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Testimony: 

Before the Committee on Oversight and Government Reform, House of 
Representatives: 

United States Government Accountability Office: 
GAO: 

For Release on Delivery: 
Expected at 10:00 a.m. EDT:
Thursday, July 29, 2010: 

Iran Sanctions: 

New Act Underscores Importance of Comprehensive Assessment of 
Sanctions' Effectiveness: 

Statement of Joseph A. Christoff, Director: 
International Affairs and Trade: 

GAO-10-928T: 

[End of section] 

Mr. Chairman and Members of the Committee: 

I am pleased to be here today to discuss our work on the 
implementation of U.S. sanctions against Iran. My testimony will 
discuss the continuing challenges the United States faces in (1) 
deterring the illegal transshipment of U.S. goods to Iran, (2) 
restricting foreign investment in Iran's energy sector, and (3) 
assessing the overall effectiveness of U.S. sanctions. In addition, I 
will discuss how the Comprehensive Iran Sanctions, Accountability, and 
Divestment Act of 2010 (signed into law on July 1, 2010) addresses 
these challenges. 

The United States has imposed multiple sanctions against Iran to deter 
it from developing its nuclear program, supporting terrorism, and 
abusing human rights. The United States has banned most U.S. trade and 
investment with Iran and prohibited firms from knowingly transshipping 
U.S. goods to Iran through other nations. The United States has also 
acted to limit Iran's ability to explore for, extract, refine, or 
transport its petroleum resources. The Comprehensive Iran Sanctions, 
Accountability, and Divestment Act of 2010 expands existing sanctions 
against Iran and requires the Administration to report on information 
related to the sanctions. 

My statement is drawn from prior GAO work related to sanctions against 
Iran.[Footnote 1] We conducted this work in accordance with all 
sections of GAO's Quality Assurance Framework and generally accepting 
government auditing standards, as appropriate. Those standards require 
that we plan and perform the audits to obtain sufficient, appropriate 
evidence to provide a reasonable basis for our findings and 
conclusions based on our audit objectives. We believe the evidence 
obtained provides a reasonable basis for our findings and conclusions 
based on our audit objectives. 

Summary: 

Iran is obtaining U.S. military and dual-use goods (civilian goods 
with potential military applications) that are illegally transshipped 
through intermediaries in third-party nations, most notably the United 
Arab Emirates, Malaysia, and Singapore. U.S. agencies have conducted 
investigations to uncover Iranian procurement networks and prosecuted 
at least 30 firms and individuals between 2007 and 2009. The 
Comprehensive Iran Sanctions, Accountability, and Divestment Act of 
2010 requires the President to designate a country as a Destination of 
Diversion Concern if certain criteria are met. Moreover, the President 
shall impose a licensing requirement upon certain U.S. exports to the 
designated country unless the President makes a number of 
determinations, including determining that it is appropriate to 
provide technical assistance to strengthen the country's export 
control systems. 

At least 41 foreign firms had commercial activity in Iran's energy 
sector between 2005 and 2009. Of these firms, seven had contracts with 
the U.S. government valued at almost $880 million. The Iran Sanctions 
Act of 1996 (ISA) provides for sanctions against persons (firms and 
individuals) who invest more than $20 million in Iran's energy sector 
in any 12-month period. However, the United States has not sanctioned 
firms under the ISA for investing in Iran's energy sector. The 
Comprehensive Iran Sanctions, Accountability, and Divestment Act of 
2010 requires the President to investigate reports of certain 
sanctionable activity where credible evidence is received and make a 
determination in writing to Congress whether such activity has indeed 
occurred. The President would then be expected either to impose or 
waive sanctions. 

We previously recommended that the Administration improve the 
disparate data collected on Iran sanctions, establish a baseline of 
information on Iran sanctions, and conduct an overall assessment of 
the sanctions' impact in achieving U.S. foreign policy goals. Recent 
congressional action has expanded sanctions against Iran and imposed 
new reporting requirements on the Administration. These actions 
underscore the importance of comprehensive assessments of the 
effectiveness of U.S. sanctions against Iran. 

Background: 

U.S. exports to Iran are severely restricted by U.S. laws and 
regulations.[Footnote 2] The U.S. trade ban generally prohibits 
exports of U.S. goods (including dual-use goods) to countries other 
than Iran without a Treasury Department license if the exporter has 
reason to know the goods are specifically intended for transshipment 
to Iran.[Footnote 3] Foreign firms are generally prohibited from 
knowingly re-exporting goods on the Commerce Department's list of 
controlled dual-use goods to Iran even if those goods were originally 
legally exported from the United States to a third country under a 
Commerce license.[Footnote 4] For example, dual-use U.S. goods 
exported to countries other than Iran under a Commerce license may not 
be subsequently transshipped to Iran without a Treasury license if the 
exporter knew or had reason to know that such goods were intended for 
Iran. The Departments of Commerce, Defense, Homeland Security, 
Justice, and the Treasury investigate allegations of illegal 
transshipment of U.S. goods to Iran. Exporters who knowingly ship U.S. 
goods to Iran through other countries without a Treasury license are 
subject to prosecution by the Department of Justice. 

Iran has the world's third largest oil reserves, or about 140 billion 
barrels, and produces about 4.2 million barrels per day. However, 
Iran's oil production has remained virtually flat in recent years and 
will likely stagnate in the medium term due to insufficient 
investment, according to the International Monetary Fund. Iran 
requires increasingly modern and advanced oil recovery technologies to 
stop natural declines of oil production, but has found advanced 
technology difficult to import due to international sanctions and high 
costs. According to the Department of Energy (DOE), Iran does not 
currently have sufficient refining capacity to meet its domestic 
demand for gasoline. Iran imported approximately 130,000 barrels of 
gasoline per day in 2009, as well as other refined products such as 
diesel fuel. Iran's nine refineries are operated by the National 
Iranian Oil Refining and Distribution Company, according to DOE. With 
the potential participation of foreign companies, Iran plans to add 
capacity at eight refineries to fully meet domestic demand for 
gasoline by 2013 or 2014, according to DOE officials. 

Iran Obtains Illegal Transshipments of U.S. Military and Dual-Use 
Goods through Other Countries; New Act Calls for Identification of 
Destinations of Diversion Concern: 

The United States banned nearly all trade and investment with Iran in 
1995 after banning imports from that country in 1987. According to a 
Treasury official, the trade and investment ban is aimed at making it 
more difficult for Iran to procure U.S. goods, services, and 
technology, including those that could be used for terrorism or 
proliferation. However, as we have reported, attempts have been made 
to circumvent the trade ban through the transshipment of U.S. exports 
through third countries. U.S officials identified several locations 
that serve as transshipment points for military and dual-use goods 
destined for Iran, including the United Arab Emirates (UAE), Malaysia, 
Singapore, Thailand, Australia, Canada, Colombia, Brazil, Austria, 
France, Germany, Luxembourg, The Netherlands, and the United Kingdom 
(see figure 1). 

Figure 1: Illegal Transshipment Routes to Iran: 

[Refer to PDF for image: illustrated world map] 

(1) U.S. exports to intermediary countries: 

(2) Location of transshipment intermediaries: 
Australia; 
Austria; 
Brazil; 
Canada; 
Colombia; 
France; 
Luxembourg; 
Malaysia; 
Netherlands; 
Singapore; 
Thailand; 
United Arab Emirates; 
United Kingdom; 

(3) Transshipments to Iran: 

Sources: GAO analysis of Justice Department data; Map Resources (map). 

[End of figure] 

A 2009 Justice Department report cited 30 cases that involved the use 
of intermediaries in these countries. More than half of the cases 
listed involved the use of intermediaries in the UAE for 
transshipment. About 20 percent involved the use of intermediaries in 
Malaysia and Singapore. U.S. goods involved in these cases included 
U.S. military aircraft components, laboratory equipment, specialty 
alloy pipes, night vision goggles, and sensitive technologies sent to 
Iranian missile and nuclear entities. 

U.S. officials stated that the UAE has taken steps to address the use 
of its territory for transshipment. They noted that the UAE has 
increased cooperation with U.S. enforcement entities and enacted new 
export control legislation in 2007. According to the UAE government, 
the new law bans the export/re-export of strategic goods (including 
arms and military hardware, chemical and biological materials, and 
dual-use goods) without a special license, and specifies penalties 
that include imprisonment or fines. Commerce officials stated that the 
law contains the basic elements of an export control regime to combat 
transshipment. However, Commerce officials have reported a high rate 
of unfavorable end-use checks for U.S. items exported to the UAE and 
U.S. officials note the potential shift of illegal transshipment 
operations to other nations, such as Malaysia and Singapore. 

The Comprehensive Iran Sanctions, Accountability, and Divestment Act 
of 2010 addresses the use of intermediaries to transship military and 
dual-use items to Iran. Under the Act, the Director of National 
Intelligence must identify to the President, relevant agency heads, 
and appropriate congressional committees the countries whose 
governments the Director believes allow the transshipment or diversion 
to Iran of certain U.S. goods, services or technologies. Moreover, the 
President shall designate a country as a Destination of Diversion 
Concern if the President determines that the government of the country 
allows substantial diversion of specified U.S. goods, services, or 
technologies through the country to Iranian end-users or Iranian 
intermediaries. Upon designation, the President must submit to the 
appropriate congressional committees a report identifying the 
countries of concern and listing the items that are being diverted 
through each respective country. After designation, the President 
shall require a license to export to the designated country the 
specified U.S. goods, services, or technologies. This licensing 
requirement may be delayed if the President makes a number of 
determinations including determining that it is appropriate to provide 
technical assistance to strengthen the country's export control 
systems. 

Foreign Firms Maintain Commercial Ties to Iran's Energy Sector; New 
Act Requires President to Begin Investigations and Report on Firms' 
Investments in Iran's Energy Sector: 

Iran's energy sector is vital to its economy and government. In recent 
years, oil export revenues have accounted for 50 to 76 percent of the 
Iranian government's revenues and 24 percent of Iran's gross domestic 
product. However, Iran has not reached peak crude oil production 
levels since 1978, does not produce sufficient natural gas for 
domestic use, and lacks the refining capacity to meet domestic demand 
for gasoline. Accordingly, Iran is seeking the participation of 
foreign firms in providing financing and technical assistance in 
numerous energy projects. 

Based on our review of open source information, we identified 41 firms 
that had commercial activity in the Iranian energy sector between 2005 
and 2009 (see appendix 1). Open source information stated that these 
firms supported activities throughout Iran that involved the 
exploration and development of oil and gas, petroleum refining, or 
petrochemicals, including the construction of pipelines and tankers 
for the transport of oil or gas (see figure 2). 

Figure 2: Map of Iranian Oil, Gas, and Petrochemical Activities: 

[Refer to PDF for image: illustrated map] 

In addition to cities in Iran and surrounding countries, the following 
entities are depicted on the map: 
Oilfield; 
Oil pipeline; 
Gas field; 
Gas pipeline; 
Refinery; 
Gas-processing plant; 
Tanker terminal; 
Agreed-upon maritime boundary. 

Source: GAO analysis of U.S. Department of Energy data. 

[End of figure] 

Of the 41 firms, seven had contracts with the U.S. government (see 
appendix II for these firms). From fiscal years 2005 through 2009, the 
U.S. government obligated almost $880 million in contracts to these 
seven firms. U.S. agencies obligated almost 90 percent of these funds 
for purchases of fuel and petroleum products overseas. 

ISA provides for sanctions against persons who invest more than $20 
million in Iran's energy sector in any 12-month period. ISA authorizes 
the President, who delegated authority to the Secretary of State, to 
ban such persons from U.S. government procurement. However, the 
Secretary of State has not determined that a firm's activities have 
met the legal criteria for sanctions under the Iran Sanctions Act 
since 1998. At that time, the Secretary waived the imposition of 
sanctions upon three foreign energy firms--Total (France), Gazprom 
(Russia), and Petronas (Malaysia). In waiving the sanctions, the 
Secretary cited the European Union's cooperation on counterterrorism 
efforts involving Iran and the possibility that the Union would take 
the issue to the World Trade Organization. 

The Comprehensive Iran Sanctions, Accountability, and Divestment Act 
of 2010 requires additional action on the part of the President. The 
new act requires, rather than authorizes, the President to initiate an 
investigation upon receipt of credible evidence that a person is 
engaged in certain prohibited activities such as investment in the 
development of Iran's petroleum sector.[Footnote 5] The President is 
also required to make a determination in writing to Congress about 
whether such activity has indeed occurred. The President would then be 
expected either to impose or waive sanctions. The Act also requires 
the President to submit a report to Congress on investments in Iraq's 
energy sector since January 2006, including a list of all significant 
energy related joint ventures, investments, and partnerships Iran has 
with entities from other countries and an estimate of the value of 
these investments. 

Our list of 41 firms with commercial activity in Iran's energy sector 
has prompted reaction from the cited firms. Upon request, 13 of the 41 
firms provided comments on a draft of the report. Since the report was 
released, four firms have provided additional comments. Tecnimont 
(Italy) stated that it had canceled its involvement in an Iranian 
energy project due to lack of financing. Statoil (Norway) confirmed 
that it had frozen new investments in Iran's South Pars natural gas 
field and halted oil exploration and development activities in Iran. 
Repsol (Spain) provided us a copy of its May 2010 letter to the 
Iranian government discontinuing its participation in a $10 billion 
project to develop Iran's Persian LNG project. Repsol's withdrawal 
from the project will be effective July 31, 2010. We also received a 
letter from Ashok Leyland Project Services of India stating that it 
had not made binding agreements regarding the cited projects and would 
not take actions that violate laws or expose it to U.S. sanctions. 
[Footnote 6] 

New Act Underscores Importance of Comprehensive Assessment of 
Sanctions' Effectiveness: 

Additional sanctions in the Comprehensive Iran Sanctions, 
Accountability, and Divestment Act of 2010 and new reporting 
requirements underscore the importance of comprehensive assessments of 
U.S. sanctions' effectiveness in deterring Iran's support for 
terrorism and continued nuclear proliferation. In December 2007, we 
recommended that the Administration complete such an assessment. We 
found that U.S. agencies--State, Treasury, Commerce, Homeland 
Security, and others--collected disparate data on the multiple 
sanctions they implemented. 

Accordingly, we recommended that U.S. agencies consider collecting and 
analyzing data on, but not limited to, 

* the number of goods seized, penalties imposed, and convictions 
obtained under the trade ban (Homeland Security, Treasury, Commerce, 
Justice); 

* sensitive items diverted to Iran through transshipment points 
(Commerce and the intelligence community); 

* the amount of assets frozen resulting from financial sanctions 
(Treasury and the intelligence community); and: 

* the extent of delays in foreign investment in Iran's energy sector 
(State, Energy, and the intelligence community). 

The data should then be used to establish baseline information for 
continuous monitoring and periodic reporting on what U.S. sanctions 
have achieved. 

The Comprehensive Iran Sanctions, Accountability, and Divestment Act 
of 2010 expands the number of activities that are sanctionable. For 
example, the Act requires the President to impose sanctions against 
persons or entities that: 

* export at least a certain value of refined petroleum products to 
Iran, 

* sell at least a certain value of services and technology to maintain 
or expand Iran's refinery capacity: 

* export sensitive technologies that the Iranian government can use to 
monitor or jam its citizens communications, and: 

* commit human rights abuses against Iranian citizens. 

The Act also adds reporting requirements that increase the 
transparency of the Administration's actions, but also underscore the 
importance of having a framework to utilize the reports' data and 
provide a comprehensive assessment. For example, the Administration 
must report on investments in Iran's energy sector, the activities of 
foreign export credit agencies, and the number of countries of 
diversion concern. 

These expanded sanctions and reporting requirements underscore the 
importance of improving data collection, establishing a baseline, and 
comprehensively assessing the impact of sanctions on Iran. Such 
assessments are important because they provide the Administration and 
Congress with important information on the impact of existing and new 
sanctions and the extent to which these collective sanctions further 
the achievement of U.S. foreign policy and security goals toward Iran. 

Mr. Chairman, this concludes my statement. I would be pleased to 
answer any questions that you or other members may have at this time. 

GAO Contacts and Staff Acknowledgments: 

Should you have any questions about this testimony, please contact 
Joseph A. Christoff at (202) 512-8979, or christoffj@gao.gov. Contact 
points for our Offices of Congressional Relations and Public Affairs 
may be found on the last page of this statement. Individuals who made 
key contributions to this statement include Tet Miyabara (Assistant 
Director), Pierre Toureille, Grace Lui, Jon Fremont, Jennifer Bryant, 
and Debbie Chung. 

[End of section] 

Appendix I: Foreign Firms Publicly Reported to Have Commercial 
Activity in the Iranian Oil, Gas, or Petrochemical Sectors As Of March 
2010: 

Firm[A]: 1. ABB Lummus; 
Country[B]: Not applicable; 
Sector: Refining, petrochemicals. 

Firm[A]: 2. Amona; 
Country[B]: Malaysia; 
Sector: Oil exploration and production. 

Firm[A]: 3. Belneftekhim; 
Country[B]: Belarus; 
Sector: Oil exploration and production. 

Firm[A]: 4. China National Offshore Oil Corporation; 
Country[B]: China; 
Sector: Natural gas. 

Firm[A]: 5. China National Petroleum Corporation; 
Country[B]: China; 
Sector: Oil exploration and production, natural gas. 

Firm[A]: 6. Costain Oil, Gas & Process Ltd.; 
Country[B]: United Kingdom; 
Sector: Natural gas. 

Firm[A]: 7. Daelim; 
Country[B]: South Korea; 
Sector: Natural gas. 

Firm[A]: 8. Daewoo Shipbuilding & Marine Engineering; 
Country[B]: South Korea; 
Sector: Oil tankers. 

Firm[A]: 9. Edison; 
Country[B]: Italy; 
Sector: Oil exploration and production. 

Firm[A]: 10. ENI; 
Country[B]: Italy; 
Sector: Oil exploration and production. 

Firm[A]: 11. Gazprom; 
Country[B]: Russia; 
Sector: Oil exploration and production, pipeline. 

Firm[A]: 12. GS; 
Country[B]: South Korea; 
Sector: Natural gas. 

Firm[A]: 13. Haldor Topsoe; 
Country[B]: Denmark; 
Sector: Refining. 

Firm[A]: 14. "Hinduja" (Ashok Leyland Project Services); 
Country[B]: "United Kingdom" (India); 
Sector: Oil exploration and production, natural gas. 

Firm[A]: 15. Hyundai Heavy Industries; 
Country[B]: South Korea; 
Sector: Oil tankers. 

Firm[A]: 16. INA; 
Country[B]: Croatia; 
Sector: Oil exploration and production, natural gas. 

Firm[A]: 17. Indian Oil Corporation; 
Country[B]: India; 
Sector: Natural gas. 

Firm[A]: 18. Inpex; 
Country[B]: Japan; 
Sector: Oil exploration and production. 

Firm[A]: 19. JGC Corporation; 
Country[B]: Japan; 
Sector: Refining. 

Firm[A]: 20. Lukoil; 
Country[B]: Russia; 
Sector: Oil exploration and production. 

Firm[A]: 21. LyondelBasell; 
Country[B]: Netherlands; 
Sector: Petrochemicals. 

Firm[A]: 22. Oil India Ltd.; 
Country[B]: India; 
Sector: Natural gas. 

Firm[A]: 23. Oil and Natural Gas Corporation; 
Country[B]: India; 
Sector: Oil exploration and production, natural gas. 

Firm[A]: 24. OMV; 
Country[B]: Austria; 
Sector: Natural gas. 

Firm[A]: 25. ONGC Videsh Ltd.; 
Country[B]: India; 
Sector: Natural gas. 

Firm[A]: 26. Petrobras; 
Country[B]: Brazil; 
Sector: Oil exploration and production. 

Firm[A]: 27. Petrofield; 
Country[B]: Malaysia; 
Sector: Natural gas. 

Firm[A]: 28. Petroleos de Venezuela S.A.; 
Country[B]: Venezuela; 
Sector: Natural gas. 

Firm[A]: 29. Petronet LNG; 
Country[B]: India; 
Sector: Natural gas. 

Firm[A]: 30. PGNiG; 
Country[B]: Poland; 
Sector: Natural gas. 

Firm[A]: 31. PTT Exploration & Production; 
Country[B]: Thailand; 
Sector: Natural gas. 

Firm[A]: 32. Repsol; 
Country[B]: Spain; 
Sector: Natural gas. 

Firm[A]: 33. Royal Dutch Shell; 
Country[B]: Netherlands; 
Sector: Natural gas. 

Firm[A]: 34. Sinopec; 
Country[B]: China; 
Sector: Oil exploration and production, refining. 

Firm[A]: 35. SKS Ventures; 
Country[B]: Malaysia; 
Sector: Natural gas. 

Firm[A]: 36. Snamprogetti; 
Country[B]: Italy; 
Sector: Pipeline. 

Firm[A]: 37. StatoilHydro; 
Country[B]: Norway; 
Sector: Oil exploration and production, natural gas. 

Firm[A]: 38. Tecnimont; 
Country[B]: Italy; 
Sector: Petrochemicals. 

Firm[A]: 39. Total; 
Country[B]: France; 
Sector: Natural gas. 

Firm[A]: 40. Turkish Petroleum Company; 
Country[B]: Turkey; 
Sector: Natural gas. 

Firm[A]: 41. Uhde; 
Country[B]: Germany; 
Sector: Petrochemicals. 

Source: GAO analysis of open source information. 

[A] Following the March 2010 publication of this table, four firms 
(Ashok Leyland, Repsol, Statoil, and Tecnimont) informed us that they 
had not gone forward with the projects cited in the table. 

[B] The country listed is the physical location of the firm. 

[End of table] 

[End of section] 

Appendix II: Firms Reported in Open Sources as Having Both Commercial 
Activity in the Iranian Energy Sector and U.S. Government Contracts: 

Firm/country[A]: Repsol/Spain; 
U.S. Government obligations: 
FY 2005: $40 million; 
FY 2006: $37 million; 
FY 2007: $110 million; 
FY 2008: $81 million; 
FY 2009: $51 million; 
Total: $319 million. 

Firm/country[A]: Total/France; 
U.S. Government obligations: 
FY 2005: $0; 
FY 2006: $27 million; 
FY 2007: $0; 
FY 2008: $154 million; 
FY 2009: $131 million; 
Total: $312 million. 

Firm/country[A]: Daelim Industrial Co./South Korea; 
U.S. Government obligations: 
FY 2005: $0; 
FY 2006: $0; 
FY 2007: $0; 
FY 2008: $0; 
FY 2009: $111 million; 
Total: $111 million. 

Firm/country[A]: ENI/Italy; 
U.S. Government obligations: 
FY 2005: $9 million; 
FY 2006: $88 million; 
FY 2007: Less than $100,000; 
FY 2008: $0; 
FY 2009: $0; 
Total: $97 million. 

Firm/country[A]: PTT Exploration and Production/Thailand; 
U.S. Government obligations: 
FY 2005: $21 million; 
FY 2006: $4 million; 
FY 2007: $6 million; 
FY 2008: $1 million; 
FY 2009: $3 million; 
Total: $35 million. 

Firm/country[A]: Hyundai Heavy Industries/South Korea; 
U.S. Government obligations: 
FY 2005: $1 million; 
FY 2006: $2 million; 
FY 2007: $1 million; 
FY 2008: $0; 
FY 2009: $0; 
Total: $5 million. 

Firm/country[A]: GS Engineering and Construction/South Korea; 
U.S. Government obligations: 
FY 2005: Less than $100,000; 
FY 2006: $0; 
FY 2007: $0; 
FY 2008: $0; 
FY 2009: $0; 
Total: Less than $100,000. 

Firm/country[A]: Total; 
U.S. Government obligations: 
FY 2005: $71 million; 
FY 2006: $158 million; 
FY 2007: $117 million; 
FY 2008: $236 million; 
FY 2009: $296 million; 
Total: $879 million. 

Source: GAO analysis of Federal Procurement Data System-Next 
Generation records and other government records. 

Note: Totals may not add due to rounding. 

[A] The country listed is the physical location of the firm as 
reported in open sources. 

[End of table] 

[End of section] 

Footnotes: 

[1] GAO, Iran Sanctions: Firms Reported to Have Commercial Activity in 
the Iranian Energy Sector and U.S. Government Contracts, [hyperlink, 
http://www.gao.gov/products/GAO-10-721T] (Washington, D.C.: May 12, 
2010); Firms Reported to Have Commercial Activity in the Iranian 
Energy Sector and U.S. Government Contracts, [hyperlink, 
http://www.gao.gov/products/GAO-10-639R] (Washington, D.C.: May 4, 
2010); Firms Reported in Open Sources as Having Commercial Activity in 
Iran's Oil, Gas, and Petrochemical Sector, [hyperlink, 
http://www.gao.gov/products/GAO-10-515R] (Washington, D.C.: March 23, 
2010); Iran Sanctions: Complete and Timely Licensing Data Needed to 
Strengthen Enforcement of Export Restrictions, [hyperlink, 
http://www.gao.gov/products/GAO-10-375] (Washington, D.C.: March 4, 
2010); and Iran Sanctions: Impact in Furthering U.S. Objectives Is 
Unclear and Should Be Reviewed, [hyperlink, 
http://www.gao.gov/products/GAO-08-58] (Washington, D.C.: December 18, 
2007). 

[2] See generally, 31 C.F.R. part 560. 

[3] 31 C.F.R. § 560.204. 

[4] 31 C.F.R. § 560.205. 

[5] Pub. L. No. 111-195, § 102(g). This reporting requirement applies 
only to activities described in section 5(a) of the ISA. 

[6] The firm also stated that it, rather than "Hinduja," should have 
been identified as a firm with commercial activities in Iran's natural 
gas sector. 

[End of section] 

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