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GAO-14-218R 1 (2014-01-07)

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G      A               U.S. GOVERNMENT ACCOUNTABILITY OFFICE
441 G St. N.W.
Washington, DC 20548



January 7, 2014

Congressional Committees

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

Iran's economy and government rely heavily on revenues from its oil and gas industry. Iran is
the fourth-largest holder of proven oil reserves in the world, and petroleum accounts for
approximately 80 percent of Iran's exports.1 Although previously heavily dependent on foreign
sources of refined petroleum products, Iran has significantly decreased its gasoline import
dependence in part by increasing its domestic refining capacity. Iran has also restricted free
speech. These restrictions include blocking access to telecommunications. The Iran Threat
Reduction and Syria Human Rights Act of 2012 and Senate reports 111-201 and 112-26 contain
recurring mandates for GAO to report on firms engaging in certain types of commercial activities
with Iran.2 Since 2010, in response to these mandates and other requests, we have issued a
series of reports on foreign firms reported to have engaged in commercial activities in Iran's
energy sector, sold refined petroleum products to Iran, or exported technologies to Iran for
blocking telecommunications.3

This report updates our prior reports by identifying any foreign firms reported to have (1)
engaged in commercial activity in Iran's energy sector between October 1, 2012, and November
7, 2013; (2) sold refined petroleum to Iran between October 1, 2012, and November 7, 2013; or
(3) exported technology to Iran between December 16, 2012, and November 7, 2013, for
telecommunications blocking. The report also identifies any firms that had U.S. contracts,
awards, or purchasing agreements while having been reported to have engaged in such
activities.4 In addition, enclosures II and III to this report update the activity status for firms that
we previously identified as having been reported to be engaged in such activities.

To accomplish our first three objectives, we used information published in open sources on or
before November 7, 2013, updating information included in our prior reports. These open
sources consisted of industry and trade publications, corporate reports and statements, and
U.S. Securities and Exchange Commission (SEC) filings. On the basis of the open-source
information, we categorized firms as Active, Insufficient information available, or


'Central Intelligence Agency, World Factbook, https://www.cia.gov/1ibrary/publications/the-word-
factbook/geos/ir.html, accessed on November 23, 2013.
2pub. L. No. 112-158, 126 Stat. 1214. S. Rep. No. 111-201 (2010) and S. Rep. No. 112-26 (2011).
3For example, see GAO, Firms Reported to Have Sold Iran Refined Petroleum Products or Engaged in Commercial
Activities in Iran's Energy Sector, GAO-1 3-173R (Washington, D.C.: Dec. 7, 2012); Firms Reported to Have Engaged
in Activities Related to Iran's Energy and Communications Sectors While Having Had U.S. Government Contracts,
GAO-1 3-344R (Washington, D.C.: Feb. 25, 2013). For a list of all seven related reports, see GAO Related Products
at the end of this report.
4In this report, contracts refers collectively to contracts, awards, and purchasing agreements.


GAO-14-218R Iranian Commercial Activities


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