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GAO-10-967R: 

United States Government Accountability Office: 
Washington, DC 20548: 

September 3, 2010: 

The Honorable Joseph I. Lieberman:
Chairman:
The Honorable Susan Collins:
Ranking Member:
Committee on Homeland Security and Governmental Affairs:
United States Senate: 

The Honorable Jon Kyl:
Ranking Member:
Subcommittee on Terrorism and Homeland Security:
Committee on the Judiciary:
United States Senate: 

Subject: Firms Reported in Open Sources to Have Sold Iran Refined 
Petroleum Products between January 1, 2009, and June 30, 2010: 

The United States has imposed multiple sanctions against Iran to deter 
it from developing its nuclear program, supporting terrorism, and 
abusing human rights. On July 1, 2010, the President signed into law 
the Comprehensive Iran Sanctions, Accountability, and Divestment Act 
(CISADA) of 2010.[Footnote 1] CISADA amends the Iran Sanctions Act of 
1996 (ISA) to require the President to impose three or more of a 
possible nine sanctions against persons who knowingly sell or provide 
Iran with refined petroleum products that, during a 12-month period, 
(1) have a fair market value of $1 million or more or (2) have an 
aggregate fair market value of $5 million or more.[Footnote 2] These 
new provisions regarding the sale or provision of refined petroleum 
products to Iran apply only to the sale or provision of refined 
petroleum products made on or after July 1, 2010. Under ISA, one of 
the sanctions that the President can apply is to bar foreign firms 
that engage in these activities from U.S. government procurement. 
[Footnote 3] The Department of State administers ISA sanctions. 

According to the Department of Energy (DOE), Iran currently does not 
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 of its nine refineries in an attempt to fully meet 
domestic demand for gasoline by 2013 or 2014 at currently projected 
demand levels, according to DOE officials. 

This report highlights open source information that, following further 
investigation by the State Department, could contribute to the 
identification of persons or firms whose activities may be 
sanctionable under ISA, as amended by CISADA. As you requested, in 
this report, we identify (1) firms that were reported to have sold 
refined petroleum products[Footnote 4] to Iran at any time during the 
period between January 1, 2009, and June 30, 2010, and (2) firms that 
also had U.S. government contracts in fiscal year 2009 or 2010 (up to 
June 2010). We define 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. GAO 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 the firms listed in this report meet the legal criteria 
specified in ISA, as amended by CISADA, and we did not attempt to 
determine whether reported transactions were conducted on or after 
July 1, 2010--the date of enactment of CISADA. The Secretary of State 
is responsible for making such determinations. 

To accomplish our objectives, we reviewed open sources, including 
energy industry standard publications and corporate statements. 
Examples of industry standard publications include Oil Daily, Oil & 
Gas News, and Platt's Oilgram News. We listed a firm as having sold 
refined petroleum products to Iran if three reputable industry 
publications or the firm's corporate statements reported that the firm 
sold these products to Iran at any time between January 1, 2009, and 
June 30, 2010. We also indicated whether open sources reported that a 
firm stopped selling refined petroleum products during this period. We 
provided firms with an opportunity to comment by telephone and e-mail 
on the information reported in open sources. Not all of our attempts 
to reach the firms were successful. To determine whether firms also 
had U.S. government contracts, we searched the primary governmentwide 
contracting database for references to the firms. We also obtained 
U.S. government documents to corroborate information found in the 
contracting database. See enclosure I for a full description of our 
scope and methodology. 

We conducted our work from April 2010 to August 2010 in accordance 
with all sections of GAO's Quality Assurance Framework that are 
relevant to our objective. 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. 

Sixteen Firms Are Reported to Have Sold Refined Petroleum Products to 
Iran between January 1, 2009, and June 30, 2010: 

The following four tables list 16 firms identified in open sources as 
having sold refined petroleum products to Iran at any time during the 
period between January 1, 2009, and June 30, 2010. GAO did not attempt 
to determine whether the firms meet the legal criteria specified in 
ISA as amended by CISADA., or whether sales were conducted on or after 
July 1, 2010--the date of enactment of CISADA. According to DOE, firms 
that sell refined petroleum products to Iran may change over the 
course of a year because a firm may increase, decrease, or end sales 
from one month to the next. According to the State Department, some 
firms may have discontinued their activities after passage of CISADA 
to avoid triggering sanctions. We sorted the 16 firms into different 
tables on the basis of open source information and the firms' 
responses to our inquiries. We provided all firms with an opportunity 
to comment on the information we found in open sources by calling the 
firms and sending each firm an e-mail. 

Table 1 lists 5 firms reported in at least three open sources as 
having sold Iran refined petroleum products at any time during the 
period between January 1, 2009 and June 30, 2010. We found no reports 
or official statements to indicate that these firms have stopped their 
sales. None of the 5 firms had provided us with comments as of August 
27, 2010. Four of the firms are based in Asia, and 1 is based in the 
Middle East. 

Table 1: Firms Reported in Open Sources to Have Sold Iran Refined 
Petroleum Products between January 1, 2009, and June 30, 2010, with No 
Indication that They Have Stopped Sales: 

Firm/Country[A]: Emirates National Oil Company/United Arab Emirates; 
Summary of open sources: Open sources reported that Emirates National 
Oil Company sold gasoline to Iran in 2010; 
Comments from firm: Attempted to contact on June 29, 2010.[B] No 
comment as of August 27, 2010. 

Firm/Country[A]: Hin Leong Trading/Singapore; 
Summary of open sources: Open sources reported that Hin Leong Trading 
sold refined petroleum products, including diesel and gas oil, to Iran 
in 2009; 
Comments from firm: Contacted on June 29, 2010. No comment as of 
August 27, 2010. 

Firm/Country[A]: ChinaOil[C]/China; 
Summary of open sources: Open sources reported that ChinaOil sold 
gasoline to Iran in 2010; 
Comments from firm: Contacted on June 29, 2010. No comment as of 
August 27, 2010. 

Firm/Country[A]: Unipec[D]/China; 
Summary of open sources: Open sources reported that Unipec sold 
gasoline to Iran in 2010; 
Comments from firm: Contacted on June 29, 2010. No comment as of 
August 27, 2010. 

Firm/Country[A]: Zhuhai Zhenrong/China; 
Summary of open sources: Open sources reported that Zhuhai Zhenrong 
sold gasoline to Iran in 2010; 
Comments from firm: Contacted on June 29, 2010. No comment as of 
August 27, 2010. 

Source: GAO review of open sources. 

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

[B] Our attempts to contact Emirates National Oil Company were 
unsuccessful. 

[C] Open sources identified ChinaOil as the trading subsidiary of 
PetroChina. 

[D] Open sources identified Unipec as the trading subsidiary of China 
Petroleum & Chemical Corporation (Sinopec). 

[End of table] 

Table 2 lists 3 firms reported in at least three open sources as 
having sold Iran refined petroleum products at any time during the 
period between January 1, 2009, and June 30, 2010, but the 3 firms are 
also reported in at least three open sources as having stopped their 
sales during this same time period. One of the firms is based in 
Europe and Asia, 1 is based in the Middle East, and 1 is based in 
Asia. Of these 3 firms, the Independent Petroleum Group of Kuwait 
confirmed that it had sold refined petroleum products to Iran during 
the period between January 1, 2009, and June 30, 2010. The other 2 
firms--Lukoil and Petronas--had not provided us with comments as of 
August 27, 2010. 

Table 2: Firms Reported in Open Sources to Have Sold Iran Refined 
Petroleum Products between January 1, 2009, and June 30, 2010, but 
Some Indication They Have Stopped Sales: 

Firm/Country[A]: Independent Petroleum Group (IPG)/Kuwait; 
Summary of open sources: Open sources reported that IPG sold gasoline 
to Iran in 2009 and 2010 and stopped in 2010; 
Comments from firm: IPG confirmed that it sold gasoline to Iran in 
2009 and 2010. 

Firm/Country[A]: Lukoil (Litasco)/Russia (Switzerland); 
Summary of open sources: Open sources reported that Litasco (Lukoil's 
trading subsidiary) sold gasoline to Iran in 2009 and 2010. Open 
sources reported that Lukoil stopped selling gasoline to Iran in 2010; 
Comments from firm: Contacted on June 29, 2010. No comment as of 
August 27, 2010. 

Firm/Country[A]: Petronas[B]/Malaysia; 
Summary of open sources: Open sources reported that Petronas sold 
gasoline to Iran in 2009 and 2010 and stopped in 2010; 
Comments from firm: Contacted on June 29, 2010. No comment as of 
August 27, 2010. 

[End of table] 

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

[B] Open sources identified both Petronas and its trading subsidiary, 
Petco, as having sold gasoline to Iran in 2010. 

Source: GAO review of open sources. 

Table 3 lists 7 firms that (1) at least three open sources reported 
had sold Iran refined petroleum products at any time during the period 
between January 1, 2009, and June 30, 2010, but (2) notified GAO that 
they had stopped their sales. Five of the firms are based in Europe, 1 
is based in Eurasia, and 1 is based in Asia. Open sources also 
reported that all of these firms have stopped selling refined 
petroleum products to Iran. 

Table 3: Firms Reported in Open Sources to Have Sold Iran Refined 
Petroleum Products between January 1, 2009 and June 30, 2010, but 
Notified GAO That They Have Stopped Sales: 

Firm/Country[A]: Glencore/Switzerland; 
Open sources reported that Summary of open sources: Glencore sold 
gasoline to Iran in 2009, but subsequently stopped in 2009; 
Comments from firm: Notified GAO that it stopped selling gasoline to 
Iran in September 2009. 

Firm/Country[A]: Reliance Industries/India; 
Open sources reported that Summary of open sources: Reliance 
Industries of India sold gasoline to Iran in 2009, but subsequently 
stopped in 2009; 
Comments from firm: Notified GAO that it stopped selling gasoline to 
Iran in May 2009, and that its gasoline export contracts prohibit 
buyers from selling its gasoline to Iran. 

Firm/Country[A]: Royal Dutch Shell/The Netherlands; 
Summary of open sources: Open sources reported that Royal Dutch Shell 
sold gasoline to Iran in 2009, but subsequently stopped in 2009; 
Comments from firm: Notified GAO that it stopped selling gasoline to 
Iran in October 2009. 

Firm/Country[A]: Total/France; 
Summary of open sources: Open sources reported that Total sold 
gasoline to Iran in 2009 and 2010, but subsequently stopped in 2010; 
Comments from firm: Notified GAO that it stopped selling gasoline to 
Iran in May 2010. 

Firm/Country[A]: Trafigura/Switzerland; 
Summary of open sources: Open sources reported that Trafigura sold 
gasoline to Iran in 2009 and 2010, but subsequently stopped in 2010; 
Comments from firm: Notified GAO that it stopped selling gasoline to 
Iran in November 2009. 

Firm/Country[A]: Tupras/Turkey; 
Summary of open sources: Open sources reported that Tupras sold 
gasoline to Iran in 2010; 
Comments from firm: Notified GAO that it stopped selling gasoline to 
Iran in July 2010, following the announcement of U.S. sanctions 
against Iran on July 1, 2010. 

Firm/Country[A]: Vitol/Switzerland; 
Summary of open sources: Open sources reported that Vitol sold 
gasoline to Iran in 2009 and 2010, but subsequently stopped in 2010; 
Comments from firm: Notified GAO that it stopped selling gasoline to 
Iran in early 2010. 

Source: GAO review of open sources. 

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

[End of table] 

Table 4 lists 1 firm that (1) at least three open sources reported had 
sold Iran refined petroleum products at any time during the period 
between January 1, 2009 and June 30, 2010, but (2) notified GAO that 
it did not sell Iran refined petroleum products during this time 
period. British Petroleum of the United Kingdom notified GAO that the 
information reported in open sources was inaccurate. 

Table 4: Firm Reported in Open Sources to Have Sold Iran Refined 
Petroleum Products between January 1, 2009, and June 30, 2010, but 
Notified GAO That It Had Not Done So: 

Firm/Country[A]: British Petroleum (BP)/United Kingdom; 
Summary of open sources: While some open sources reported that BP sold 
gasoline to Iran in 2009 or 2010, other open sources reported that BP 
stopped selling gasoline to Iran in 2008; 
Comments from firm: Notified GAO that it stopped selling gasoline to 
Iran in October 2008. BP claimed that the information in the open 
sources that reported BP sold gasoline to Iran in 2009 or 2010 was 
inaccurate. 

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

[End of table] 

Three of the 16 Firms Also Had Contracts with the U.S. Government: 

In fiscal years 2009 and 2010, the U.S. government obligated over $2.3 
billion in contracts to 3 of the 16 firms identified in tables 1 
through 4.[Footnote 5] The Department of Defense (DOD) obligated over 
99 percent of these funds for purchases of fuel and petroleum products 
overseas. The firms are presented in table 5 in order of magnitude of 
obligations, from greatest to least, as reported by the primary 
government contracting database.[Footnote 6] 

Table 5: Firms Reported to Have Sold Iran Refined Petroleum Products 
between January 1, 2009, and June 30, 2010, and Have U.S. Government 
Contracts: 

Firm/Country[A]: British Petroleum[D]/United Kingdom; 
U.S. government obligations[B]: FY 2009: $1,359,726,907; 
U.S. government obligations[B]: FY 2010[C]: $837,505,914; 
U.S. government obligations[B]: Total: $2,197,232,821. 

Firm/Country[A]: Total[D]/France; 
U.S. government obligations[B]: FY 2009: $131,022,563; 
U.S. government obligations[B]: FY 2010[C]: $376,716; 
U.S. government obligations[B]: Total: $131,399,279. 

Firm/Country[A]: Emirates National Oil Company/United Arab Emirates; 
U.S. government obligations[B]: FY 2009: $235,067; 
U.S. government obligations[B]: FY 2010[C]: $0; 
U.S. government obligations[B]: Total: $235,067. 

Firm/Country[A]: Total; 
U.S. government obligations[B]: Total: $2,328,867,167. 

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

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

[B] We confirmed that each of these firms had U.S. government 
contracts by obtaining official documents and statements that 
confirmed the existence of contracts with these firms. For a complete 
description of the methodology used to complete this table, see 
Enclosure I. 

[C] We searched for U.S. government contracts in the first 8 months of 
fiscal year 2010. 

[D] British Petroleum and Total notified GAO that they stopped selling 
gasoline to Iran in November 2008 and May 2010, respectively. 

[End of table] 

According to the primary governmentwide contracting database, DOD 
obligated funds to: 

* British Petroleum for the purchase of jet and turbine fuel; 

* Total of France for the purchase of jet fuel, gasoline, and diesel; 
and: 

* Emirates National Oil Company for the lease of fuel storage 
buildings. 

Agency Comments: 

We provided the Departments of State, Energy, and Defense with a draft 
of this report for their review. State and Energy provided technical 
comments, which we incorporated into the report. The State Department 
stated that it did not independently confirm the validity of these 
open source reports. The DOD declined to comment. 

As agreed with your offices, unless you publicly announce the contents 
of this report earlier, we plan no further distribution until 30 days 
from the report date. At that time, we will send copies of the report 
to the appropriate congressional committees, the Secretary of State, 
the Secretary of Energy, the Secretary of Defense, and other 
interested parties. In addition, the report will be available at no 
charge on GAO's Web site at [hyperlink, http://www.gao.gov]. 

If you or your staffs have any questions about this report, please 
contact me 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 report. Major contributors to this report 
include Tetsuo Miyabara (Assistant Director), JoAnna Berry, Jennifer 
Bryant, Jon Fremont, Lauren Membreño, and Pierre Toureille. Technical 
support was provided by Colleen Candrl, Debbie Chung, Phillip Farah, 
Julia Kennon, Grace Lui, Jodi Munson, and Erin Smith. 

Signed by: 

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

[End of section] 

Enclosure I: 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 
January 1, 2009, and June 30, 2010, we analyzed open source 
information that GAO energy and information specialists determined to 
be credible and comprehensive. We reviewed open sources published 
through July 21, 2010, to capture activity that may have occurred 
through June 30, 2010. Open source information is overt and publicly 
available information, as opposed to covert or classified. It is a key 
component of traditional intelligence and information-gathering 
agencies, such as the Central Intelligence Agency. Open source 
information can provide a broad range of useful data for analysis, but 
the validity of an analysis can be compromised if it relies on open 
sources that contain inaccurate, imprecise, incomplete, or otherwise 
faulty information. We took the following steps to mitigate this risk 
in developing our analysis. 

First, we relied only on government reports and information, energy 
industry trade publications from around the world, and corporate Web 
site information to develop a preliminary listing of firms reported in 
open sources to have sold refined petroleum products to Iran at any 
time during the period between January 1, 2009, and June 30, 2010. We 
obtained reports and information from the Department of Energy (DOE), 
the Congressional Research Service (CRS), the Organization of 
Petroleum Exporting Countries, the International Energy Agency, and 
the United Nation's commodity trade statistics database. We 
interviewed officials from DOE and the Department of State regarding 
the Iranian energy sector. We searched almost 200 industry trade 
publications for reports of firms selling refined petroleum products, 
including diesel fuel and gas oil, to Iran at any time during the 
period between January 1, 2009, and June 30, 2010. 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. The trade publications were 
compiled by Nexis and include Oil Daily, Oil and Gas News, Oil and Gas 
Journal, and Platt's Oilgram News, among others. We excluded sources 
deemed insufficiently reliable, such as newspaper reports, newswires, 
and direct news releases from the Iranian government. We also searched 
our sources for specific firms named in U.S. government reports from 
DOE and CRS as sellers of refined petroleum products to Iran. We also 
searched firm Web sites for press releases and corporate statements 
regarding their activity in the sale of refined petroleum products to 
Iran or for corrected information that had been publicly reported. 

Second, we required multiple corroborating sources of information for 
every entry in our tables of firms reported to have sold refined 
petroleum products to Iran at any time during the period between 
January 1, 2009, and June 30, 2010 (see tables 1 through 4). To 
determine whether the preliminary listing of firms resulting from the 
above searches was based on sufficient evidence, a team of GAO 
analysts reviewed the list and confirmed that 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 January 1, 2009, and 
June 30, 2010, or (2) the firm provided information on its corporate 
Web site about its sale of refined petroleum products to Iran at any 
time during this period and at least one standard industry publication 
cited the firm's sale of refined petroleum products to Iran at any 
time during this period. If not all of the analysts on the team were 
completely satisfied that these criteria were met, the firm was not 
included in our tables. We also applied the same methodology to 
determine whether a firm had stopped selling refined petroleum 
products to Iran during the same period. As in all GAO products, our 
evidence also had to convince independent GAO fact-checkers--who 
confirmed that the appropriate criteria had been met for all firms--
before it could be included in our final listing. Therefore, the firms 
listed in tables 1 through 4 represent a minimum number of firms that 
sold refined petroleum products to Iran at any time during the period 
between January 1, 2009, and June 30, 2010. 

Analysts fluent in the appropriate language contacted the firms by 
telephone to introduce GAO, explain our project, and obtain an 
appropriate point of contact within the firm to officially comment on 
the information reported in open sources. We then sent the firms a 
letter containing information from tables 1 through 4 concerning the 
firms' reported activities. As of August 27, 2010, 9 of the 16 firms 
had responded. We incorporated these responses into tables 1 through 4. 

To determine the extent to which the 16 firms identified in open 
sources as having sold refined petroleum products to Iran also have 
contracts with the U.S. government, 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 FPDS-NG 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.[Footnote 7] The Office of Management and Budget 
established FPDS-NG, and the General Services Administration 
administers the system.[Footnote 8] More than 60 government 
departments, agencies, and other entities submit contract data to FPDS-
NG. The database contains data on obligations, which are recorded when 
a government agency enters into a contract to purchase services or 
goods. 

We searched the FPDS-NG archives for fiscal years 2009 and 2010 (our 
search included the first 8 months of fiscal year 2010) using search 
terms that would select any record with the same firm name as 
identified in any of tables 1 through 4. After matching firms from 
these tables with records in FPDS-NG, we obtained the Data Universal 
Numbering System (DUNS) numbers for the firms determined to be 
identical matches and searched FPDS-NG for these DUNS numbers. 
[Footnote 9] With certain exceptions, all firms that do business with 
U.S. agencies are required by the U.S. government to register with the 
U.S. government Central Contract Registration database and to obtain a 
unique DUNS number. We matched all of the data in table 5 to 
individual firms' DUNS numbers. Additionally, we matched the firms' 
street addresses listed in the Central Contract Registration database 
to the firm's officially listed addresses. 

We took steps to corroborate key FPDS-NG information by obtaining U.S. 
government documents and public statements confirming that the 3 firms 
listed in table 5 have U.S. contracts. To do so, we searched the 
Department of Defense's Electronic Document Access system[Footnote 10] 
to locate copies of relevant contract documents. 

Our searches for U.S. contracts only covered firms that we had 
identified as being directly involved in the sale of refined petroleum 
products to Iran. We included a parent firm or subsidiary only if that 
firm had also been reported in open sources as having sold refined 
petroleum products to Iran. Therefore, U.S. contracts held by a 
subsidiary of a parent firm might not be identified if (1) the firm 
that actually sold refined petroleum products to Iran is a subsidiary 
of a parent firm, but the open sources identified the subsidiary by a 
common name associated with the parent firm; and (2) the parent firm 
identified in open sources was not listed in FPDS-NG as the recipient 
of the U.S. contract. 

[End of section] 

Footnotes: 

[1] Pub. L. No. 111-195, 124 Stat. 1312. 

[2] Pub. L. No. 111-195, § 102, 124 Stat. 1317-1321. 

[3] Iran-Libya Sanctions Act of 1996, Pub. L. No. 104-172, §§ 5-6, 110 
Stat. 1541, 1543-45, as amended. Other sanctions include a denial of 
Export-Import Bank assistance, a ban on issuing licenses to export 
controlled technologies to the sanctioned firm, and other sanctions to 
restrict imports from a sanctioned person in accordance with the 
International Emergency Economic Powers Act. The Secretary of State, 
to whom the President has delegated ISA authorities, may waive the 
sanctions if the Secretary determines that it is necessary to the 
national interests of the United States to do so. Pub. L. No. 104-172, 
§ 9; Memorandum: Delegation of Responsibilities Under the Iran and 
Libya Sanctions Act of 1996, 61 Fed. Reg. 64,249 (Nov. 21, 1996). 

[4] Refined petroleum products include but are not limited to 
gasoline, kerosene, diesel fuel, and gas oil. According to the U.S. 
Energy Information Administration, refined petroleum products include 
but are not limited to gasoline, kerosene, distillates (including No. 
2 fuel oil), liquefied petroleum gas, asphalt, lubricating oils, 
diesel fuels, and residual fuels. Gas oil is a European and Asian 
designation for No. 2 diesel fuel and No. 2 heating oil. 

[5] An obligation is recorded when a government agency enters into a 
binding agreement to purchase services or goods. 

[6] The Federal Procurement Data System-Next Generation (FPDS-NG) is 
the primary governmentwide contracting database. More than 60 
government agencies, departments, and other entities submit contract 
data to FPDS-NG. The database can be accessed at [hyperlink, 
https://www.fpds.gov/fpdsng_cms/]. Reporting requirements for FPDS-NG 
are in the Federal Acquisition Regulation (FAR), subpart 4.6. FPDS-NG 
data are described in FAR 4.602. 

[7] FPDS-NG can be accessed at [hyperlink, 
https://www.fpds.gov/fpdsng_cms/]. Reporting requirements for FPDS-NG 
are in the Federal Acquisition Regulation (FAR) subpart 4.6. FPDS-NG 
data are described in FAR 4.602. 

[8] For more information on FPDS-NG and other federal procurement data 
systems, see GAO, Federal Contracting: Observations on the 
Government's Contracting Data Systems, [hyperlink, 
http://www.gao.gov/products/GAO-09-1032T] (Washington, D.C.: Sept. 29, 
2009). 

[9] DUNS numbers are nine-digit identifying numbers obtained by firms 
through Dun and Bradstreet to uniquely identify a firm. Dun and 
Bradstreet is a leading source of commercial information and maintains 
a commercial database with more than 140 million business records. 
U.S. vendors must be registered in the U.S. government Central 
Contract Registration database prior to the award of a U.S. government 
contract, and a firm must have a DUNS number to register. We also 
compared the street addresses of the firms listed in tables 1 through 
4 with street addresses listed in the Central Contract Registration 
database [hyperlink, https://www.bpn.gov/ccr/]. 

[10] The Electronic Document Access system is a Department of Defense 
online system designed to provide acquisition-related information. 

[End of section] 

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E-mail: fraudnet@gao.gov: 
Automated answering system: (800) 424-5454 or (202) 512-7470: 

Congressional Relations: 

Ralph Dawn, Managing Director, dawnr@gao.gov: 
(202) 512-4400: 
U.S. Government Accountability Office: 
441 G Street NW, Room 7125: 
Washington, D.C. 20548: 

Public Affairs: 

Chuck Young, Managing Director, youngc1@gao.gov: 
(202) 512-4800: 
U.S. Government Accountability Office: 
441 G Street NW, Room 7149: 
Washington, D.C. 20548: