Iranian Commercial Activities: Foreign Firms Reported to Have Engaged in Certain Activities Involving Iran's Energy or Communications Sectors

What GAO Found

GAO's 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, including one previously-unidentified firm--China Oilfield Services Limited. In addition, since the last report issued in December 2012, GAO moved four firms--INA, ONGC Videsh Ltd., Petronet LNG, and Sasol--to the "Withdrawn" category. For eight additional firms that GAO previously identified as reported to have engaged in commercial activity in Iran's energy sector, GAO found insufficient information to indicate that they had either continued or ceased such activity during the specified time period.

GAO's 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 the last report in December 2012, GAO moved one firm--Zhuhai Zhenrong--from the "Insufficient information available" category to the "Withdrawn" category. For four additional firms that GAO previously identified as reported to have sold refined petroleum products to Iran, the open-source review provided insufficient information to indicate either that they had continued or ceased selling such products to Iran during the specified time period.

GAO's 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, GAO reported on numerous challenges to identifying firms through open sources. 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 GAO 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 the Federal Procurement Data System-Next Generation. As already noted, GAO 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.

Why GAO Did This Study

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. Since 2010, in response to these mandates and other requests, GAO has 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.

This report updates GAO's prior reports by identifying 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.

GAO used information published in open sources on or before November 7, 2013, updating information included in prior reports. These open sources consisted of industry and trade publications, corporate reports and statements, and U.S. Securities and Exchange Commission filings. On the basis of the open-source information, GAO categorized firms as "Active," "Insufficient information available," or "Withdrawn." GAO attempted to contact all 15 firms identified as "Active" or "Insufficient information available" to offer them an opportunity to comment on the findings. GAO 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; GAO did not attempt to make such determinations. For the fourth objective, GAO searched the Federal Procurement Data System-Next Generation, the primary government-wide contracting database since 1978.