FDD Report on Iran's Energy Partners

_________________________________________________________________________________________________________ Iran Energy Project Foundation for Defense of Democracies www.iranenergyproject.org www.defenddemocracy.org

Iran’s Energy Partners

Companies Requiring Investigation Under U.S. Sanctions Law

A Mark Dubowitz Laura Grossman

August 2010

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Iran Energy Project Foundation for Defense of Democracies www.iranenergyproject.org www.defenddemocracy.org

July 2010

About the Authors

Mark Dubowitz is the Executive Director of the Foundation for Defense of Democracies. He is the Director of the Iran Energy Project which provides leading research and analysis in support of strong, broad-based energy sanctions -- including gasoline, natural gas, and oil sanctions -- as part of a comprehensive strategy to end the Iranian regime's pursuit of nuclear weapons, support for terrorism and human rights abuses. It also focuses on the risks to foreign companies in doing business with the U.S. government-blacklisted Islamic Revolutionary Guard Corps, a dominant force in the Iranian energy sector.

Mark writes frequently on Iran energy sanctions issues. He is a regular contributor to

Forbes' Energy Source. Mark's work is often featured in international print and broadcast media.

Mark has testified before Congress on Iran sanctions issues and briefed the U.S. military, U.S., European and Canadian government officials, members of Congress, and counterter-rorism officials on a range of national security and terrorism-related concerns. He has also provided evidence in a successful terrorism case against U.S.-based supporters of Hezbol-lah.

Laura Grossman is a Research Analyst for the Foundation for Defense of Democracies’ Iran Energy Project. She received her bachelor’s degree in History from the University of Michigan in Ann Arbor and a M.S. in Global Affairs from New York University. She co-authored Homegrown Terrorists in the U.S. and U.K. and Terrorism in

the West 2008 with Daveed Gartenstein-Ross. At NYU, she was a founding member and managing editor of Perspectives on Global Issues, the first student-run publication at NYU’s Center for Global Affairs.

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About The Iran Energy Project

The Iran Energy Project is a project of the Foundation for Defense of Democracies (FDD). Iranenergyproject.org provides research and analysis that identifies Iran’s energy vul-nerabilities as part of a comprehensive sanctions strategy to end the Iranian regime’s nu-clear weapons program, support for terrorism, and human rights abuses. The Iran Energy Project also analyzes the prominent role of the Islamic Revolutionary Guard Corps in Iran’s energy industry. Companies still doing business with Iran now risk being sanctioned by the United States, the European Union, Canada, Australia, and other countries. The Iran Energy Project tracks these companies using available open sources and publishes its findings on a website that is free to the public. The website also provides breaking news, critical analysis, and rele-vant legislation.

In recent months, many of Iran's major energy partners have ended their business ties with Iran. To assist government officials with effective sanctions enforcement, the Iran Energy Project provides updates on companies that remain in the Iranian energy sector, as well as those that resume their business ties.

FDD’s Iran Energy Experts

� Mark Dubowitz

Executive Director

� Reuel Marc Gerecht Senior Fellow

� Emanuele Ottolenghi Senior Fellow, Brussels

� Benjamin Weinthal Fellow, Berlin

� Laura Grossman Research Analyst

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Introduction President Barack Obama has repeatedly said that preventing Iran from acquiring a nuclear weapon is a top priority. To this end, the Obama administration can strike a blow at the heart of Iran’s energy business, without which Tehran would face significant eco-nomic and political challenges.

The Iran Energy Project has identified a num-ber of companies active in Iran’s energy sec-tor. These companies deserve further investi-gation under The Comprehensive Iran Sanc-

tions, Accountability, and Divestment Act (the

“Comprehensive Act”) signed into law on July 1, 2010, and the Iran and Libya Sanctions Act

of 1996 (amended in 2006 to the Iran Sanc-

tions Act).

FDD collected its information about these com-panies from open source reports. The informa-tion is carefully footnoted and sourced, but is far from exhaustive. Rather, it provides a glimpse of how these companies do business with Iran and, in some cases, the United States, through federal government contracts and other U.S. business interests.

FDD’s Iran Energy Project has a more compre-hensive list of international companies operating in Iran’s energy sector. The list is available at www.iranenergyproject.org.

Drawing from that list, FDD has identified the following companies as having substantial op-erations in Iran:

Company

Country

Sector (s)

Aker Solutions Norway Natural Gas

China National Petroleum Company China Gasoline Supplier; Oil Exploration & Production; Natural Gas

Daelim Industrial Corporation South Korea Refining; Petrochemicals

Elektrizitäts-Gesellschaft Laufenburg Switzerland Natural Gas

Gazprom Russia Oil Exploration & Production

Haldor Topsoe Denmark Refining; Petrochemicals

Inpex Japan Oil Exploration & Production

The Linde Group Germany Refining; Petrochemicals

LyondellBasell Netherlands Refining; Petrochemicals

Oil & Natural Gas Corporation India Oil Exploration & Production

Petróleos de Venezuela, S.A. Venezuela Oil Exploration & Production; Natural Gas

Sasol Limited South Africa Refining; Petrochemicals

Sinopec China Gasoline Supplier; Oil Exploration & Production; Refining

SKS Ventures Malaysia Refining; Petrochemicals; Natural Gas

ThyssenKrupp Germany Refining; Petrochemicals

Tupras Turkey Gasoline Supplier

WorleyParsons Australia Natural Gas; Petrochemicals

Zhuhai Zhenrong Corporation China Gasoline Supplier

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The State of the Iranian Energy Sector Iran is the world’s fourth-largest producer of crude oil.1 Oil export revenues constitute more than 24 percent of Iran’s gross domestic product,2 according to Government Account-ability Office estimates, 80 percent of export earnings,3 and up to 76 percent of govern-ment revenues.4 Iran also has the second largest natural gas reserves in the world after Russia, which could give Tehran even more influence over global energy markets if it ac-quires the requisite investment and technol-ogy.5

Yet, in spite of the country’s enormous oil and gas reserves, Iran’s energy infrastructure is rusting. The Wall Street Journal recently noted that “Iran’s beleaguered oil industry could be on its way to passing an ignominious milestone: being replaced [by 2015] by its onetime nemesis, Iraq, as the Middle East’s second-biggest oil producer.”6

During President Mahmoud Ahmadinejad’s first four years in office, foreign investment in Iran’s energy industry plummeted by 64 per-cent, from $4.2 billion to $1.5 billion.7 Gov-

1 U.S. Energy Information Administration, “Iran,” Country

Analysis Briefs, January 2010, p. 8. (http://www.eia.doe.gov/emeu/cabs/Iran/pdf.pdf) 2 Joseph A. Christoff, “Iran Sanctions: Firms Reported to Have Commercial Activity in the Iranian Energy Sector and U.S. Gov-ernment Contracts,” Testimony before the Senate Homeland

Security and Governmental Affairs Committee, May 12, 2010. (http://www.gao.gov/new.items/d10721t.pdf) 3 U.S. Energy Information Administration, “Iran,” Country

Analysis Briefs, January 2010, p. 7. (http://www.eia.doe.gov/emeu/cabs/Iran/pdf.pdf) 4 Joseph A. Christoff, “Iran Sanctions: Firms Reported to Have Commercial Activity in the Iranian Energy Sector and U.S. Gov-ernment Contracts,” Testimony before the Senate Homeland

Security and Governmental Affairs Committee, May 12, 2010. (http://www.gao.gov/new.items/d10721t.pdf) 5 U.S. Energy Information Administration, “Iran,” Country

Analysis Briefs, January 2010, p. 8. (http://www.eia.doe.gov/emeu/cabs/Iran/pdf.pdf) 6 Spencer Swartz and Benoit Faucon, “Iran’s Falling Oil Output Means Less Revenue, Clout,” The Wall Street Journal, June 26, 2010. (http://online.wsj.com/article/SB10001424052748704569204575328851816763476.html) 7 Doron Peskin, “Iran: Foreign Investment in Oil Drops During Ahmadinejad’s Term,” Ynet News, April 30, 2010. (http://www.ynetnews.com/articles/0,7340,L-3880348,00.html)

ernment mismanagement has also hamstrung Iran’s energy sector. Ahmadinejad has replaced a number of competent energy technocrats with regime loyalists, including Islamic Revolutionary Guard Corps (IRGC) officials who have no prior experience in the energy business. Iranian officials now say that without an annual investment of at least $25 billion, Iran could become a net importer of oil.8

As a result of its limited refining capacity and domes-tic subsidies, which have driven up demand for gaso-line, Iran imports approximately 30 percent of its gasoline from foreign suppliers. For the U.S. and its allies, this presents a significant opportunity to in-crease pressure on the regime.

According to a 2009 Congressional Research Service report, the mere threat of sanctions has “constrained Iran’s energy sector significantly.”9 Not only are Iran’s gasoline suppliers exiting the market, but en-ergy investors, banks, technology providers, and in-surers now face growing pressure to choose between doing business with Iran and maintaining business in the far larger U.S. market.

The mere possibility of meaningful energy sanctions has already achieved tangible results: ten of Iran’s top suppliers have reportedly stopped selling gaso-line to Iran after calculating that the political risks of continued trade were too high. They include: BP, Vitol, Trafigura, Glencore, Total, Shell, Reliance, Lu-koil, Petronas, and the Independent Petroleum Group.10

8 “UPDATE 1-Iran Needs $25 bln/year in Energy Investment-Report,” Reuters, May 10, 2010. (http://in.reuters.com/article/idINLDE6490X420100510) 9 Kenneth Katzman, “The Iran Sanctions Act (ISA),” Congressional Re-

search Service, June 4, 2009, p. 4. (http://italy.usembassy.gov/pdf/other/rs20871.pdf) 10 “Petronas Halts Petrol Sale to Iran,” Emirates Financial News, April 15, 2010. (http://www.emiratesfn.com/news/newsfull.php?newid=356995); and Stanley Carvalho, “Western Oil Firms Stop Business with Iran,” Reuters, June 28, 2010. (http://uk.reuters.com/article/idUKDAH85080620100628); and “Com-panies Cutting Ties Their Iran Energy Ties, IranEnergyProject.org, ac-cessed July 26, 2010. (http://www.iranenergyproject.org/hotsheet/)

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Four major insurance companies ― Lloyd’s of London, Munich Re, Hannover Re and Allianz ― announced they would stop or sharply re-duce their underwriting for Iran’s gasoline trade.1 Numerous energy companies includ-ing Statoil, ENI, Lukoil, and Repsol have ter-minated or significantly reduced their in-vestments in Iranian oil and natural gas, and the U.S. State Department estimates that $50-$60 billion in upstream development projects are either on hold or have been terminated in the past few years.2 Foreign companies that were already cutting back their energy ties to Iran before the legislation passed now have even more incentive to do so.3

U.S. and International Energy Sanctions

On July 1, 2010, President Obama signed into law the Comprehensive Iran Sanctions, Ac-countability, and Divestment Act (the “Com-prehensive Act”), extending the energy sanc-tions contained in the Iran Sanctions Act (formerly the Iran and Libya Sanctions Act of 1996), which sanctioned investments of $20 million or more in any one year in the Iranian energy industry. Historically, sanctions en-forcement has been eclipsed by a fear of a backlash from the major players in Iran’s en-ergy business, some of which have significant trade relations with the United States.

The key provisions target Iran’s economic Achilles’ heel: the regime’s need to import up to 30 percent of its gasoline from foreign companies. Tehran lacks the refinery capacity

1 Katherine Blackler, “Allianz Will Not Renew Business in Iran,” Reinsurance, February 19, 2010. (http://www.postonline.co.uk/reinsurance/news/1592838/allianz-renew-business-iran); and Jamie Dunkley, “Lloyd’s of London Backs US Sanctions on Iran,” The Telegraph, July 9, 2010. (http://www.telegraph.co.uk/finance/newsbysector/banksandfinance/insurance/7882144/Lloyds-of-London-backs-US-sanctions-on-Iran.html) 2 Robert Einhorn, Testimony before the House Committee on

Oversight and Government Reform, July 29, 2010. (http://oversight.house.gov/index.php?option=com_content&task=

view&id=5059&Itemid=2) 3 “Factbox―Foreign Companies Step Away from Iran,” Reuters, July 23, 2010. (http://af.reuters.com/article/energyOilNews/idAFLDE66M16X20100723); and “Factbox – Sanctions and Fuel Supplies to Iran,” Reuters, July 23, 2010. (http://af.reuters.com/article/energyOilNews/idAFLDE66L1VR20100723?sp=true)

to produce enough gasoline to meet its demand. Congress has exploited this shortfall by extend-ing the Iran Sanctions Act, giving the President authority to sanction foreign companies involved in Iran’s refined petroleum trade, including sup-pliers, insurers, banks, shippers, investors and providers of technology, support, goods, ser-vices, and energy-related information.

The final legislation also targets the oil and natu-ral gas sectors and Iranian overseas energy pro-jects. Congress eliminated a sentence in the Iran

Sanctions Act that for 14 years permitted com-panies providing technology, goods, and services to the Iranian oil and natural gas sectors to es-cape U.S. sanctions. Congress also added addi-tional language to the legislation that requires the President to report to Congress on foreign companies entering into joint ventures, partner-ships, and investments with the Iranian regime for energy-related projects outside Iran, and to sanction those companies providing energy know-how to the Iranian government through these projects.

U.N., E.U., Canadian, and Australian actions sup-port these U.S. energy sanctions. In June 2010, the United Nations Security Council took critical first steps to target the Iranian energy sector. The preamble of the recently adopted U.N. Secu-rity Council Resolution 1929 emphasizes the “potential connection between Iran’s revenues derived from its energy sector and the funding of Iran’s proliferation-sensitive nuclear activities.”4 The resolution also expresses concern that “chemical process equipment and materials re-quired for the petrochemical industry have much in common with those required for certain sensi-tive nuclear fuel cycle activities.”5

At a summit on June 17, 2010, E.U. officials stated that sanctions had “become inevitable,” and announced that the E.U. would ban new in-vestment, technical assistance and technology transfers in connection with Iran’s natural gas

4 UN Security Council, 6335th Meeting, “Resolution 1929 (2010),” June 9, 2010, p. 3. (http://www.defenddemocracy.org/images/UNSC_Resolution_1929_6_9_10.pdf) 5 Ibid.

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and oil industry.6 On July 26, 2010, the E.U. approved these sanctions on Iran’s energy sector.7 The Canadian and Australian gov-ernments have adopted similar measures banning new investment in Iran’s oil and natural gas sectors.8

How Tehran is Skirting Sanctions

Despite these developments, a sober assess-ment of energy sanctions shows that they have significant room for improvement. To counter the threat of international sanctions, Iran has signed major energy deals with countries not likely to cooperate with sanc-tions. Iran plans substantial upgrades to seven of its nine existing oil refinery facilities. Iran also has decades of experience adopting countermeasures to circumvent sanctions. It is highly adept at using cutouts, smuggling, and front companies to procure the goods, technology, equipment, and services that are vital to its energy sector. Much of this activity takes place through Dubai, as well as other points of transshipment, including Malaysia, Hong Kong, Turkey and Singapore.

Furthermore, companies without significant exposure to U.S. energy markets may calcu-late that the rewards of doing business with Iran outweigh the risks. Other companies may note Washington’s relatively weak his-torical record of enforcing energy sanctions and determine that their interests are not in real jeopardy. Asian and Persian Gulf coun-tries will watch carefully the level of Ameri-can and European commitment to enforce-

6 Paul Harrington, “EU Hits Iran with Tougher Sanctions Over Nuclear Row,” AFP, June 17, 2010. (http://www.google.com/hostednews/afp/article/ALeqM5gKj7RH7aI19u02uMKMH9e3Dk3YVQ) 7 James G. Neuger and Jonathan Stearns, “EU to Impose Sanc-tions on Iran in Bid to Halt Nuclear Drive,” Bloomberg, July 26, 2010. (http://www.bloomberg.com/news/2010-07-26/eu-will-impose-sanctions-on-iran-to-ban-oil-investment-scrutinize-banks.html) 8 Campbell Clark, “Canada to Impose Tough New Sanctions on Iran,” The Globe & Mail, July 25, 2010. (http://www.theglobeandmail.com/news/politics/canada-to-impose-tough-new-sanctions-on-iran/article1651467/); “Aus-tralia Adopts New Sanctions Against Iran,” Associated Press, July 29, 2010. http://www.google.com/hostednews/ap/article/ALeqM5ipiHvuB3sTHUgyPl7-R0E1DBjCKQD9H8HGAO0

ment with the understanding that they will never be expected to do more than Washington and Brussels.

The Iranian regime claims it can withstand en-ergy sanctions. But the efficacy of its counter-measures, including expanding refinery capacity and introducing flex-fuel cars, is greatly exagger-ated. Its most effective option, a sharp reduction in gasoline subsidies, could force Iran’s already skyrocketing inflation rates to double or triple.

The Need for Energy Sanctions Enforcement

As the U.S. and its allies enact energy sanctions, a growing number of Iranians no longer believe their leaders’ attempts to blame Washington for Iran’s diplomatic isolation and stagnating econ-omy. In November 2008, a group of 60 Iranian economists criticized President Mahmoud Ahmadinejad for his “tension-creating” foreign policy that “scared off foreign investment and inflicted heavy damage on the economy.”9 They noted that sanctions had cost Iran billions of dol-lars by forcing it to rely on middlemen for im-ports and exports. Indeed, many Iranians despise the regime not only for its human rights abuses but also because of the disastrous state of the economy, which suffers from double-digit inflation and soaring unemployment.10 Sanctions can exacerbate Iran’s economic crisis. For example, riots followed Tehran's decision in 2007 to ration gasoline supplies. Drivers torched gas stations. A concerned Iranian parliament quickly pressed the government to scrap the ra-tioning plan.11 Last year, the Iranian government announced plans to reduce subsidies for energy and basic

9 Borzou Daragahi, “Economists in Iran Criticize Ahmadinejad,” Los

Angeles Times, November 10, 2008. (http://articles.latimes.com/2008/nov/10/world/fg-iran10) 10 Babak Dehghanpisheh, “In Iran, Inflation Could Threaten Re-gime,” Newsweek, February 5, 2010. (http://www.newsweek.com/blogs/wealth-of-nations/2010/02/05/in-iran-inflation-could-threaten-regime.html) 11 “Iran Fuel Rations Spark Violence,” BBC News, June 27, 2007. (http://news.bbc.co.uk/2/hi/middle_east/6243644.stm)

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commodities.12 The decision was motivated by the regime’s desire to reduce soaring de-mand for cheap gasoline (to counter the ef-fects of gasoline sanctions) and to save the Iranian treasury billions of dollars in subsidy support payments. However, if the govern-ment allows the prices of gasoline and other commodities to rise to market levels, it could drive Iran’s current inflation rate from unoffi-cial estimates of 20-25 percent13 to as high as 40 percent14 ― compounding the country’s economic problems and fanning the flames of domestic discontent. Iran’s energy sector is now under more pres-sure than it has been in recent memory, and this happened without a concerted effort by the White House to actually enforce sanctions legislation. The level of discontent is high in Iran. Sanc-tions could accelerate the political transfor-mation that many Iranians seek. This could increase the likelihood of stopping the Iranian nuclear weapons program.

Conclusion

The eighteen companies listed in this report represent a cross-section of international companies that are investing in the Iranian energy sector, providing goods, technology, and services for Iran’s oil and natural gas sec-tors, or involved in the refined petroleum supply chain, according to open source re-porting. While this list is not exhaustive, these companies should be investigated by the Obama administration for possible sanc-tions violations.

12 Henry Meyer, “Iran Government Subsidy Cuts to Reduce Fuel Imports, Central Banker Says,” Bloomberg, May 16, 2010. (http://www.bloomberg.com/news/2010-05-16/iran-government-subsidy-cuts-to-curb-sanction-impact-central-banker-says.html) 13 Hossein Askari, “Iran on the Edge,” Foreign Policy, November 3, 2009. (http://www.foreignpolicy.com/articles/2009/11/03/iran_on_the_edge?page=0,0) 14 Ibid.

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Aker Solutions (Norway) In April 2005, Norwegian-based Aker won a $25 million contract to provide engineering and man-agement services for phases 9 and 10 of Iran’s South Pars gas field project. Aker Kvaerner part-nered with National Iranian Oil Company (NIOC) subsidiary Pars Oil & Gas Company (POGC) and Hir-bodan, a private Iranian engineering firm. After winning the project, Executive Vice President Simen Lieungh called it, “a good project for Aker Kvaerner. Our track record on executing large projects and the teaming up with a competitive Iranian partner were important winning factors for the contract.” The project is reportedly ongoing.1 NIOC has been des-ignated by the U.S. Treasury.2 In June 2009, Aker Solutions acquired Wirth, form-ing a new subsidiary company. Aker Wirth main-tains corporate offices in Tehran through a subsidi-ary, WPS Group.3 Aker Wirth’s projects in Iran in-clude a metro tunnel in Esfahan and several water tunnels.4 Aker Wirth’s clients include Kala Naft, an entity designated by the U.S. Treasury for its ties to the Islamic Revolutionary Guard Corps (IRGC).5 One of Aker Wirth’s tunnel projects is overseen by the Iranian firm Sahel Consulting Engineers, which is owned by the IRGC.6 The website of Wirth’s Ira-nian subsidiary shows a photograph of a welcome sign to the site bearing the logo of the IRGC.7

Aker Solutions and its subsidiary companies main-tain offices across the U.S. In 2009, it signed a con-

1 “Breakthrough Contract in Iran: South Pars Phases 9 and 10,” Aker Kvaerner

Website, April 27, 2005. (http://www.akersolutions.com/Internet/MediaCentre/PressReleases/All/2005/AKPressRelease_991368.htm) 2 U.S. Department of the Treasury, Office of Foreign Assets Control, “Recent OFAC Actions,” June 16, 2010. (http://www.treas.gov/offices/enforcement/ofac/actions/20100616.shtml) 3 “Aker Wirth Worldwide,” Wirth website. (http://www.wirth-erkelenz.de/index.php?id=253&L=0&r=2) The subsidiary company is called WPS Group. Its website is http://www.wps.ir/. 4 “List of Customers and References,” Aker Wirth Website, accessed July 29, 2010. (http://www.wirth-erkelenz.de/index.php?id=158&L=0 & http://www.wirth-erkelenz.de/index.php?id=157&L=0) 5 “Oil & Natural Gas,” Aker Wirth Website, accessed July 29, 2010.

(http://www.wirth-erkelenz.de/index.php?id=159&L=0) and U.S. Depart-

ment of the Treasury, Office of Foreign Assets Control, “Recent OFAC Actions,” June 16, 2010. (http://www.treas.gov/offices/enforcement/ofac/actions/20100616.shtml) 6 Emanuele Ottolenghi, “The Iranian Shell Game,” Commentary, July – August 2008, p. 52. (http://www.commentarymagazine.com/viewpdf.cfm?article_id=11460) 7 “Ghomroud Water Conveyance Tunnel - Lot 5 (IRAN),” WPS Group Website, accessed June 30, 2010. (http://www.wps.ir/ghomroudlot5.htm)

tract with BP America to perform sub-sea con-struction activities at two oil fields in the Gulf of Mexico.8

Aker Solutions has received $6.3 million in con-tracts from the U.S. government since 2000, the majority of which came from the Department of Defense.9

Aker Solutions is listed by the Minnesota State Board of Investment as a restricted company,10 the California Public Employees’ Retirement System (CalPERS) as a newly identified com-pany under review,11 and the Florida State Board of Administration as a company for con-tinued examination,12 and it appears on the Illi-nois State Board of Investment’s list of scruti-nized companies.13 However, company spokes-man Jannick Lindbaek stated to The New York

Times that Aker does not currently have any business in Iran, but that the company is not barred from selling products to Iran, and it is following Norwegian law.14

8 Aker Solutions, Press Release, “Subsea Installation Contract to Aker Solutions,” September 23, 2009. (http://www.akersolutions.com/Internet/MediaCentre/PressReleases/OilAndGas/AKPressRelease_1342868.htm) 9 “Aker Solutions,” USASpending.gov, accessed June 29, 2010. (http://www.usaspending.gov/) 10 Minnesota State Board of Investment, Report on Iran Required by Laws

of Minnesota 2009, Chapter 90 (January 11, 2010), p. 3. (http://archive.leg.state.mn.us/docs/2010/mandated/100088.pdf) 11 California Public Employees’ Retirement System, Iran Related Invest-

ments – Second Legislative Report (February 22, 2010), p. 12. (http://www.calpers.ca.gov/eip-docs/investments/reports/iran-related-investments.pdf) 12 Florida State Board of Administration, Protecting Florida’s Investment

Acts (PFIA): Quarterly Report (July 29, 2010) p.13. (http://www.sbafla.com/fsb/LinkClick.aspx?fileticket=LSsNe4oN3SA%3d&tabid=402) 13 Illinois State Board of Investment, Public Act 95-616 (“Iran Act”):

Annual Report (January 1, 2010), p. 5. (http://www.isbi.illinois.gov/pdf/ISBI_Annual_Report_IRAN.pdf) 14 “Profiting From Iran, and the U.S.,” The New York Times, March 12, 2010. (http://www.nytimes.com/interactive/2010/03/06/world/iran-

sanctions.html)

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China National Petroleum Company (CNPC) (China)

Chinaoil, CNPC’s trading arm, has reportedly taken advantage of other sellers leaving the Iranian market.1 According to Reuters, it “sold two gasoline cargoes for April [2010] delivery to Iran.” The deliveries were Chinaoil’s first direct sales to Iran since January 2009.2

In 2004, the National Iranian Oil Company (NIOC) granted a service contract to CNPC to develop the Masjed-i-Suleiman oil field. NIOC has been designated by the U.S. Treasury.3 In 2007, CNPC increased investment in the pro-ject.4 CNPC began drilling in the oil field in 2007, and maintains a 75 percent share of the oil field.5

In May 2005, CNPC signed an $18 million deal to develop the Kuhdasht Block in Iran.6 The project was formally launched in 2005. In 2007, its first exploration well provided 1,250 barrels in daily testing.7

In January 2009, CNPC and NIOC inked a nearly $2 billion deal to develop the North Azadegan oil field.8 The field could produce 75,000 bar-rels per day by 2012.9 Development is set to take place in two phases spanning 30 years; by its end, the field could produce up to 150,000

1 Simon Webb, “UPDATE 2-Iran Relies on Friendly Powers for Fuel Sup-

plies,” Reuters, July 8, 2010. (http://uk.reuters.com/article/idUKLDE6671UA20100708) 2 Luke Pachymuthu and Seng Li Peng, “Exclusive: China's Top Oil Firms Sell Gasoline to Iran-Trade,” Reuters, April 14, 2010. (http://www.iranenergyproject.org/373/exclusive-chinas-top-oil-firms-sell-gasoline-to) 3 U.S. Department of the Treasury, Office of Foreign Assets Control, “Recent OFAC Actions,” June 16, 2010. (http://www.treas.gov/offices/enforcement/ofac/actions/20100616.shtml) 4 “Iran - Masjid-i-Suleiman,” APS Review Oil Market Trends, April 13, 2009. (http://findarticles.com/p/articles/mi_hb6478/is_15_72/ai_n31566333/) 5 Joseph A. Christoff. “Firms Reported in Open Sources as Having Commer-cial Activity in Iran’s Oil, Gas, and Petrochemical Sectors,” U.S. Government Accountability Office, March 23, 2010, p. 17. (http://www.gao.gov/new.items/d10515r.pdf) 6 “IRAN SANCTIONS: Impact in Furthering U.S. Objectives Is Unclear and Should Be Reviewed,” U.S. Government Accountability Office, December 2007. (http://www.gao.gov/new.items/d0858.pdf) 7 “CNPC in Iran,” CNPC Website, accessed April 27, 2010. (http://www.cnpc.com.cn/en/cnpcworldwide/iran/) 8 Alison Klayman, “China Works to Raise Mideast Profile,” Voice of America, January 15, 2009. (http://www1.voanews.com/english/news/a-13-2009-01-15-voa14-68810252.html?CFTOKEN=60235739&jsessionid=003013ee5b02ab62087b7f65367a40c754f2&CFID=285053156) 9 David Pierson, “The World,” Los Angeles Times, October 16, 2009. (http://articles.latimes.com/2009/oct/16/world/fg-china-iran16)

barrels per day.10 Pending NIOC’s approval, drilling is slated for 2010.11 CNPC signed a deal with NIOC’s overseas investment subsidiary, Naftiran Intertrade Company (NICO), a U.S. Treasury designated entity,12 in September 2009 to develop Iran’s South Azadegan oil field, buying 70 percent of the project. CNPC will re-portedly hand over the field to NIOC after de-velopment and will receive payments from the oil production to cover its investment.13 In July 2010, CNPC’s Master Development Plan (MDP) for the project was approved, enabling the company to develop the field.14

Also in 2009, CNPC replaced France’s Total in a contract to develop South Pars phase 11.15 CNPC has a 12.5 percent share of the project, valued at over $13 billion.16 The deal was final-ized in February 2010.17

CNPC does not operate in the U.S., according to its website.18 However, CNPC subsidiary Petro-China has a subsidiary with offices in New Jer-sey.19 PetroChina has been listed on the New York Stock Exchange since 2000.20 According to the U.S. Securities & Exchange Commission

10 Xiao Wan, “CNPC to Develop Azadegan Oilfield,” China Daily, January 16, 2009. (http://www.chinadaily.com.cn/cndy/2009-01/16/content_7402843.htm) 11 “CNPC Plans Drilling in Iran's Azadegan in 2010-Source,” Reuters, June 9, 2009. (http://www.forbes.com/feeds/afx/2009/06/09/afx6520304.html) 12 U.S. Department of the Treasury, Office of Foreign Assets Control, “Re-cent OFAC Actions,” June 16, 2010. (http://www.treas.gov/offices/enforcement/ofac/actions/20100616.shtml) 13 “Iran, China Sign Major Deal to Develop South Azadegan,” Rig Zone, September 30, 2009. (http://www.egyptoil-gas.com/read_article_international.php?NID=1139) 14 “CNPC’s MDP for Iran’s Azadegan Approved,” Shana (Iran), July 21, 2010. (http://www.bedigest.com/NEWS/42915.aspx) 15 “CNPC Replaces Total at South Pars 11,” Upstream Online, June 3, 2009. (http://www.upstreamonline.com/live/article179964.ece) 16 Joseph A. Christoff. “Firms Reported in Open Sources as Having Com-mercial Activity in Iran’s Oil, Gas, and Petrochemical Sectors,” U.S. Gov-ernment Accountability Office, March 23, 2010, p. 17. (http://www.gao.gov/new.items/d10515r.pdf) 17 “CNPC Clinches South Pars Deal,” Upstream Online, February 10, 2010. (http://www.upstreamonline.com/live/article205885.ece) 18 “CNPC Worldwide,” CNPC Worldwide, accessed June 22, 2010. (http://www.cnpc.com.cn/en/cnpcworldwide/default.htm) 19 “Company Profile,” PetroChina Website, accessed July 16, 2010. (http://www.petrochina.com.cn/Ptr/About_PetroChina/Company_Profile/) 20 “PetroChina Company Limited,” New York Stock Exchange Website, accessed July 14, 2010. (http://www.nyse.com/about/listed/ptr.html)

9

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(SEC), PetroChina uses Bank of New York Mel-lon as its depository for U.S. stocks.21 CNPC created PetroChina in 1999, holding suc-cessful initial public offerings (IPO) in New York and Hong Kong in April 2000.22 CNPC re-mains PetroChina’s largest shareholder, own-ing 86.2 percent of the company.23 JPMorgan Chase & Company holds reportedly 5.37 per-cent of the company’s Hong Kong shares and 0.62 percent of PetroChina’s total share capi-tal.24 In 2009, Canada announced PetroChina’s $1.7 billion acquisition of two Athabasca Oil Sands Corporation projects in Alberta. PetroChina agreed to invest over $250 million to cover the oil sands development. The U.S. is the largest consumer of bitumen from the oil sands.25 In 2010, PetroChina acquired a large crude oil storage facility in the Caribbean from Saudi Arabia. The facility grants “access to fuel and oil markets in the Americas, including the United States.”26 In May 2010, PetroChina inked an agreement with Boeing and China’s National Energy Ad-ministration to evaluate the sustainable avia-tion biofuels industry in China.27

21 “Form 20-F – PetroChina Company Limited,” U.S. Securities & Exchange

Commission, December 31, 2009, p. 112. (http://www.petrochina.com.cn/resource/EngPdf/annual/20-f_2009.pdf) 22 “Public Companies Operating in Sudan: The Relationship of PetroChina Company Ltd. to China National Petroleum Corporation,” KLD Research &

Analytics, Inc, May 9, 2007, p. 3-4. (http://www.kld.com/newsletter/archive/press/pdf/KLD_Analysis_of_PetroChina_Company.pdf) 23 “PetroChina Company Limited Annual Report,” PetroChina, 2009, p. 012. (http://www.petrochina.com.cn/Resource/pdf/xwygg/2009ANNUALREPORT%28e%29.pdf) 24 “Form 20-F – PetroChina Company Limited,” U.S. Securities & Exchange

Commission, December 31, 2009, p. 89. (http://www.petrochina.com.cn/resource/EngPdf/annual/20-f_2009.pdf) 25 “Canada OKs Major PetroChina Oil Sands Investment,” AFP, December 29, 2009. (http://www.google.com/hostednews/afp/article/ALeqM5jJIhurt0GHA2Ij6fNCNjXWu7u2_g) 26 “China Replaces Saudi Arabia in Caribbean Oil Storage Deal,” UPI, Janu-ary 7, 2010. (http://www.upi.com/Science_News/Resource-Wars/2010/01/07/China-replaces-Saudi-Arabia-in-Caribbean-oil-storage-deal/UPI-16731262898000/) 27 “PetroChina to Team With Boeing to Develop Aviation Biofuels,” People’s

Daily Online, May 28, 2010. (http://english.peopledaily.com.cn/90001/90778/90860/7003812.html#)

According to USASpending.gov, CNPC has re-ceived no U.S. government contracts in the past 10 years.28

CNPC is listed by the Minnesota State Board of Investment as a restricted company,29 the Cali-fornia Public Employees’ Retirement System (CalPERS) as a newly identified company under review,30 and CNPC appears on the Illinois State Board of Investment’s list of scrutinized companies.31 PetroChina appears on the Flor-ida State Board of Administration as a scruti-nized company.32

28 USASpending.gov, accessed July 12, 2010. (http://www.usaspending.gov) 29 Minnesota State Board of Investment, Report on Iran Required by Laws of

Minnesota 2009, Chapter 90 (January 11, 2010), p. 3. (http://archive.leg.state.mn.us/docs/2010/mandated/100088.pdf) 30 California Public Employees’ Retirement System, Iran Related Invest-

ments – Second Legislative Report (February 21, 2010), p.13 (http://www.calpers.ca.gov/eip-ocs/investments/reports/iran-related-investments.pdf) 31 Illinois State Board of Investment, Public Act 95-616 (“Iran Act”): Annual

Report (January 1, 2010), p. 5. (http://www.isbi.illinois.gov/pdf/ISBI_Annual_Report_IRAN.pdf) 32 Florida State Board of Administration, Protecting Florida’s Investment

Acts (PFIA): Quarterly Report (July 29, 2010) p.11. (http://www.sbafla.com/fsb/LinkClick.aspx?fileticket=LSsNe4oN3SA%3d&tabid=402)

10


Daelim Industrial Corporation (South Korea)

South Korea’s Daelim Industrial Corporation has three offices in Iran supporting its opera-tions there.1

In May 2003, Iranian firm Petropars Ltd. awarded Daelim (along with Japan’s Toyo En-gineering Company and JGC Corporation, and the Industrial Development and Renovation Organization of Iran) a contract to build a gas processing plant in Iran’s Bandar Assaluyeh region. Under the $1.2 billion deal, the con-sortium will “provide design, procurement, construction and commissioning services for a natural gas processing plant with a throughput of 3,000 mmscfd [million stan-dard cubic feet per day] and offsite utilities.”2 The status of the project is unknown. Petropars was designated by the U.S. Treas-ury.3

In February 2007, Daelim signed a $300 mil-lion deal with the National Iranian Oil Com-pany (NIOC) to build three liquefied natural gas (LNG) and two liquefied petroleum gas (LPG) storage tanks in Tombak, southern Iran, to be completed by August 2010.4 Ghorb Nooh, a subsidiary of the Islamic Revolution-ary Guard Corps’ (IRGC) Khatam-al-Anbiya, is a partner with Daelim on the project.5 Ghorb Noor is designated by the U.S. Treasury.6

In March 2007, several international firms won a contract to upgrade Iran’s Esfahan oil refinery. The companies included Daelim, as well as Germany’s Uhde and Lurgi, and Ira-

1 “Overseas Network,” Daelim Website, accessed July 26, 2010. (http://eng.daelim.co.kr/daelim/overseas.jsp#9) 2 “Toyo Engineering and JGC Awarded Joint Contract for Gas-Plant in Iran,” Japan Corporate News Network, May 19, 2003. (http://www.japancorp.net/article.asp?Art_ID=5133#at) 3 U.S. Department of the Treasury, Office of Foreign Assets Control, “Recent OFAC Actions,” June 16, 2010. (http://www.treas.gov/offices/enforcement/ofac/actions/20100616.shtml) 4 “S. Korea Daelim Confirms Iran Gas Storage Deal,” Reuters, February 8, 2007. (http://uk.reuters.com/article/idUKSEO29837020070208) 5 “Total Criticised,” APS Review Gas Market Trends, April 20, 2009. (http://www.iranenergyproject.org/922/total-criticised) 6 U.S. Department of the Treasury, Press Release, “Fact Sheet: Designa-tion of Iranian Entities and Individuals for Proliferation Activities and Support for Terrorism,” October 25, 2007. (http://www.treas.gov/press/releases/hp644.htm)

nian companies Nargan, Namvaran, and Chage-lesh.7 NIOC, a company designated by the U.S. Treas-ury,8 signed a $111 million deal with Daelim to build an LNG plant in Iran in June 2009.9 Daelim is expected to complete the project by June 2011.10 Daelim won a contract to build onshore facilities to process gas from phase 12 of Iran’s South Pars field in October 2009. In the project, Daelim is part of a consortium with three Iranian compa-nies: Sazeh Consult, Kayson, and Iran Industrial Networks Development Company. The deal is reported to be worth around $2 billion.11 A spokesperson from Daelim confirmed that in 2009 it had received a $600 million deal to de-velop a phase of the South Pars gas field.12 In July 2010, Daelim announced that it would continue its contracts in Iran. A Daelim source commented, “according to our lawyers, our pro-jects are protected and cannot be punished by law since the contracts were signed much ear-lier.”13

In the United States, Daelim has offices in Hous-ton, Texas.14 According to USASpending.gov,

7 “Daelim, Others to Upgrade Iran’s Esfahan Refinery,” Chemical News &

Intelligence, March 19, 2007. (http://www.iranenergyproject.org/403/daelim-others-to-upgrade-iran-s-esfahan-refinery) 8 U.S. Department of the Treasury, Office of Foreign Assets Control, “Recent OFAC Actions,” June 16, 2010. (http://www.treas.gov/offices/enforcement/ofac/actions/20100616.shtml) 9 “Iran Awards Liquefied Gas Contract to Daelim; Contract Awards,” Middle

East Economic Digest, June 19, 2009. (http://www.iranenergyproject.org/923/iran-awards-liquefied-gas-contract-to-daelim) 10 “Daelim Industrial Wins 139 Bln Won Order from Iran,” Yonhap News

Agency (South Korea), June 11, 2009. (http://www.iranenergyproject.org/925/daelim-industrial-wins-139-bln-won-order-from-iran) 11 “Economic Performance: South Korean Firms Sign Gas Deals with Iran,” EIU Country Report Select, November 10, 2009. (http://www.iranenergyproject.org/459/economic-performance-south-korean-firms-sign-gas) 12 “Profiting From Iran, and the U.S.,” The New York Times, March 12, 2010. (http://www.nytimes.com/interactive/2010/03/06/world/iran-sanctions.html) 13 “Daelim Pushes On in Iran Despite Sanctions,” International Oil Daily, July 8, 2010. (http://www.iranenergyproject.org/1290/daelim-pushes-on-in-iran-despite-sanctions) 14 “Overseas Network,” Daelim Website, accessed August 3, 2010. (http://eng.daelim.co.kr/daelim/overseas.jsp#9)

11

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Daelim Industrial Corporation received $135,261,255 from the Department of De-fense between 2000 and 2010.15 The New

York Times reported that in 2009, the U.S. Army awarded Daelim Industrial Corporation a $111 million contract to build housing on a base in South Korea.16 Daelim Industrial Company is listed by the Minnesota State Board of Investment as a re-stricted company,17 the California Public Em-ployees’ Retirement System (CalPERS) as a company being monitored,18 and the Florida State Board of Administration as a company for continued examination,19 and it appears on the Illinois State Board of Investment’s list of scrutinized companies.20

15 “Daelim,” USASpending.gov, accessed July 26, 2010. (http://www.usaspending.gov) 16 “U.S. Enriches Companies Defying Its Policy on Iran,” The New York

Times, March 6, 2010. (http://www.nytimes.com/2010/03/07/world/middleeast/07sanctions.html?_r=2) 17 Minnesota State Board of Investment, Report on Iran Required by Laws

of Minnesota 2009, Chapter 90 (January 11, 2010), p. 3. (http://archive.leg.state.mn.us/docs/2010/mandated/100088.pdf) 18 California Public Employees’ Retirement System, Iran Related Invest-



Annual Report (January 1, 2010), p. 5. (http://www.isbi.illinois.gov/pdf/ISBI_Annual_Report_IRAN.pdf)

12


Elektrizitäts-Gesellschaft Laufenburg (EGL) (Switzerland)

In February 2008, Elektrizitäts-Gesellschaft Laufenburg (EGL) and the National Iranian Gas Export Company (NIGEC), a subsidiary of the National Iranian Oil Company (NIOC), which has been designated by the U.S. Treas-ury,1 signed a deal for Iran “to supply 5.5 bil-lion cubic metres of gas per year for up to 25 years” to Switzerland. The value of the deal is estimated at between €10 and €20 billion. It was reported that supply would begin as early as 2009.2 However, it appears that the gas deliveries will not begin until 2011. “The gas will come from Iran and through the new Trans Adriatic Pipeline (TAP) will flow to It-aly. In addition to the EGL, Norway's Statoil and the Germany company E.ON are partici-pating.”3 The energy deal could be worth up to €18 billion.4

An EGL spokesman noted in 2010 that “sanc-tions will not have an impact on the contract.” But added, “should the international state community impose continued sanctions against Iran, which would impact the contract with … [NIGEC], we would, of course, respect the sanctions.”5

EGL has not been awarded any U.S. federal government contracts in the past 10 years.6

1 U.S. Department of the Treasury, Office of Foreign Assets Control, “Recent OFAC Actions,” June 16, 2010. (http://www.treas.gov/offices/enforcement/ofac/actions/20100616.shtml) 2 Carl Mortished, “Swiss Brush Aside Criticism Over Gas Contract with Iran,” The Times, March 24, 2008. (http://business.timesonline.co.uk/tol/business/industry_sectors/utilities/article3607258.ece) 3 “Verschärfte Iran-Sanktionen setzen Schweiz unter Druck,” Schweize-

rische Depeschenagentur AG (Germany), July 5, 2010. (http://www.schweiz-uno.ch/index.php/de/news/210-verschaerfte-iran-sanktionen-setzen-schweiz-unter-druck) 4 Benjamin Weinthal, “Switzerland to Sign Huge Iran Gas Deal,” The

Jerusalem Post, March 16, 2008. (http://www.jpost.com/Home/Article.aspx?id=95185) 5 “Verschärfte Iran-Sanktionen setzen Schweiz unter Druck,” Schweize-

rische Depeschenagentur AG (Germany), July 5, 2010. (http://www.schweiz-uno.ch/index.php/de/news/210-verschaerfte-iran-sanktionen-setzen-schweiz-unter-druck) 6 “EGL,” USASpending.gov, accessed June 24, 2010. (http://www.usaspending.gov)

13


Gazprom (Russia)

In June 2008, the Armenian government an-nounced that Gazprom was planning to invest over “$200 million into the construction of the Iran-Armenia gas pipeline.”1

Gazprom Neft, a subsidiary of Gazprom, agreed to develop Iran’s North Azadegan oil field in September 2008.2 In March 2010, Gazprom Neft’s chief executive stated that the company was no longer in talks with Iran to develop the oil fields.3

In June 2008, Gazprom announced its interest to invest in a gas “Peace Pipeline” linking Iran, Pakistan and India. Construction for the pipe-line was set to begin in 2009, and was to be completed in 2014, but there has been no in-dication that the timeline will be met.4 The project is said to be worth over $7 billion.5

In June 2009, Gazprom expressed an interest in a proposed pipeline to transport oil from the Caspian Sea region to the Gulf of Oman. Iran invited bids from Gazprom.6

Gazprom signed a Memorandum of Under-standing with Iran’s Petroleum Engineering & Development Company to develop the Azar oil field in November 2009. While a final con-tract has yet to be signed between the two parties, Upstream Online quoted a NIOC offi-cial remarking in March 2010 that “the con-tract on the development of Azar oilfield will

1 “Gazprom to Invest USD 200 Million in Iran Armenia Gas Pipeline,”

SteelGuru, June 8, 2008. (http://www.steelguru.com/middle_east_news/Gazprom_to_invest_USD_200_million_in_Iran_Armenia_gas_pipeline/49499.html) 2 “Gazprom Neft Eager to Develop Oilfields in Iran,” RIA Novosti, Sep-tember 8, 2008. (http://www.tehrantimes.com/index_View.asp?code=177309) 3 “Russia's Lukoil Stops Iran Work on Sanctions,” Dow Jones, March 24, 2010. (http://business.maktoob.com/20090000451586/Russia_s_Lukoil_stops_Iran_work_on_sanctions/Article.htm) 4 “Gazprom Eyes Role in Iran-Pakistan Pipeline,” AFP, May 26, 2009. (http://www.google.com/hostednews/afp/article/ALeqM5i6-iLT_b3Nu1fKk-eeO0vtD1tgnQ) 5 “Iran Approves "Peace Pipeline" Deal with Pakistan,” Reuters, June 13, 2010. (http://www.reuters.com/article/idUSTRE65C0MI20100613) 6 “Iran Eyes Russia for Pipeline Investments,” UPI, June 24, 2009. (http://www.upi.com/Science_News/Resource-Wars/2009/06/24/Iran-eyes-Russia-for-pipeline-investments/UPI-61471245850440/)

be signed later this (Iranian) month with an Ira-nian-Russian consortium.”7

As of July 2010, Gazprom Neft was in talks with the Iran Commission of the Moscow Chamber of Commerce & Industry discussing whether the company will deliver gasoline to Iran. According to the head of the Commission, the first delivery may take place as early as late August.8

According to USASpending.gov, Gazprom has not received any U.S. government contracts.9 How-ever, Gazprom Marketing & Trading, a subsidiary of Gazprom, began natural gas marketing and trading operations throughout North America in the fourth quarter of 2009. The group maintains an office in Houston, Texas.10

Gazprom is listed by the Minnesota State Board of Investment as a restricted company,11 the California Public Employees’ Retirement System (CalPERS) as a company being monitored,12 the Florida State Board of Administration as a scru-tinized company,13 and on the Illinois State Board of Investment’s list of scrutinized compa-nies.14

7 “Iran Closes in on Gazprom Azar Pact,” Upstream Online, March 2, 2010. (http://www.upstreamonline.com/live/article207732.ece) 8 Lucian Kim and Stephen Bierman, “Iran May Get Gasoline From Russia State Companies Next Month, Chamber Says,” Bloomberg, July 29, 2010. (http://www.bloomberg.com/news/2010-07-29/iran-may-get-gasoline-from-russian-state-companies-dodging-u-s-sanctions.html) 9 “Gazprom,” USASpending.gov, accessed June 24, 2010. (http://www.usaspending.gov) 10 “GM&T USA,” Gazprom Marketing & Trading Website, accessed August 2, 2010. (http://www.gazprom-mt.com/ourbusiness/usa.asp) 11 Minnesota State Board of Investment, Report on Iran Required by Laws of

Minnesota 2009, Chapter 90 (January 11, 2010), p. 3. (http://archive.leg.state.mn.us/docs/2010/mandated/100088.pdf) 12 California Public Employees’ Retirement System, Iran Related Investments

– Second Legislative Report (February 22, 2010), p. 14. (http://www.calpers.ca.gov/eip-docs/investments/reports/iran-related-investments.pdf) 13 Florida State Board of Administration, Protecting Florida’s Investment Acts

(PFIA): Quarterly Report (July 29, 2010) p.11. (http://www.sbafla.com/fsb/LinkClick.aspx?fileticket=LSsNe4oN3SA%3d&tabid=402) 14 Illinois State Board of Investment, Public Act 95-616 (“Iran Act”): Annual

Report (January 1, 2010), p. 5. (http://www.isbi.illinois.gov/pdf/ISBI_Annual_Report_IRAN.pdf)

14


Haldor Topsoe (Denmark)

In 2002, Danish firm Haldor Topsoe signed an initial agreement with the Petrochemical Re-search & Technology Company (NPC-RT) of Iran. In June 2004, Haldor Topsoe announced that the collaboration resulted in a contract with Zagros Petrochemical Company to “li-cense technology, provide engineering and supply catalyst for a dimethyl ether (DME) plant. The plant which is to be constructed at Bandar Assaluyeh … is based on technology and catalyst developed by Haldor Topsoe A/S for dehydration of methanol and made avail-able in Iran by joint scientific and technical collaboration with NPC-RT.”1

In March 2007, a consortium of international companies won a contract to upgrade Iran’s Esfahan oil refinery. Haldor Topsoe, along with France’s Axens, British firm UOPL and Italy’s Technip, “will carry out basic engineer-ing for the licensed units.”2

In March 2009, Haldor Topsoe announced that it “signed contracts with the Iranian companies Marjan Petrochemical and Ki-miaye Pars for supply of technology for two methanol plants – both with involvement from National Petrochemical Company.”3 The National Petrochemical Company has been designated by the U.S. Treasury.4 Topsoe’s deal involves “the licensing of technology, en-gineering design, catalysts and technical sup-

1 Haldor Topsoe, Press Release, “Contract License and Basic Engineering of the First Large-scale Plant for Production of DME,” June 16, 2004. (http://www.topsoe.com/news/News/2004/2004-06-16%20Contract%20License%20and%20Basic%20Engineering.aspx) 2 “Daelim, Others to Upgrade Iran’s Esfahan Refinery,” Chemical

News & Intelligence, March 19, 2007. (http://www.iranenergyproject.org/403/daelim-others-to-upgrade-iran-s-esfahan-refinery) 3 Haldor Topsoe, Press Release, “Topsoe Signs Contract for Two Large Methanol Plants with Marjan Petrochemical and Kimiaye Pars,” March 13, 2009. (http://www.topsoe.com/News/News/2009/130309.aspx) 4 U.S. Department of the Treasury, Office of Foreign Assets Control, “Recent OFAC Actions,” June 16, 2010. (http://www.treas.gov/offices/enforcement/ofac/actions/20100616.shtml)

port services.”5 The plants are expected to come on line in 2013.

Haldor Topsoe has a subsidiary company, Haldor Topsoe Inc. based in Houston, Texas. There is no indication that the company has received any federal government contracts.

5 “Danish Firm to Set up Methanol Plants in Iran,” Middle East and

North Africa Financial Network, June 29, 2009. (Accessed via Nexis)

15


Inpex Corporation (Japan)

In 2006, Japanese firm, Inpex Corporation’s stake in Iran’s Azadegan oilfield was cut from 75 percent to 10 percent when development talks fell through due to delays in plans by Inpex.1 Much of the project was relinquished to Petroiran Development Company, a sub-sidiary of the National Iranian Oil Company (NIOC).2 Petroiran was designated by the U.S. Treasury.3 In July 2010, Inpex Corporation President Toshiaki Kitamura stated that the company will maintain its position in the Azadegan oil field.4 In the United States, Inpex has been active in upstream energy projects in the Gulf of Mex-ico since 2006. The company currently has three projects in the Gulf including the West Cameron Block, Main Pass Block 118 and Louisiana Block SL19372.5 Inpex is listed by the Minnesota State Board of Investment as a restricted company,6 the California Public Employees’ Retirement Sys-tem (CalPERS) as a company being moni-tored,7 the Florida State Board of Administra-tion as a scrutinized company,8 and as a com-

1 “FACTBOX: Iran’s Major Oil Customers, Energy Partners,” Reuters, August 18, 2009. (http://www.reuters.com/article/idUSTRE57H1UJ20090818) 2 “Azadegan From Discovery to Development: Review of Early Production from Iran’s Biggest Oil Field,” Shana (Iran), No-vember 12, 2007. (http://www.shana.ir/newsprint.aspx?lang=en&newsid=118720) 3 U.S. Department of the Treasury, Office of Foreign Assets Control, “Recent OFAC Actions,” June 16, 2010. (http://www.treas.gov/offices/enforcement/ofac/actions/20100616.shtml) 4 “Japan’s Inpex Not to Pull Out of Iran's Azadegan,” Mehr News

Agency (Iran), July 6, 2010. (http://www.payvand.com/news/10/jul/1053.html) 5 “Inpex Corporation Annual Report 2009,” Inpex Corporation

website, June 30, 2009, p. 45. (http://www.inpex.co.jp/english/ir/library/pdf/annual_report/e-annual2009.pdf) 6 Minnesota State Board of Investment, Report on Iran Required

by Laws of Minnesota 2009, Chapter 90 (January 11, 2010), p. 3. (http://archive.leg.state.mn.us/docs/2010/mandated/100088.pdf) 7 California Public Employees’ Retirement System, Iran Related

Investments – Second Legislative Report (February 22, 2010, p. 15. (http://www.calpers.ca.gov/eip-docs/investments/reports/iran-related-investments.pdf 8 Florida State Board of Administration, Protecting Florida’s

Investment Acts (PFIA): Quarterly Report (July 29, 2010) p.13.

pany on the Illinois State Board of Investment’s list of scrutinized companies.9

(http://www.sbafla.com/fsb/LinkClick.aspx?fileticket=LSsNe4oN3SA%3d&tabid=402) 9 Illinois State Board of Investment, Public Act 95-616 (“Iran Act”):


16


The Linde Group (Germany)

The Linde Group signed a contract with Iran’s National Petrochemical Company (NPC), a company designated by the U.S. Treasury,1 in 1996 to build equipment for Iran’s petro-chemical complex at Bandar Imam Khomeini. In 1998, Linde signed the final contracts with NPC to provide the design, engineering and equipment for the project.2 Linde received $333 million for the project in July 2000.3 Linde signed a deal in September 2000 with NPC to build a natural gas separation plant in Bandar Assaluyeh. The deal was reportedly worth €180 million. The plant will process gas from South Pars.4 In July 2005, Linde announced it would lead a consortium of firms (along with South Ko-rea’s Hyundai Engineering and Construction and Iran’s Sazeh) to build two ethylene plants for Iranian firm Bakhtar Petrochemical.5 The deal was cancelled by Bakhtar Petrochemical in April 2006. The reason was unclear.6 In 2008, Linde won a contract from NPC for engineering work on an olefins plant in As-saluyeh (expected 2014).7

1 U.S. Department of the Treasury, Office of Foreign Assets Control, “Recent OFAC Actions,” June 16, 2010. (http://www.treas.gov/offices/enforcement/ofac/actions/20100616.shtml) 2 Anne K. Rhodes, “Iran to Build World-Scale, Flexible-Feed Olefins Unit,” Oil and Gas Journal, August 16, 1999. (http://www.iranenergyproject.org/956/iran-to-build-world-scale-flexible-feed-olefins) 3 “IRAN - Bandar Imam Projects,” APS Review Downstream

Trends, April 9, 2001. (http://www.entrepreneur.com/tradejournals/article/72956505.html) 4 “Linde erhält Auftrag für Erdgasanlage im Iran,” Handelsblatt (Germany), September 6, 2000. (http://www.handelsblatt.com/archiv/linde-erhaelt-auftrag-fuer-erdgasanlage-im-iran;325195) 5 The Linde Group, Press Release, “Linde Obtains Major Order from Iran,” July 8, 2005. (http://www.linde.com/international/web/linde/like35lindecom.nsf/docbyalias/hugin_1001804) 6 “Iran Cancels Linde Olefins 11 Contract,” ICIS, April 24, 2006. (http://www.icis.com/Articles/2006/04/24/1058132/iran-cancels-linde-olefins-11-contract.html) 7 Natasha Alperowicz, “Linde Lands to Work on Iran's Olefins 12 Complex,” Chemical Week, June 30, 2008. (http://www.iranenergyproject.org/955/linde-lands-to-work-on-irans-olefins-12-complex)

During its annual meeting in 2009, the company “confirmed that Linde is involved in Iran’s na-tional gas liquefaction project (LNG) with the state owned National Iranian Oil Company,”8 a company designated by the U.S. Treasury.9 Iran LNG still lists Linde as a process licensor on its website.10 Linde AG received over $174 million in federal contracts from 2000 to 2010.11 Linde has offices across the U.S. A spokesman stated that Linde is not accepting new Iranian orders, but will fulfill current con-tractual obligations. According to a statement, its business in Iran totals €36 million a year, or 0.3 percent of total sales.12

8 “German Government Supports Business in Iran,” Hudson New

York, May 20, 2009. (http://www.hudsonny.org/2009/05/german-government-supports-business-in-iran.php) 9 U.S. Department of the Treasury, Office of Foreign Assets Control, “Recent OFAC Actions,” June 16, 2010. (http://www.treas.gov/offices/enforcement/ofac/actions/20100616.shtml) 10 Iran LNG Website, accessed June 28, 2010. (http://www.iranlng.ir/home-partiesinvolved-processlicensors-en.html) 11 “Linde AG,” USASpending.gov, accessed August 3, 2010. (http://www.usaspending.gov) 12 “Profiting From Iran, and the U.S.,” The New York Times, March 12, 2010. (http://www.nytimes.com/interactive/2010/03/06/world/iran-sanctions.html)

17


LyondellBasell (Netherlands)

Dutch firm LyondellBasell supplies technol-ogy for a high-density polyethylene (HDPE) petrochemical plant in Kermanshah, Iran, which was expected to go online in 2009 or 2010 and increase Iran’s annual production by 300,000 metric tons.1

LyondellBasell is also supplying technology for a low-density polyethylene (LDPE) plant in Sanandaj. The project was scheduled to start in 2008.2 The Kurdistan Petrochemical Company, an affiliate of Iran’s National Petro-chemical Company (NPC) which was desig-nated by the U.S. Treasury,3 awarded Basell the contract in August 2005, before Basell merged with Lyondell. This deal marked the 13th license Basell granted for use of its tech-nology for projects in Iran.4

Mehr Petro Kimia, a subsidiary of Parsian In-vestment Company, announced in November 2008 that it planned to build a propane dehy-drogenation (PDH) facility and a polypropyl-ene (PP) plant that will use LyondellBasell’s process technology in the Pars Special Eco-nomic Zone.5

In June 2009, LyondellBasell reportedly signed a contract with NPC to supply technol-ogy to produce HDPE at the Dehdasht, Mama-sani and Boroujen petrochemical complexes.6

1 Joseph A. Christoff, “Firms Reported in Open Sources as Having Com-mercial Activity in Iran’s Oil, Gas, and Petrochemical Sectors,” U.S. Government Accountability Office, March 23, 2010, p. 15. (http://www.gao.gov/new.items/d10515r.pdf) 2 Ibid. 3 U.S. Department of the Treasury, Office of Foreign Assets Control, “Recent OFAC Actions,” June 16, 2010. (http://www.treas.gov/offices/enforcement/ofac/actions/20100616.shtml) 4 “Kurdestan Petrochemical Selects Basell’s Lupotech T Tech-nology for a New LDPE Plant in Iran,” Chemie, August 5, 2005. (http://www.chemie.de/news/e/48110/) 5 “Iran’s Mehr Petro Kimia Plans PDH, PP Plants,” Chemical

News and Intelligence, November 25, 2008. (http://www.iranenergyproject.org/510/irans-mehr-petro-kimia-plans-pdh-pp-plants) 6 “World Praises Iran’s Petrochemical Achievements: Lyon-dellBasell Exec,” Tehran Times, June 10, 2009. (http://www.tehrantimes.com/index_View.asp?code=196379)

LyondellBasell has both manufacturing and technology centers in the United States.7 How-ever, according to USASpending.gov, the com-pany has not received any grants or contracts from the U.S. government in the last 10 years.8

In its 2009 Annual Report, LyondellBasell states that its “non-U.S. subsidiaries conduct business in countries subject to U.S. economic sanctions, including Iran.…These business activities pre-sent a potential risk that could subject Lyondell-Basell to penalties. LyondellBasell is continuing to review its compliance risks in this area.”9

7 “North America,” LyondellBasell Website, accessed June 29, 2010. (http://www.lyondellbasell.com/WorldWideLocations/NorthAmerica/) 8 “LyondellBasell,” USASpending.gov, accessed June 29, 2010. (http://www.usaspending.gov) 9 LyondellBasell, “LyondellBasell Industries AF S.C.A. 2009 Annual Report,” 2009, p. I-11. (http://www.lyondellbasell.com/InvestorRelations/FinancialInformation/AnnualReports/)

18


Oil & Natural Gas Corporation (ONGC) (India)

In 2002, Iran awarded development rights to the Farsi offshore oil block to a consortium of Indian companies, including ONGC, Indian Oil Corporation and Oil India.1 ONGC manages its international activities through its interna-tional investment arm, ONGC Videsh, also known as OVL.

In July 2009, the consortium agreed to invest in the development of the Farzad B gas field in the Farsi block of the Persian Gulf.2 Two months later, the consortium announced it was dropping its plans to extract crude oil from the field due to its high sulfur content, opting instead to produce gas.3 The consor-tium submitted a development plan for the gas field in 2009, proposing an investment of $5 billion over a period of seven to eight years.4

In another deal, ONGC signed an agreement in December 2009 to develop phase 12 of Iran’s South Pars gas field with Hinduja Group and Petronet LNG. In the agreement, ONGC took a 40 percent stake in the $7.5 billion project.5

In tandem with its agreement to develop phase 12 of South Pars, ONGC also agreed to take a 20 percent stake in the Iran LNG gas liquefaction plant, alongside Hinduja Group

1 “India’s Oil Cos Propose $5B Investment in Iranian Gas Block,” Rigzone, June 25, 2009. (http://www.rigzone.com/news/article.asp?a_id=77633) 2 “Iran, India to Continue Talks on Farzad Gas Field,” Tehran

Times, July 26, 2009. (http://www.tehrantimes.com/index_View.asp?code=199550) 3 “OVL Drops Plan to Produce Oil from Farsi Block in Iran,” The

Economic Times (India), September 16, 2009. (http://economictimes.indiatimes.com/news/news-by-industry/energy/oil-gas/OVL-drops-plan-to-produce-oil-from-Farsi-block-in-Iran/articleshow/5016181.cms) 4 “OVL, Partners Drop Plans to Develop Oil Field in Iran,” PTI, September 15, 2009. http://www.livemint.com/2009/09/15120028/OVL-partners-drop-plans-to-de.html) 5 “ONGC Picks Up Stake in Iran Gas Field, LNG Plant,” The Hindu (India), December 2, 2009. (http://www.in.com/news/business/fullstory-ongc-picks-up-stake-in-iran-gas-field-lng-plant-11883673-125916-1.html)

and Petronet.6 The plant is valued at $4.35 bil-lion.7

ONGC has not received any U.S. government con-tracts or grants in the past 10 years.8 Addition-ally, the company does not appear to have any business interests in the United States. ONGC is listed by the Minnesota State Board of Investment as a restricted company,9 the Florida State Board of Administration as a scrutinized company,10 and it appears on the Illinois State Board of Investment’s list of scrutinized compa-nies.11

6 “ONGC to Develop Gas Fields in Iran,” The Economic Times (India), December 2, 2009. (http://economictimes.indiatimes.com/ONGC-to-develop-gas-fields-in-Iran/articleshow/5293442.cms) 7 Joseph A. Christoff, “Firms Reported in Open Sources as Having Commercial Activity in Iran’s Oil, Gas, and Petrochemical Sectors,” U.S. Government Accountability Office, March 23, 2010, p. 15. (http://www.gao.gov/new.items/d10515r.pdf) 8 USASpending.gov, accessed June 30, 2010. (http://www.usaspendinggov) 9 Minnesota State Board of Investment, Report on Iran Required by Laws of Minnesota 2009, Chapter 90 (January 11, 2010), p. 3. http://archive.leg.state.mn.us/docs/2010/mandated/100088.pdf 10 Florida State Board of Administration, Protecting Florida’s In-

vestment Acts (PFIA): Quarterly Report (July 29, 2010) p.13. (http://www.sbafla.com/fsb/LinkClick.aspx?fileticket=LSsNe4oN3SA%3d&tabid=402) 11 Illinois State Board of Investment, Public Act 95-616 (“Iran Act”):


19

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Petróleos de Venezuela, S.A. (PDVSA) (Venezuela)

Iranian firm Petropars signed a deal with Venezuelan state-owned PDVSA in 2005 for studies of the Ayacucho block 7 in the Ori-noco oil belt, off the coast of Venezuela.1 In 2006, PDVSA and Petropars began drilling there.2 In 2007, Iran and Venezuela agreed to invest another $4 billion in the Ayacucho pro-ject. According to Venezuela’s energy and pe-troleum minister, “there are some 31 billion barrels of original oil in place.”3 Oil produc-tion is expected in 2012.4 Petropars is an en-tity designated by the U.S. Treasury.5

Petropars is helping PDVSA subsidiary, Cor-poracion Venezolana del Petroleo (CVP), to develop Venezuela’s North of Paria offshore project by providing management and techni-cal services. Petropars inked an agreement with CVP for quantification activities at the Ayacucho blocks 1 and 2, which began in Au-gust 2006. The project was completed in early 2007.6

In December 2006, CVP created a joint ven-ture with Iranian Sadra Company subsidiary Sadra America Latina C.A. called Venezirian Oil Company. The company will conduct off-shore hydrocarbon exploration and produc-

1 “International Affairs & Business Development,” Petropars

Website, accessed July 13, 2010. (http://www.petropars.com/tabid/65/Default.aspx) 2 “PDVSA, Iran's Petropars Begin Ayacucho 7 Block Drilling,” Business News Americas, September 21, 2006. (http://petropars.com/tabid/253/Default.aspx) 3 PDVSA, Press Release, “Iran, Venezuela to invest USD 4 billion in Orinoco Oil Belt,” July 10, 2007. (http://www.pdv.com/index.php?tpl=interface.en/design/readsearch.tpl.html&newsid_obj_id=4175&newsid_temas=0) 4 “Venezuela - New Orinoco JVs.,” APS Review Oil Market Trends, November 16, 2009. (http://www.allbusiness.com/mining-extraction/oil-gas-exploration-extraction-oil-oil/13424713-1.html) 5 U.S. Department of the Treasury, Office of Foreign Assets Control, “Recent OFAC Actions,” June 16, 2010. (http://www.treas.gov/offices/enforcement/ofac/actions/20100616.shtml) 6 “International Affairs & Business Development,” Petropars

Website, accessed July 13, 2010. (http://www.petropars.com/tabid/65/Default.aspx)

tion projects in Venezuela with technology and equipment made in Iran.7

In 2007, Iran and Venezuela formed a joint com-pany “for the purpose of developing, exploring, processing and producing oil, and a Service Agreement for the quantification of reserves in Blocks Ayacucho 3, 4 and 5 of the Orinoco Oil Belt.”8

Iran’s oil ministry announced in 2008 that the National Iranian Oil Company (NIOC) and PDVSA would form a joint venture company to buy and/or charter oil tankers with an investment of $400 million.9 NIOC has been designated by the U.S. Treasury.10

In 2009, Caracas and Tehran signed a Memoran-dum of Understanding (MOU) to develop 17 oil fields in the South Pars region.11 PDVSA report-edly invested $760 million in South Pars phase 12,12 and retains a 10 percent stake in the pro-ject.13 In 2009, Iran and Venezuela signed an-other MOU, leading to a joint venture, the Vene-zuela Iran Oil and Gas Company (VENIROGC), by PDVSA and Iran’s Petropars. VENIROGC’s first

7 PDVSA, Press Release, “PDVSA and Iranian Consortium Incorpo-rate Mixed Company of Offshore Services and Construction,” De-cember 21, 2006. (http://www.pdv.com/index.php?tpl=interface.en/design/readsearch.tpl.html&newsid_obj_id=3391&newsid_temas=0) 8 PDVSA, Press Release, “Venezuela and Iran Sign 11 Cooperation and Complementary Agreements,” January 13, 2007. (http://www.pdv.com/index.php?tpl=interface.en/design/readsearch.tpl.html&newsid_obj_id=3496&newsid_temas=0) 9 “Venezuela - New Orinoco JVs.,” APS Review Oil Market Trends, November 16, 2009. (http://www.allbusiness.com/mining-extraction/oil-gas-exploration-extraction-oil-oil/13424713-1.html) 10 U.S. Department of the Treasury, Office of Foreign Assets Control, “Recent OFAC Actions,” June 16, 2010. (http://www.treas.gov/offices/enforcement/ofac/actions/20100616.shtml) 11 Geoff King and Kate Dourian, “Iran Sign Oil Field Development MOU,” Platts Oilgram News, April 7, 2009. (http://www.iranenergyproject.org/401/iran-sign-oil-field-development-mou) 12 “Venezuela: Iran, Venezuela Swap $760 mln Energy Invest-ments,” Tenders Info, September 7, 2009. (http://www.iranenergyproject.org/402/venezuela-iran-venezuela-swap-760-mln-energy) 13 Joseph A. Christoff, “Firms Reported in Open Sources as Having Commercial Activity in Iran’s Oil, Gas, and Petrochemical Sectors,” U.S. Government Accountability Office, March 23, 2010, p. 16. (http://www.gao.gov/new.items/d10515r.pdf)

20

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project was a Syrian oil refinery, with possi-ble future projects in China and Africa.14

During a visit to Iran in 2009, President Hugo Chavez signed a deal enabling Petropars to operate in the Dubokubi block of Venezuela’s Orinoco gas belt in a joint venture with PDVSA. In a separate deal, Venezuela agreed to supply Iran with 20,000 barrels a day of gasoline in anticipation of U.S. sanctions.15 PDVSA has a wholly-owned subsidiary in the U.S. called PDV America, Inc. PDV owns Texas-based oil giant CITGO.16 PDVSA initially bought 50 percent of CITGO in 1986 and the other half in 1990.17 CITGO, according to its website, has gasoline refineries in Louisiana, Texas, and Illinois that yearly yield “117 million barrels of gasoline, 61 million barrels of distillates and 25 million barrels of jet fuel.”18 In September 2008, CITGO confirmed an order from the U.S. Stra-tegic Oil Reserve for the Lake Charles refinery for one million barrels of crude oil “to miti-gate the potential deficit of fuel in the U.S. market.”19 Venezuela’s embassy signed a deal with Maine enabling CITGO to supply heating oil to Native American groups in 2006.20 CITGO also provided inexpensive heating oil to low-

14 “Energy Cooperation Drives a Murky Venezuela-Iran Rela-tionship,” OilPrice.com, June 6, 2010. (http://oilprice.com/Geo-Politics/International/Energy-Cooperation-Drives-a-Murky-Venezuela-Iran-Relationship.html) 15 “Venezuela - New Orinoco JVs.,” APS Review Oil Market

Trends, November 16, 2009. (http://www.allbusiness.com/mining-extraction/oil-gas-exploration-extraction-oil-oil/13424713-1.html) 16 “About Citgo,” CITGO Website, accessed July 20, 2010. (http://www.citgo.com/AboutCITGO.jsp) 17 “Company History,” CITGO Website, accessed July 20, 2010. (http://www.citgo.com/AboutCITGO/CompanyHistory.jsp) 18 “Refining,” CITGO Website, accessed July 20, 2010. (http://www.citgo.com/AboutCITGO/Operations/Refining.jsp) 19 PDVSA, Press Release, “CITGO Vows Reliable Supply to the United States,” September 15, 2008. (http://www.pdvsa.com/index.php?tpl=interface.en/design/readsearch.tpl.html&newsid_obj_id=6663&newsid_temas=0) 20 PDVSA, Press Release, “CITGO Will Supply Heating Oil to Indigenous Groups in the United States,” January 6, 2006. (http://www.pdvsa.com/index.php?tpl=interface.en/design/readsearch.tpl.html&newsid_obj_id=2198&newsid_temas=0)

income houses in New York and Boston in 2005. The deals were criticized by U.S. lawmakers as an attempt by Venezuela to embarrass the U.S.21 According to USASpending.gov, PDVSA has not received any federal contracts. However, through CITGO, Venezuela received $217,295,898 in federal contracts since 2002.22

21 “New York Gets Venezuela Cheap Oil,” BBC News, December 7, 2005. (http://news.bbc.co.uk/2/hi/americas/4505936.stm) 22 “Citgo,” USASpending.gov, accessed August 3, 2010. (http://www.usaspending.gov)

21


Sasol Limited (South Africa)

African Amines, a firm jointly owned by Sasol and Air Products South Africa, agreed to a plea bargain in South Africa’s Durban Re-gional Court in November 2004 for illegally exporting 120 tons of the chemical dimethyl-amine to Iran in March 2003 without a per-mit. Dimethylamine is used as an agricultural herbicide, but can also be used in chemical weapons production. African Amines deliv-ered the chemicals to Iranian firm Sasadja Moavenate Bazargani, which is listed as a WMD end-user by Germany and Japan.1

Sasol entered into a joint venture forming the Arya Sasol Polymer Company with Iran’s Pars Petrochemical Company in 2003. Arya Sasol built and operated an ethylene complex that became fully operational in 2009.2 Sasol sub-sidiary, Sasol Polymers Germany GmbH was responsible for the $900 million joint ven-ture.3 The facilities are located in Assaluyeh.4

Sasol paused plans for a gas-to-liquids (GTL) plant in Iran in 2006 over concerns about American sanctions. Sasol and Iran’s National Petrochemical Company, a company desig-nated by the U.S. Treasury, had been in talks for over two years to build the plant that would use gas from South Pars.5

Sasol is also a majority stakeholder in South Africa’s Natref refinery which purchased 12,000 barrels per day (bpd) of crude oil from Naftiran Intertrade Company for feed-

1 Wisani Wa Ka Ngobeni, “How Sasol Firm Sold WMD Chemicals to Iran,” Mail and Guardian (South Africa), February 18, 2005. (http://www.mg.co.za/article/2005-02-18-how-sasol-firm-sold-wmd-chemicals-to-iran) 2 “Form 20-F – Sasol Limited,” U.S. Securities and Exchange Commis-

sion, October 9, 2009, p. 32. (http://www.sasol.com/sasol_internet/downloads/Sasol_Form20F_2009_1255111757839.PDF) 3 Investor Insight, Sasol, December 2004, p. 11. (http://www.sasol.com/sasol_internet/downloads/Investor%20Insight%20Dec%2004_1103557890079.pdf) 4 “Arya Sasol Polymer Company, Olefins Ethylene Complex, Iran,” Chemicals-Technology.com, accessed July 19, 2010. (http://www.chemicals-technology.com/projects/arya-sasol/) 5 “Sasol Halts Iran GTL,” International Petroleum Finance, April 10, 2006. (http://www.iranenergyproject.org/1119/sasol-halts-iran-gtl) and U.S. Department of the Treasury, Office of Foreign Assets Control, “Recent OFAC Actions,” June 16, 2010. (http://www.treas.gov/offices/enforcement/ofac/actions/20100616.shtml)

stock.6 Naftiran was designated by the U.S. Treasury.7 Sasol also supplies products to Iran through its subsidiaries Sasol Middle East and Sasol Gulf.8

Sasol has North American sales and distribution network for its solvent products.9 It was first listed on the New York Stock Exchange in 2003.10

Sasol has a U.S.-based subsidiary, Sasol North America that employs roughly 700 people with several manufacturing facilities across the coun-try.11 In 2008, Sasol Ltd. received $1,531,500 in contracts from the Department of Defense.12

Sasol is listed by the Minnesota State Board of Investment as a restricted company,13 the Cali-fornia Public Employees’ Retirement System (CalPERS) as a company being monitored,14 and the Florida State Board of Administration as a company for continued examination,15 and it ap-pears on the Illinois State Board of Investment’s list of scrutinized companies.16

6 “Form 20-F – Sasol Limited,” U.S. Securities and Exchange Commission, October 9, 2009, p. 51. (http://www.sasol.com/sasol_internet/downloads/Sasol_Form20F_2009_1255111757839.PDF) 7 U.S. Department of the Treasury, Office of Foreign Assets Control, “Recent OFAC Actions,” June 16, 2010. (http://www.treas.gov/offices/enforcement/ofac/actions/20100616.shtml) 8 “Explore Sasol,” Sasol Website, August 13, 2009. (http://www.sasol.com/sasol_internet/frontend/navigation.jsp?pnav=coun-try%20profile&countryId=3400027&navid=2&cnav=dubai&rootid=2) 9 “Chemicals Storefront,” Sasol Website, July 27, 2009. (http://www.sasol.com/sasol_internet/frontend/navigation.jsp?navid=700051&rootid=600001) 10 Sasol Limited, Press Release, “Sasol Celebrates 5 Years on NYSE,” April 9, 2008. (http://www.sasol.com/sasol_internet/frontend/navigation.jsp;jsessionid=VOPIPNTXXUKPRG5N4EZSFEQ?articleTypeID=2&articleId=21200008&navid=4&rootid=4) 11 “History & Future,” Sasol North America Website, accessed July 19, 2010. (http://www.sasolnorthamerica.com/history_future.asp) 12 “Sasol Ltd.,” USASpending.gov, accessed July 19, 2010. (http://www.usaspending.gov) 13 Minnesota State Board of Investment, Report on Iran Required by Laws of Minnesota 2009, Chapter 90 (January 11, 2010), p. 3. (http://archive.leg.state.mn.us/docs/2010/mandated/100088.pdf) 14 California Public Employees’ Retirement System, Iran Related Invest-




22


Sinopec (China)

Unipec sold gasoline to Iran between 2001 and 2004, but reportedly ceased sales until 2010.1 However, in April 2010, traders stated that China’s Sinopec’s trading arm, Unipec, “booked a vessel to load 250,000 barrels in Singapore… with options to discharge in the Gulf. The cargo was likely to go to Iran.”2 In June 2010, industry sources reported that Unipec purchased gasoline from independent traders in the United Arab Emirates for sale to Iran.3 In June, Sinopec delivered around 600,000 barrels to Iran.4

In 2006, Sinopec signed a €108 million con-tract to partner with the National Iranian Oil Refining & Distribution Company (NIORDC) and other Iran-based companies to increase gasoline production at the Tabriz refinery.5 The project is set for completion in 2010.6

In June 2006, Sinopec “signed an agreement with Iran’s Oil Exploration and Service Com-pany (OESC) to jointly develop the Garmsar oil block.”7

Sinopec reportedly signed a contract with Iran in 2007 to drill in Iran’s Yadavaran oil

1 “Sinopec Ships 600,000 Barrels of Gasoline to Iran,” Reuters, May 25, 2010. (http://english.alrroya.com/content/sinopec-ships-600000-barrels-gasoline-iran) 2 Luke Pachymuthu and Seng Li Peng, “Exclusive: China's Top Oil Firms Sell Gasoline to Iran-Trade,” Reuters, April 14, 2010. (http://www.iranenergyproject.org/373/exclusive-chinas-top-oil-firms-sell-gasoline-to) 3 Luke Pachymuthu and Chen Aizhu, “China's Sinopec ships gasoline from UAE to Iran,” Reuters, June 1, 2010. (http://www1.hymarkets.com/html/news/2010/6/1/1275387396nLDE64T029.html) 4 “Sinopec Ships 600,000 Barrels of Gasoline to Iran,” Reuters, May 25, 2010. (http://english.alrroya.com/content/sinopec-ships-600000-barrels-gasoline-iran) 5 “Overseas Projects,” Sinopec Engineering Website, 2009. (http://www.sinopecengineering.com/ABOUT_US/MAIN_ACHIVEMENT.asp) 6 “Refinery Expansion Projects,” National Iranian Oil Refining &

Distribution Company Website, 2009. (http://www.niordc.ir/index.aspx?siteid=77&siteid=77&pageid=979#BandarAbbasRefinery) 7 “China's Sinopec Signs a Deal to Develop Oil Block in Iran – Report,” AFX News Limited, June 20, 2006. (http://www.forbes.com/feeds/afx/2006/06/20/afx2829188.html)

field, which has about 17 billion bbl in estimated reserves.8

Sinopec inked a $3.2 million contract with NIORDC in 2008 to increase gasoline production at the Arak refinery.9 According to the U.S. Gov-ernment Accountability Office (GAO), the project will be completed in 2011.10

Sinopec also agreed to purchase 160,000 barrels per day from Iran in 2008, nearly tripling its in-take of Iranian oil.11 According to the GAO, the contract is valued at $2 billion.12

The National Iranian Oil Products Distribution Co. (NIOPDC) and Sinopec signed an agreement in August 2009 to work on two Iranian oil pro-jects, including the Iran Abadan Oil Refinery.13

Sinopec did not receive any contracts from the U.S. federal government between 2000 and 2010.14 However one of Sinopec’s subsidiary firms, Sinopec Shanghai Petrochemical Company Limited has been listed on the New York Stock Exchange since July of 1993.15 Additionally, in 2002 the U.S. Trade and Development Agency gave Sinopec a $429,000 grant “to help an im-

8 Vivienne Walt, “How Iran Might Beat Future Sanctions: The China Card,” Time, July 16, 2009. (http://www.time.com/time/world/article/0,8599,1910669,00.html) 9 “Refinery Expansion Projects,” National Iranian Oil Refining &

Distribution Company Website, 2009. (http://www.niordc.ir/index.aspx?siteid=77&siteid=77&pageid=979#BandarAbbasRefinery) 10 Joseph A. Christoff, “Firms Reported in Open Sources as Having Commercial Activity in Iran’s Oil, Gas, and Petrochemical Sectors,” U.S. Government Accountability Office, March 23, 2010, p. 17. (http://www.gao.gov/new.items/d10515r.pdf) 11 Chen Aizhu, “UPDATE 2-Sinopec Agrees Deal to Triple Iran Crude Imports,” Reuters, December 13, 2007. (http://www.reuters.com/article/idUSPEK10194020071213?sp=true) 12 Joseph A. Christoff, “Firms Reported in Open Sources as Having Commercial Activity in Iran’s Oil, Gas, and Petrochemical Sectors,” U.S. Government Accountability Office, March 23, 2010, p. 17. (http://www.gao.gov/new.items/d10515r.pdf) 13 “Sinopec Said to Join Iran Oil Refinery Expansion Project,” Sino-

Cast Daily Business Beat, August 5, 2009. (http://www.tradingmarkets.com/.site/news/Stock%20News/2461237/) 14 “Sinopec,” USASpending.gov, accessed July 12, 2010. (http://www.usaspending.gov) 15 “Sinopec Shanghai Petrochemical Company Limited” New York

Stock Exchange website, accessed July 12, 2010. (http://www.nyse.com/about/listed/shi.html)

23


port-export subsidiary to develop an elec-tronic procurement system.”16 In March 2007, the Fujian Petrochemical Company, a subsidiary of Sinopec, inaugu-rated a joint venture with Exxon Mobil and Saudi Aramco creating the Fujian Refining & Ethylene Joint Venture Project and the Fujian Fuels Marketing Joint Venture in China.17 In July 2009, Marathon Oil announced an agreement with Sinopec and the China Na-tional Offshore Oil Company (CNOOC) through its subsidiary, Marathon Interna-tional Petroleum Angola Block 32 Limited to explore and develop the offshore block in An-gola.18 In March 2010, the Chinese press announced that Sinopec was considering cooperating with ExxonMobil and Saudi Aramco to build an oil refinery in Fujian. The refinery would be able to process 12 million tons of crude oil per year. The three companies are currently conducting a feasibility study on the project.19 Sinopec is listed by the California Public Em-ployees’ Retirement System (CalPERS) as a company being monitored,20 and the Florida

16 Matthew Godsey and Gary Milhollin, “A Shell Game in the Arms Race,” The New York Times, February 25, 2005. (http://query.nytimes.com/gst/fullpage.html?res=9B03E3D8173DF936A15751C0A9639C8B63&sec=&spon=&pagewanted=all) 17 “Inauguration Ceremony in Beijing Marks the Formation of the Ventures,” Exxon Mobil Chemical Website, March 30, 2007. (http://www.exxonmobilchemical.com.cn/China-Eng-lish/LCW/PA/Newsroom/Fujian_Project_Inauguration_Ceremony.asp) 18 Marathon Oil, Press Release, “Marathon Announces $1.3 Billion Sale of 20 Percent Interest in Angola Block 32,” July 17, 2009. (http://www.marathon.com/News/Press_Releases/Press_Release/?id=1308708) 19 “Analysts Upbeat on Cooperation with ExxonMobil, Saudi Aramco,” People’s Daily Online, March 9, 2010. (http://english.peopledaily.com.cn/90001/90778/90861/6913314.html) 20 California Public Employees’ Retirement System, Iran Re-

lated Investments – Second Legislative Report (February 22, 2010), p. 18. (http://www.calpers.ca.gov/eip-docs/investments/reports/iran-related-investments.pdf)

State Board of Administration as a scrutinized company.21

21 Florida State Board of Administration, Protecting Florida’s In-

vestment Acts (PFIA): Quarterly Report (July 29, 2010) p.13. (http://www.sbafla.com/fsb/LinkClick.aspx?fileticket=LSsNe4oN3SA%3d&tabid=402)

24


SKS Ventures (Malaysia)

The Iran Power Development Company (IPDC) and SKS Ventures signed a Memoran-dum of Understanding in January 2007 to construct a combined cycle power plant in Zanjan, Iran.1 SKS was still involved in this project as of September 2009.2 In March 2007, SKS Development, a company owned by SKS Ventures, offered the National Iranian Oil Company (NIOC), a company des-ignated by the U.S. Treasury,3 a minority stake in its Kedah refinery in Malaysia, a pro-ject worth $2.2 billion. The source claimed that the refinery would process 200,000 bpd of Iranian crude oil.4 In 2008, Iran and Malay-sia signed agreements “pertaining to exports of 250,000-bpd of heavy and ultra-heavy crude oil” to the Kedah Refinery. The deal also included the export from Iran to Malay-sia of 120,000 bpd of gas condensates.5 In August 2009, Iran and Malaysia signed “two memorandums of understanding for the construction of Pars gas condensates refining in Iran's Shiraz Refinery and Kedah Refinery in northern Malaysia,” according to a director at the National Iranian Engineering Oil Con-struction Company (NIEOC). The total in-vestment was reported to be as much as $7 billion and would create a new joint company called SKS-PARS.6 The deal was signed be-

1 “Iran and Malaysia Sign MoU to Set up Power Plant in North-Western Iran,” Tehran Times, January 15, 2007. (http://www.gasandoil.com/goc/company/cnm70762.htm) 2 Yeow Pooi Ling, “Syed Mokhtar in Kuwait Telco Foray,” The

Star Online (Malaysia), September 10, 2009. (http://biz.thestar.com.my/news/story.asp?file=/2009/9/10/business/4681823&sec=business) 3 U.S. Department of the Treasury, Office of Foreign Assets Control, “Recent OFAC Actions,” June 16, 2010. (http://www.treas.gov/offices/enforcement/ofac/actions/20100616.shtml) 4 “New Malaysian Refinery Invites Iran to Take Stake,” PressTV

(Iran), March 23, 2007. (http://www.gasandoil.com/goc/company/cnm71533.htm) 5 “Iran and Malaysia Sign $14 Billion of Oil and Gas Cooperation Agreements,” Industrial Info Resources, December 15, 2008. (http://www.pump-zone.com/global-news/global-news/iran-and-malaysia-sign-14-billion-of-oil-and-gas-cooperation-agreements.html) 6 “Iran, Malaysia Team Up on Energy,” UPI, August 17, 2009. (http://www.upi.com/Science_News/Resource-

tween NIEOC and SKS Development. The new company was slated to fund 30 percent of the project while loans were secured for the remain-ing 70 percent.7 SKS subsidiary, Petrofield, entered into a pre-liminary agreement with NIOC in December 2007 for $6 billion to develop the Golshan and Ferdowsi gas fields and set up a plant to produce liquefied natural gas (LNG). Iranian Oil Minister Gholamhossein Nozari stated that completion is slated for 2014.8 The deal was signed by Pet-rofield’s subsidiary SKS Oil and Gas International (SKOSG) and it was approved by NIOC's Board of Directors on January 1, 2008. The contract will end when SKOSG fully recovers the development costs it invested plus remuneration fees.9 The contract is expected to take over 5 years.10 At the time of the deal, Tom Lantos, then chair-man of the House Foreign Affairs Committee, requested that the free trade talks between the U.S. and Malaysia be suspended until Malaysia canceled the deal. Rafidah Aziz, Malaysia's trade minister, told the U.S. to stop meddling in Malay-sia's internal affairs and threatened to cancel the free trade agreement (FTA) talks.11 In December 2008, NIOC and Petrofield signed an agreement building upon the one signed in 2007. In this agreement, SKS would develop the Golshan and Ferdowsi gas fields on a buy-back contract and Petrofield would build a LNG facil-ity in Deir, Iran. According to the agreement,

Wars/2009/08/17/Iran-Malaysia-team-up-on-energy/UPI-38801250525875/) 7 “Iran, Malaysia to Push Ahead with $7b Joint Venture,” Tehran

Times, August 16, 2009. (http://www.tehrantimes.com/index_View.asp?code=201037) 8 Vidya Ram, “Iran Deal Is A Gas for Malaysia's SKS,” Forbes, De-cember 26, 2007. (http://www.forbes.com/2007/12/26/iran-malaysia-oil-markets-comm-cx_vr_1226markets08.html) 9 “Projects – Golshan Gas Field,” Pars Oil and Gas Company Website, accessed July 23, 2010. (http://pogc.ir/Default.aspx?tabid=156) 10 Joseph A. Christoff, “Firms Reported in Open Sources as Having Commercial Activity in Iran’s Oil, Gas, and Petrochemical Sectors,” U.S. Government Accountability Office, March 23, 2010, p. 17. (http://www.gao.gov/new.items/d10515r.pdf) 11 “Malaysia Unbowed by US Threat,” Al Jazeera English, February 2, 2007. (http://english.aljazeera.net/news/asia-pacific/2007/02/200852513192922240.html)

25


“NIOC will assume complete ownership of the LNG facility after a period of 25 years. NIOC and Petrofield will also set up a shipping company through a 50:50 joint venture for the transport of LNG.”12 Petrofield will fi-nance 100 percent of the building costs of the plant and its investment will be repaid in seven years from the sale of gas and other related products.13 In December 2009, SKS proposed to invest $20 billion in the Ferdowsi and Golshan gas fields. It was also reported that Iran and Ma-laysia plan to build refineries in Vietnam and Syria as well.14 According to USASpending.gov, SKS Ventures has received no federal contracts.15 It also appears that SKS Ventures does not have any direct business activities in the United States.

12 “Iran and Malaysia Sign $14 Billion of Oil and Gas Coopera-tion Agreements,” Industrial Info Resources, December 15, 2008. (http://www.pump-zone.com/global-news/global-news/iran-and-malaysia-sign-14-billion-of-oil-and-gas-cooperation-agreements.html) 13 Joseph A. Christoff, “Firms Reported in Open Sources as Hav-ing Commercial Activity in Iran’s Oil, Gas, and Petrochemical Sectors,” U.S. Government Accountability Office, March 23, 2010, p. 17. (http://www.gao.gov/new.items/d10515r.pdf) 14 “Malaysia to Invest $20bn in Iran's Fields,” PressTV (Iran), December 8, 2009. (http://www.presstv.ir/detail.aspx?id=113169&sectionid=351020103) 15 USASpending.gov, accessed July 23, 2010. (http://www.usaspending.gov)

26


ThyssenKrupp (Germany)

German company ThyssenKrupp’s relation-ship with Iran dates back to 1974 when the Iranian government became an investor in Fried. Krupp GmbH, which later merged with Thyssen AG to form ThyssenKrupp.1 Although ThyssenKrupp forced the state-owned Iran Foreign Investment Company to give up some of its shares in the company in 2003, Iran re-mains a ThyssenKrupp shareholder owning 4.5 percent of the company. In 2007, Iran made €18.5 million in dividends through its investment in ThyssenKrupp.2 Thyssen was involved in a project to upgrade Iran’s Esfahan refinery.3 ThyssenKrupp is also active in Iran’s energy sector through some of its subsidiaries, including Krupp Uhde which is a contractor on a project to construct poly-ethylene plants, one of which was inaugu-rated in June 2008.4

In its 2000-2001 annual report, Krupp Uhde announced that it had negotiated two con-tracts with Iran’s National Petrochemical Company (NPC) to construct polyethylene (olefin) plants in Bandar Imam and Bandar Assaluyeh. NPC is an entity designated by the U.S. Treasury.5 “The two contracts together are worth more than DM [Deutsche Mark] 430 million [approximately $721 million, as of January 1, 2001] and include the basic en-gineering, the supply of all imported equip-

1 “1976 – State of Iran Acquires Interest in Fried. Krupp GmbH,” ThyssenKrupp Website, accessed July 26, 2010. (http://www.thyssenkrupp.com/en/konzern/geschichte_chronik_k1976.html) 2 “German Business with Iran: The Example ThyssenKrupp,” Stop the Bomb, accessed July 26, 2010. (http://de.stopthebomb.net/en/start/germany/d-iran/thyssenkrupp.html) 3 Ibid. 4 “Iran to Inaugurate 10th Olefin Project,” Steel Guru, June 22, 2008. (http://www.steelguru.com/middle_east_news/Iran_to_inaugurate_10th_olefin_project/51821.html) 5 U.S. Department of the Treasury, Office of Foreign Assets Control, “Recent OFAC Actions,” June 16, 2010. (http://www.treas.gov/offices/enforcement/ofac/actions/20100616.shtml)

ment and the provision of technical assistance for the project.”6

Uhde has a wholly-owned subsidiary in the United States, Uhde Corporation of America, in Pennsylvania.7 While this subsidiary has not re-ceived any U.S. Federal government contracts, ThyssenKyupp AG has received $134,357,910 in contracts since 1999.8

6 “Krupp Uhde Annual Report 2000/2001,” September 31, 2001. (http://www.uhde.eu/cgi-bin/byteserver.pl/pdf/KruppUhde_JB_2000_2001engl.pdf) 7 “Locations – Americas,” Uhde Website, accessed July 26, 2010. (http://www.uhde.eu/locations/america.en.html) 8 “Uhde,” USASpending.gov, accessed June 25, 2010. (http://www.usaspending.gov) and “ThyssenKrupp AG,” USAS-

pending.gov, accessed August 3, 2010. (http://www.usaspending.gov)

27


Tupras (Turkey)

Turkish oil refiner Tupras supplied Iran with gasoline in June 2010 after an eighteen-month pause in deliveries.1 For the month of July, reports indicate that Turkey is expected to deliver four to five gasoline cargoes to Iran. “Two of the gasoline cargoes coming from Turkey were scheduled to load from Turkish refiner Tupras’ Izmit refinery, while two or three were scheduled to load from Tupras’ Izmir refinery, sources said. The cargoes would be loaded load onto ships owned by the state energy giant Na-tional Iranian Oil Company (NIOC), they added.”2 NIOC is designated by the U.S. Treasury.3 In a letter to the Financial Times, Tupras’ General Manager claimed that the gasoline sales were part of a solicitation bid that took place in early 2010, prior to the passage of sanctions against Iran.4 In 2009, Iran supplied Tupras with 3.2 million tons of crude oil, which was significantly less than the amount it delivered in 2007 and 2008, about 8.86 million and 7.5 million re-spectively.5 Reuters estimated that in June 2010 Iran exported about 63,000 bpd of crude oil to Tupras.6

1 Simon Webb, “UPDATE 2-Iran Relies on Friendly Powers for Fuel Supplies,” Reuters, July 8, 2010. (http://uk.reuters.com/article/idUKLDE6671UA20100708) 2 Ibid. 3 U.S. Department of the Treasury, Office of Foreign Assets Control, “Recent OFAC Actions,” June 16, 2010. (http://www.treas.gov/offices/enforcement/ofac/actions/20100616.shtml) 4 Yavuz Erkut, “Tupras is a Private Company and Thus Sets its Own Policy,” Financial Times, July 30, 2010. (http://www.ft.com/cms/s/0/aa9a11b6-9b71-11df-8239-00144feab49a.html) 5 “FACTBOX-Turkey's Economic Relations with the Middle East,” Reuters, June 24, 2010. (http://www.reuters.com/article/idUSLDE65G1TH20100624) 6 “FACTBOX-Iran's Crude Oil Buyers in Europe, Asia,” Reuters, June 18, 2010. (http://www.reuters.com/article/idUSLDE64J11C20100618)

As a Turkish refining company, the company does not have any operations in Iran or in the United States. The company does not appear to have received any significant contracts from the United States government.

28


WorleyParsons (Australia)

Ranhill Worley — a joint venture of Ranhill Berhad and Australian WorleyParson sub-sidiary Worley Engineering — served as a contractor in 2006 for the National Iranian Oil Company (NIOC) and the Petroiran Devel-opment Company (PEDCO). Ranhill Worley worked on a project at the Salman Offshore Facility in Iran.1 NIOC and PEDCO are desig-nated by the U.S. Treasury.2

According to the Tehran Raymand company website, Iran's Industrial Development and Renovation Organization (IDRO) and Oil In-dustries Engineering and Construction (OIEC) awarded WorleyParsons a contract to con-duct the basic engineering and Front-end En-gineering and Design (FEED) for the onshore gas facilities at South Pars phases 17 and 18.3

In February 2008, Ranhill WorleyParsons won a $17 million “engineering contract for the South Pars gas development project in the Persian Gulf.” Ranhill WorleyParsons’ CEO said the contract covers engineering of well head drilling and gas processing facilities that will allow for 2 billion cubic feet of gas to be produced each day.4

Pars International Development & Engineer-ing Co. (PIDECO) and WorleyParsons signed a contract in March 2008 for one of the natural gas liquefaction phases of a $1.1 billion deal with the Iran LNG Company. The project is

1 “Reference Detail,” Alcedo Consulting Website, accessed July 23, 2010. (http://alcedoconsulting.com/reference_list.asp?client=NIOC%2FPEDCO) 2 U.S. Department of the Treasury, Office of Foreign Assets Control, “Recent OFAC Actions,” June 16, 2010. (http://www.treas.gov/offices/enforcement/ofac/actions/20100616.shtml) 3 “TR Projects,” Tehran Raymand Company Website, accessed July 8, 2010. (http://www.tehranraymand.com/Projects/Projects_26.html) 4 Ranhill Clinches RM55m Persian Gulf Engineering Job,” New

Straits Times, February 25, 2008. (http://findarticles.com/p/news-articles/new-straits-times/mi_8016/is_20080225/ranhill-clinches-rm55m-persian-gulf/ai_n44391475/)

slated to become operational in January 2011.5

Iran Offshore Engineering & Construction (IOEC) awarded a sub-contract to WorleyParsons in April 2008 to design parts of the platforms on phase 12 of the South Pars gas field.6

In February 2010, “WorleyParsons teamed up with Linde of Germany to carry out a FEED for China National Offshore Oil Corporation’s (CNOOC’s) planned liquefied natural gas plant at the North Pars gas project.” Additionally, in May 2010 WorleyParsons signed an agreement with China National Petroleum Corporation (CNPC) “to review a front-end engineering and design job left behind by departing French giant Total for Iran's South Pars (SP) Phase 11 gas project.” The project is expected to last three months.7

WorleyParsons has several offices in the United States, which manage its operations across the country, according to the company’s website.8

The Houston subsidiary of WorleyParsons Lim-ited has received approximately $10 million in contracts from the federal government in the last 10 years, the majority of which came from the Department of Defense.9

5 “Iran LNG” Liquefaction Deal Signed,” Platts, March 22, 2008. (http://www.iranoilgas.com/news/details2/?type=news&p=current&newsID=1789&restrict=no) 6 “Iran Awards South Pars Design Deal to Worley Parsons,” Middle

East Economic Digest, April 22, 2008. (http://www.gasandoil.com/goc/company/cnm82025.htm) 7 “New Player Set to Review Iran's South Pars 11 FEED,” Upstream, May 9, 2010. (http://www.bedigest.com/NEWS/39013.aspx) 8 “Operations in the United States,” WorleyParsons Website, ac-cessed July 9, 2010. (http://www.worleyparsons.com/GlobalPresence/UnitedStates/Pages/default.aspx) 9 “WorleyParsons,” USASpending.gov, accessed August 3, 2010. (http://www.usaspending.gov)

29


Zhuhai Zhenrong Corporation (China)

Chinese state-run Zhuhai Zhenrong has been shipping a cargo or two each month to Iran for at least a year, according to Reuters in Sep-tember 2009.1 While the company has not publicly announced that it was ceasing its gasoline deliveries to Iran, it has not been mentioned in recent press reports as one of the Chinese firms still supplying Iran with gasoline. Zhuhai Zhenrong is a subsidiary of China North Industries Corporation (Norinco) cre-ated in 1994 with the task of importing crude oil from Iran.2 The company extended is con-tract to purchase Iranian fuel in 2009; how-ever, Zhuhai Zhenrong canceled its 2010 ten-der with the National Iranian Oil Company (NIOC) in January. The company reportedly ended the contract as a result of high com-modity prices and shipping costs.3 NIOC is designated by the U.S. Treasury.4 Amongst its worldwide locations, the com-pany maintains an office in Tehran.5

The company does not have any operations in the United States, nor has it received any money from the U.S. federal government in the past ten years.

1 “China Firms Selling Fuel to Iran as U.S. Sanctions Loom,” Reuters, September 23, 2009. (http://www.reuters.com/article/idUSTRE58M1BK20090923 2 “Iran to Sell $20 Billion Worth of LNG to China,” Energy-Pedia, March 19, 2004. (http://www.energy-pedia.com/article.aspx?articleid=104733) 3 “Zhuhai Zhenrong Annuls 2010 Fuel Oil Term Contract with NIOC,”C1 Energy, January 28, 2010. (http://www.c1energy.com/common/2593582,0,0,0,2.htm) 4 U.S. Department of the Treasury, Office of Foreign Assets Control, “Recent OFAC Actions,” June 16, 2010. (http://www.treas.gov/offices/enforcement/ofac/actions/20100616.shtml) 5 “Organization Structure,” Zhuhai Zhenrong Corporation Web-

site, accessed July 12, 2010. (http://www.zhzrgs.com.cn/en/2007.asp)

30


F O U N D A T I O N F O R D E F E N S E O F D E M O C R A C I E S

LEADERSHIP COUNCIL

Dr. Paula J. Dobriansky

Fmr. Under Secretary of State for Democracy and

Global Affairs

Steve Forbes

CEO, Forbes Magazine

Judge Louis J. Freeh

Fmr. FBI Director

Newt Gingrich

Fmr. Speaker, U.S. House of Representatives

Max M. Kampelman

Fmr. Ambassador

Bill Kristol

Editor, Weekly Standard

Senator Joseph Lieberman

(DI-CT) U.S. Senator

Robert C. McFarlane

Fmr. National Security Advisor

R. James Woolsey

Fmr. CIA Director

BOARD OF ADVISORS

Gary Bauer

Representative Eric Cantor

Gene Gately

General P.X. Kelley

Charles Krauthammer

Kathleen Troia “KT” McFarland

Hon. Charles E. Allen

Richard Perle

Steven Pomerantz

Oliver “Buck”Revell

Bret Stephens

Hon. Francis J. “Bing” West

IN MEMORIAM

Jack Kemp

Fmr. Secretary of Housing and Urban

Development

Dr. Jeane J. Kirkpatrick

Fmr. Ambassador to the UN

Clifford D. May

President

Mark Dubowitz

Executive Director

Ambassador Richard W. Carlson

Vice-Chairman


July 2010

NONPARTISAN & NONPROFIT, FDD FIGHTS TERRORISM & PROMOTES FREEDOM P.O. Box 33249 Washington, DC 20033-3249 www.defenddemocracy.org

IRAN ENERGY PROJECT www.iranenergyproject.org

Documents

FDD Report on Iran's Energy Partners