Iranian Sanctions Information.

Effects of Comprehensive Iran Sanctions, Accountability, and Divestment Act

In response to the new U.S. legislation, business are scaling back their investments in the Iranian energy sector and suspending their ties with Iran. Below is a list of companies that have announced that they are ceasing business in Iran and other useful data on the effect on sanctions on Iran. This information is public knowledge.

April 30, 2009 - The Iran Refined Petroleum Sanctions Act (IRPSA) is introduced in the House

December 15, 2009 – IRPSA passes the House

June 9, 2010 – UN Security Council passes new sanctions against Iran (Res 1929)

June 17, 2010 – EU announces guidelines for new sanctions on Iran

June 24, 2010 – House and Senate pass CISADA (408-8 and 99-0)

July 1, 2010 – Obama signs CISADA into law

July 26, 2010 – EU passes new sanctions on Iran, Canada passes new sanctions

July 29, 2010 – Australia imposes sanctions against Iran

Sept. 3, 2010 – Japan imposes sanctions on Iran.

Sept. 8, 2010 – South Korea imposes sanctions on Iran.

Energy Companies and Energy Sector (including construction)

• At the end of June, France’s Total announced that it had suspended all sales of gasoline and refined petroleum products to Iran. In April, Total announced that they would stop selling petroleum to Iran if the United States passed legislation barring the activity.

• At the end of June, Spain's Repsol announced that it had pulled out of a contract to develop part of the South Pars gas field.

• South Korean construction company GS Engineering & Construction announced at the end of June that it has suspended its $1.2 billion project to sweeten the natural gas from South Pars.

o Global Insight states that this project is worth $1.89 billion.

• At the beginning of July, BP announced that it will stop refueling Iranian airplanes. In a statement, BP said, “We fully comply with any international sanctions in any areas in which we operate.” Under the new U.S. sanctions legislations, companies that supply Iran with refined petroleum products (including jet fuel) are liable for sanction.

o BP confirmed that the contract to supply jet fuel to Iran Air at Germany’s Hamburg airport expired at the end of June and was not renewed.

• At the beginning of July, industry sources reported that Royal Dutch Shell will not renew its contracts to provide Iran Air with jet fuel. Most of these contracts have already expired. Shell had previously stopped supplying gasoline to Iran back in March.

• In mid-July, the Iranian Revolutionary Guard Corps’ construction firm Khatam al-Anbiya announced that it was pulling contracts worth $2.09 billion to develop the two phases of the South Pars field due to international sanctions. Because these sanctions target the IRGC, the construction firm blamed these sanctions for the failure to secure the partnership of international energy firms.

• Europe’s fourth-largest oil refiner Turkish company Tupras announced, in the middle of August, that it would no longer sell fuel products to Iran in light of U.S. and EU sanctions. Tupras purchases about one third of its crude oil from Iran, and in June Tupras provided half of Iran’s gasoline needs. Since that time, sales to Iran have dropped more than 70%.

• In the middle of August, the energy consortium behind the Nabucco gas pipeline announced that they decided not to move forward with plans to source Iranian natural gas for the pipeline. The consortium includes Austria's OMV AG, Romania's Transgaz, Bulgaria's Bulgargaz, Hungary's MOL Nyrt. and Germany's RWE AG.

o Spokesman Christian Dolezal explained, “Nabucco is not planning an Iranian feeder line any

more because Nabucco is acting in full accordance with international laws and regulations.”

• At the end of August, LyondellBasell Industries NV announced that it would end its business operations in Iran, Syria, and Sudan in order to avoid U.S. sanctions. Dutch-based LyondellBasell is one of the world’s biggest plastic and chemical producers. The company will cease all licensing of its propriety technology and services to Iranian petrochemical companies which in turn use the products to produce plastics and other items from natural gas.

• At the end of August, Australian engineering company WorleyParsons said that it would complete existing contracts but would not sign any new contracts with Iran. WorleyParsons was involved in construction in Iran’s energy sector.

• Iran has been forced to curb its ambitions to become an exporter of liquefied natural-gas because Iran’s inability to access Western technology due to sanctions.

• At the beginning of September, Germany’s Linde AG announced that it would halt all business operations in Iran. Previously, in the middle of August, the company announced that while it had sold Iran LNG technologies in the past, Linde AG was not considering new business in Iran.

• At the beginning of September, Iranian Oil Minister Masoud Mir-Kazemi announced that Iran had achieved self-sufficiency in the production of refined petroleum. Because many analysts are skeptical about Iran’s ability to actually convert petrochemical facilities for the production of gasoline as quickly as Iran has claimed, the statement demonstrates Iran’s concern about the need to reassure its public given the difficulties it is facing in importing gasoline.

o This decision – to convert petrochemical facilities for the production of gasoline – is not sustainable long-term, according to analysis by Samuel Ciszuk at Global Insight, and it risks the long-term destruction and short-term depreciation of Iran’s petrochemical industry.

• Previously, Iran had been pursuing a large refinery capacity expansion program with the aim of self-sufficiency in refined petroleum products by 2012. However, construction of the new refineries has fallen at least two years behind schedule due to Iran’s inability to obtain crucial equipment and technology from foreign firms and inability to finance the projects, according to analysis by Global Insight.

• According to a report by Juan Zarate in the National Review, the State Department estimates that $50-60 billion worth of upstream energy-development projects in Iran have been terminated or put on hold over the past few years.

• In the middle of September, the European energy companies behind the planned Trans-Adriatic Pipeline (TAP) stated that the pipeline will not transport Iranian gas. In 2008, Switzerland's EGL, Germany's E.ON Ruhrgas and Norway's Statoil had signed a contract to buy gas from Iran’s NIGEC.

• At the end of September, Germany’s largest steelmaker ThyssenKrupp announced that it would freeze all new business with Iran immediately and terminate existing contracts as soon as possible. Chief executive Ekkehard Schulz explained that this decision was made in order to “support[] the sanctions policies” of Germany, the EU, and the United States. The company also stated that the decision “goes beyond current sanctions.” ThyssenKrupp had been involved in engineering projects for cement factories.

Insurance and shipping

• At the beginning of July, Lloyd’s of London – a major insurance market which provides 8-10% of the global maritime insurance – announced that it would restrict insurance for any vessels shipping petroleum to Iran.

o The following week, on July 9, Lloyd's General Counsel Sean McGovern explained this change in policy stating, “The U.S. is an important market for Lloyd's and, in recognition of this, the market will not insure or reinsure refined petroleum going into Iran.”

• According to a report in The Washington Post, dozens of Iranian ships have been denied insurance coverage in the month of July. “Iranian-flagged ships are facing problems all over the world as they currently have no insurance coverage because of the new sanctions," said Mohammad Rounaghi, deputy manager of Sea Pars, an Iranian company that provides services for international ship owners and maritime insurance companies.

• In July, IRISL had been refused insurance coverage by several companies according to a representative of a Dutch maritime insurer.

• In July, INTERTANKO, a shipping association whose members own the majority of the world’s tanker fleet, drafted a clause for its members to use in their contracts to allow the charter party to refuse to ship petroleum to Iran.

o According to Global Insight, this cause was included in contracts as early as March 2010.

• In July, BIMCO, the world’s largest ship owners’ association introduced a clause into its contracts allowing its members to refuse shipment to Iran.

• In July, UK P&I Club, a leading Protection and Indemnity insurance provider, said that its directors can terminate the insurance of members who have “exposed or will expose the club to a material risk of sanction.”

• At the beginning of August, Lloyd’s Market Association announced that it had drafted a clause in its contracts to ensure that its underwriters do not violated UN, US, and EU Iran sanctions.

o “Underwriters have taken steps to ensure they do not contravene the sanctions. One of the ways of doing that is to write carefully the allowed business using an appropriate exclusion or limitation clause,” Neil Roberts, a senior technical executive with the LMA, told Reuters.

Financial

• At the end of August, Head of the Central Bank of Iran Mahmoud Bahmani announced that Iran had withdrawn all assets from European banks in order to avoid international sanctions

• In August, the head of Bank Saderat said in comments on the bank’s website that $432 million worth of assets had been frozen in Europe.

• At the beginning of September, banking executives reported that most banks in the UAE have stopped all money transfers to Iran “in all currencies,” according to a report in Agence France Presse.

• Vice President of the Iranian Business Council in Dubai reported that trade between Iran and Dubai “has been reduced by 50%” as compared to before sanctions.

• The UAE central bank ordered the freezing of 41 bank accounts, and Dubai closed the offices of 40 Iranian firms suspected of violating sanctions.

• At the beginning of September, the UAE central bank asked the country’s banks to start detailing remittances sent to Iran in order to study the impact of sanctions.

• According to a report in The Financial Times, following the imposition of sanctions by Japan and South Korean, Chinese banks will likely be the only source willing to provide financing for the Iranian energy trade.

• Younes Hormozi, chairman of Bank Mellat's Turkish unit, told Reuters, that several Turkish banks have halted financial trade with Iran in order to maintain their relationships with the United States and the EU. Turkish banks are important source of euros for the Iranian economy.

Oil and gasoline trade

• In July, only three cargoes of gasoline were imported into Iran, according to documents obtained by Reuters. Traditionally, during the summer, Iran imports 11-13 cargoes per month. The three cargoes were supplied by Turkish refiners Tupras and Unipec and China’s Sinopec. One more cargo from Venezuela was expected to arrive at the end of the month.

• According to a report in Reuters, in the middle of July, the owner of a gasoline tanker refused to allow the vessel – reportedly the Liberian flagged oil tanker the Lia – to sail from Turkey to Iran.

• INTERTANKO’s managing director Peter Swift said, “There are many tanker owners who have stopped trading refined products to Iran in line with sanctions.”

• According to the International Energy Agency, in July, Iran imported half of the amount of petroleum that they had imported in May.

• Turkey’s gasoline exports to Iran dropped by 74% in July.

• The International Energy Agency reported that as a result of sanctions, Iran has been forced to pay a 25% premium over the market prices for petroleum products because many companies are refusing to sell to Iran.

• Chinese imports of crude oil from Iran declined by 13 million barrels in June as compared to the same time last year.

• Vijay Mukherji, a researcher with Energy Market Consultants, reported that Iran’s imports have dropped 50% between May and July. In May, Iran imported 120,000 bpd whereas in July, Iran only imported 60,000 bpd.

• Reuters reported that shipping sources say that ships carrying refined petroleum to Iran are facing greater scrutiny at ports in the UAE and are seeking alternative ports.

• Between January and September, Iran exported only one cargo of fuel oil to China whereas Iran had been exporting 2-3 cargos per month. The lower demand throughout Asia has also forced Iran to sell at much lower prices.

• Iran is facing difficulties selling crude oil because banks are refusing to issue letters of credit, shipping companies are refusing to send tankers to Iranian oil terminals, and insurance companies are refusing to insure the cargos, according to a report in The Financial Times.

• According to a report in Global Insight, Iran’s petrochemical sector is having trouble exporting products due to international sanctions.

• According to Reuters, Iran's gasoline imports for August were down by almost 90% from a year ago.

Other

• At the beginning of August, Toyota Motor Corp announced that it suspended auto exports to Iran because of U.S. sanctions. According to a report in Nikkei business daily, while the company’s sales did not violate U.S. sanctions, it decided to stop shipments in order to avoid any scrutiny from the U.S. government. A week prior, on August 3, Japan approved measures to implement the new UN Security Council resolution on Iran.

• South Korea’s Kia Motors announced, in September following Seoul’s implementation of sanctions against Iran, that the company had suspended all exports including spare parts to Iran in August. One Kia car, The Pride, makes up about 30-40 percent of all vehicles on the road in Iran.

• According to a survey by the Small and Medium Business Administration in South Korea, three-quarters of small and mid-sized exporters have partially (48%) or totally (28%) halted shipments to Iran following Seoul’s imposition of sanctions. The companies cited the fear that they would be unable to receive payments as the reason for the cut-off.

Bottom line: YOU need to know this. No one is a fully-informed voter, but we must do the best we can with what we have. I'm learning the importance of collaboration, integrity and respect while here in DC, and I wanted to share that bit with you.