2019. The second agreement was entered into in June 2015 to license 80 hours of programming content for various three-year license terms for a one-time fee of €45,700. To date, no programming content has been provided, and the license fee has not been paid, pursuant to the agreement. We believe that Sky conducted its licensing activity in compliance with applicable laws and that the licenses are for the permissible exportation of informational materials pursuant to certain statutory and regulatory exemptions from U.S. sanctions."

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In 2018, the U.S. state of Michigan listed Comcast on its state list of Companies Doing Business with the Iran rendering Comcast ineligible for investment and/or state contracting.

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In its January 2017 SEC report Comcast notes: “We are not aware of any activity, transaction or dealing during the year ended December 31, 2017 that requires disclosure under the Act, except with respect to a January 2016 licensing agreement by a non-U.S. subsidiary of DreamWorks Animation prior to our August 2016 DreamWorks Animation acquisition. The agreement licensed a prior season of a children’s animated television series for a three-year, non-cancelable term and for a one-time fee of $5,200 to a broadcasting company that is owned and controlled by the Government of Iran. The broadcasting company paid the license fee in the first quarter of 2016. We believe that DreamWorks Animation conducted its licensing activity in compliance with applicable laws and that the license is for the permissible exportation of informational materials pursuant to certain statutory and regulatory exemptions from U.S. sanctions.”

In 2018, the U.S. state of Ohio listed Banglalink on its state list of Companies Doing Business with the Iran rendering Banglalink ineligible for investment and/or state contracting.

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Subsidiary of Global Telecom Holding.

Letter was written over participation in the Iran Telecom Innovation October 2017 exhibition. ATDI informed UANI

We didn’t know that CRA Iran was sanctioned in May 2017...we inform you that our company will not participate in the Iran telecom innovations 16-19 October 2017 exhibition.

Listed as an exhibitor at the 2017 Iran telecoms Innovations exhibition.

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Nestor Cables was an exhibitor at the Iran Telecom Innovations Conference (the “Conference”) that took place on September 25‑28, 2016 in Tehran, Iran. (Nestor Cables Website, “Profile”; Iran Telecom Innovations Website, “Exhibitor List”).

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“[m]arket area in Iran is finally opening its doors for Western companies after years of embargo… Nestor Cables is interested in this new market area and its potential.”  (Nestor Cables Website, “Nestor Cables at Telecom Innovations 2016 in Iran 25.-28.9.2016,” 10/4/2016).