Economic sanctions on Iran have been getting tougher in recent years, and the United States tightened the screws a little more last summer with the Iran Threat Reduction and Syria Human Rights Act (PDF).
One unusual aspect of that law is that it started requiring companies traded on US stock exchanges to disclose more about the business they’re doing with Iran, and the Securities and Exchange Commission created the clunkily named IRANNOTICE filing to help them do it.
Companies were already beginning to disclose more about their ties to Iran, Syria, Cuba and other countries non grata (at least in US eyes) under pressure from the SEC. Now they must be systematic about it—and disclose gross revenue and net profits wherever possible.
Quartz’s partial tally: more than $540 million in gross revenue and $15.5 million in profits for US-listed companies from their business with Iran in 2012—and that’s just from 30 or so large companies that have made the disclosures since mid-February.
The numbers underscore the difficulty of maintaining tight sanctions in a global economy. But they also hide a lot of nuance and variation.
Companies based outside the US accounted for 99% of the revenue and three-quarters of the profit. (They made the disclosures because they list shares or American Depository Receipts on US markets.)
In fact, a big chunk of the total came from one company: $414 million in revenue for Statoil ASA, the Norwegian oil and gas company, from Statoil’s contracts with the National Iranian Oil Co.
Statoil also said it has terminated its agreements with Iran, abandoned it licenses there, and “will not make any investments in Iran under present circumstances.”
That’s a common refrain in the disclosures we saw: Many, though not all, of the disclosed transactions reflected companies wrapping up old business en route to cutting most or all ties with the Islamic republic. Typically, the transactions hadn’t been prohibited before the new rules kicked in.
Among the other noteworthy disclosures:
- ING Groep said it collected €58 million in revenue and €395,000 in profits from repayment of old loans and a collection of frozen Iranian bank accounts. (Of course, in June, ING also settled allegations by the US Treasury and federal prosecutors that it hid transactions with Cuba and helped finance some sales to Iran, by agreeing to pay $619 million in penalties. It if keeps its nose clean for 18 months, the prosecutors will drop their charges.)
- The biggest disclosure by a US company came from auto-parts maker TRW Automotive Holdings, which said it collected $8.3 million in revenue and $377,000 in profits from non-US subsidiaries that “sold products to customers that could be affiliated with, or deemed to be acting on behalf of, the Industrial Development and Renovation Organization” — one of the Iranian entities on the federal government’s massive list.
- Under broad rules defining corporate “affiliates,” TRW’s transactions forced investor Blackstone Group to file its own disclosure. And Carlyle Group disclosed that a European portfolio company, Applus Servicios Technologicos, collected €1.19 million in revenue (and €200,000 in profits) from Iranian customers “that could be affiliated with the Industrial Development and Renovation Organization.” Similarly, Hertz had to report that a French affiliate of investor Clayton, Dubilier & Rice had received €2.5 million in payments from Iranian interests to an account at Bank Melli last year. And Apollo Global Management disclosed that portfolio company LyondellBasell Industries (Apollo funds owned 19.6%) reported collecting €4.2 million in revenue and €2.4 million in profit last year from Iranian entities.
- Thomson Reuters reported $2.4 million in revenue and $426,000 in profits from selling news and intellectual-property and financial data to Iran-linked entities.
- Other big Iran-related disclosures included GlaxoSmithKline at £19.7 million in revenue and £2.8 million in profits, and AstraZeneca at $14 million in revenue and $6 million in profits, both through distributors. Glaxo said that, after a review of the business, it “intends to supply only products of high medical/public health need (as determined using criteria set by the World Health Organization) from its Pharmaceuticals and Vaccines businesses.” AstraZeneca says it has a US license to do some business with Iran, but so far has sold only drugs from outside the US to distributors there.
Amusingly, at least for observers, there doesn’t seem to be a lower threshold to the disclosure requirement. So Dell, the Texas computer company, disclosed a whopping £106.13 ($169.90 at the time) in revenue from Iran, collected by a United Kingdom subsidiary to Quest Software, which Dell said last year it would acquire. The fees were paid by a unit of Bank Melli, which the US government links to Iran’s nuclear and missile programs, for maintenance licenses on software that helps search email and other communications. Drafting Dell’s 374-word disclosure probably cost the company more than the licenses brought in. (Dell says it canceled the service contract and won’t do further business with Bank Melli.)
Other picauyne disclosures include Hyatt Hotels, which said the Park Hyatt Hamburg collected $9,300 for 33 room nights under a preferred-rate arrangement with Europaeisch-Iranische Handelsbank, which is on the US Treasury’s Blocked Persons List. And CME Group said it received $3,150 in revenue for selling market data to Iran’s Government Trading Group and a European subsidiary of the National Iranian Oil Company.
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