GAO-12-321R Sales of Refined Petroleum Products to Iran

January 24, 2012

The Honorable Joseph Lieberman

Chairman

The Honorable Susan M. Collins

Ranking Member

Committee on Homeland Security 

 and Governmental Affairs

United States Senate

Subject: Firms Reported in Open Sources to Have Sold Iran Refined Petroleum Products 

Declined Since June 30, 2010

Iran’s involvement in illicit nuclear activities, support for terrorism, and abuse of human 

rights has led the United States, as well as other nations, to impose 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 that 

are relevant to Iran’s proliferation activities and block the transfer of weapons and 

technology related to Iran’s missile and nuclear programs.2 One of the measures enacted 

by the United States, intended to limit resources available for proliferation and support for 

terrorism, imposes sanctions on firms that sell refined petroleum products to Iran. 

According to the Department of Energy (DOE), Iran has limited refinery capacity and has 

been reliant on imports of refined petroleum products to meet domestic demand for 

gasoline. Foreign commercial activity in Iran’s energy sector has also declined in recent 

years, limiting Iran’s ability to produce gasoline to meet demand, much less to export 

refined petroleum products on world markets. However, according to State and DOE 

officials, Iran has attempted to reduce its dependence on foreign refined petroleum 

products by reducing gasoline subsidies to its citizens in order to reduce demand, 

converting petrochemical facilities to produce gasoline, as well as expediting the 

construction of new refineries or the expansion of current refineries. In 2009, Iran imported 

approximately 130,000 barrels of gasoline per day, but, according to DOE, in 2010 the 

amount of gasoline shipped to Iran declined to an estimated 78,000 barrels per day, and 

by July 2011 it had declined to 50,000 barrels per day, according to Petroleum Intelligence 

Weekly.

 

1

For example, the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010, Pub. L. No. 

111-195, 124 Stat. 1312 and Council Decision 2010/413/CFSP Concerning Restrictive Measures Against Iran 

and Repealing Common Position 2007/140/CFSP, 2010 O.J. (L 195) 39.

2

The International Atomic Energy Agency reported in November 2011 on concerns regarding the possible 

military dimensions to Iran’s nuclear program. International Atomic Energy Agency, Implementation of the 

NPT Safeguards Agreement and relevant provisions of Security Council resolutions in the Islamic Republic of 

Iran, GOV/2011/65. (Vienna, Austria: November 8, 2011). 

United States Government Accountability Office

Washington, DC 20548
Page 2 GAO-12-321R Sales of Refined Petroleum Products to Iran

The United States has imposed multiple 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 amends ISA, among other provisions.4 ISA, as 

amended, 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.5 In 2010, we identified, in open sources, 16 firms that 

reported having sold refined petroleum products to Iran from January 1, 2009, to June 30, 

2010.6 This report updates the findings of the 2010 report. 

As you requested, this report (1) provides a list of firms reported to have sold refined 

petroleum products to Iran from July 1, 2010, through December 31, 2011, and firms 

reported to have stopped sales to Iran since the 2010 report, and (2) identifies which of 

those firms have contracts with the U.S. government. We defined the sale of refined 

petroleum products as receiving payment for the provision of any such products through 

direct sale, shipment, or brokering (i.e., trading) of these products to Iran. 

To accomplish our objectives, we reviewed open source information, including industry 

and trade publications, corporate reports and statements, and Securities and Exchange 

Commission filings. We listed firms that were reported to have sold Iran refined petroleum 

products if at least three reputable industry publications and/or the firm’s corporate 

statements reported the firm to have sold or provided refined petroleum products to Iran 

from July 1, 2010, through December 31, 2011. We also listed the firms that were 

reported to have stopped sales to Iran if open source information reported and/or the firm 

indicated in a letter to us that the firm had stopped sales by June 30, 2010, and if we did 

not find open source reports of sales to Iran during the time period. In cases where dates 

of activity were not specified in the reports, we used the date of publication for the date of 

activity. We provided the firms that were reported to have sold refined petroleum products 

to Iran an opportunity to comment on our findings. While we spoke with U.S. intelligence 

agency officials, we only used unclassified, open source information for this report. To 

determine the firms that also had contracts with the U.S. government, we searched the 

Federal Procurement Data System-Next Generation (FPDS-NG), the primary governmentwide contracting database since 1978, for active contracts from July 1, 2010, through 

December 31, 2011. We first searched in FPDS-NG for firms identified as having sold 

refined petroleum products to Iran. We did not review the contracts or documents 

underlying these transactions reported in open sources and did not independently verify 

these transactions. Further, we did not attempt to determine whether reported sales of 

 

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, 110 Stat. 1541, as amended.

4

Pub. L. No. 111-195. 

5

Pub. L. No. 104-172, § 5, as amended.

 

6

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).
Page 3 GAO-12-321R Sales of Refined Petroleum Products to Iran

refined petroleum products to Iran by the firms listed in this report met the legal criteria of 

sanctionable activities specified in ISA, as amended by CISADA. The Secretary of State is 

responsible for making such determinations. In a related report, we described State's 

process for enforcing energy related sanctions under ISA, including those for the sale of 

refined petroleum products to Iran.7 See enclosure I for a full description of our scope and 

methodology.

We conducted our work from September 2011 to January 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.

Summary

Based on open source information, four firms—Petróleos de Venezuela S.A., China Oil, 

Unipec, and Zhuhai Zhenrong—were reported to have sold refined petroleum products to 

Iran between July 1, 2010, and December 31, 2011. Of the four firms, Petróleos de 

Venezuela S.A. was not identified in our 2010 report. According to open sources, the 

number of firms selling refined petroleum products to Iran has decreased since the 

release of our 2010 report. Eleven of the 16 firms that we listed in our 2010 report were 

reported in open sources and/or indicated in letters to us that they had stopped sales of 

refined petroleum products to Iran, and we did not find any open sources that reported the 

firms having sold refined petroleum products to Iran since June 30, 2010. For two firms 

that our 2010 report listed as having been reported to have sold refined petroleum 

products to Iran—Emirates National Oil Company and Hin Leong Trading Corporation—

we did not find sufficient open source information that reported whether the firms had 

continued or ceased sales of refined petroleum products to Iran since June 30, 2010. 

According to DOE and open source reports, as well as a State official, sanctions have 

made it difficult for Iran to import gasoline as many suppliers of refined petroleum products 

stopped shipments after the passage of CISADA. According to DOE and State officials, 

Iran has attempted to increase its ability to refine its own gasoline and to reduce domestic 

demand.

The U.S. government did not have contracts with the three Chinese firms or Petróleos de 

Venezuela S.A., which were reported in open sources to have sold Iran refined petroleum 

products between July 1, 2010, and December 31, 2011.

Background

The United States enacted legislation that allows for the imposition of sanctions on 

activities with Iran’s nuclear, missile, energy, and financial sectors, including activities 

related to Iran’s nuclear and conventional weapons technology and activities that involve 

human rights violations.8

 

7

GAO, Actions to Enforce the Iran Sanctions Act and Implement Contractor Certification Requirement, GAO12-316R (Washington, D.C.: Jan. 24, 2012).

U.S. law has restricted U.S. and foreign firms from engaging in 

 

8

Pub. L. No. 111-195. 
Page 4 GAO-12-321R Sales of Refined Petroleum Products to Iran

activities through a variety of sanctions since 1987. According to State, these measures 

are designed to 

(1) block the transfer of weapons, components, technology, and dual-use items to Iran’s 

prohibited nuclear and missile programs;

(2) target selected sectors of the Iranian economy relevant to its proliferation activities; 

and 

(3) induce Iran to engage constructively, through discussions with the United States and 

other countries, to return to compliance with its nonproliferation obligations.

CISADA was enacted on July 1, 2010, adding additional requirements and measures to 

the Iran Sanctions Act of 1996 (ISA).9 ISA, as amended by CISADA, 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.10 For any person determined to have engaged in a sanctionable activity after 

July 1, 2010, the President can impose three or more of a possible nine sanctions, 

including prohibiting the foreign firm from engaging in U.S. government procurement. The 

President, who delegated certain authorities under the act to the Secretary of State, may 

waive the imposition of sanctions for these activities.11 State is the agency primarily 

responsible for implementing the provisions of ISA and the amendments by CISADA.

Four Foreign Firms Sold Refined Petroleum Products to Iran from July 1, 2010 to 

December 31, 2011, According to Open Sources

Open Sources Reported Four Foreign Firms That Sold Refined Petroleum Products to 

Iran

Based on open sources, we identified four foreign firms that reported sales of refined 

petroleum products to Iran from July 1, 2010, through December 31, 2011. Three Chinese 

firms—China Oil, Unipec, and Zhuhai Zhenrong—and Petróleos de Venezuela S.A. were 

reported, in open sources, to have sold refined petroleum products to Iran during this 

period. Of the four firms reported to have sold refined petroleum products to Iran after 

June 30, 2010, only Petróleos de Venezuela S.A. was not identified in our 2010 report. A 

September 2010 report in EI Finance stated that the number of gasoline cargoes to Iran 

declined after the passage of CISADA, leaving Iran heavily reliant on Chinese traders to 

provide it with gasoline. In our September 2010 report, we identified 16 firms that open 

sources reported had sold refined petroleum products to Iran from January 1, 2009, 

through June 30, 2010. However, 11 of these firms were reported in open sources and/or 

indicated in letters to us that they had stopped sales of refined petroleum products to Iran, 

and we did not find any open source information indicating that these firms had resumed 

selling refined petroleum products to Iran after June 30, 2010. For two firms that were 

reported as having sold refined petroleum products to Iran in our 2010 report—Emirates 

 

9

Id.

 

10Pub. L. 104-172 § 5(a), as amended.

11Memorandum: Delegation of Certain Functions and Authorities under the Comprehensive Iran Sanctions, 

Accountability, and Divestment Act of 2010, 75 Fed. Reg. 67025 (Sept. 23, 2010). 
Page 5 GAO-12-321R Sales of Refined Petroleum Products to Iran

National Oil Company and Hin Leong Trading—we did not find sufficient open source 

information that reported whether or not the firms sold refined petroleum products to Iran 

after June 30, 2010, and the firms did not respond to our requests to comment on activity 

with Iran after June 30, 2010. The firms we identified in our September 2010 report and 

this 2011 update are listed in table 1. We did not attempt to determine whether the 

reported sales of refined petroleum products to Iran met the legal criteria for sanctionable 

activities under ISA. The Secretary of State is responsible for making such 

determinations.

Table 1: Comparison of Foreign Firms Reported in Open Sources to Have Sold Refined Petroleum 

Products to Iran during the Periods of January 2009 through June 2010 and July 2010 through 

December 2011

Firm Country a Summary of reported 

sales – Jan. 2009 to 

June 2010 

Summary of reported sales – July 

2010 to Dec. 2011

1. China Oil China Sold gasoline to Iran in 

2010.

Sold gasoline to Iran in 2010 and 

2011. No comment on our findings 

as of December 31, 2011.

2. Unipec China Sold gasoline to Iran in 

2010.

Sold gasoline to Iran in 2010 and 

2011. No comment on our findings 

as of December 31, 2011.

3. Zhuhai Zhenrong China Sold gasoline to Iran in 

2010.

Sold gasoline to Iran in 2010 and 

2011. No comment on our findings 

as of December 31, 2011.

4. Petróleos de 

Venezuela S.A.

Venezuela No reported sales. Sold petroleum products to Iran in 

2011. No comment on our findings 

as of December 31, 2011.

5. Emirates National 

Oil Company

United Arab 

Emirates 

Sold gasoline to Iran in 

2010.

No reported sales and no reports that 

the firm stopped sales. No comment 

on our findings as of December 31, 

2011.

6. Hin Leong Trading Singapore Traded refined 

petroleum products to 

Iran in 2009.

No reported sales and no reports that 

the firm stopped sales. No comment 

on our findings as of December 31, 

2011.

7. British Petroleum United 

Kingdom

Sold gasoline to Iran in 

2008, but stopped in 

2009.

No reported sales. Stopped sales in 

2009.

8. Glencore Switzerland Sold gasoline to Iran in 

2009, but stopped in 

2009.

No reported sales. Stopped sales in 

2009.

9. Independent 

Petroleum Group (IPG)

Kuwait Sold gasoline to Iran in 

2009 and 2010, but 

stopped in 2010.

No reported sales. Stopped sales in 

2010.

10. Lukoil (Litasco) Russia 

(Switzerland)

Sold gasoline to Iran in 

2009 and 2010, but 

stopped in 2010.

No reported sales. Stopped sales in 

2010.

11. Petronas Malaysia Sold gasoline to Iran in 

2009 and 2010, but 

stopped in 2010.

No reported sales. Stopped sales in 

2010.

12. Reliance Industries India Sold gasoline to Iran in 

2009, but stopped in 

No reported sales. Stopped sales in 

2009.
Page 6 GAO-12-321R Sales of Refined Petroleum Products to Iran

Firm Country a Summary of reported 

sales – Jan. 2009 to 

June 2010 

Summary of reported sales – July 

2010 to Dec. 2011

2009.

13. Royal Dutch Shell the 

Netherlands

Sold gasoline to Iran in 

2009, but stopped in 

2009.

No reported sales. Stopped sales in 

2009.

14. Total France Sold gasoline to Iran in 

2009 and 2010, but 

stopped in 2010.

No reported sales. Stopped sales in 

2010.

15. Trafigura Switzerland Sold gasoline to Iran in 

2009 and 2010, but 

stopped in 2010.

No reported sales. Stopped sales in 

2010.

16. Tupras Turkey Sold gasoline to Iran in 

2010, but stopped in 

2010.

No reported sales. Stopped sales in 

2010.

17. Vitol Switzerland Sold gasoline to Iran in 

2009 and 2010, but 

stopped in 2010.

No reported sales. Stopped sales in 

2010.

Source: GAO analysis of open source information. 

a

The country listed in this column is the physical location of the firm as reported in open sources.

According to Open Sources, Sales of Refined Petroleum Products to Iran Have 

Decreased

Based on open sources, since the enactment of CISADA in July 2010, sales of refined 

petroleum products to Iran have decreased. According to DOE, Iran imported 

approximately 130,000 barrels of gasoline per day in 2009. DOE reported that in 2010 

Iran imported an estimated 78,000 barrels per day, and Petroleum Intelligence Weekly 

reported in July 2011 that the imports had declined to an estimated 50,000 barrels per 

day. According to State and DOE officials, the reduction in the sales of refined petroleum 

products to Iran can be attributed to multiple causes, including (1) a decrease in the 

number of firms selling refined petroleum products to Iran, (2) increased Iranian refining 

capacity, and (3) a reduction in Iranian government gasoline subsidies provided to Iranian 

citizens, which aimed to lower domestic demand.

According to a 2011 DOE report, Iran has a limited refinery capacity for the production of 

fuel and consequently imports a sizable share of its gasoline supply. According to DOE, 

the sanctions imposed on Iran have made it difficult for Iran to import the needed volumes 

of gasoline to meet demand, as the number of firms that are reported to have sold refined 

petroleum products to Iran has decreased.

In addition, Iran is expanding its refining capacity to meet domestic demand and reduce 

reliance on foreign refined petroleum products. For example, according to an open 

source, Iran has expanded its Shazand refinery, which quadrupled gasoline production 

capacity to 100,000 barrels per day. Increased refinery output will eventually lead to a 

further reduction in Iran's purchase of gasoline from foreign firms, and DOE reported that 

if proposed expansions occur as planned, Iran could export gasoline in 2015. 
Page 7 GAO-12-321R Sales of Refined Petroleum Products to Iran

Furthermore, DOE, an Institute for Defense Analyses briefing, and open source reports 

indicated that, in order to compensate for the reduction of shipments of refined petroleum 

products, Iran has been producing gasoline at petrochemicals facilities.12 According to 

these sources, gasoline produced in this way is of poor quality and reduces the output of 

petrochemicals that would have been produced in these facilities otherwise. 

Finally, according to DOE and International Monetary Fund reports, Iran has also reduced 

the amount of gasoline subsidies for citizens in an effort to reduce domestic demand for 

gasoline and further limit the impact of reduced imports of refined petroleum products. The 

government of Iran subsidizes petroleum sales in-country, but on December 19, 2010, it

announced a reduction in the subsidy of gasoline for Iranian citizens, increasing the cost 

of gasoline from approximately $0.10 per liter to $0.40 per liter for up to 60 liters of 

gasoline per month, according to open source reports. According to an International 

Monetary Fund report, gasoline consumption in Iran declined as a result of the change.

The Secretary of State Imposed Sanctions on Eleven Foreign Firms for Providing Refined 

Petroleum Products to Iran

Since the enactment of CISADA in July 2010, the Secretary of State has imposed 

sanctions under ISA on 13 firms, including sanctions on 11 firms for the sale of refined 

petroleum products or related goods and services to Iran.13 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, and 

Tanker Pacific Management Pte. Ltd.14

• 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. 

On January 12, 2012, State imposed sanctions on 

Zhuhai Zhenrong, FAL Oil Company Limited (United Arab Emirates), and Kuo Oil (S) Pte. 

Ltd. (Singapore) for conducting business with Iran’s energy sector. According to State, the 

firms were sanctioned for the following reasons: 

 

12Jessica L. Knight, Dr. Robert A. Zirkle, and Dr. Richard H. White, Institute for Defense Analyses. Iran’s 

Petrochemical Plants: An Open Source Primer, annotated briefing prepared for United States Central 

Command (Alexandria, Va: Mar. 22, 2011). The Institute for Defense Analyses annotated briefing is an 

unclassified, open source review of Iran’s petrochemical plants, and includes findings and conclusions 

regarding the production, development, and expansion of Iran’s petrochemical industry.

13In addition to the sanctions imposed on eleven firms for the sale of refined petroleum products or related 

goods and services to Iran, on October 13, 2010, and April 5, 2011, the Secretary of State imposed sanctions 

on two firms, Belarusneft (Belarus) and NaftIran Intertrade Company (Switzerland) for their investment in 

Iran’s oil, gas, and petrochemical sectors. 75 Fed. Reg. 62916-02 (Oct. 13, 2010) (imposing sanctions on 

Naftiran Intertrade Company) and 76 Fed. Reg. 18821-04 (Apr. 5, 2011) (imposing sanctions on Belarusneft).

14See Public Notice 7585, 76 Fed. Reg. 56866 (Sep. 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.). 

 
Page 8 GAO-12-321R Sales of Refined Petroleum Products to Iran

• 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.

• Zuhai Zhenrong is the largest supplier of refined petroleum products to Iran, and

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 over 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.

To identify firms that sell refined petroleum products to Iran, a State official 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. 

According to a State official, companies are going to great lengths to hide the sales of 

refined petroleum products to Iran. According to a State official, intelligence information 

gathered by the U.S. government led to the determination to impose sanctions on all but 

one of the firms.

15 

In a related report, we described State's process for enforcing energy-related sanctions 

under ISA, including those for the sale of refined petroleum products to Iran.16

None of the Four Firms Had Contracts with the U.S. Government

From July 1, 2010, to December 31, 2011, the U.S. government did not have any 

contracts with the four firms that were reported in open sources to have sold refined 

petroleum products to Iran during that period. As noted in our 2010 report, the U.S. 

government obligated funds to three firms that were reported to have sold refined 

petroleum products to Iran, but open sources did not report that these firms sold such 

products to Iran after the enactment of CISADA in July 2010.

 

15We searched open sources for information on the eleven firms on which State imposed sanctions for the 

sale of refined petroleum products or related goods and services to Iran. We identified reports in at least three 

credible and reliable open sources that Petróleos de Venezuela S.A. and Zuhai Zhenrong had sold refined 

petroleum products to Iran between July 1, 2010, and December 31, 2011. We did not find sufficient 

information in at least three credible and reliable open sources that reported that the remaining nine firms had 

sold or transported refined petroleum products to Iran during that time period.

16GAO-12-316R. 
Page 9 GAO-12-321R Sales of Refined Petroleum Products to Iran

Agency Comments

We provided the Departments of State, Energy, and Defense with a draft of this report for 

review and comment. The Department of State provided technical comments, which we

incorporated into the report as appropriate. The Departments of Defense and Energy did 

not comment on the report.

In addition, we provided the firms listed in this report as having sold refined petroleum 

products to Iran between July 1, 2010, and December 31, 2011, an opportunity to 

comment on the open source information about their activities. As of December 31, 2011, 

we had not received any responses from firms that were reported to have sold Iran refined 

petroleum products or the firms that did not have sufficient information on whether they 

sold or stopped selling refined petroleum products to Iran after June 30, 2010.

- - - - - 

As agreed with your offices, unless you publicly announce the contents of this report 

earlier, we plan no further distribution until 7 days from the report date. At that time, we 

will send copies to appropriate congressional committees, the Secretary of State, 

Secretary of Energy, and Secretary of Defense. In addition, the report will be available at 

no charge on GAO’s website at http://www.gao.gov. 

If you or your staffs 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 major 

contributions to this report are listed in enclosure II.

Thomas Melito

Director, International Affairs and Trade

Enclosures - 2 
Enclosure I

Page 10 GAO-12-321R Sales of Refined Petroleum Products to Iran

Scope and Methodology

To identify firms reported in open sources to have sold refined petroleum products to Iran 

at any time during the period between July 1, 2010, and December 31, 2011, 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. To generate our list of 

firms that provided refined petroleum products to Iran, we reviewed open sources 

published between July 1, 2010, and December 31, 2011. Open source information is 

overt and publicly available information, as opposed to covert or classified. 

We searched industry trade publications for reports of firms selling refined petroleum 

products to Iran at any time during the period between July 1, 2010, and December 31, 

2011. 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 reviewed 

the open sources for specific firms named in U.S. government reports from the 

Department of State (State) and the Department of Energy (DOE) as sellers of refined 

petroleum products to Iran. We also reviewed company publications, annual reports, 

Securities and Exchange Commission filings, and press releases and corporate 

statements reporting the sale of refined petroleum products to Iran or for corrected 

information that had been publicly reported. In addition, we reviewed government reports 

from the Congressional Research Service, as well as other reports from international and 

industry organizations, such as the International Atomic Energy Agency and IHS Global 

Insight. 

After identifying firms in open sources, we confirmed that the reports of the sales of 

refined petroleum products to Iran were reliable if one of the following criteria had been 

met: (1) at least three standard industry publications cited the firm as having sold refined 

petroleum products to Iran at any time during the period between July 1, 2010, and 

December 31, 2011, (2) the firm provided information on its corporate website about its 

sale of refined petroleum products to Iran at any time during this period, and at least one 

standard industry publication corroborated the firm’s reported sale of refined petroleum 

products to Iran at any time during this period, or (3) the firm provided information in a 

corporate report, a Securities and Exchange Commission filing, or confirmed in a letter to 

us that the firm sold refined petroleum products to Iran during this period. If none of these 

criteria were met, the firm was not included in our tables. We did not review the contracts 

or documents underlying these transactions reported in open sources and did not 

independently verify these transactions. We reviewed open source information to identify 

the details of the reported sale of refined petroleum products to Iran. 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 reported sales of refined petroleum 

products to Iran met the legal criteria for sanctionable activities under the Iran Sanctions 

Act, as amended by the Comprehensive Sanctions Accountability and Divestment Act. 

The Secretary of State is responsible for making such determinations. We also applied the 
Enclosure I

Page 11 GAO-12-321R Sales of Refined Petroleum Products to Iran

same methodology to determine whether to list a firm that was reported to have stopped 

selling refined petroleum products to Iran during the same period. We determined to list 

firms that were reported to have stopped sales if three separate open sources reported 

and/or the firm provided information to GAO that it had stopped sales of refined petroleum 

products to Iran. We also reviewed open sources to confirm that no new reports of refined 

petroleum product sales by these companies had resumed after June 30, 2010.

We interviewed officials from State and DOE regarding the Iranian energy sector and 

sales of refined petroleum products to Iran. We also met with intelligence agency officials 

to discuss sales of refined petroleum products to Iran and Iran’s energy sector, but we did 

not present any classified information in this report. 

After identifying the firms that were reported to have sold refined petroleum products to 

Iran, we attempted to contact the firms by telephone to explain the purpose of our report 

and obtain an appropriate point of contact within the firm to officially comment on the 

information reported in open sources. We then e-mailed the firms a letter containing 

information from table 1 concerning the firms’ reported sales to Iran. As of December 31, 

2011, none of the firms had responded. 

To determine whether the four firms identified in open sources as having sold refined 

petroleum products to Iran also had contracts with the U.S. government from July 1, 2010, 

through December 31, 2011, we searched the Federal Procurement Data System-Next 

Generation (FPDS-NG) for references to these firms. We chose FPDS-NG to determine 

whether any of these firms also had contracts with the U.S. government because FPDSNG has served as the primary governmentwide contracting database since 1978. 

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

of data on agency contracting actions, procurement, and spending. The Office of 

Management and Budget established FPDS-NG, and the General Services Administration 

administers the system. More than 60 government departments, agencies, and other 

entities submit contract data to FPDS-NG. 

We searched the FPDS-NG archives from July 1, 2010, through December 31, 2011 

using search terms that would select any record with the names of firms that were 

reported to have sold refined petroleum products to Iran, as identified in table 1. Our 

searches for U.S. contracts only covered firms that we had identified in open sources as 

having sold or shipped refined petroleum products to Iran.

We conducted our work from September 2011 to January 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 12 GAO-12-321R Sales of Refined Petroleum Products to Iran

GAO Contact and Staff Acknowledgments

GAO Contact

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

Staff Acknowledgments

In addition to the individual named above, Tetsuo Miyabara (Assistant Director), John F. 

Miller, Joanna Berry, Grace Lui, Julia Kennon, Debbie Chung, and Dave Hancock made 

key contributions to this report.

(320865)
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