Page 1 GAO-14-218R Iranian Commercial Activities

441 G St. N.W.

Washington, DC 20548

January 7, 2014

Congressional Committees

Iranian Commercial Activities: Foreign Firms Reported to Have Engaged in Certain 

Activities Involving Iran’s Energy or Communications Sectors

Iran’s economy and government rely heavily on revenues from its oil and gas industry. Iran is 

the fourth-largest holder of proven oil reserves in the world, and petroleum accounts for 

approximately 80 percent of Iran’s exports.1 Although previously heavily dependent on foreign 

sources of refined petroleum products, Iran has significantly decreased its gasoline import 

dependence in part by increasing its domestic refining capacity. Iran has also restricted free 

speech. These restrictions include blocking access to telecommunications. The Iran Threat 

Reduction and Syria Human Rights Act of 2012 and Senate reports 111-201 and 112-26 contain 

recurring mandates for GAO to report on firms engaging in certain types of commercial activities 

with Iran.2 Since 2010, in response to these mandates and other requests, we have issued a 

series of reports on foreign firms reported to have engaged in commercial activities in Iran’s 

energy sector, sold refined petroleum products to Iran, or exported technologies to Iran for 

blocking telecommunications.3

This report updates our prior reports by identifying any foreign firms reported to have (1) 

engaged in commercial activity in Iran's energy sector between October 1, 2012, and November 

7, 2013; (2) sold refined petroleum to Iran between October 1, 2012, and November 7, 2013; or 

(3) exported technology to Iran between December 16, 2012, and November 7, 2013, for 

telecommunications blocking. The report also identifies any firms that had U.S. contracts, 

awards, or purchasing agreements while having been reported to have engaged in such 

activities.4 In addition, enclosures II and III to this report update the activity status for firms that 

we previously identified as having been reported to be engaged in such activities. 

To accomplish our first three objectives, we used information published in open sources on or 

before November 7, 2013, updating information included in our prior reports. These open 

sources consisted of industry and trade publications, corporate reports and statements, and 

U.S. Securities and Exchange Commission (SEC) filings. On the basis of the open-source 

information, we categorized firms as “Active,” “Insufficient information available,” or 

 1

Central Intelligence Agency, World Factbook, https://www.cia.gov/library/publications/the-worldfactbook/geos/ir.html, accessed on November 23, 2013.

2

Pub. L. No. 112-158, 126 Stat. 1214. S. Rep. No. 111-201 (2010) and S. Rep. No. 112-26 (2011).

3

For example, see GAO, Firms Reported to Have Sold Iran Refined Petroleum Products or Engaged in Commercial 

Activities in Iran’s Energy Sector, GAO-13-173R (Washington, D.C.: Dec. 7, 2012); Firms Reported to Have Engaged 

in Activities Related to Iran’s Energy and Communications Sectors While Having Had U.S. Government Contracts, 

GAO-13-344R (Washington, D.C.: Feb. 25, 2013). For a list of all seven related reports, see GAO Related Products 

at the end of this report.

4

In this report, “contracts” refers collectively to contracts, awards, and purchasing agreements.
Page 2 GAO-14-218R Iranian Commercial Activities

“Withdrawn.”5 We attempted to contact all 15 firms that we identified as “Active” or “Insufficient 

information available” to offer them an opportunity to comment on our findings.6 We did not 

review the contracts and documents underlying any reported transactions and did not 

independently verify such transactions. The Secretary of State is responsible for determining 

whether such activities met the legal criteria for sanctionable activities under U.S. law; we did 

not attempt to make such determinations.7 For our fourth objective, we searched the Federal 

Procurement Data System-Next Generation (FPDS-NG), the primary government-wide 

contracting database since 1978. See enclosure I for further details of our scope and 

methodology.

We conducted this performance audit from August 2013 to January 2014 in accordance with 

generally accepted government auditing standards. Those standards require that we plan and 

perform the audit to obtain sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that the evidence obtained 

provides a reasonable basis for our findings and conclusions based on our audit objectives.

Results in Brief 

Our reviews of open sources published between October 1, 2012, and November 7, 2013, 

identified four foreign firms that were reported to have engaged in commercial activity in Iran’s 

energy sector during this time period. These firms include one firm that we had not identified 

previously—China Oilfield Services Limited. In addition, since our last report in December 2012, 

we have moved four firms—INA, ONGC Videsh Ltd., Petronet LNG, and Sasol—to the 

“Withdrawn” category. For eight additional firms that we previously identified as reported to have 

engaged in commercial activity in Iran’s energy sector, we found insufficient information to 

indicate that they had either continued or ceased such activity during the specified time period.

Our reviews of open sources published between October 1, 2012, and November 7, 2013, did 

not identify any firms that were reported to have sold refined petroleum products to Iran during 

this time period. In addition, since our last report in December 2012, we have moved one firm—

Zhuhai Zhenrong—from the “Insufficient information available” category to the “Withdrawn” 

category. For four additional firms that we previously identified as reported to have sold refined 

petroleum products to Iran, our open-source review provided insufficient information to indicate 

 5

For example, for each of our first three objectives, we categorized a firm’s status as “Active” if such activity was 

reported in (1) at least three standard industry publications; (2) the firm’s corporate statements and at least one 

standard industry publication; or (3) the firm’s corporate reports or statements, an SEC filing, or a letter from the firm 

to GAO. We categorized a firm’s status as “Withdrawn” if at least three open sources published during the specified 

time period reported that the firm had ceased the activity. If a firm notified us that it had ceased the activity, we 

categorized the firm as “Withdrawn” only if our open-source review found no new reports of the activity since we last 

reported on the firm. If our last report listed a firm as “Withdrawn,” we continued to categorize it as “Withdrawn” in our 

current report if we did not identify at least three open sources indicating that the firm had sold refined petroleum 

products to, or engaged in commercial activities in, Iran within the specified time period. We categorized a firm’s 

status as “Insufficient information available” if the results of our review of open sources, published within the specified 

time period, did not meet the criteria to categorize the firm as either “Active” or “Withdrawn” (as defined above). See 

enclosure I for more information about our use of these criteria.

6

We sent letters to 14 of the firms. Because there was no mail service to Syria, the location of one of the firms, we 

attempted to contact the firm, Sytrol, by telephone but were not successful. As of December 31, 2013, 7 of the 15 

firms had responded to our requests for comment.

7

For a discussion of sanctions against Iran, see, for example, GAO, U.S. and International Sanctions Have Adversely 

Affected the Iranian Economy, GAO-13-326 (Washington, D.C.: Feb. 25, 2013). 
Page 3 GAO-14-218R Iranian Commercial Activities

either that they had continued or ceased selling such products to Iran during the specified time 

period. 

Our review of open sources published between December 16, 2012, and November 7, 2013, did 

not identify any foreign firms that were reported to have exported technologies to the Iranian 

government for blocking telecommunications by monitoring, filtering, or disrupting the flow of 

information and communications. In a prior report, we noted numerous challenges to identifying 

such firms through open sources.8 For example, a firm’s intention in selling Iran technology may 

be difficult to determine because technology that can enable acceptable filtering to block 

objectionable sites can also be used for unacceptable filtering to disrupt the free flow of 

information and communication.

None of the four firms that we identified as reported to have engaged in commercial activity in 

Iran’s energy sector at some point between October 1, 2012, and November 7, 2013, had U.S. 

government contracts, according to FPDS-NG. As already noted, we did not identify any firms 

that were reported to have either sold Iran refined petroleum products or exported technologies 

for telecommunications blocking between those dates. 

Four Foreign Firms Were Reported in Open Sources to Have Engaged in Commercial 

Activity in Iran’s Energy Sector between October 1, 2012, and November 7, 2013

Our review of open sources published between October 1, 2012, and November 7, 2013, 

identified four foreign firms that were reported to have engaged in commercial activity in Iran’s 

energy sector during this time period (see table 1). These firms included one firm, China Oilfield 

Services Limited, that we had not previously identified. Enclosure II shows our categorizations 

of all firms reported in open sources to have engaged in commercial activity in Iran’s energy 

sector at some point between January 1, 2005, and November 7, 2013.

Table 1: Foreign Firms Reported in Open Sources as Engaging in Commercial Activity in Iran’s Energy 

Sector between October 1, 2012, and November 7, 2013

Firm Country

1. China National Petroleum Corporation

a

China

2. China Oilfield Services Limited China

3. Oil and Natural Gas Corporation (ONGC) India

4. Oil India Ltd. India

Source: GAO analysis of open-source information.

Notes: We categorized a firm reported to have engaged in commercial activity as (“Active”) if the relevant activity was reported in (1) 

at least three standard industry publications; (2) the firm’s corporate statements and at least one standard industry publication; or (3) 

the firm’s corporate reports or statements, an SEC filing, or a letter from the firm to GAO. We based our categorizations of firms’

status on open-source information published between October 1, 2012, and November 7, 2013. 

a

The country listed is the firm’s physical location as reported in open sources. 

In addition, since our last report in December 2012, we have moved four firms—INA, ONGC 

Videsh Ltd., Petronet LNG, and Sasol—to the “Withdrawn” category. For an additional eight

 8

See GAO, The U.S. Government Is Establishing Procedures for a Procurement Ban against Firms that Sell Iran 

Technology to Disrupt Communications but Has Not Identified Any Firms, GAO-11-706R (Washington, D.C.: June 30, 

2011).
Page 4 GAO-14-218R Iranian Commercial Activities

firms that we identified in prior reports as reported to have engaged in commercial activity in 

Iran’s energy sector, we found insufficient open-source information to indicate that they had 

either continued or ceased such activities during the specified time period (see table 2). 

According to Department of State (State) officials, the number of firms that open sources report 

as engaged in commercial activities in Iran’s energy sector is decreasing, in part because some 

firms have found ways to avert mention of these activities in open sources. 

Table 2: Foreign Firms for Which There Was Insufficient Open-Source Information to Indicate That They Had 

Either Continued or Ceased Engaging in Commercial Activity in Iran’s Energy Sector between October 1, 

2012, and November 7, 2013

Firm Country

1. Amona 

a

Malaysia

2. China National Offshore Oil Corporation China

3. Daelim South Korea

4. Indian Oil Corporation Ltd. India

5. Petrofield Malaysia

6. Petróleos de Venezuela S.A. Venezuela

7. Sinopec China

8. SKS Ventures Malaysia

Source: GAO analysis of open-source information.

Notes: We categorized a firm’s status as “Insufficient information available” if our review of open sources published between 

October 1, 2012, and November 7, 2013, did not identify, for example, at least three open-source reports indicating whether a firm 

that one of our prior reports identified as “Active” or “Insufficient information available” had continued or ceased commercial activity 

in Iran’s energy sector.

a

The country listed is the firm’s physical location as reported in open sources. 

No Foreign Firms Were Reported in Open Sources to Have Sold Refined Petroleum 

Products to Iran between October 1, 2012, and November 7, 2013

Our review of open sources published between October 1, 2012, and November 7, 2013, did 

not identify any firms that were reported to have sold refined petroleum products to Iran during 

this time period. In addition, since our last report, we have moved one firm—Zhuhai Zhenrong—

from the “Insufficient information available” category to the “Withdrawn” category.9 For four firms 

we identified in prior reports as reported to have sold refined petroleum products to Iran, our 

open-source review found insufficient information to indicate that they had either continued or 

ceased selling such products to Iran during the specified time period (see table 3). Enclosure III 

shows our categorizations of all firms reported in open sources to have sold Iran refined 

petroleum products at some point between January 1, 2009, and November 7, 2013.

 9

On January 12, 2012, State imposed sanctions on Zhuhai Zhenrong for its sales of refined petroleum products to 

Iran. State’s process for determining whether to impose sanctions on a firm includes a review of nonpublic 

information. In this report, we rely on open-source information that is overt and publicly available. Pursuant to our 

methodology, Zhuhai Zhenrong was placed in the “Withdrawn” category because the firm notified us that it had 

ceased the activity and our open-source review from October 1, 2012, through November 7, 2013, found no new 

reports of the activity since our prior report. 
Page 5 GAO-14-218R Iranian Commercial Activities

Table 3: Foreign Firms for Which There Was Insufficient Open-Source Information to Indicate That They Had 

Either Continued or Ceased Selling Refined Petroleum Products to Iran between October 1, 2012, and 

November 7, 2013 

Firm Countrya

1. China Oil China

2. Petróleos de Venezuela S.A. Venezuela

3. Sytrol Syria

4. Unipec China

Source: GAO analysis of open-source information.

Notes: We categorized a firm’s status as “Insufficient information available” if our review of open sources published between

October 1, 2012, and November 7, 2013, did not identify, for example, at least three open-source reports indicating whether a firm

that one of our prior reports identified as “Active” or “Insufficient information available” had continued or ceased sales of refined 

petroleum products to Iran. 

a

No Foreign Firms Were Reported in Open Sources to Have Exported Technologies to Iran 

for Blocking Telecommunications between December 16, 2012, and November 07, 2013

The country listed is the firm’s physical location as reported in open sources.

Our review of open sources published between December 16, 2012, and November 07, 2013, 

did not identify any foreign firms that were reported to have exported technologies to the Iranian 

government for blocking telecommunications by monitoring, filtering, or disrupting information 

and communication flows during the specified time period.10 Our prior reviews of open sources 

for firms reported to have exported telecommunications-blocking technologies also did not 

identify any firms.11 We previously reported on numerous challenges to identifying firms through 

open sources; these challenges may account for our inability to identify any firms. For example, 

the competitive and proprietary nature of the communication industry limits information, if any, 

reported in open sources. Additionally, a firm’s intention in selling Iran technology may be 

difficult to determine, because technology that can enable acceptable filtering for objectionable 

sites, such as pornography, can also be used to disrupt the free flow of information and 

communication.12

None of the Firms Reported to Have Engaged in Commercial Activity in Iran’s Energy 

Sector between October 1, 2012, and November 7, 2013, Had U.S. Government Contracts

None of the four firms that we identified as reported to have engaged in commercial activity in 

Iran’s energy sector between October 1, 2012, and November 7, 2013, had U.S. government 

 10We would identify firms as reported to have exported technologies to the Iranian government for monitoring, 

filtering, or disrupting information and communication flows between December 16, 2012, and November 07, 2013, 

only when three standard industry publications or the firm’s corporate statements reported the firm to have signed an 

agreement to conduct business, invested capital, or received payment for providing goods or services. 

11GAO-13-344R, GAO-11-706R. 

12For a more complete discussion of these challenges, see GAO-11-706R.
Page 6 GAO-14-218R Iranian Commercial Activities

contracts.13 As already noted, we did not identify any firms reported to have sold Iran refined 

petroleum products or exported technologies for telecommunications blocking between those 

dates. 

Agency Comments

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

comment.

---

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 IV.

Thomas Melito

Director, International Affairs and Trade

Enclosures - 4

 13Of the 11 foreign firms for which we found insufficient information published between October 1, 2012, and 

November 7, 2013, to determine whether they were reported to have withdrawn from previously-reported commercial 

activity in Iran’s energy sector or sales of refined petroleum products to Iran, one had U.S. government contracts. 

According to data from FPDS-NG, that firm—Daelim—has contracts for housing construction at a U.S. military base 

in South Korea.
Page 7 GAO-14-218R Iranian Commercial Activities

List of Committees

The Honorable Carl Levin

Chairman

The Honorable James M. Inhofe

Ranking Member

Committee on Armed Services

United States Senate

The Honorable Tim Johnson

Chairman 

The Honorable Mike Crapo

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 Robert Menendez

Chairman 

The Honorable Bob Corker

Ranking Member

Committee on Foreign Relations

United States Senate 

The Honorable Howard P. McKeon

Chairman

The Honorable Adam Smith

Ranking Member

Committee on Armed Services

House of Representatives

The Honorable Jeb Hensarling

Chairman 

The Honorable Maxine Waters

Ranking Member

Committee on Financial Services

House of Representatives

The Honorable Edward R. Royce

Chairman 

The Honorable Eliot L. Engel 

Ranking Member

Committee on Foreign Affairs 

House of Representatives
Page 8 GAO-14-218R Iranian Commercial Activities

The Honorable Dave Camp

Chairman 

The Honorable Sander Levin

Ranking Member

Committee on Ways and Means

House of Representatives
Enclosure I 

Page 9 GAO-14-218R Iranian Commercial Activities

Scope and Methodology

To identify foreign firms that were reported to have engaged in commercial activities in Iran’s 

energy sector since our last report on the topic, issued in December 2012,14 we reviewed and 

analyzed open—that is, overt and publicly available —sources published between October 1, 

2012, and November 7, 2013. 

• We conducted searches of industry publications and company reports and statements. 

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 the Iranian 

oil, gas, or petrochemical sectors. When reports varied regarding certain details of a 

firm’s project, we presented the information reported in the most recent source available. 

• We searched English-language open-source information that we determined to be 

credible and comprehensive in consultation with an information specialist who is 

knowledgeable about the energy sector. We used the Nexis Oil and Energy databases, 

which list trade publications where more than 60 percent of the stories pertain to the oil 

and energy industries. These publications included Oil Daily, Oil and Gas News, Oil and 

Gas Journal, and Platt’s Oilgram News, among others. We then screened the 

publications and excluded sources that we deemed insufficiently reliable, such as 

newspaper reports, newswires, and direct news releases from the Iranian government.

• We searched for the names of firms identified in our last report issued in December 2012 

as well as for key terms such as “Iran” that appeared within 25 words from “explore,” 

“drill,” “refinery,” “natural gas,” or “petroleum.”15 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; U.S. Securities and Exchange 

Commission (SEC) filings, if available; firms’ press releases and corporate statements 

that publicly reported their commercial activities in Iran; and corrected information that 

had been publicly reported. We excluded firms 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. We identified firms that 

were 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. We did not 

review the contracts and documents underlying the reported transactions and did not 

independently verify the transactions. The Secretary of State is responsible for 

determining whether activity in Iran’s energy sector meets the legal criteria for 

sanctionable activities under U.S. law; we did not attempt to make such determinations. 

 14GAO, Firms Reported to Have Sold Iran Refined Petroleum Products or Engaged in Commercial Activities in Iran’s 

Energy Sector, GAO-13-173R (Washington, D.C.: Dec. 7, 2012).

15GAO-13-173R.
Enclosure I 

Page 10 GAO-14-218R Iranian Commercial Activities

To identify foreign firms that were reported to have sold refined petroleum products to Iran since 

our last report on the topic, issued in December 2012,16 we reviewed and analyzed open-source 

information published between October 1, 2012, and November 7, 2013, to identify sales 

reported to have occurred during that period. Again, we searched open-source information that 

we determined to be credible and comprehensive in consultation with an information specialist 

on our staff. For the purposes of our search, we defined refined petroleum products to include 

gasoline, kerosene, diesel fuel, and gas oil. We searched the English-language industry and 

trade publications already described for reports of such activity by firms at any time between 

October 1, 2012, and November 7, 2013. We 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, 

SEC filings, Federal Register Notices, and press releases and corporate statements for reports 

of sales of refined petroleum products to Iran or for corrected information that had been publicly 

reported. 

To identify foreign firms reported to have exported technologies to the Iranian government for 

blocking telecommunications by monitoring, filtering, and disruption of information and 

communications flows since our last report on the topic, issued in February 2013,17 we reviewed 

and analyzed open-source information published between December 16, 2012, and November 

7, 2013. Again, we searched open-source information that we determined to be credible and 

comprehensive in consultation with an information specialist on our staff. For the purposes of 

our search, relevant activity for telecommunications firms included, for example, firms’ corporate 

statements reporting that the firm had signed an agreement to conduct business, invested 

capital, or received payment for providing goods or services in connection with these 

technologies. We reviewed a range of English-language open-source information in an attempt 

to identify firms, including industry standard trade publications, marketing reports, corporate 

statements, SEC filings, and general web searches. We excluded sources that we deemed 

insufficiently reliable, such as newspaper reports, newswires, and direct news releases from the 

Iranian government. We searched Nexis.com to find content files covering the Internet,

telecommunications, and electronics industries for the time period between December 16, 2012, 

and November 7, 2013. Included in these files were numerous industry standard trade 

publications, such as the Electronics Engineering Times, Communications Today, and 

TechWeb. We searched Gartner.com for marketing reports and firm websites for press releases 

and corporate statements. We searched and analyzed Securities and Exchange Commission 

filings filed between December 16, 2012, and November 7, 2013. We also conducted general 

web searches for specific firms named in nongovernmental reports or in interviews with private 

sector firms or mentioned in the media.

After identifying firms reported to have engaged in such activities, we categorized the status of 

each firm’s activities as “Active” for the reporting period if one of the following criteria had been 

met: (1) at least three standard industry publications reported that the firm was engaged in the 

relevant activity at any time during the specified time period; (2) the firm provided information on 

its corporate website about the identified activity at any time during the specified period, and at 

least one standard industry publication corroborated the firm’s activity at any time during this 

period; or (3) the firm indicated in a corporate report (or statements) or an SEC filing, or 

confirmed in a letter to us, that it had conducted the relevant activity during this period. If none 

 16GAO-13-173R.

17GAO, Firms Reported to Have Engaged in Activities Related to Iran’s Energy and Communications Sectors While 

Having Had U.S. Government Contracts, GAO-13-344R (Washington, D.C.: Feb. 25, 2013). 
Enclosure I 

Page 11 GAO-14-218R Iranian Commercial Activities

of these criteria were met, we did not categorize the firm as “Active.” 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. 

For firms identified in prior GAO reports that did not meet our criteria for “Active,” we used the 

following criteria to categorize each firm’s activities as “Withdrawn” or “Insufficient information 

available” (see fig. 1): 

• We categorized a firm’s status as “Withdrawn” if three open sources, published during 

the specified time period, reported that the firm had ceased the activity. If a firm notified 

us that it had ceased the activity, we listed the firm as “Withdrawn” only if our opensource review found no new reports of the activity since we last reported on the firm. If a 

firm had been listed as “Withdrawn” in our last report, we continued to list it as 

“Withdrawn” in this report if we did not identify three open-source reports indicating that 

the firm had made sales of refined petroleum products or engaged in commercial 

activities within the specified time period. 

• We categorized a firm’s status as “Insufficient information available” if the results of our 

review of open sources, published within the specified time period, did not meet the 

criteria to categorize the firm as either “Active” or “Withdrawn” (as defined above). For 

example, if a firm previously listed as “Active” or “Insufficient information available” was 

identified in 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.” Similarly, we categorized a firm as “Insufficient information available” if (1) it 

notified us that it had ceased commercial activity in Iran’s energy sector and (2) one 

open-source report indicated that the firm was engaged in such activities during the 

specified time period.
Enclosure I 

Page 12 GAO-14-218R Iranian Commercial Activities

Figure 1: Criteria for Categorizing Firms Identified in Prior GAO Reports as Reported to Have Engaged in Certain 

Activities in Iran’s Energy or Communications Sectors

We attempted to send letters via FedEx International Priority to 14 of the 15 firms whose status 

we categorized as “Active” or “Insufficient information available,” requesting comment on our 

findings. We searched each firm’s official website or the Internet to identify its contact 

information. Because there was no mail service to Syria, we attempted to contact the Syrian firm 

Sytrol by telephone but were not successful. In addition, because our letter to Petróleos de 

Venezuela S.A. was returned, we attempted to contact the firm by telephone. As of December 

31, 2013, seven of the 15 firms had responded. We have incorporated their comments into our 

findings, as appropriate. 

To identify firms (reported in open sources to have engaged in the relevant activities) that had 

been awarded contracts, awards, or purchasing agreements with the U.S. government, we 

searched the Federal Procurement Data System-Next Generation (FPDS-NG). We chose 

FPDS-NG because it has served as the primary government-wide contracting database since 
Enclosure I 

Page 13 GAO-14-218R Iranian Commercial Activities

1978.18 We searched the FPDS-NG archives for the period from December 16, 2012, to 

November 7, 2013, using the Data Universal Numbering System (DUNS) numbers for the four 

firms identified as having commercial activities in Iran and for the firms categorized as 

“Insufficient information available.” With certain exceptions, all firms that do business with U.S. 

agencies are required to register with the U.S. government’s central contractor registry and 

obtain a unique DUNS number. 

We conducted this performance audit from August 2013 to January 2014 in accordance with 

generally accepted government auditing standards. Those standards require that we plan and 

perform the audit to obtain sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that the evidence obtained 

provides a reasonable basis for our findings and conclusions based on our audit objectives. 

 18Congress, executive branch agencies, and the public rely on FPDS-NG for a broad range of data on agency 

contracting actions, procurement, and spending. FPDS-NG can be accessed at https://www.fpds.gov/fpdsng_cms/. 

Reporting requirements for FPDS-NG are in Federal Acquisition Regulation (FAR) subpart 4.6; FPDS-NG data are 

described in FAR 4.602. The Office of Management and Budget established FPDS-NG, and the U.S. General 

Services Administration administers the system. For more information on FPDS-NG and other federal procurement 

data systems, see GAO, Federal Contracting: Observations on the Government’s Contracting Data Systems, GAO09-1032T (Washington, D.C.: Sept. 29, 2009).
Enclosure II 

Page 14 GAO-14-218R Iranian Commercial Activities

Firms Reported in Open Sources to Have Engaged in Commercial Activity in Iran’s Energy 

Sector at Some Point between January 1, 2005, and November 7, 2013

Table 4 lists information about firms that open sources—published between January 1, 2005, and 

November 7, 2013—reported to have engaged in commercial activity in Iran’s energy sector at some point 

during the specified time period. The table includes information presented in our March 2010, August 

2011, and December 2012 reports.19 Over this period of time, we changed the status of 31 firms from 

“Active” to “Withdrawn,” based on open source reports of their commercial activities between January 1, 

2005, and November 7, 2013. (The Secretary of State is responsible for determining whether activity in 

Iran’s energy sector meets the legal criteria for sanctionable activities under U.S. law. We did not attempt 

to make such determinations).

Table 4: Foreign Firms That Open Sources Reported to Have Engaged in Commercial Activity in Iran’s Energy Sector at 

Some Point between January 1, 2005, and November 7, 2013, and Comments about Their Current Status 

Firm Country

Status in 

GAO’s March 

2010 report a

Status in GAO’s 

August 2011 

report b

Status in GAO’s 

December 2012 

report

Status in GAO’s 

current report Comments

1. China 

National 

Petroleum 

Corporation

China Active 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 31, 

2013.

2. China Oilfield 

Services 

Limited

China Not listed Not listed Not listed Active Open sources published during the 

period of our current review reported 

that the firm has ongoing drilling 

operations in Iran. The firm had not 

commented on our findings as of 

December 31, 2013.

3. Oil and 

Natural Gas 

Corporation 

(ONGC)

 India Active Active Insufficient 

information

available

Active The firm’s 2012-2013 annual report 

stated that the firm has a 40 percent 

interest in the Farsi Block Project. 

However, the firm also notified us that 

it has not been involved in any 

commercial activities in Iran’s energy 

sector or any block, field, or project in 

Iran for the last several years.

 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); 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); Firms Reported to Have Sold Iran Refined Petroleum 

Products or Engaged in Commercial Activities in Iran’s Energy Sector, GAO-13-173R (Washington, D.C.: Dec. 7, 2012).
Enclosure II 

Page 15 GAO-14-218R Iranian Commercial Activities

Firm Country

Status in 

GAO’s March 

2010 report a

Status in GAO’s 

August 2011 

report b

Status in GAO’s 

December 2012 

report

Status in GAO’s 

current report Comments

4. Oil India Ltd. India Active Active Active Active The firm’s 2012-2013 annual report 

stated that the firm has a 20 percent 

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 the 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.

5. Amona Malaysia Active Insufficient 

information 

available

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 31, 2013.

6. China 

National 

Offshore Oil 

Corporation

China Active 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 31, 2013.

7. Daelim South Korea Active 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.” In 

response to our current review, the 

firm contacted us and stated that it is 

in discussions with the U.S. 

Government regarding the application 

of U.S. law to its activities in Iran.

8. Indian Oil 

Corporation 

Ltd.

India Active 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 31, 2013.

9. Petrofield Malaysia Active Insufficient 

information 

available

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 31, 2013.

10. Petróleos de 

Venezuela 

S.A.

Venezuela Active 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 31, 2013.

11. Sinopec China Active 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 31, 2013.
Enclosure II 

Page 16 GAO-14-218R Iranian Commercial Activities

Firm Country

Status in 

GAO’s March 

2010 report a

Status in GAO’s 

August 2011 

report b

Status in GAO’s 

December 2012 

report

Status in GAO’s 

current report Comments

12. SKS Ventures Malaysia Active Insufficient 

information

available

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 31, 2013.

13. Ashok 

Leyland 

Project 

Services 

(Hinduja 

Group)

India (United 

Kingdom)

c

Active Withdrawn Withdrawn Withdrawn There were no open-source reports of 

the firm conducting commercial 

activity in Iran during the time period 

of our current report.

14. Belneftekhim/

Belarusneft

Belarus Active 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.

15. Costain Oil, 

Gas & 

Process Ltd.

United 

Kingdom

Active Withdrawn Withdrawn Withdrawn There were no open-source reports of 

the firm conducting commercial 

activity in Iran during the time period 

of our current report.

16. Daewoo 

Shipbuilding 

& Marine 

Engineering

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

the firm conducting commercial 

activity in Iran during the time period 

of our current report. 

17. Edison Italy Active 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.

18. ENI Italy Active Withdrawn 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. Gazprom Russia Active Insufficient 

information

available

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. GS South Korea Active Withdrawn Withdrawn Withdrawn There were no open-source reports of 

the firm conducting commercial 

activity in Iran during the time period 

of our current report.

21. Haldor 

Topsoe

Denmark Active Withdrawn 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. Hyundai 

Heavy 

Industries

South Korea Active 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.

23. INA Croatia Active 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 the exploration phase of the 

service contract in the Moghan-2 

Block expired on May 31, 2012, 

without INA fulfilling its minimum 

exploration obligations. In addition, 

the firm notified us that it is not 

planning to conduct any activities in 

Iran. 
Enclosure II 

Page 17 GAO-14-218R Iranian Commercial Activities

Firm Country

Status in 

GAO’s March 

2010 report a

Status in GAO’s 

August 2011 

report b

Status in GAO’s 

December 2012 

report

Status in GAO’s 

current report Comments

24. Inpex Japan Active Withdrawn 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. JGC 

Corporation

Japan Active Withdrawn Withdrawn Withdrawn There were no open-source reports of 

the firm conducting commercial 

activity in Iran during the time period 

of our current report.

26. Lukoil Russia Active Withdrawn 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. Lyondel

Basell

Netherlands Active Withdrawn 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. OMV Austria Active 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. ONGC Videsh 

Ltd.

India Active Active Active Withdrawn At least three open sources published 

during the period of our current 

review reported that the firm had not 

engaged in commercial activities in 

Iran. The firm notified us that it had 

no plans to pursue further work on 

the Farsi Block.

30. Petrobras Brazil Active Withdrawn Withdrawn Withdrawn There were no open-source reports of 

the firm conducting commercial 

activity in Iran during the time period 

of our current report.

31. Petronet LNG India Active Insufficient 

information

available

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 stopped conducting 

commercial activity in Iran.

32. PGNiG Poland Active Insufficient 

information

available

Withdrawn Withdrawn There were no open-source reports of 

the firm conducting commercial 

activity in Iran during the time period 

of our current report.

33. PTT 

Exploration & 

Production

Thailand Active Withdrawn 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 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 Withdrawn There were no open-source reports of 

the firm conducting commercial 

activity in Iran during the time period 

of our current report.

36. Sasol South Africa Not listed Active Active Withdrawn At least three open sources published 

during the period of our current 

review reported that the firm 

completed the sale of its 50 percent 

stake in Arya Sasol Polymer 

Company, an Iranian petrochemical 

project on August 16, 2013. 
Enclosure II 

Page 18 GAO-14-218R Iranian Commercial Activities

Firm Country

Status in 

GAO’s March 

2010 report a

Status in GAO’s 

August 2011 

report b

Status in GAO’s 

December 2012 

report

Status in GAO’s 

current report Comments

37. Snamprogetti Italy Active Withdrawn Withdrawn Withdrawn There were no open-source reports of 

the firm conducting commercial 

activity in Iran during the time period 

of our current report.

38. Sonangol Angola Not listed 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. StatoilHydro Norway Active Withdrawn Withdrawn Withdrawn There were no open-source reports of 

the firm conducting commercial 

activity in Iran during the time period 

of our current report.

40. Tecnimont Italy Active Insufficient 

information

available

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. Total France Active Withdrawn 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. Turkish 

Petroleum 

Company

Turkey Active Withdrawn Withdrawn Withdrawn There were no open-source reports of 

the firm conducting commercial 

activity in Iran during the time period 

of our current report. 

43. Uhde Germany Active Withdrawn 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: We listed a firm’s status as “Active,” “Withdrawn,” or “Insufficient information available.” We listed a firm’s status as ”Active” if, for example, 

at least three open sources, published within the specified time period, reported that the firm had engaged in commercial activities in Iran’s energy 

sector during this time period. We listed a firm’s status as ”Withdrawn” if, for example, at least three open sources published within the specified 

time period reported that it withdrew from its commercial activities in Iran’s energy sector during this time period. We listed a firm’s status as 

“Insufficient information available” if, for example, our review of open sources published within the specified time period did not identify at least 

three open-source reports indicating whether a firm previously identified as “Active” or “Insufficient information available” in one of our prior reports 

had continued or ceased commercial activity in Iran’s energy sector. Firms are grouped by current status based on open-source reports published 

from October 1, 2012, through November 7, 2013. 

a

The country listed is the firm’s physical location as reported in open sources.

b

The Iran Threat Reduction and Syria Human Rights Act of 2012 mandated that we provide information since January 1, 2009; thus, we have 

included information from the 2010 report, which aggregated the data between 2005 and 2009.

c

In response to our request for comment in November 2012, 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. 
Enclosure III 

Page 19 GAO-14-218R Iranian Commercial Activities

Firms Reported in Open Sources to Have Sold Iran Refined Petroleum Products at Some 

Point between January 1, 2009, and November 7, 2013

Table 5 lists information about foreign firms that open sources—published between January 1, 2009, and 

November 7, 2013—reported to have sold refined petroleum products to Iran at some point during the 

specified time period. The table includes information presented in our September 2010, January 2012, 

and December 2012 reports.20 Over this period of time, we changed the status of 13 firms from “Active” to 

“Withdrawn,” based on open-source reports of their refined petroleum product sales to Iran between 

January 1, 2009, and November 7, 2013. (The Secretary of State is responsible for determining whether 

activity in Iran’s energy sector meets the legal criteria for sanctionable activities under U.S. law. We did 

not attempt to make such determinations.)

Table 5: Foreign Firms That Open Sources Reported to Have Sold Refined Petroleum Products to Iran at Some Point 

between January 1, 2009, and November 7, 2013, and Comments about Their Current Status

Firm Country

Status in 

GAO’s 

September 

2010 report a

Status in GAO’s 

January 2012 

report

Status in GAO’s 

December 2012 

report

Status in current 

report Comments

1. China Oil China Active Active Insufficient 

information available

Insufficient 

information available

Open sources provided 

insufficient information to 

classify the firm as “Active” or 

“Withdrawn.” The firm had not 

commented on our findings 

as of December 31, 2013.

2. Petróleos de 

Venezuela 

S.A. 

Venezuela Not listed Active Insufficient 

information available

Insufficient 

information available

Open sources provided 

insufficient information to 

classify the firm as “Active” or 

“Withdrawn.” The firm had not 

commented on our findings 

as of December 31, 2013.

3. Sytrol Syria Not listed Not listed Active Insufficient 

information available

Open sources provided 

insufficient information to 

classify the firm as “Active” or 

“Withdrawn.” The firm had not 

commented on our findings 

as of December 31, 2013.

4. Unipec China Active Active Insufficient 

information available

Insufficient 

information available

Open sources provided 

insufficient information to 

classify the firm as “Active” or 

“Withdrawn.” The firm had not 

commented on our findings 

as of December 31, 2013.

5. Emirates 

National Oil 

Company 

UAE Active Insufficient 

information 

available

Withdrawn Withdrawn There were no open source 

reports of the firm selling 

petroleum products to Iran 

during the time period of our 

current report. 

 20GAO, 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); 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); Firms Reported to Have Sold Iran 

Refined Petroleum Products or Engaged in Commercial Activities in Iran’s Energy Sector, GAO-13-173R (Washington, D.C.: Dec. 

7, 2012).
Enclosure III 

Page 20 GAO-14-218R Iranian Commercial Activities

Firm Country

Status in 

GAO’s 

September 

2010 report a

Status in GAO’s 

January 2012 

report

Status in GAO’s 

December 2012 

report

Status in current 

report Comments

6. Glencore Switzerland Withdrawn Withdrawn b Withdrawn Withdrawn There were no open source 

reports of the firm selling 

petroleum products to Iran 

during the time period of our 

current report.

7. Hin Leong 

Trading

Singapore Active Insufficient 

information 

available

Withdrawn Withdrawn There were no open source 

reports of the firm selling 

petroleum products to Iran 

during the time period of our 

current report.

8. Independent 

Petroleum 

Group (IPG) 

Kuwait Withdrawn Withdrawn b Withdrawn Withdrawn There were no open source 

reports of the firm selling 

petroleum products to Iran 

during the time period of our 

current report.

9. Litasco Switzerland Withdrawn Withdrawn b Withdrawn Withdrawn There were no open source 

reports of the firm selling 

petroleum products to Iran 

during the time period of our 

current report.

10. Petronas Malaysia Withdrawn Withdrawn b Withdrawn Withdrawn There were no open source 

reports of the firm selling 

petroleum products to Iran 

during the time period of our 

current report.

11. Reliance 

Industries 

India Withdrawn Withdrawn b Withdrawn Withdrawn There were no open source 

reports of the firm selling 

petroleum products to Iran 

during the time period of our 

current report.

12. Royal Dutch 

Shell

Netherlands Withdrawn Withdrawn b Withdrawn Withdrawn There were no open source 

reports of the firm selling 

petroleum products to Iran 

during the time period of our 

current report. 

13. Total France Withdrawn Withdrawn b Withdrawn Withdrawn There were no open source 

reports of the firm selling 

petroleum products to Iran 

during the time period of our 

current report.

14. Trafigura Switzerland Withdrawnb Withdrawn Withdrawn Withdrawn There were no open source 

reports of the firm selling 

petroleum products to Iran 

during the time period of our 

current report.

15. Tupras Turkey Withdrawn Withdrawn b Withdrawn Withdrawn There were no open source 

reports of the firm selling 

petroleum products to Iran 

during the time period of our 

current report.

16. Vitol Switzerland Withdrawn Withdrawn b Withdrawn Withdrawn There were no open source 

reports of the firm selling 

petroleum products to Iran 

during the time period of our 

current report.
Enclosure III 

Page 21 GAO-14-218R Iranian Commercial Activities

Firm Country

Status in 

GAO’s 

September 

2010 report a

Status in GAO’s 

January 2012 

report

Status in GAO’s 

December 2012 

report

Status in current 

report Comments

17. Zhuhai 

Zhenrong 

China Active 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 stopped 

selling refined petroleum 

products to Iran.

Source: GAO analysis of open-source information. 

Notes: We listed a firm’s status as “Active,” ”Withdrawn,” or “Insufficient information available.” We listed a firm’s status as “Active” if, for example, 

at least three open sources, published within the specified time period, reported that the firm sold refined petroleum products to Iran during this 

time period. We listed a firm’s status as ”Withdrawn” if, for example, at least three open sources published within the specified time period 

reported that it ceased selling refined petroleum products to Iran during this time period. We listed a firm’s status as “Insufficient information 

available” if, for example, our review of open sources published within the specified time period did not identify at least three open-source reports 

indicating whether a firm previously identified as “Active” or “Insufficient information available” in one of our prior reports had continued or ceased 

sales of refined petroleum products to Iran. A firm’s status in the current GAO report is based on open-source reports published from October 1, 

2012, through November 7, 2013. 

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 is the firm’s physical location 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 this time period. 
Enclosure IV 

Page 22 GAO-14-218R Iranian Commercial Activities

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, Mason Thorpe Calhoun, Martin de Alteriis, Reid Lowe, and Grace Lui made 

key contributions to this report.
Related GAO Products

Page 23 GAO-14-218R Iranian Commercial Activities

GAO. Firms Reported to Have Engaged in Activities Related to Iran’s Energy and 

Communications Sectors While Having Had U.S. Government Contracts. GAO-13-344R.

Washington, D.C.: February 25, 2013.

GAO. Firms Reported to Have Sold Iran Refined Petroleum Products or Engaged in 

Commercial Activities in Iran’s Energy Sector. GAO-13-173R. Washington, D.C.: December 7, 

2012. 

GAO. Firms Reported in Open Sources to Have Sold Iran Refined Petroleum Products Declined 

Since June 30, 2010. GAO-12-321R. Washington, D.C.: January 24, 2012.

GAO. Firms Reported in Open Sources as Having Commercial Activity in Iran’s Oil, Gas, and 

Petrochemical Sectors. GAO-11-855R. Washington, D.C.: August 3, 2011.

GAO. The U.S. Government Is Establishing Procedures for a Procurement Ban against Firms 

that Sell Iran Technology to Disrupt Communications but Has Not Identified Any Firms. GAO11-706R. Washington, D.C.: June 30, 2011.

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.: September 3, 2010.

GAO. Firms Reported in Open Sources as Having Commercial Activity in Iran’s Oil, Gas, and 

Petrochemical Sectors. GAO-10-515R. Washington, D.C.: March 23, 2010.

(320994)
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