oversight

Firms Reported to Have Sold Iran Refined Petroleum Products or Engaged in Commercial Activities in Iran's Energy Sector

Published by the Government Accountability Office on 2012-12-07.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

United States Government Accountability Office
Washington, DC 20548




          December 7, 2012

          Congressional Committees

          Subject: Firms Reported to Have Sold Iran Refined Petroleum Products or Engaged in
          Commercial Activities in Iran’s Energy Sector

          Iran’s involvement in illicit nuclear activities, support for terrorism, and abuse of human rights
          have led the United States, as well as other nations, to impose multiple sanctions in an
          attempt to curb these activities. 1 According to the Department of State (State), the sanctions
          are intended to, among other things, target sectors of the Iranian economy relevant to its
          proliferation activities and block the transfer of weapons and technology related to Iran’s
          missile and nuclear programs. In authorizing sanctions on entities engaging in certain
          transactions in Iran’s energy sector, Congress declared that it is the policy of the United States
          to deny Iran the ability to support proliferation and terrorism by limiting the development of
          Iran’s energy sector. 2 The Secretary of State is responsible for determining whether a firm
          should be sanctioned for its activities in Iran’s energy sector.

          The United States has imposed these sanctions through various legislation and executive
          orders, including the Iran Sanctions Act of 1996 (ISA). 3 On July 1, 2010, the President signed
          into law the Comprehensive Iran Sanctions, Accountability, and Divestment Act (CISADA) of
          2010, which added new activities for which entities can be sanctioned under ISA. 4 As
          amended by CISADA, ISA provides for sanctions to be imposed against persons, including
          foreign firms, who engage in certain activities in Iran’s energy sector, including selling or
          providing Iran with refined petroleum products or investing more than $20 million in the



          1
           For example, see the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010, Pub. L. No. 111-
          195, 124 Stat. 1312 and Council Decision 2010/413/CFSP Concerning Restrictive Measures Against Iran and
          Repealing Common Position 2007/140/CFSP, 2010 O.J. (L 195) 39.
          2
           Iran and Libya Sanctions Act of 1996, Pub. L. No. 104-172, § 3, 110 Stat. 1541. In this report, we use the term
          “energy sector” to refer to Iran’s oil, gas, and petrochemical sectors.
          3
           International Emergency Economic Powers Act, Pub. L. No. 95-223, 91 Stat. 1625 (1977); National Emergencies
          Act, Pub. L. No. 94-412, 90 Stat. 1255 (1976), and 3 U.S.C. § 301 as implemented by Executive Order 12957, 60
          Fed. Reg. 14615 (Mar. 15, 1995) (prohibiting U.S. involvement with petroleum development in Iran), Executive
          Order 12959, 60 Fed. Reg. 24757 (May 6, 1995) (banning specified exports and investment), and Executive Order
          13059, 62 Fed. Reg. 44531 (Aug. 19, 1997) (prohibiting virtually all trade and investment activities with Iran by U.S.
          persons, wherever located). Iran and Libya Sanctions Act of 1996, Pub. L. No. 104-172, as amended (the name of
          this law was changed to the Iran Sanctions Act of 1996 by the Iran Freedom Support Act, Pub. L. No. 109-293, 120
          Stat. 1344 (2006)).
          4
              Pub. L. No. 111-195, § 102, 124 Stat. 1312, 1317-28.




                                                                                            GAO-13-173R Iran Energy Sector
development of Iran’s petroleum resources. 5 On August 10, 2012, the President signed into
law the Iran Threat Reduction and Syria Human Rights Act of 2012 (ITRSHRA), which further
amended ISA in part by increasing the number of activities for which entities can be
sanctioned. 6

ITRSHRA also requires GAO to submit to the Congress a report “listing foreign investors in
Iran's energy sector” for the period beginning on January 1, 2009. The list is “to include entities
that exported gasoline and other refined petroleum products to Iran,” and “entities involved in
commercial transactions of any kind, including joint ventures anywhere in the world, with
Iranian energy companies.” In response to this requirement, this report identifies (1) firms
reported in open sources published between January 1, 2009 and September 30, 2012 to
have sold refined petroleum products to Iran during that same time period; and (2) firms
reported in open sources published between January 1, 2005 and September 30, 2012 to
have had commercial activities in Iran's energy sector during that same time period. In
addition, we list the status of each firm’s activity as of September 30, 2012. ITRSHRA did not
ask us to attempt to determine whether the activities for which the firms are listed in our
reports met the legal criteria for sanctionable activities under the ISA, as amended. We plan to
issue a report in 2013 that will address other aspects of our reporting requirement under this
provision of the ITRSHRA legislation.

To accomplish these objectives, we updated information included in four prior GAO reports.
Two of these reports, taken together, identified firms reported in open sources published from
January 2009 through December 2011 as having sold refined petroleum products to Iran
during that same time period. 7 The other two reports, taken together, identified firms reported
in open sources published from January 2005 through May 2011 as having engaged in
commercial activities in Iran’s energy sector during that same time period. 8 This report
updates the information in those reports to include information from open sources published
through September 30, 2012. As we did in the previous reports, we reviewed open source
information, including industry and trade publications, corporate reports and statements, and
U.S. Securities and Exchange Commission filings. Regarding petroleum product sales, we
listed firms that were reported in open sources to have sold Iran refined petroleum products if,
for example, at least three reputable industry publications and/or the firm’s corporate
statements reported that the firm had done so at some point between January 1, 2012 and
September 30, 2012. We defined refined petroleum products to include gasoline, kerosene,
diesel fuel, and gas oil. Regarding commercial activities, we included a firm on our list if, for
example, at least three reputable industry publications and/or the firm’s corporate statements

5
 Pub. L. No. 104-172, § 5, as amended. Sanctions related to the provision of refined petroleum products Iran are
authorized when the refined petroleum products have a fair market value of at least $1 million or, during a 12-month
period, have an aggregate fair market value of at least $5 million. The act also allows for sanctions against persons
providing goods, technology, or services to Iran knowing that such provision would contribute materially to Iran’s
ability to acquire or develop chemical, biological, or nuclear weapons or related technologies, or acquire or develop
destabilizing numbers and types of advanced conventional weapons.
6
    Pub. L. No. 112-158, 126 Stat. 1214.
7
 GAO, Firms Reported in Open Sources to Have Sold Iran Refined Petroleum Products between January 1, 2009,
and June 30, 2010, GAO-10-967R (Washington, D.C.: Sept. 3, 2010). GAO, Firms Reported in Open Sources to
Have Sold Iran Refined Petroleum Products Declined Since June 30, 2010, GAO-12-321R (Washington, D.C.: Jan.
24, 2012).
8
 GAO, Firms Reported in Open Sources as Having Commercial Activity in Iran's Oil, Gas, and Petrochemical
Sectors, GAO-10-515R (Washington, D.C.: Mar. 23, 2010). GAO, Firms Reported in Open Sources as Having
Commercial Activity in Iran's Oil, Gas, and Petrochemical Sectors, GAO-11-855R (Washington, D.C.: Aug. 3, 2011).


Page 2                                                                     GAO-13-173R Iran Energy Sector
reported the firm to have had commercial activities in Iran’s energy sector at some point
between June 1, 2011 and September 30, 2012. We defined commercial activity as a firm
having signed an agreement to conduct business; invested capital; held an interest in an
Iranian energy sector project; or received payment for the provision of goods or services in
connection with a specific Iranian oil, gas, or petrochemical project. Regarding sales of refined
petroleum products and commercial activities, in cases where a report did not specify the date
of such activity, we used the report’s date of publication for the date of activity. We did not
review the contracts and documents underlying the reported transactions and activities and did
not independently verify the transactions and activities. We did not attempt to determine
whether the activities for which the firms are listed in our reports met the legal criteria for
sanctionable activities under ISA, as amended. The Secretary of State is responsible for
making such determinations.

We sent a letter to each firm whose status we had listed as “active” or “insufficient information
available” in our January 2012 report on refined petroleum sales or our August 2011 report on
commercial activities that had not responded to our previous attempt to contact them, to
request comment on activities identified by those open source reviews. We subsequently sent
a letter to each firm for which we found at least three open source reports of new activity
during our current review period, to request comment on those activities. See enclosure I for a
full description of our scope and methodology.

We conducted our work from October 2012 to December 2012 in accordance with all sections
of GAO’s Quality Assurance Framework that are relevant to our objectives. The framework
requires that we plan and perform the engagement to obtain sufficient and appropriate
evidence to meet our stated objective and discuss any limitations in our work. We believe that
the information and data obtained, and the analysis conducted, provide a reasonable basis for
any findings and conclusions.

Results in Brief

Our reviews of open sources published between January 1, 2009 and September 30, 2012
identified a total of 17 foreign firms that were reported to have sold refined petroleum products
to Iran during that same time period (see enclosure II). Our review of open sources published
from January 2012 through September 2012 indicated that only 1 of these 17 firms—Sytrol—
was reported to have sold refined petroleum products to Iran during that same time period. In
addition, our open source review and communication with firms indicated that 12 of the 17
firms were reported to have stopped selling these products to Iran before September 30, 2012;
however, our review did not identify sufficient information to indicate either that the remaining 4
firms had continued to sell or ceased selling refined petroleum products to Iran at some point
between January 1, 2012 and September 30, 2012.

Our reviews of open sources published from January 1, 2005 through September 30, 2012
identified a total of 42 foreign firms that were reported to have had commercial activity in Iran’s
energy sector during that same time period (see enclosure III). Our review of open sources
published from June 1, 2011 to September 30, 2012 indicated that 7 of these 42 firms were
reported to have engaged in commercial activities in Iran’s energy sector during that same
time period. In addition, our open source review and communications with firms indicated that
19 of the 42 were reported to have withdrawn from commercial activities in Iran by June 2011,
and 8 more had withdrawn from such activities as of September 30, 2012; however, our review
did not identify sufficient information to indicate either that the remaining 8 firms had continued



Page 3                                                          GAO-13-173R Iran Energy Sector
or ceased engaging in commercial activity in Iran’s energy sector at some point between June
1, 2011 and September 30, 2012.

Background

Iran’s economy and government rely heavily on revenues from its oil and gas industry.
According to the 2012 Central Intelligence Agency World Factbook, Iran is the fifth-largest
holder of proven oil reserves in the world and petroleum accounts for approximately 80
percent of Iran’s exports. 9 Iran’s crude oil production peaked in 1978 and has not matched
that peak since then because of a high rate of natural decline in mature oil fields, limited
investment, and sanctions. IHS Global Insight found that Iran’s oil sector will require
approximately $25 billion in annual investments to maintain existing production and
considerably more to develop and enhance recovery techniques that could lift its daily output
from an estimated 4.2 million barrels in 2011 to 5.8 million barrels by 2015. 10 In addition, Iran
has limited refinery capacity and has been reliant on imports of refined petroleum products to
meet domestic demand for gasoline, according to the Department of Energy.

The August 10, 2012 enactment of ITRSHRA added additional requirements and measures to
ISA. 11 ISA, as amended, provides for sanctions to be imposed against firms that are
determined to knowingly sell or provide Iran with refined petroleum products that (1) have a
fair market value of $1 million or more, or (2) during a 12-month period, have an aggregate fair
market value of $5 million or more. 12 It also provides for sanctions to be imposed on
companies that are determined to have made investments of at least $20 million that directly
and significantly contributes to the enhancement of Iran’s ability to develop petroleum
resources. 13 As amended, ISA also provides for sanctions to be imposed against persons who
knowingly participate, on or after August 10, 2010, in a joint venture established on or after
January 1, 2002, where the Government of Iran is a substantial partner or investor or where
the Government of Iran could receive knowledge or equipment not already available to it that
would enhance Iran’s ability to develop domestic petroleum resources. 14 The President, who
delegated certain authorities under the act to the Secretary of State, may waive the imposition



9
 Central Intelligence Agency, World Factbook, https://www.cia.gov/library/publications/the-world-
factbook/geos/ir.html, accessed on November 14, 2012.

10
  IHS Global Insight, “Iran,” Energy: Report, viewed May 26, 2011. IHS Global Insight provides economic and
financial information for the energy industry on a contract basis, including analysis and forecasting for the Iranian
oil, gas, and petrochemical sectors discussed in this report.

11
     Pub. L. No. 112-158, §§ 201-208.

12
     Pub. L. No. 104-172, § 5(a), as amended.
13
  Pub. L. No. 104-172, § 5(a), as amended. The investment must be either at least $20 million or a combination of
investments of at least $5 million which aggregates to at least $20 million in a 12-month period.
14
  Pub. L. No. 104-172, § 5(a), as amended. Generally, ITRSHRA also extended ISA sanctions to the following
commercial activities: (1) engaging in specific activities supporting Iran’s refined petroleum sector, (2) contributing
to the development of infrastructure that supports the delivery of refined petroleum in Iran, (3) transporting crude oil
from Iran, and (4) evasion of sanctions by shipping companies. Pub. L. No. 112-158, Subtitle A. For sanctions to
apply to these activities, differing conditions such as dollar-value thresholds must also be met. Pub. L. No. 112-
158, Subtitle A.




Page 4                                                                        GAO-13-173R Iran Energy Sector
of sanctions for these activities. 15 State is primarily responsible for implementing ISA as
amended.


According to Open Sources, 17 Foreign Firms Sold Iran Refined Petroleum Products at
Some Point between January 1, 2009 and September 30, 2012

Our reviews of open sources published between January 1, 2009 and September 30, 2012
identified a total of 17 foreign firms that were reported to have sold refined petroleum products
to Iran during that same time period (see enclosure II). Our review of open sources published
from January 2012 through September 2012 indicated that 1 of these 17 firms—Syria’s state-
owned Sytrol—was reported to have sold gasoline to Iran during that same time period (see
table 1). We did not attempt to determine whether the activities for which the firm is listed met
the legal criteria for sanctionable activities under ISA, as amended. The Secretary of State is
responsible for making such determinations. The Secretary of State imposed sanctions on
Sytrol on August 10, 2012 for selling Iran 33,000 metric tons of gasoline valued at over $36
million (see enclosure IV for a list of foreign firms sanctioned by State pursuant to ISA, as
amended). 16

Table 1: Foreign Firm Reported in Open Sources to Have Sold Refined Petroleum Products to Iran at Some
Point between January 1, 2012 and September 30, 2012

Firm                                   Countrya      Status in GAO’s January 2012              Status in current GAO report
                                                     report
1.     Sytrol                          Syria         Not listed                                Active
Source: GAO analysis of open source information.


Notes: For the purposes of this report, we listed a firm’s status as “active” if, for example, three open sources published within the
specified time period reported that the firm sold refined petroleum products to Iran during that same time period. A firm’s status in
the current GAO report is based on open source reports published between January 1, 2012 and September 30, 2012. See
enclosure I for the full scope and methodology.
a
The country listed in this column is the physical location of the firm as reported in open sources.


In addition, our open source reviews and communications with firms indicated that 12 of the 17
firms were reported to have stopped selling refined petroleum products to Iran before
September 30, 2012 (see enclosure II). Our review did not identify sufficient information to
indicate either that the remaining 4 firms had continued to sell or ceased selling refined
petroleum products to Iran at some point between January 1, 2012 and September 30, 2012
(see table 2).




15
 Pub. L. No. 104-172, §§ 4, 9, as amended, and Memorandum: Delegation of Certain Functions and Authorities
under the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010, 75 Fed. Reg. 67025 (Sept.
23, 2010).
16
     Public Notice 8040, 77 Fed. Reg. 59034 (Sept. 25, 2012).


Page 5                                                                                 GAO-13-173R Iran Energy Sector
Table 2: Foreign Firms for Which There Was Insufficient Open Source Information to Indicate Either That
They Had Continued or Ceased Selling Refined Petroleum Products to Iran at Some Point between January
1, 2012 and September 30, 2012

                                                      Status in GAO’s January 2012
Firm                                   Countrya       report                                    Status in current GAO report
1.     China Oil                       China          Active                                    Insufficient information available
2.     Petróleos de                    Venezuela      Active                                    Insufficient information available
       Venezuela S.A.
3.     Unipec                          China          Active                                    Insufficient information available
4.     Zhuhai Zhenrong                 China          Active                                    Insufficient information available

Source: GAO analysis of open source information.


Notes: For the purposes of this report, we listed a firm’s status as “active,” ”withdrawn,” or ”insufficient information available.” We
listed a firm’s status as “active” if, for example, three open sources published within the specified time period reported that the firm
sold refined petroleum products to Iran during that same time period. We listed a firm’s status as “insufficient information
available” if the review of open sources published within the specified time period did not identify sufficient information to indicate
either that the firm had continued to sell refined petroleum products to Iran during that same time period (active), or that the firm
had ceased making such sales (withdrawn). A firm’s status in the current GAO report is based on open source reports published
from January 1, 2012 through September 30, 2012. See enclosure I for the full scope and methodology.
a
The country listed in this column is the physical location of the firm as reported in open sources.


According to Open Sources, 42 Foreign Firms Engaged in Commercial Activity in Iran’s
Energy Sector at Some Point between January 1, 2005 and September 30, 2012

Our reviews of open source information published from January 1, 2005 through September
30, 2012 together identified 42 foreign firms that were reported to have had commercial
activity in Iran’s energy sector during that same time period (see enclosure III). 17 Open
sources published from June 2011 through September 2012 reported that 7 of these 42 firms
had engaged in such commercial activity since our last report on this topic in August 2011 (see
table 3). We did not attempt to determine whether the activities for which these firms are listed
met the legal criteria for sanctionable activities under ISA, as amended. The Secretary of State
is responsible for making such determinations.

Table 3: Foreign Firms Reported in Open Sources As Engaging in Commercial Activity in Iran’s Energy
Sector at Some Point between June 1, 2011 and September 30, 2012

                                                                      Status in GAO’s August             Status in current GAO
Firm                                               Countrya           2011 report                        report
1. China National Petroleum Corporation            China              Active                             Active
2. Daelim                                          South Korea        Active                             Active
3. Indian Oil Corporation Ltd.                     India              Active                             Activeb
4. Oil India Ltd.                                  India              Active                             Activec
5. ONGC Videsh Ltd.                                India              Active                             Actived
6. Sasol                                           South Africa       Active                             Activee
7. Sinopec                                         China              Active                             Active

Source: GAO analysis of open source information.


Notes: For the purposes of this report, we listed a firm’s status as “active” if, for example, three open sources published within the
specified time period reported that the firm engaged in commercial activity in Iran’s energy sector during that same time period. A
firm’s status in the current GAO report is based on open source reports published from June 1, 2011 through September 30, 2012.
See enclosure I for the full scope and methodology.



17
  For the purposes of this report, we defined commercial activity as a firm having signed an agreement to conduct
business; invested capital; held an interest in an Iranian energy sector project; or received payment for the provision
of goods or services in connection with a specific Iranian oil, gas, or petrochemical project.


Page 6                                                                                  GAO-13-173R Iran Energy Sector
a
    The country listed in this column is the physical location of the firm as reported in open sources.
b
 Open sources, including the firm’s annual report for 2011- 2012, reported Indian Oil Corp., Ltd. as having a 40 percent interest in
Iran’s Farsi Block gas field; however, the firm notified us that although negotiations had taken place, no agreements had been
reached and no contracts to develop the gas field had been signed, and it had decided under the present circumstances not to
pursue further work on the Farsi block.
c
 Open sources, including the firm’s annual report for 2011-2012, reported Oil India Ltd. as having a 20 percent interest in the
Farzad B gas field in Iran’s Farsi Block; however, the firm notified us that although negotiations were held, no agreement had
been reached and no contracts to develop the gas field had been signed, and it had decided not to pursue further work on the
Farsi Block gas field under the present circumstances.
d
 Open sources reported ONGC Videsh Ltd. as having a 40 percent interest in the Farsi Block, an Iranian gas field; however, the
firm notified us that although negotiations were held, no agreements had been reached and no contracts to develop the field had
been signed, and it had decided not to pursue further work on the Farsi Block gas field under the present circumstances.
e
    Open sources reported that Sasol is currently trying to divest its joint venture.


In addition, our open source reviews and communications with firms indicated that 19 of the 42
firms were reported to have withdrawn from such commercial activity before June 2011, and
that 8 more were reported to have withdrawn from such activities by September 30, 2012 (see
enclosure III). Our review of open sources did not identify sufficient information to indicate
either that the remaining 8 firms had continued to engage or had ceased engaging in
commercial activity in Iran’s energy sector at some point between June 1, 2011 and
September 30, 2012 (see table 4).

Table 4: Foreign Firms for Which There Was Insufficient Open Source Information to Indicate Either That
They Had Continued to Engage or Had Ceased Engaging in Commercial Activity in Iran’s Energy Sector at
Some Point between June 1, 2011 and September 30, 2012

                                                                          Status in GAO’s August
Firm                                                  Countrya            2011 report                     Status in current GAO report
1. Amona                                              Malaysia            Insufficient information        Insufficient information available
                                                                          available
2.      China National Offshore Oil Corporation       China               Active                          Insufficient information available
3.      INA                                           Croatia             Active                          Insufficient information available
4.      Oil and Natural Gas Corporation               India               Active                          Insufficient information available
        (ONGC)
5.      Petrofield                                    Malaysia            Insufficient information        Insufficient information available
                                                                          available
6.      Petróleos de Venezuela S.A.                   Venezuela           Active                          Insufficient information available
7.      Petronet LNG                                  India               Insufficient information        Insufficient information available
                                                                          available
8.      SKS Ventures                                  Malaysia            Insufficient information        Insufficient information available
                                                                          available
Source: GAO analysis of open source information.


Notes: For the purposes of this report, we listed a firm’s status as “active,” ”withdrawn,” or “insufficient information available.” We
listed a firm’s status as ”active” if, for example, three open sources published within the specified time period reported that the firm
engaged in commercial activities in Iran’s energy sector during that same time period. We listed a firm’s status as “insufficient
information available” if the review of open sources published within the specified time period did not identify sufficient information
to indicate that the firm had either continued to engage in commercial activities in Iran’s energy sector during that same time
period (active) or that the firm had stopped such activity (withdrawn). A firm’s status in the current GAO report is based on open
source reports published from June 1, 2011 through September 30, 2012. See enclosure I for the full scope and methodology.
a
    The country listed in this column is the physical location of the firm as reported in open sources.


Agency Comments

We provided a draft of this report to State for comment. State declined to comment.

                                                                   -----



Page 7                                                                                     GAO-13-173R Iran Energy Sector
We are sending copies of this report to appropriate congressional committees and the
Secretary of State. In addition, the report is available at no charge on the GAO website at
http://www.gao.gov.

If you or your staff have any questions about this report, please contact me at (202) 512-9601
or melitot@gao.gov. Contact points for our Offices of Congressional Relations and Public
Affairs may be found on the last page of this report. GAO staff who made key contributions to
this report are listed in enclosure V.




Thomas Melito
Director, International Affairs and Trade

Enclosures - 5




Page 8                                                        GAO-13-173R Iran Energy Sector
List of Committees

The Honorable Tim Johnson
Chairman
The Honorable Richard C. Shelby
Ranking Member
Committee on Banking, Housing, and Urban Affairs
United States Senate

The Honorable Max Baucus
Chairman
The Honorable Orrin G. Hatch
Ranking Member
Committee on Finance
United States Senate

The Honorable John Kerry
Chairman
The Honorable Richard G. Lugar
Ranking Member
Committee on Foreign Relations
United States Senate

The Honorable Spencer Bachus
Chairman
The Honorable Barney Frank
Ranking Member
Committee on Financial Services
House of Representatives

The Honorable Ileana Ros-Lehtinen
Chairman
The Honorable Howard Berman
Ranking Member
Committee on Foreign Affairs
House of Representatives

The Honorable Dave Camp
Chairman
The Honorable Sander Levin
Ranking Member
Committee on Ways and Means
House of Representatives




Page 9                                             GAO-13-173R Iran Energy Sector
Enclosure I


                                        Scope and Methodology

To generate our list of firms that were reported to have provided refined petroleum products to
Iran, we used information in our earlier reports on the sale of refined petroleum products to
Iran for the period from January 2009 through December 2011. 18 Then we updated that
information by reviewing open sources published between January 1, 2012 and September
30, 2012 to identify such sales reported to have occurred during that time period. We searched
open source information that was determined to be credible and comprehensive by an
information specialist on our staff, who has conducted work on the energy sector and worked
for firms that conduct audits in the oil processing industry, such as refining and petrochemical
production. For the purposes of our search, we defined refined petroleum products to include
gasoline, kerosene, diesel fuel, and gas oil. Open source information is overt and publicly
available information. We searched English-language industry and trade publications for
reports of such activity by firms at any point during the period between January 1, 2012 and
September 30, 2012. Our information specialist used the Nexis Oil and Energy databases,
which contain trade publications where more than 60 percent of the stories pertain to the oil
and energy industries. Publications include Oil Daily, Oil and Gas News, Oil and Gas Journal,
and Platt’s Oilgram News, among others. The information specialist then screened the
publications and excluded sources deemed insufficiently reliable, such as newspaper reports,
newswires, and direct news releases from the Iranian government. We also reviewed
company publications, annual reports, U.S. Securities and Exchange Commission (SEC)
filings, Federal Register Notices, and press releases and corporate statements reporting the
sale of refined petroleum products to Iran or for corrected information that had been publicly
reported.

To generate our list of firms that were reported to have had commercial activities in Iran’s
energy sector, we used information in our earlier reports on commercial activities in Iran’s
energy sector for the period from January 2005 through May 2011. 19 Then we updated that
information by reviewing open sources published between June 1, 2011 and September 30,
2012 to identify firms that were reported to have engaged in commercial activity in Iran’s
energy sector during that period. To do so, we conducted searches in industry publications
and company reports and statements published between June 1, 2011 and September 30,
2012. For the purposes of our search, we defined commercial activity as having signed an
agreement to conduct business, invested capital, held an interest in an Iranian energy sector
project, or received payment for the provision of goods or services in connection with the
Iranian oil, gas, or petrochemical sectors. Our information specialist used the same English-
language sources that were used to identify sales of refined petroleum products to Iran. The
information specialist searched for the specific names of firms identified in our 2011 report, as
well as key terms such as “Iran,” within 25 words of “explore,” “drill,” “refinery,” “natural gas,”
and “petroleum.” We also searched for locations in Iran where oil, gas, and petrochemical
activities were being conducted. In addition, we reviewed company publications, including
annual reports; SEC filings, if available; press releases and corporate statements that publicly
reported their commercial activities in Iran; or corrected information that had been publicly

18
 GAO, Firms Reported in Open Sources to Have Sold Iran Refined Petroleum Products between January 1, 2009,
and June 30, 2010, GAO-10-967R (Washington, D.C.: Sept. 3, 2010). GAO, Firms Reported in Open Sources to
Have Sold Iran Refined Petroleum Products Declined Since June 30, 2010, GAO-12-321R (Washington, D.C.: Jan.
24, 2012).
19
 GAO, Firms Reported in Open Sources as Having Commercial Activity in Iran's Oil, Gas, and Petrochemical
Sectors, GAO-10-515R (Washington, D.C.: Mar. 23, 2010). GAO, Firms Reported in Open Sources as Having
Commercial Activity in Iran's Oil, Gas, and Petrochemical Sectors, GAO-11-855R (Washington, D.C.: Aug. 3, 2011).


Page 10                                                                  GAO-13-173R Iran Energy Sector
Enclosure I


reported. We excluded companies that reported purchasing crude oil or natural gas from Iran
because these purchases did not meet our definition of commercial activity in Iran’s oil, gas, or
petrochemical sectors. Our June 2011 through September 2012 review spans both the period
preceding and following the enactment of the Iran Threat Reduction and Syria Human Rights
Act of 2012. 20 We identified firms reported as having contracts, agreements, and
memorandums of understanding to conduct commercial activity in Iran. We did not determine
whether the agreements represented final contracts or memorandums of understanding, which
are typically nonbinding agreements. When reports varied about certain details of a firm’s
project, we presented the information reported in the most recent source available.

For both lists, after identifying firms reported in open sources, we confirmed that the reports
were reliable and classified the firm’s status as “active” for this current reporting period if one
of the following criteria had been met: (1) at least three standard industry publications reported
that the firm had engaged in the identified activity at any point during the specified time period;
(2) the firm provided information on its corporate website about the identified activity at any
point during the specified period, and at least one standard industry publication corroborated
the firm’s activity at any point during this period; or (3) the firm provided information in a
corporate report or an SEC filing, or confirmed in a letter to us, that it had conducted the
relevant activity during this period. If none of these criteria were met, we did not list the firm as
“active” in our tables. We did not review the contracts or documents underlying the
transactions and activities reported in open sources and did not independently verify these
transactions and activities. We reviewed open source information to identify the reported
details of the activities. In cases where dates of activity were not specified in the reports, we
used the date of publication for the date of activity. We did not attempt to determine whether
the identified activities met the legal criteria for sanctionable activities under the Iran Sanctions
Act of 1996, as amended. 21 The Secretary of State is responsible for making such
determinations.

We sent a letter to each firm whose status we had listed as “active” or “insufficient information
available” in our January 2012 report on refined petroleum product sales or in our August 2011
report on commercial activities and who had not responded to our previous attempt to contact
them, to request comment on activities identified by those open source reviews. We
subsequently sent a letter to each firm for which we found at least three open source reports of
new activity during our current review period, to request comment on those activities. We
searched each firm’s official website or the Internet to identify its contact information. If we
were unable to confirm delivery of a letter to a firm or find a working address, we (1) e-mailed
the firm a letter containing the open source information we had identified and (2) made at least
three attempts to contact the firm by telephone during the normal business hours of its
headquarters location. As of December 3, 2012, 12 of the firms had responded. We have
incorporated their comments into our findings, as appropriate.

We listed a firm’s status as “withdrawn” if three separate open sources published during the
specified time period reported that the firm had ceased the activity and/or the firm notified us
that it had ceased the activity. If our only source of evidence that a firm had ceased the activity
was a notification to us from the firm, we listed the firm as “withdrawn” only if our open source
review found no new reports of the activity since our last report. If a firm was listed as
“withdrawn” in our last report, we continued to list it as “withdrawn” in this report if we did not


20
     Pub. L. No. 112-158.
21
     Pub. L. No. 104-172.



Page 11                                                           GAO-13-173R Iran Energy Sector
Enclosure I


identify three open source reports indicating that it had made sales of refined petroleum
products or engaged in commercial activities within the specified time period.

For the purposes of this report, we listed a firm’s status as “insufficient information available” if
our review of open sources published within the specified time period did not identify at least
three open source reports indicating whether the firm had continued or ceased selling refined
petroleum products to Iran or engaging in commercial activities in Iran’s energy sector. For
example, if a firm previously listed as “active” or “insufficient information available” was
identified in one or two open source reports as selling refined petroleum products to Iran
during the specified time period, we listed the firm’s status as “insufficient information
available.”

We conducted our work from October 2012 to December 2012 in accordance with all sections
of GAO’s Quality Assurance Framework that are relevant to our objectives. The framework
requires that we plan and perform the engagement to obtain sufficient and appropriate
evidence to meet our stated objective and discuss any limitations in our work. We believe that
the information and data obtained, and the analysis conducted, provide a reasonable basis for
any findings and conclusions.




Page 12                                                            GAO-13-173R Iran Energy Sector
Enclosure II


     Firms Reported in Open Sources to Have Sold Iran Refined Petroleum Products at
                 Some Point between January 2009 and September 2012

Table 5 compiles information on foreign firms that were reported in open sources published
between January 1, 2009 and September 30, 2012 to have sold refined petroleum products to
Iran at some point during that same time period. It includes information presented in our
September 2010 and January 2012 reports. 22 We did not attempt to determine whether the
activities for which the firms are listed in our reports met the legal criteria for sanctionable
activities under the Iran Sanctions Act of 1996, as amended. The Secretary of State is
responsible for making such determinations.

Table 5: Foreign Firms Reported in Open Sources to Have Sold Refined Petroleum Products to Iran at Some
Point between January 2009 and September 2012 and Comments Regarding Their Status

                                 Status in GAO’s   Status in GAO’s   Status in
                                 September 2010    January 2012      current
Firm                Countrya     report            report            GAO report     Comments
1. Sytrol           Syria        Not listed        Not listed        Active         Open sources reported that
                                                                                    the firm sold gasoline to Iran in
                                                                                    2012. The firm had not
                                                                                    commented on our findings as
                                                                                    of December 3, 2012.
2.   China Oil      China        Active            Active            Insufficient   Open sources published
                                                                     information    during our current period of
                                                                     available      review provided insufficient
                                                                                    information to classify the firm
                                                                                    as active or withdrawn. The
                                                                                    firm had not commented on
                                                                                    our findings as of December 3,
                                                                                    2012.
3.   Petróleos de   Venezuela    Not listed        Active            Insufficient   Open sources published
     Venezuela                                                       information    during our current period of
     S.A.                                                            available      review provided insufficient
                                                                                    information to classify the firm
                                                                                    as active or withdrawn. During
                                                                                    our previous reviews, open
                                                                                    sources reported that the firm
                                                                                    sold petroleum products to Iran
                                                                                    in 2011. The firm had not
                                                                                    commented on our findings as
                                                                                    of December 3, 2012.
4.   Unipec         China        Active            Active            Insufficient   Open sources published
                                                                     information    during the period of our current
                                                                     available      review provided insufficient
                                                                                    information to classify the firm
                                                                                    as active or withdrawn. The
                                                                                    firm had not commented on
                                                                                    our findings as of December 3,
                                                                                    2012.
5.   Zhuhai         China        Active            Active            Insufficient   Open sources published
     Zhenrong                                                        information    during the period of our current
                                                                     available      review provided insufficient
                                                                                    information to classify the firm
                                                                                    as active or withdrawn. The
                                                                                    firm had not commented on
                                                                                    our findings as of December 3,
                                                                                    2012.
6.   Emirates       UAE          Active            Insufficient      Withdrawn      There were no open source
     National Oil                                  information                      reports of the firm selling


22
  GAO, Firms Reported in Open Sources to Have Sold Iran Refined Petroleum Products between January 1, 2009,
and June 30, 2010, GAO-10-967R (Washington, D.C.: Sept. 3, 2010). GAO, Firms Reported in Open Sources to
Have Sold Iran Refined Petroleum Products Declined Since June 30, 2010, GAO-12-321R (Washington, D.C.: Jan.
24, 2012).


Page 13                                                                 GAO-13-173R Iran Energy Sector
Enclosure II


                                   Status in GAO’s   Status in GAO’s   Status in
                                   September 2010    January 2012      current
Firm                 Countrya      report            report            GAO report   Comments
       Company                                       available                      petroleum products to Iran
                                                                                    during the time period of our
                                                                                    current report. The firm notified
                                                                                    us that it had stopped selling
                                                                                    gasoline to Iran.
7.     Glencore      Switzerland   Withdrawnb        Withdrawn         Withdrawn    There were no open source
                                                                                    reports of the firm selling
                                                                                    petroleum products to Iran
                                                                                    during the time period of our
                                                                                    current report. During our
                                                                                    previous reviews, open
                                                                                    sources reported that the firm
                                                                                    sold gasoline to Iran in 2009
                                                                                    but stopped in 2009. The firm
                                                                                    confirmed these reports.
8.     Hin Leong     Singapore     Active            Insufficient      Withdrawn    There were no open source
       Trading                                       information                    reports of the firm selling
                                                     available                      petroleum products to Iran
                                                                                    during the time period of our
                                                                                    current report. The firm notified
                                                                                    us that it had stopped selling
                                                                                    gasoline to Iran.
9.     Independent   Kuwait        Withdrawnb        Withdrawn         Withdrawn    During our previous reviews,
       Petroleum                                                                    open sources reported that the
       Group (IPG)                                                                  firm stopped selling gasoline to
                                                                                    Iran in 2010. The firm
                                                                                    confirmed that it sold gasoline
                                                                                    to Iran in 2009 and 2010.
10. Litasco          Switzerland   Withdrawnb        Withdrawn         Withdrawn    During our previous reviews,
                                                                                    open sources reported that the
                                                                                    firm sold gasoline to Iran in
                                                                                    2009 and 2010 but stopped in
                                                                                    2010.
11. Petronas         Malaysia      Withdrawnb        Withdrawn         Withdrawn    There were no open source
                                                                                    reports of the firm selling
                                                                                    petroleum products to Iran
                                                                                    during the time period of our
                                                                                    current report. During our
                                                                                    previous reviews, open
                                                                                    sources reported that the firm
                                                                                    sold gasoline to Iran in 2009
                                                                                    and 2010 but stopped in 2010.
12. Reliance         India         Withdrawnb        Withdrawn         Withdrawn    There were no open source
    Industries                                                                      reports of the firm selling
                                                                                    petroleum products to Iran
                                                                                    during the time period of our
                                                                                    current report. The firm notified
                                                                                    us that it stopped selling
                                                                                    gasoline to Iran in May 2009,
                                                                                    and that its gasoline export
                                                                                    contracts prohibit buyers from
                                                                                    selling its gasoline to Iran.
13. Royal Dutch      Netherlands   Withdrawnb        Withdrawn         Withdrawn    There were no open source
    Shell                                                                           reports of the firm selling
                                                                                    petroleum products to Iran
                                                                                    during the time period of our
                                                                                    current report. The firm notified
                                                                                    us that it stopped selling
                                                                                    gasoline to Iran in October
                                                                                    2009.




Page 14                                                                  GAO-13-173R Iran Energy Sector
Enclosure II


                                                   Status in GAO’s   Status in GAO’s    Status in
                                                   September 2010    January 2012       current
Firm                         Countrya              report            report             GAO report      Comments
14. Total                    France                Withdrawnb        Withdrawn          Withdrawn       There were no open source
                                                                                                        reports of the firm selling
                                                                                                        petroleum products to Iran
                                                                                                        during the time period of our
                                                                                                        current report. The firm notified
                                                                                                        us that it stopped selling
                                                                                                        gasoline to Iran in May 2010.
15. Trafigura                Switzerland           Withdrawnb        Withdrawn          Withdrawn       There were no open source
                                                                                                        reports of the firm selling
                                                                                                        petroleum products to Iran
                                                                                                        during the time period of our
                                                                                                        current report. The firm notified
                                                                                                        us that it stopped selling
                                                                                                        gasoline to Iran in November
                                                                                                        2009. During our previous
                                                                                                        reviews, open sources
                                                                                                        reported that it stopped in
                                                                                                        2010.
16. Tupras                   Turkey                Withdrawnb        Withdrawn          Withdrawn       There were no open source
                                                                                                        reports of the firm selling
                                                                                                        petroleum products to Iran
                                                                                                        during the time period of our
                                                                                                        current report. The firm notified
                                                                                                        us that it stopped selling
                                                                                                        gasoline to Iran in July 2010.
17. Vitol                    Switzerland           Withdrawnb        Withdrawn          Withdrawn       There were no open source
                                                                                                        reports of the firm selling
                                                                                                        petroleum products to Iran
                                                                                                        during the time period of our
                                                                                                        current report. The firm notified
                                                                                                        us that it stopped selling
                                                                                                        gasoline to Iran in early 2010.
                                                                                                        During our previous reviews,
                                                                                                        open sources reported that it
                                                                                                        stopped in 2010.
Source: GAO analysis of open source information.

Notes: The firms are listed in alphabetical order by activity status in the current report.

For the purposes of this report, we listed a firm’s status as “active,” ”withdrawn,” or “insufficient information available.” We listed a
firm’s status as “active” if, for example, three open sources published within the specified time period reported that the firm sold
refined petroleum products to Iran during that same time period. We listed a firm’s status as ”withdrawn” if, for example, three
open sources published within the specified time period reported that it stopped selling refined petroleum products to Iran during
that same time period. We listed a firm’s status as “insufficient information available” if the review of open sources published within
the specified time period did not identify sufficient information to indicate either that the firm had continued to sell refined
petroleum products to Iran during the same time period (active), or that the firm had ceased making such sales (withdrawn). A
firm’s status in the current report is based on open source reports published from January 1, 2012 through September 30, 2012.
See enclosure I for the full scope and methodology.

We listed British Petroleum in our September 2010 report because at least three open sources reported that it sold refined
petroleum products to Iran at some point between January 1, 2009 and June 30, 2010, the period covered by our first review. The
firm notified us that it stopped selling gasoline to Iran in October 2008, but at the time we did not find open source corroboration of
the firm’s statement. After our report was issued, open sources confirmed the firm’s statement and indicated that the earlier open
source reports of the firm’s activity were incorrect. Because we did not find three open source reports of British Petroleum selling
refined petroleum products to Iran in any of our subsequent open source review time periods, we removed British Petroleum from
this list.
a
The country listed in this column is the physical location of the firm as reported in open sources.
b
 For firms listed as “withdrawn” in the September 2010 report, we found at least three open sources reporting that the firms had
sold refined petroleum products to Iran during the specified time period, but also subsequently found at least three open sources
reporting that the firms had ended sales of refined petroleum products to Iran during that same time period.




Page 15                                                                                       GAO-13-173R Iran Energy Sector
Enclosure III


     Firms Reported in Open Sources to Have Engaged in Commercial Activity in Iran’s
         Energy Sector at Some Point between January 2005 and September 2012

Table 6 compiles information on firms that were reported in open sources published between
January 1, 2005 and September 30, 2012 to have had commercial activity in Iran’s energy
sector at some point during that same time period. This table includes information presented in
our March 2010 and August 2011 reports. 23 We did not attempt to determine whether the
activities for which the firms are listed in our reports met the legal criteria for sanctionable
activities under the Iran Sanctions Act of 1996, as amended. The Secretary of State is
responsible for making such determinations.

Table 6: Foreign Firms Reported in Open Sources to Have Engaged in Commercial Activity in Iran’s Energy
Sector at Some Point between January 2005 and September 2012 and Comments Regarding Their Status

                                      Status in
                                      GAO’s       Status in     Status in
                                      March       GAO’s         GAO’s
                                      2010        August 2011   current
Firm                    Country a     report b    report        report        Comments
1. China National       China         Active      Active        Active        Open sources published during the
     Petroleum                                                                period of our current review reported that
     Corporation                                                              the firm has an interest in the project to
                                                                              develop the Azadegan Oil Field. The firm
                                                                              had not commented on our findings as of
                                                                              December 3, 2012.
2.   Daelim             South Korea   Active      Active        Active        Open sources published during the
                                                                              period of our current review provided
                                                                              insufficient reports to classify the firm as
                                                                              active or withdrawn. However, in
                                                                              response to our current review, the firm
                                                                              contacted us and confirmed its
                                                                              involvement in the development of the
                                                                              South Pars gas fields in Iran and its
                                                                              involvement in gas storage tanks for an
                                                                              LNG project at Tombak.
3.   Indian Oil         India         Active      Active        Active        Open sources, including the firm’s own
     Corporation Ltd.                                                         annual 2011-2012 report, published
                                                                              during the period of our current review
                                                                              reported that the firm has a 40% interest
                                                                              in the Farsi Block gas field. However, the
                                                                              firm also notified us that the exploration
                                                                              period under its exploration service
                                                                              contract had expired, that it had recently
                                                                              been in negotiations with National Iranian
                                                                              Oil Company (NIOC) but no agreements
                                                                              had been reached nor contracts signed
                                                                              for development of the field, and it had
                                                                              no plans to pursue further work on the
                                                                              Farsi Block.
4.   Oil India Ltd.     India         Active      Active        Active        Open sources published during the
                                                                              period of our current review, including
                                                                              the firm’s own 2011-2012 annual report,
                                                                              reported that the firm has a 20% interest
                                                                              in the Farsi Block gas field. However, the
                                                                              firm also notified us that the exploration
                                                                              period under its exploration service
                                                                              contract had expired, that it had recently
                                                                              been in negotiations with NIOC but no
                                                                              agreements had been reached nor
                                                                              contracts signed for development of the


23
  GAO, Firms Reported in Open Sources as Having Commercial Activity in Iran's Oil, Gas, and Petrochemical
Sectors, GAO-10-515R (Washington, D.C.: Mar. 23, 2010). GAO, Firms Reported in Open Sources as Having
Commercial Activity in Iran's Oil, Gas, and Petrochemical Sectors, GAO-11-855R (Washington, D.C.: Aug. 3, 2011).


Page 16                                                                     GAO-13-173R Iran Energy Sector
Enclosure III


                                       Status in
                                       GAO’s        Status in      Status in
                                       March        GAO’s          GAO’s
                                       2010         August 2011    current
Firm                    Country a      report b     report         report           Comments
                                                                                    field, and it had no plans to pursue
                                                                                    further work on the Farsi Block.
5.     ONGC Videsh      India          Active       Active         Active           Open sources published during the
       Ltd.                                                                         period of our current review reported that
                                                                                    the firm has a 40% interest in the Farsi
                                                                                    Block gas field. However, the firm also
                                                                                    notified us that the exploration period
                                                                                    under its exploration service contracts
                                                                                    had expired, that it had recently been in
                                                                                    negotiations with NIOC but no
                                                                                    agreements had been reached, nor
                                                                                    contracts signed for development of the
                                                                                    field, and it had no plans to pursue
                                                                                    further work on the Farsi Block.
6.     Sasol            South Africa   Not listed   Active         Active           Open sources published during the
                                                                                    period of our current review report that
                                                                                    the firm is active in a joint venture in Iran
                                                                                    but is looking to divest. The firm recently
                                                                                    stated that it is continuing to engage with
                                                                                    a number of interested parties in relation
                                                                                    to the firm’s possible divestiture.
7.     Sinopec          China          Active       Active         Active           Open sources published during the
                                                                                    period of our current review reported that
                                                                                    the firm has a 51% stake in Iran's
                                                                                    Yadavaran onshore oil field. The firm had
                                                                                    not commented on our findings as of
                                                                                    December 3, 2012.
8.     Amona            Malaysia       Active       Insufficient   Insufficient     Open sources published during the
                                                    information    information      period of our current review provided
                                                    available      available        insufficient reports to classify the firm as
                                                                                    active or withdrawn. The firm had not
                                                                                    commented on our findings as of
                                                                                    December 3, 2012.
9.     China National   China          Active       Active         Insufficient     Open sources published during the
       Offshore Oil                                                information      period of our current review provided
       Corporation                                                 available        insufficient reports to classify the firm as
                                                                                    active or withdrawn. The firm had not
                                                                                    commented on our findings as of
                                                                                    December 3, 2012.
10. INA                 Croatia        Active       Active         Insufficient     Open sources published during the
                                                                   information      period of our current review provided
                                                                   available        insufficient reports to classify the firm as
                                                                                    active or withdrawn. The firm notified us
                                                                                    that while it had entered into a service
                                                                                    contract for the exploration and
                                                                                    development of the Moghan 2 Oil Block
                                                                                    in 2008, it had not conducted any activity
                                                                                    under the contract and had no plans to
                                                                                    conduct any activity in Iran.
11. Oil and Natural       India        Active       Active         Insufficient     Open sources published during the
    Gas                                                            information      period of our current review provided
    Corporation                                                    available        insufficient reports to classify the firm as
    (ONGC)                                                                          active or withdrawn. The firm notified us
                                                                                    that it is not currently commercially active
                                                                                    with respect to any block, field, or project
                                                                                    in Iran.
12. Petrofield          Malaysia       Active       Insufficient   Insufficient     Open sources published during the
                                                    information    information      period of our current review provided
                                                    available      available        insufficient reports to classify the firm as
                                                                                    active or withdrawn. The firm had not
                                                                                    commented on our findings as of
                                                                                    December 3, 2012.
13. Petroleos de        Venezuela      Active       Active         Insufficient     Open sources published during the
    Venezuela S.A.                                                 information      period of our current review provided




Page 17                                                                           GAO-13-173R Iran Energy Sector
Enclosure III


                                     Status in
                                     GAO’s       Status in      Status in
                                     March       GAO’s          GAO’s
                                     2010        August 2011    current
Firm                 Country a       report b    report         report           Comments
                                                                available        insufficient reports to classify the firm as
                                                                                 active or withdrawn. The firm had not
                                                                                 commented on our findings as of
                                                                                 December 3, 2012.
14. Petronet LNG        India        Active      Insufficient   Insufficient     Open sources published during the
                                                 information    information      period of our current review provided
                                                 available      available        insufficient reports to classify the firm as
                                                                                 active or withdrawn. The firm had not
                                                                                 commented on our findings as of
                                                                                 December 3, 2012.
15. SKS Ventures     Malaysia        Active      Insufficient   Insufficient     Open sources published during the
                                                 information    information      period of our current review provided
                                                 available      available        insufficient reports to classify the firm as
                                                                                 active or withdrawn. The firm had not
                                                                                 commented on our findings as of
                                                                                 December 3, 2012.
16. Ashok Leyland    India (United   Active      Withdrawn      Withdrawn        Open sources published during the
    Project          Kingdom)                                                    period of our previous reviews reported
    Services                                                                     that the firm had withdrawn from
    (Hinduja                                                                     commercial activity in Iran. The firm
    Group)c                                                                      recently notified us that it had made no
                                                                                 binding commitments or investments with
                                                                                 respect to any oil or gas sector projects
                                                                                 in Iran.
17. Belneftekhim/    Belarus         Active      Active         Withdrawn        Open sources published during the
    Belarusneft                                                                  period of our current review reported that
                                                                                 the firm had withdrawn from all activity in
                                                                                 Iran. The firm confirmed to us that it had
                                                                                 stopped conducting commercial activity
                                                                                 in Iran.
18. Costain Oil,     United          Active      Withdrawn      Withdrawn        There were no open source reports of
    Gas & Process    Kingdom                                                     the firm conducting commercial activity in
    Ltd.                                                                         Iran during the time period of our current
                                                                                 report.
19. Daewoo           South Korea     Active      Withdrawn      Withdrawn        There were no open source reports of
    Shipbuilding &                                                               the firm conducting commercial activity in
    Marine                                                                       Iran during the time period of our current
    Engineering                                                                  report.
20. Edison           Italy           Active      Active         Withdrawn        Open sources published during the
                                                                                 period of our current review reported that
                                                                                 the firm had withdrawn from all activity in
                                                                                 Iran. The firm confirmed to us that it had
                                                                                 stopped conducting commercial activity
                                                                                 in Iran.
21. ENI              Italy           Active      Withdrawn      Withdrawn        There were no open source reports of
                                                                                 the firm conducting commercial activity in
                                                                                 Iran during the time period of our current
                                                                                 report.
22. Gazprom          Russia          Active      Insufficient   Withdrawn        Open sources published during the
                                                 information                     period of our current review reported that
                                                 available                       the firm had withdrawn from commercial
                                                                                 activity in Iran. The firm notified us that it
                                                                                 had no current investment in Iran's
                                                                                 energy sector.
23. GS               South Korea     Active      Withdrawn      Withdrawn        There were no open source reports of
                                                                                 the firm conducting commercial activity in
                                                                                 Iran during the time period of our current
                                                                                 report.
24. Haldor Topsoe    Denmark         Active      Withdrawn      Withdrawn        There were no open source reports of
                                                                                 the firm conducting commercial activity in
                                                                                 Iran during the time period of our current
                                                                                 report.
25. Hyundai Heavy    South Korea     Active      Active         Withdrawn        There were no open source reports of
    Industries                                                                   the firm conducting commercial activity in




Page 18                                                                        GAO-13-173R Iran Energy Sector
Enclosure III


                                    Status in
                                    GAO’s        Status in      Status in
                                    March        GAO’s          GAO’s
                                    2010         August 2011    current
Firm                  Country a     report b     report         report        Comments
                                                                              Iran during the time period of our current
                                                                              report. The firm notified us that it had
                                                                              stopped conducting commercial activity
                                                                              in Iran.
26. Inpex             Japan         Active       Withdrawn      Withdrawn     There were no open source reports of
                                                                              the firm conducting commercial activity in
                                                                              Iran during the time period of our current
                                                                              report.
27. JGC               Japan         Active       Withdrawn      Withdrawn     There were no open source reports of
    Corporation                                                               the firm conducting commercial activity in
                                                                              Iran during the time period of our current
                                                                              report.
28. Lukoil            Russia        Active       Withdrawn      Withdrawn     There were no open source reports of
                                                                              the firm conducting commercial activity in
                                                                              Iran during the time period of our current
                                                                              report.
29. LyondelBasell     Netherlands   Active       Withdrawn      Withdrawn     There were no open source reports of
                                                                              the firm conducting commercial activity in
                                                                              Iran during the time period of our current
                                                                              report.
30. OMV               Austria       Active       Active         Withdrawn     There were no open source reports of
                                                                              the firm conducting commercial activity in
                                                                              Iran during the time period of our current
                                                                              report. The firm notified us that it had
                                                                              stopped conducting commercial activity
                                                                              in Iran.
31. Petrobras         Brazil        Active       Withdrawn      Withdrawn     There were no open source reports of
                                                                              the firm conducting commercial activity in
                                                                              Iran during the time period of our current
                                                                              report.
32. PGNiG             Poland        Active       Insufficient   Withdrawn     There were no open source reports of
                                                 information                  the firm conducting commercial activity in
                                                 available                    Iran during the time period of our current
                                                                              report. The firm notified us that it had no
                                                                              commercial activity in Iran.
33. PTT Exploration   Thailand      Active       Withdrawn      Withdrawn     There were no open source reports of
    & Production                                                              the firm conducting commercial activity in
                                                                              Iran during the time period of our current
                                                                              report.
34. Repsol            Spain         Active       Withdrawn      Withdrawn     There were no open source reports of
                                                                              the firm conducting commercial activity in
                                                                              Iran during the time period of our current
                                                                              report.
35. Royal Dutch       Netherlands   Active       Withdrawn      Withdrawn     There were no open source reports of
    Shell                                                                     the firm conducting commercial activity in
                                                                              Iran during the time period of our current
                                                                              report.
36. Snamprogetti      Italy         Active       Withdrawn      Withdrawn     There were no open source reports of
                                                                              the firm conducting commercial activity in
                                                                              Iran during the time period of our current
                                                                              report.
37. Sonangol          Angola        Not listed   Active         Withdrawn     There were no open source reports of
                                                                              the firm conducting commercial activity in
                                                                              Iran during the time period of our current
                                                                              report. The firm notified us that it had
                                                                              stopped conducting commercial activity
                                                                              in Iran.
38. StatoilHydro      Norway        Active       Withdrawn      Withdrawn     There were no open source reports of
                                                                              the firm conducting commercial activity in
                                                                              Iran during the time period of our current
                                                                              report.
39. Tecnimont         Italy         Active       Insufficient   Withdrawn     There were no open source reports of
                                                 information                  the firm conducting commercial activity in
                                                 available                    Iran during the time period of our current




Page 19                                                                     GAO-13-173R Iran Energy Sector
Enclosure III


                                                   Status in
                                                   GAO’s       Status in      Status in
                                                   March       GAO’s          GAO’s
                                                   2010        August 2011    current
Firm                           Country a           report b    report         report            Comments
                                                                                                report. The firm notified us that it had no
                                                                                                commercial activity in Iran.
40. Total                      France              Active      Withdrawn      Withdrawn         There were no open source reports of
                                                                                                the firm conducting commercial activity in
                                                                                                Iran during the time period of our current
                                                                                                report.
41. Turkish                    Turkey              Active      Withdrawn      Withdrawn         There were no open source reports of
    Petroleum                                                                                   the firm conducting commercial activity in
    Company                                                                                     Iran during the time period of our current
                                                                                                report.
42. Uhde                       Germany             Active      Withdrawn      Withdrawn         There were no open source reports of
                                                                                                the firm conducting commercial activity in
                                                                                                Iran during the time period of our current
                                                                                                report.
Source: GAO analysis of open source information.


Notes: The firms are listed in alphabetical order by activity status in the current report.

For the purposes of this report, we listed a firm’s status as “active,” “withdrawn,” or “insufficient information available.” We listed a
firm’s status as ”active” if, for example, three open sources published within the specified time period reported that the firm had
engaged in commercial activities in Iran’s energy sector during that same time period. We listed a firm’s status as ”withdrawn” if,
for example, three open sources published within the specified time period reported that it withdrew from its commercial activities
in Iran’s energy sector during that same time period. We listed a firm’s status as “insufficient information available” if the review of
open sources published within the specified time period did not identify three open sources reporting either that the firm had
continued its commercial activities in Iran’s energy sector (active) or that it had ceased its activities (withdrawn). A firm’s status in
the current report is based on open source reports published from June 1, 2011 through September 30, 2012. See enclosure I for
the full scope and methodology.
a
    The country listed in this column is the physical location of the firm as reported in open sources.
b
 Because ITRSHRA mandated that we provide information since January 1, 2009, we have included information from the 2010
report, which aggregated the data between 2005 and 2009.
c
 In response to our request for comment, Ashok Leyland Project Services (ALPS) in India stated that it, rather than Hinduja Group
in the United Kingdom, should be identified as a firm appearing in the table. According to the firm, ALPS is an independent board-
managed company.




Page 20                                                                                       GAO-13-173R Iran Energy Sector
Enclosure IV


     Foreign Firms Sanctioned by State under the Iran Sanctions Act of 1996 as Amended

Since the enactment of the Comprehensive Iran Sanctions, Accountability, and Divestment Act
of 2010, the Secretary of State has imposed sanctions under the Iran Sanctions Act of 1996, as
amended, on 14 firms for the sale of refined petroleum products to Iran or for investment in
Iran’s oil, gas, and petrochemical sectors. 24 In October 2010 and April 2011, State imposed
sanctions on Naftiran Intertrade Company and Belarusneft, respectively. In September 2011,
State imposed sanctions against Allvale Maritime Inc., Associated Shipbroking, Petrochemical
Commercial Company International, Petróleos de Venezuela S.A., Royal Oyster Group, Société
Anonyme Monégasque D’Administration Maritime Et Aérienne, Speedy Ship, Tanker Pacific
Management Pte. Ltd. On January 12, 2012, State imposed sanctions on Zhuhai Zhenrong,
FAL Oil Company Limited, and Kuo Oil (S) Pte. Ltd., and on August 10, 2012, on Sytrol.
According to State, the firms were sanctioned for the following reasons:

      •   Petrochemical Commercial Company International, Royal Oyster Group, and Speedy
          Ship were among the largest current suppliers of refined petroleum products to Iran and
          all three regularly engaged in deceptive practices in order to ship these products to Iran
          and evade U.S. sanctions.

      •   Allvale Maritime Inc., Associated Shipbroking, Société Anonyme Monégasque
          D’Administration Maritime Et Aérienne, and Tanker Pacific Management were
          sanctioned for their roles in a September 2010 transaction that provided a tanker valued
          at $8.65 million to the Islamic Republic of Iran Shipping Lines, an entity that has been
          determined to have supported Iran's nuclear and missile programs.

      •   Petróleos de Venezuela S.A., the state-owned oil company of Venezuela, delivered at
          least two cargoes of reformate, a blending component that improves the quality of
          gasoline, to Iran between December 2010 and March 2011, worth approximately $50
          million.

      •   Zhuhai Zhenrong, the largest supplier of refined petroleum products to Iran, brokered the
          delivery of over $500 million in gasoline to Iran between July 2010 and January 2011.

      •   FAL Oil Company Limited, a large independent energy trader based in the UAE,
          provided over $70 million in refined petroleum to Iran in multiple shipments in late 2010.

      •   Kuo Oil (S) Pte. Ltd., an energy trading company, provided over $25 million in refined
          petroleum to Iran between late 2010 and early 2011.

      •   Belarusneft and Naftiran Intertrade Company were sanctioned for their investment in
          Iran’s energy sector.



24
  See Public Notice 8040, 77 Fed. Reg. 59034 (Sept. 25, 2012) (imposing sanctions on Sytrol). See also Public
Notice 7197, 75 Fed. Reg. 62916 (Oct. 13, 2010) (imposing sanctions on Naftiran Intertrade Company), Public Notice
7408, 76 Fed. Reg. 18821 (Apr. 5, 2011) (imposing sanctions on Belarusneft), Public Notice 7585, 76 Fed. Reg.
56866 (Sept. 14, 2011) (imposing sanctions on Allvale Maritime Inc., Associated Shipbroking, Petrochemical
Commercial Company International, Petróleos de Venezuela S.A., Royal Oyster Group, Société Anonyme
Monégasque D'Administration Maritime Et Aérienne, Speedy Ship, and Tanker Pacific Management (Singapore) Pte.
Ltd.), Public Notice 7776, 77 Fed. Reg. 4389 (Jan. 27, 2012) (imposing sanctions on FAL Oil Company Limited, Kuo
Oil (S) Pte. Ltd., and Zhuhai Zhenrong Company).


Page 21                                                                   GAO-13-173R Iran Energy Sector
Enclosure IV


     •   Sytrol, Syria’s state-run oil company, sold 33,000 metric tons of gasoline worth $36
         million to Iran.

The sanctions prohibit, among other things, various commercial activities in the United States or
with U.S.-based firms. 25 To identify firms that sell refined petroleum products to Iran, State
officials indicated that State collects and reviews information from numerous sources, including
open source information, but relies on information from numerous intelligence organizations,
including State’s Bureau of Intelligence and Research, the Office of the Director of National
Intelligence, the Central Intelligence Agency, and the Office of Naval Intelligence.




25
  The available sanctions include prohibitions on: (1) export assistance from the Export-Import Bank of the United
States; (2) licenses for export of U.S. military, “dual use,” or nuclear-related goods or technology; (3) private U.S.
bank loans exceeding $10 million in any 12-month period; (4) designation as a primary dealer in U.S. Government
debt instruments or service as a repository of U.S. Government funds, if the sanctioned person is a financial
institution; (5) procurement contracts with the U.S. Government; (6) foreign exchange transactions subject to U.S.
jurisdiction; (7) banking transactions, involving any interest of the sanctioned person, that are subject to U.S.
jurisdiction; (8) transactions with respect to property and interests in property subject to U.S. jurisdiction; (9) imports
from the sanctioned person, in accordance with the International Emergency Economic Powers Act; (10) ban on
investment in equity or debt of the sanctioned person; (11) exclusion (visa ban) of corporate officers or principals of,
or a shareholder with a controlling interest in, the sanctioned entity; or (12) sanctions (any of the above) on principal
executive officers of sanctioned entities.



Page 22                                                                          GAO-13-173R Iran Energy Sector
Enclosure V


                         GAO Contact and Staff Acknowledgments

GAO Contact

Thomas Melito, (202) 512-9601 or melitot@gao.gov

Staff Acknowledgments

In addition to the contact named above, Pierre Toureille (Assistant Director), Jeffrey Baldwin-
Bott, JoAnna Berry, Debbie Chung, Martin de Alteriis, Grace Lui, Michael Maslowski, and David
Schneider made key contributions to this report.




(320946)


Page 23                                                       GAO-13-173R Iran Energy Sector
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