GAO-13-173R Iran Energy Sector

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

 

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.

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 

 

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.

United States Government Accountability Office

Washington, DC 20548
Page 2 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

 

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.

 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 

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 3 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 4 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

 

9

Central Intelligence Agency, World Factbook, 

The President, who 

delegated certain authorities under the act to the Secretary of State, may waive the imposition 

https://www.cia.gov/library/publications/the-worldfactbook/geos/ir.html, accessed on November 14, 2012. 

10IHS 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.

11Pub. L. No. 112-158, §§ 201-208.

 

12Pub. L. No. 104-172, § 5(a), as amended.

13Pub. 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.

 

14Pub. 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 5 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 stateowned 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 

report

Status in current GAO 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). 

 

15Pub. 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). 

 

16Public Notice 8040, 77 Fed. Reg. 59034 (Sept. 25, 2012). 
Page 6 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 

Firm Countrya 

Status in GAO’s January 2012 

report Status in current GAO report

1. China Oil China Active Insufficient information available

2. Petróleos de 

Venezuela S.A.

Venezuela Active Insufficient information available

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

Firm Countrya

Status in GAO’s August 

2011 report

Status in current GAO 

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. 

 

17For 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 7 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

Firm Countrya

Status in GAO’s August 

2011 report Status in current GAO report 

1. Amona Malaysia Insufficient information 

available

Insufficient information 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 

(ONGC)

India Active Insufficient information available

5. Petrofield Malaysia Insufficient information 

available

Insufficient information available

6. Petróleos de Venezuela S.A. Venezuela Active Insufficient information available

7. Petronet LNG India Insufficient information 

available

Insufficient information available

8. SKS Ventures Malaysia Insufficient information 

available

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 

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 8 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 9 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
Enclosure I

Page 10 GAO-13-173R Iran Energy Sector

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

 

18GAO, 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).

 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 Englishlanguage 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 

19GAO, 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). 
Enclosure I

Page 11 GAO-13-173R Iran Energy Sector

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.
Enclosure I

Page 12 GAO-13-173R Iran Energy Sector

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.
Enclosure II 

Page 13 GAO-13-173R Iran Energy Sector

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

Firm Countrya

Status in GAO’s 

September 2010 

report

Status in GAO’s 

January 2012 

report

Status in 

current 

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 

information 

available

Open sources published

during our current period of 

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 

S.A. 

Venezuela Not listed Active Insufficient 

information 

available

Open sources published 

during our current period of 

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 

information 

available

Open sources published 

during the period of our current 

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 

Zhenrong 

China Active Active Insufficient 

information 

available

Open sources published 

during the period of our current 

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 

National Oil 

UAE Active Insufficient 

information 

Withdrawn There were no open source 

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). 
Enclosure II 

Page 14 GAO-13-173R Iran Energy Sector

Firm Countrya

Status in GAO’s 

September 2010 

report

Status in GAO’s 

January 2012 

report

Status in 

current 

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 

Trading

Singapore Active Insufficient 

information 

available

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 had stopped selling 

gasoline to Iran.

9. Independent 

Petroleum 

Group (IPG) 

Kuwait Withdrawnb Withdrawn Withdrawn During our previous reviews, 

open sources reported that the 

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 

Industries 

India 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 2009, 

and that its gasoline export 

contracts prohibit buyers from 

selling its gasoline to Iran. 

13. Royal Dutch 

Shell

Netherlands 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 October 

2009. 
Enclosure II 

Page 15 GAO-13-173R Iran Energy Sector

Firm Countrya

Status in GAO’s 

September 2010 

report

Status in GAO’s 

January 2012 

report

Status in 

current 

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. 
Enclosure III

Page 16 GAO-13-173R Iran Energy Sector

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 

Firm Country a

Status in 

GAO’s 

March 

2010 

report b

Status in 

GAO’s 

August 2011 

report

Status in 

GAO’s 

current 

report Comments

1. China National 

Petroleum 

Corporation

China Active Active Active Open sources published during the 

period of our current review reported that 

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 

Corporation Ltd.

India Active Active Active Open sources, including the firm’s own 

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). 
Enclosure III

Page 17 GAO-13-173R Iran Energy Sector

Firm Country a

Status in 

GAO’s 

March 

2010 

report b

Status in 

GAO’s 

August 2011 

report

Status in 

GAO’s 

current 

report Comments

field, and it had no plans to pursue 

further work on the Farsi Block.

5. ONGC Videsh 

Ltd.

India Active Active Active Open sources 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 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 

information 

available

Insufficient 

information 

available

Open sources published during the 

period of our current review provided 

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 

Offshore Oil 

Corporation

China Active Active Insufficient 

information 

available

Open sources published during the 

period of our current review provided 

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 

information 

available

Open sources published during the 

period of our current review provided 

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 

Gas 

Corporation 

(ONGC)

 India Active Active Insufficient 

information 

available

Open sources published during the 

period of our current review provided 

insufficient reports to classify the firm as 

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 

information 

available

Insufficient 

information 

available

Open sources published during the 

period of our current review provided 

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 S.A.

Venezuela Active Active Insufficient 

information 

Open sources published during the 

period of our current review provided 
Enclosure III

Page 18 GAO-13-173R Iran Energy Sector

Firm Country a

Status in 

GAO’s 

March 

2010 

report b

Status in 

GAO’s 

August 2011 

report

Status in 

GAO’s 

current 

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 

information 

available

Insufficient 

information 

available

Open sources published during the 

period of our current review provided 

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 

information 

available

Insufficient 

information 

available

Open sources published during the 

period of our current review provided 

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 

Project 

Services 

(Hinduja 

Group)c

India (United 

Kingdom)

Active Withdrawn Withdrawn Open sources published during the 

period of our previous reviews reported 

that the firm had withdrawn from 

commercial activity in Iran. The firm 

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/

Belarusneft

Belarus 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. 

18. Costain Oil, 

Gas & Process 

Ltd.

United 

Kingdom

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.

19. Daewoo 

Shipbuilding & 

Marine 

Engineering

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. 

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 

information 

available

Withdrawn Open sources published during the 

period of our current review reported that 

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 

Industries

South Korea Active Active Withdrawn There were no open source reports of 

the firm conducting commercial activity in 
Enclosure III

Page 19 GAO-13-173R Iran Energy Sector

Firm Country a

Status in 

GAO’s 

March 

2010 

report b

Status in 

GAO’s 

August 2011 

report

Status in 

GAO’s 

current 

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 

Corporation

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.

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 

information 

available

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 no 

commercial activity in Iran.

33. PTT Exploration 

& Production

Thailand 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. 

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 

Shell

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.

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 

information 

available

Withdrawn There were no open source reports of 

the firm conducting commercial activity in 

Iran during the time period of our current 
Enclosure III

Page 20 GAO-13-173R Iran Energy Sector

Firm Country a

Status in 

GAO’s 

March 

2010 

report b

Status in 

GAO’s 

August 2011 

report

Status in 

GAO’s 

current 

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 

Petroleum 

Company

Turkey 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. 

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 boardmanaged company.
Enclosure IV 

Page 21 GAO-13-173R Iran Energy Sector

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).
Enclosure IV 

Page 22 GAO-13-173R Iran Energy Sector

• 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

 

25The 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.

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.
Enclosure V

Page 23 GAO-13-173R Iran Energy Sector

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 BaldwinBott, JoAnna Berry, Debbie Chung, Martin de Alteriis, Grace Lui, Michael Maslowski, and David 

Schneider made key contributions to this report.

(320946)
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