Volume VI - Annexes 292-343

IN THE NAME OF GOD
INTERNATIONAL COURT OF JUSTICE
CASE CONCERNING
ALLEGED VIOLATIONS OF THE 1955 TREATY OF AMITY,
ECONOMIC RELATIONS, AND CONSULAR RIGHTS
(ISLAMIC REPUBLIC OF IRAN V. UNITED STATES OF AMERICA)
ANNEXES TO THE MEMORIAL
OF THE ISLAMIC REPUBLIC OF IRAN
VOLUME V
24 May 2019

TABLE OF CONTENTS
PART VIII – CONSEQUENCES OF THE U.S. SANCTIONS ON THE ENERGY SECTOR
8.1 Witness Statements
Annex 205 Witness statement of Mr H. Salari, Deputy Director of
International Affairs at National Iranian Oil Company,
23 April 2019
p. 1
Annex 206 Witness statement of Mr S. M. Hossein Hosseini, Financial
Director of National Iranian Gas Company, 30 April 2019
p. 7
Annex 207 Witness statement of Mr H. Bovard, Managing Director of
Iranian Offshore Oil Company, 1 May 2019
p. 11
8.2 Official and Academic Sources
Annex 208
The Oxford Institute for Energy Studies, “Iranian Energy: a
comeback with hurdles”, University of Oxford, January 2017
p. 19
Annex 209
Total SA, “Iran: Total and NIOC sign contract for the
development of phase 11 of the giant South Pars gas field”,
3 July 2017
p. 31
Annex 210
Total SA, “U.S. withdrawal from the JCPOA: Total’s position
related to the South Pars 11 project in Iran”, 16 May 2018
p. 35
Annex 211 U.S. Department of State, “Briefing with an Iran Diplomacy
Update”, Special Briefing, 2 July 2018
p. 39
Annex 212
U.S. Department of State, “Senior Administration Officials
Previewing Iran Sanctions”, Special Briefing, 6 August 2018
p. 47
Annex 213
U.S. Energy Information Administration, “OPEC Revenues
Fact Sheet”, 21 August 2018
p. 57
Annex 214
U.S. Energy Information Administration, “Iran has produced
and exported less crude oil since sanctions announcement”,
23 October 2018
p. 63
Annex 215 OPEC, “Monthly Oil Market Report”, 14 March 2019
(excerpts)
p. 69
Annex 216
International Energy Agency, “IEA statement on global oil
markets”, 23 April 2019
p. 73
Annex 217
U.S. Energy Information Administration, “April 2019
Monthly Energy Review”, 25 April 2019 (excerpts)
p. 77
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8.3 Private Sources
Annex 218 E-mail from Honeywell (China) to Sinopec, 18 May 2018
p. 83
Annex 219 Letter from EEW China Marketing & Services to Sinopec,
31 May 2018
p. 87
Annex 220 Letter from Phocéenne to Sinopec, 7 June 2018
p. 91
Annex 221 E-mail from Roots Systems to Sinopec, 18 June 2018
p. 95
Annex 222 Letter from Wuxi Compressor to Sinopec, 19 June 2018
p. 99
Annex 223 Letter from Sulzer to Sinopec, 19 June 2018
p. 103
Annex 224 Letter from Howden to Sinopec, 19 June 2018
p. 107
Annex 225 Letter from GEA to Sinopec, 20 June 2018
p. 111
Annex 226 E-mail from Kelvion China to Sinopec, 21 June 2018
p. 115
Annex 227 Letter from EagleBurgmann Dailian Co. Ltd to Sinopec,
26 June 2018
p. 119
Annex 228 Letter from Beijing Kelitong Instrument Technology
Development Co. LTD to Sinopec, 26 July 2018
p. 123
8.4 Other Sources
Annex 229
F. Mohamedi, “The Oil and Gas Industry”, The Iran Primer,
August 2015
p. 127
Annex 230
H. Tunnicliffe, “Sinopec to upgrade Iran’s Abadan refinery”,
The Chemical Engineer, 9 July 2018
p. 137
Annex 231
S. Kar-Gupta & J. Irish, “France's Total to quit Iran gas
project if no sanctions waiver”, Reuters, 16 May 2018
p. 141
Annex 232
N. Tzur, “Poland’s PGNiG plans to suspend gas project in
Iran because of U.S. sanctions”, Reuters, 18 May 2018
p. 145
Annex 233
G. de Clercq, “Engie says to end engineering contracts in Iran
by November”, Reuters, 18 May 2018
p. 149
Annex 234
V. Soldatkin, “Lukoil puts Iran plans on hold due to threat of
U.S. sanctions”, Reuters, 29 May 2018
p. 153
Annex 235
H. Choi, “South Korea's Daelim industrial says $2.08 billion
order from Iran cancelled”, Reuters, 1 June 2018
p. 157
Annex 236
‘European refiners winding down purchases of Iranian oil’,
p. 161
Reuters, 6 June 2018
Annex 237
T. Di Christopher & S. Sedgwick, “U.S. sanctions mean no
big oil company can risk doing business with Iran, Total CEO
says”, CNBC, 20 June 2018
p. 165
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Annex 238
“U.S. Toughens Stance on Future Iran Oil Exports”, The Wall
Street Journal, 26 June 2018
p. 169
Annex 239 R. Valdmanis, “Indonesia's Pertamina says Iran oil field deal
frozen over U.S. sanctions”, Reuters, 26 June 2018
p. 177
Annex 240
“U.S. pushes allies to halt Iran oil imports, waivers unlikely”,
Reuters, 27 June 2018
p. 181
Annex 241
“India’s HPCL cancels Iran oil shipment after insurer
excludes coverage”, Reuters, 26 July 2018
p. 185
Annex 242
J. Lee & I. Garcia Perez, “Buyers of Iranian Oil Get Waivers:
Sanctions Wrap”, Bloomberg, 6 August 2018
p. 189
Annex 243
“Exclusive: UK’s Quercus pulls plug on $570 million Iran
solar plant as sanctions bite”, Reuters, 14 August 2018
p. 197
Annex 244
“Iran’s Oil Market Realities: How India, Others Are Preparing
for U.S. Sanctions”, The Times of India, 16 August 2018
p. 203
Annex 245
“L’Iran annonce officiellement que Total a quitté le projet
South Pars”, L’Usine Nouvelle, 20 August 2018
p. 209
Annex 246
J. Park and H. Yang, “South Korea's Hyundai E&C cancels
$521 million petrochemicals deal, cites Iran financing
failure”, Reuters, 29 October 2018
p. 213
Annex 247 B. Scheid, “Questions remain over UAE imports of Iranian
condensate amid US sanctions”, S&P Global,
15 November 2018
p. 217
Annex 248 D. Hudson, “Despite sanctions, Iran’s oil exports rise in early
2019: sources”, Reuters, 19 February 2019
p. 221
Annex 249
F. Tan, “U.S. says Iran has lost $10 billion in oil revenue due
to sanctions”, Reuters, 13 March 2019
p. 225
Annex 250
“Sources: Iran's Oil Exports Hit 2019 Low in April”, Reuters,
16 April 2019
p. 229
Annex 251
J. Rogin, “No more waivers: The United States will try to
force Iranian oil exports to zero”, Washington Post, 21 April
2019
p. 235
Annex 252
D. Zhdannikov, “Iran's oil exports to slide in May, but not to
zero: sources”, Reuters, 3 May 2019
p. 239
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PART IX – CONSEQUENCES OF THE U.S. SANCTIONS ON THE AVIATION SECTOR
9.1 Witness Statements
Annex 253 Witness statement by Mr M. Asaadi Samani, Secretary of the
Association of Iranian Airlines (AIA), 18 August 2018
p. 245
Annex 254 Witness statement of Mr A. Abedzade, President of the Civil
Aviation Organization of Iran, 24 April 2019
p. 251
Annex 255 Witness statement of Mr M. Mahini, Director General of
Legal Department of Iran Air, 30 April 2019
p. 261
9.2 Official and Academic Sources
Annex 256
ICAO, “Continuity of the US trade embargo on the civil
aviation of the Islamic Republic of Iran and the safety
deficiencies arising out of it”, Information Paper,
15 March 2006
p. 267
Annex 257
“Zagros Airlines places a commitment for 28 new Airbus
aircraft”, Airbus, 22 June 2017
p. 275
Annex 258
“Iran Airtour commits to 45 A320neo aircraft”, Airbus,
22 June 2017
p. 279
Annex 259 Letter from Civil Aviation Organization of Iran to ICAO,
11 November 2018 (enclosing official statement dated
27 October 2018)
p. 283
9.3 Private Sources
Annex 260 Letter from Dunlop to Kish Air, 22 May 2018
p. 291
Annex 261 Letter from a non-U.S. company to Iran Air, 22 May 2018
(redacted)
p. 299
Annex 262 Email from a non-U.S. aircraft engine parts supplier to Iran
Air, 31 May 2018 (redacted)
p. 303
Annex 263 Email from a non-U.S. aircraft tyres supplier to Iran Air,
6 June 2018 (redacted)
p. 307
Annex 264 Letter from a non-U.S. aircraft part supplier to Iran Air,
25 June 2018 (redacted)
p. 311
Annex 265 Letter from a U.S. company to Iran Air, 10 July 2018
(redacted)
p. 315
Annex 266 Letter from a non-U.S. service provider to Iran Air, 17 July
2018 (redacted)
p. 319
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Annex 267 Letter from a non-U.S. oil company to Iran Air, 18 July 2018
(redacted)
p. 323
Annex 268 Email from a non-U.S. aviation service provider to Iran Air,
24 July 2018 (redacted)
p. 327
Annex 269 Letter from a non-U.S. equipment supplier to Iran Air,
30 August 2018 (redacted)
p. 331
Annex 270 Letter from IATA to Iran Air, 14 September 2018
p. 335
Annex 271 Letter from a French bank to Iran Air, 17 September 2018
(redacted)
p. 339
Annex 272 Email from a fuel supplier to Iran Air, 5 November 2018
(redacted)
p. 343
Annex 273 Letter from Airbus to Zagros Airlines, 11 November 2018
p. 347
Annex 274 Email from Boeing to Zagros Airlines, 20 November 2018
p. 351
Annex 275 Letter from Airbus to Zagros Airlines, 13 December 2018
p. 355
Annex 276
Set of letters from a non-U.S. airline company to Iran Air,
31 January 2019 (redacted)
p. 359
Annex 277 Email from Honeywell to Kish Air, 9 April 2019
p. 367
9.4 Other Sources
Annex 278
“Iranian airline finalizes deal to purchase 60 Boeing planes”,
AP, 10 June 2017
p. 373
Annex 279
“Iran Aseman Airlines crash: Years of sanctions have left
passengers with one of oldest air fleets in the world”, The
Independent, 18 February 2018
p. 377
Annex 280
“Iran Airport Traffic Expands 8 Percent”, Financial Tribune,
7 April 2018
p. 381
Annex 281
T. Hepher, “Factbox – Iran’s $38 billion airplane purchases
under nuclear deal”, Reuters, 8 May 2018
p. 385
Annex 282
D. Lawder, “U.S. Treasury's Mnuchin: Revoking Boeing,
Airbus licenses to sell jets to Iran”, Reuters, 8 May 2018
p. 391
Annex 283 C. Charpentreau, “Boeing confirms passing $20B Iran deal”,
AeroTime News, 7 June 2018
p. 395
Annex 284
A. Feitz, “ATR passe entre les gouttes de l’embargo iranien”,
Les Echos, 6 August 2018
p. 399
Annex 285
“Tehran Slams Ankara for Refusing to Refuel Iranian
Aircraft”, Iran Front Page News, 3 November 2018
p. 403
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Annex 286
E. Batmanghelidj, “For Iranian Passengers, Old Planes and
Few Parts Make Air Travel 5.5 More Times Deadly”, Bourse
& Bazaar, 5 December 2018
p. 409
Annex 287
P. Hafezi, “Iran urges EU to press Washington on Airbus
deliveries: ISNA”, Reuters, 17 December 2018
p. 413
Annex 288
“Europeans refusing fuel to Iranian aircraft”, presstv.com, 18
December 2018
p. 417
Annex 289
S. Shahrabi, “Plane Crash in Iran: Failed Navigation System
Was to Blame”, Aircraft Rescue & Fire Fighting Working
Group, 14 January 2019
p. 423
Annex 290
M. Kraft, “Boeing 737 MAX 8 stuck in Iran since December
14, a real headache for Norwegian”, Airlive, 29 January 2019
p. 427
Annex 291
Nima Alipour, “Obstruction Against Iranian Aircraft; From
p. 431
Europe to Persian Gulf”, Iranian Students’ News Agency
(ISNA), 23 April 2019
- vi -

Annex 205
Witness statement of Mr H. Salari, Deputy Director of International Affairs at
National Iranian Oil Company, 23 April 2019

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NIOC
NIOC
International Affairs
International Affairs
I, Hootan Salari, the Deputy Director of International Affairs at National Iranian Oil
Company (NOC), with registered office at NIOC Central Building, Taleghani Avenue, Tehran,
Iran, have held this position since 2017.
I, Hootan Salari, the Deputy Director of International Affairs at National Iranian Oil
Company (NOC), with registered office at NIOC Central Building, Taleghani Avenue, Tehran,
Iran, have held this position since 2017.
I, hereby, make the following statements under oath and acknowledge that I have
personally and directly professional knowledge of the facts hereinafter stated and I
do believe that to the best of my knowledge, such matters and facts to be true.
2. NIOC operates and manages the upstream oil and gas operations, among others,
1.
1.
I, hereby, make the following statements under oath and acknowledge that I have
personally and directly professional knowledge of the facts hereinafter stated and I
do believe that to the best of my knowledge, such matters and facts to be true.
2. NIOC operates and manages the upstream oil and gas operations, among others,
i. Exploration, exploitation, development and production of oil and gas
i. Exploration, exploitation, development and production of oil and gas
resources; and
ii. oil trade;
resources; and
ii. oil trade;
iii. Purchase, lease, construction, completion, development, maintenance and
repair of facilities and equipment related to upstream petroleum
operations.
iv. NIOC carries out oil trade by entering into different types of commercial
contracts with Iranian and foreign companies.
3. Following the Joint Comprehensive Plan of Action (ICPOA), NIOC started
iii. Purchase, lease, construction, completion, development, maintenance and
repair of facilities and equipment related to upstream petroleum
operations.
iv. NOC carries out oil trade by entering into different types of commercial
contracts with Iranian and foreign companies.
negotiations and/or concluded contracts with a number of companies with a view to
boosting its marketing and sale activities.
3. Following the Joint Comprehensive Plan of Action (ICPOA), NIOC started
negotiations and/or concluded contracts with a number of companies with a view to
boosting its marketing and sale activities.
4, However, the anticipat
4, However, the anticipation as well as the actual re-imposition of the US sanctions as
from 8 May 2018 significantly impacted Iran's export of crude oil, natural gas
condensate and petroleum products,
i on as well as the actual re-imposition of the US sanctions as
from 8 May 2018 significantly impacted Iran's export of crude oil, natural gas
condensate and petroleum products,
5. After the conclusion of the JCPOA, the export of
5. Ater the conclusion of the JCPOA, the export of
Iran's crude oil, natural gas
Iran's crude oil, natural gas
condensate and petroleum products had been steadily increasing: in the mid of
condensate and petroleum products had been steadily increasing: in the mid of
2016, NIOC recovered its 2011- 2012 market share and, up until mid 2018, NIOC was
selling all produced crude oil, natural gas condensate and petroleum products in
excess of the local consumption, generating revenues to maintain and upgrade the
oil and gas industry.
6. However and as a direct consequence of the re-imposition of U.S. sanctions, as of
2016, NIOC recovered its 2011- 2012 market share and, up until mid 2018, NIOC was
selling all produced crude oil, natural gas condensate and petroleum products in
excess of the local consumption, generating revenues to maintain and upgrade the
oil and gas industry.
6. However and as a direct consequence of the re-imposition of U.S. sanctions, as of
May 2018 and in anticipation thereof, these exports have decreased dramatically,
May 2018 and in anticipation thereof, these exports have decreased dramatically,
including for the fallowing reasons:
including for the fallowing reasons:
i. Some importers of Iranian oil have suspended and/or terminated their
purchase contracts with NiOC, either without giving any justification or
relying on the re-imposition of US sanctions as a ground to do so;
i. Some importers of Iranian oil have suspended and/or terminated their
purchase contracts with NiOC, either without giving any justification or
relying on the re-imposition of US sanctions as a ground to do so;
ii. NIOC has been encountering issues with obtaining payments from these
foreign buyers due to the US sanctions on the banking sector, which caused
ii. NIOC has been encountering issues with obtaining payments from these
foreign buyers due to the US sanctions on the banking sector, which caused
the intermediary banks of the buyers refusing to process and effect the
payments for fear of U,S. retaliatory measures;
the intermediary banks of the buyers refusing to process and effect the
payments for fear of U,S. retaliatory measures;
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iii. Vessels/ tankers avoid carrying Iranian crude oil, natural gas condensate
and/or petroleum products due to the US sanctions on
Iran's oil
iii. Vessels/ tankers avoid carrying Iranian crude oil, natural gas condensate
and/or petroleum products due to the US sanctions on
Iran's oil
transportation and trade: foreign ship owners refuse to transport Iranian
cargo, forcing NIOC to rely only on local fleet to export, which in any case is
inadequate to maintain the 2017/2018 level of exportation and in any event
is facing major hurdles in repair, maintenance and bunkering. In addition, the
Iranian fleet, on which Iran now exclusively relies for its oil exportation, are
less and less able due to the US sanctions, to obtain the insurance coverage
transportation and trade: foreign ship owners refuse to transport Iranian
cargo, forcing NIOC to rely only on local fleet to export, which in any case is
inadequate to maintain the 2017/2018 level of exportation and in any event
is facing major hurdles in repair, maintenance and bunkering. In addition, the
Iranian fleet, on which Iran now exclusively relies for its oil exportation, are
less and less able due to the US sanctions, to obtain the insurance coverage
necessary to carry out their activities, which constitutes a major barrier to oil
necessary to carry out their activities, which constitutes a major barrier to oil
and petroleum products' transportation.
and petroleum products' transportation.
7. The difficulties related to the export of crude oil, natural gas condensate and
petroleum-products, have not only caused and continue to cause damage to Iran's
market share, but also force NIOC to incur greater additional costs while, at the same
time, it can neither increase the price nor shift such additional costs to the buyers. As
a consequence, Iran's revenue as well as profit margin have been sharply decreasing.
7. The difficulties related to the export of crude oil, natural gas condensate and
petroleum-products, have not only caused and continue to cause damage to Iran's
market share, but also force NIOC to incur greater additional costs while, at the same
time, it can neither increase the price nor shift such additional costs to the buyers. As
a consequence, Iran's revenue as well as profit margin have been sharply decreasing.
The additional costs NIOC has had to incur include, among others, storage costs - due
to the decrease in exports, NIOC has accumulated large oil surplus - the excess costs
The additional costs NIOC has had to incur include, among others, storage costs - due
to the decrease in exports, NIOC has accumulated large oil surplus - the excess costs
of the shipping, which used to be paid, since mid 2018, by the importers, as well as
other associated costs and expenses which shifted to NIOC.
of the shipping, which used to be paid, since mid 2018, by the importers, as well as
other associated costs and expenses which shifted to NIOC.
8. Since November 2018, certain companies from some 8 countries which were granted
8. Since November 2018, certain companies from some 8 countries which were granted
a significant reduction exception (SRE") by the US authorities under the US law
a significant reduction exception ("SRE") by the US authorities under the US law
applicable to sanctions have been resuming their purchase of Iran oil, yet not at the
same level as prior to May 2018 and under less favorable conditions: the banks of
these companies refuse to transfer the payments for oil - denominated in the
purchasing country's currency - to ran. As a consequence, the Central Bank of Iran is
forced to exchange these funds denominated in local currencies against commodities
provided by the importing countries, which limitation on access to hard currency can
put pressure on the value of national currency and may affect oil sector in various
applicable to sanctions have been resuming their purchase of Iran oil, yet not at the
same level as prior to May 2018 and under less favorable conditions: the banks of
these companies refuse to transfer the payments for oil - denominated in the
purchasing country's currency - to ran. As a consequence, the Central Bank of Iran is
forced to exchange these funds denominated in local currencies against commodities
provided by the importing countries, which limitation on access to hard currency can
put pressure on the value of national currency and may affect oil sector in various
ways.
ways.
9.For the avoidance of doubt, what I stated herein is merely with a view to describing
the facts on the ground as to the actual impact and consequences of both the
anticipation of and the actual US withdrawal from JCPOA and re-imposition of US
sanctions as of 8 May 2018 on the marketing, sale and export of crude oil, natural gas
condensate and petroleum products and, therefore, it shall not prejudice nor shall it
9. For the avoidance of doubt, what I stated herein is merely with a view to describing
the facts on the ground as to the actual impact and consequences of both the
anticipation of and the actual US withdrawal from JCPOA and re-imposition of US
sanctions as of 8 May 2018 on the marketing, sale and export of crude oil, natural gas
condensate and petroleum products and, therefore, it shall not prejudice nor shall it
be construed in any manner as causing prejudice to the positions already taken or
might be taken by NIOC and/or its subsidiaries/affiliates vis-~-vis their counterparts.
be construed in any manner as causing prejudice to the positions already taken or
might be taken by NIOC and/or its subsidiaries/affiliates vis-~-vis their counterparts.
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10. I believe that all the above are true to the best of my knowledge.
10. I believe that all the above are true to the best of my knowledge.
Hooten Salari
Hootan Salari
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..-.-%%%-.........

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Annex 206
Witness statement of Mr S. M. Hossein Hosseini, Financial Director of National
Iranian Gas Company, 30 April 2019

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Date: 30/04/2019
Date: 30/04/2019
.atianaf anian
.Natianaf 'aian
No: G8/000/13935
No: G8/000/13935
Witness Statement
Witness Statement
I, Seyed Mohammad Hossein Hosseini, Financial Director of National Iranian Gas Company (NIGC), with registered
office at NIGC main building- South Aban St- Karimkhan Zand Ave- Tehran- Iran,
Having occupied the following positions:
1998- 2008 the Financial Director of Iranian Gas Company of Khorasan Razavi province;
I, Seyed Mohammad Hossein Hosseini, Financial Director of National Iranian Gas Company (NIGC), with registered
office at NIGC main building- South Aban St- Karimkhan Zand Ave- Tehran- Iran,
Having occupied the following positions:
1998- 2008 the Financial Director of Iranian Gas Company of Khorasan Razavi province;
2008- 2016 Deputy Manager for Financial Affairs of Iranian Gas Compnay of Khorasan Razavi province;
2008- 2016 Deputy Manager for Financial Affairs of Iranian Gas Compnay of Khorasan Razavi province;
2016-2017 Deputy Financial Director of National Iranian Gas Company;
2016-2017 Deputy Financial Director of National Iranian Gas Company;
2017 onwards Financial Director of National Iranian Gas Company;
Being responsible for the following duties:
Issuance of all invoices under the gas export contracts with Turkey and Iraq;
Issuance of all invoices under all LPG sale contracts with the foreign companies,
Testify that I have personal and direct knowledge of the facts hereinafter stated except where it is indicated that
matters are based on information or belief, in which case I believe the relevant matters to be true.
2017 onwards Financial Director of National Iranian Gas Company;
Being responsible for the following duties:
Issuance of all invoices under the gas export contracts with Turkey and Iraq;
Issuance of all invoices under all LPG sale contracts with the foreign companies,
Testify that I have personal and direct knowledge of the facts hereinafter stated except where it is indicated that
matters are based on information or belief, in which case I believe the relevant matters to be true.
1. The National Iranian Gas Company ("NIGC") is a subsidiary of Iran's Ministry of Petroleum. Its functions
include the refining, domestic supply and export of natural gas and LPG mainly from the South Pars Field,
the transfer and distribution of gas inside the country mainly produced by the South Pars Gas Field, and the
exportation of gas from the territory of Iran.
1. The National Iranian Gas Company ("NIGC") is a subsidiary of Iran's Ministry of Petroleum. Its functions
include the refining, domestic supply and export of natural gas and LPG mainly from the South Pars Field,
the transfer and distribution of gas inside the country mainly produced by the South Pars Gas Field, and the
exportation of gas from the territory of Iran.
2. Between January 2016 and May 2018, the production and the exportation of gas by NIGC increased.
Compared to the period of August 2014 to December 2015, the production of gas by NIGC during the 16
2. Between January 2016 and May 2018, the production and the exportation of gas by NIGC increased.
Compared to the period of August 2014 to December 2015, the production of gas by NIGC during the 16
months - January 2016 to April 2018 - after the implementation of the JCPOA rose by 10% while its
exportations of gas, also in volume, rose by 50% percent.
months - January 2016 to April 2018 - after the implementation of the JCPOA rose by 10% while its
exportations of gas, also in volume, rose by 50% percent.
3. Prior to the 8 May 2018, NIGC had been exporting, through gas pipelines, 30 million cubic meters ("mcm")
of gas per day to Turkey, and 25 mcm per day to Iraq. Turkey and Iraq are the main importers of Iran's gas,
with Azerbaijan, to which NIGC provides gas through swap agreements. NIGC also used to export large
quantities of liquefied petroleum gas (LPG) to the Asian destinations mostly.
3. Prior to the 8 May 2018, NIGC had been exporting, through gas pipelines, 30 million cubic meters ("mcm")
of gas per day to Turkey, and 25 mcm per day to Iraq. Turkey and Iraq are the main importers of Iran's gas,
with Azerbaijan, to which NIGC provides gas through swap agreements. NIGC also used to export large
quantities of liquefied petroleum gas (LPG) to the Asian destinations mostly.
4. Since the 8 May 2018, access to the proceeds of the exported gas by NIGC has become almost impossible.
4. Since the 8 May 2018, access to the proceeds of the exported gas by NIGC has become almost impossible.
5. Moreover, with regard to NIGC's exports of gas to Iraq, they have fallen to 10 to 15 mcm per day as the
banks of the Ministry of Electricity of Iraq have refused to execute payments either in Euros or in U.S
Dollars to NIGC for the gas deliveries, for fear of the US sanctions and accordingly NIGC has reduced its gas
export to Iraq to avoid the accumulation of the unpaid amounts.
5. Moreover, with regard to NIGC's exports of gas to Iraq, they have fallen to 10 to 15 mcm per day as the
banks of the Ministry of Electricity of Iraq have refused to execute payments either in Euros or in U.S
Dollars to NIGC for the gas deliveries, for fear of the US sanctions and accordingly NIGC has reduced its gas
export to Iraq to avoid the accumulation of the unpaid amounts.
6. During the "first round" of US sanctions, and even after the conclusion of the JCPOA, NIGC and the Trade
Bank of Iraq - Iraq's Ministry of Electricity bank in Iraq -, had agreed on the following financial scheme so
that the gas deliveries could be paid in Euros rather than in dollars as provided in the gas contract: NIGC
would issue invoices in Euros, the Trade Bank of Iraq would then order another bank to pay these invoices
in Euros by wire transfer to the euro bank account maintained by NIGC with the Muscat Bank account with
EIH bank in Germany through an LC mechanism. However, after the US announced on 8 May 2018 the re­
imposition of the sanctions, Muscat Bank refused to process further payments in Euros to NIGC.
It
motivated this termination of services by the re-imposed U.S. sanctions.
6. During the "first round" of US sanctions, and even after the conclusion of the JCPOA, NIGC and the Trade
Bank of Iraq - Iraq's Ministry of Electricity bank in Iraq-, had agreed on the following financial scheme so
that the gas deliveries could be paid in Euros rather than in dollars as provided in the gas contract: NIGC
would issue invoices in Euros, the Trade Bank of Iraq would then order another bank to pay these invoices
in Euros by wire transfer to the euro bank account maintained by NIGC with the Muscat Bank account with
EIH bank in Germany through an LC mechanism. However, after the US announced on 8 May 2018 the re­
imposition of the sanctions, Muscat Bank refused to process further payments in Euros to NIGC. It
motivated this termination of services by the re-imposed U.S. sanctions.
NIGC Main Building,south Aban St.,Karimkhan Zand Ave.,Tehran.Iran
NIGC Main Building,south Aban St.,Karimkhan Zand Ave.,Tehran.lran
P.O.Box 11365-4694 & 15875-4533, Tel: (+9821)84870, Fax. (+9821)88824750
Internet Site : www.nigc.ir, E-Mail : [email protected]
P.O.Box 11365-4694 & 15875-4533, Tel: (+9821)84870, Fax. (+9821)88824750
Internet Site : www.nigc.ir, E-Mail : [email protected]
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Date: 30/04/2019
A'ati@net 'jscnian
Date: 30/04/2019
No: G8/000/13935
'atiana€ 'Janian
No: G8/000/13935
7. Since then, neither the Trade Bank of Iraq nor NIGC have found a bank willing to execute payments in Euros
to NIGC for the delivery of gas. The Trade Bank of Iraq can now pay Iraq's gas importation from Iran in Iraqi
Dinars, which is not a hard currency and as such not economically interesting for NIGC: the Iraqi Dinar is
hardly tradable and is of limited use to NIGC since very few of its suppliers are Iraqi entities. As a
consequence, NIGC had to reduce its exports of gas to Iraq by 50 %.
7. Since then, neither the Trade Bank of Iraq nor NIGC have found a bank willing to execute payments in Euros
to NIGC for the delivery of gas. The Trade Bank of Iraq can now pay Iraq's gas importation from Iran in Iraqi
Dinars, which is not a hard currency and as such not economically interesting for NIGC: the Iraqi Dinar is
hardly tradable and is of limited use to NIGC since very few of its suppliers are Iraqi entities. As a
consequence, NIGC had to reduce its exports of gas to Iraq by 50 %.
8. As for NIGC's exports of gas to Turkey, for now their volume has remained the same as prior to the 8 May
8. As for NIGC's exports of gas to Turkey, for now their volume has remained the same as prior to the 8 May
2018 announcement. However, the payment of these deliveries can only be made in Euros and on accounts
opened with Turkish banks, who refuse to transfer these funds to Iranian banks.
2018 announcement. However, the payment of these deliveries can only be made in Euros and on accounts
opened with Turkish banks, who refuse to transfer these funds to Iranian banks.
9. A a result, the revenues generated by NIGC from the exportation of its gas to Turkey are de facto frozen on
its bank account in Turkey, and NIGC is therefore barred from any meaningful use of these revenues.
9. As a result, the revenues generated by NIGC from the exportation of its gas to Turkey are de facto frozen on
its bank account in Turkey, and NIGC is therefore barred from any meaningful use of these revenues.
10. In addition, as from the 8 May 2018 and the re-imposition of U.S. sanctions, the importers of liquefied
petroleum gas provided by NIGC and their banks have been refusing to pay NIGC in Euros - as they used to
do until then. The payments are now denominated exclusively in local currency - Yuan, Rupees -, rather
than in widely transferable currency, which is financially detrimental to NIGC since these exports revenues
are illiquid, for the same reason mentioned above about payments in Iraqi Dinars. Moreover, NIGC has no
access to its money so paid as they should be used for the purchase of local goods only.
10. In addition, as from the 8 May 2018 and the re-imposition of U.S. sanctions, the importers of liquefied
petroleum gas provided by NIGC and their banks have been refusing to pay NIGC in Euros - as they used to
do until then. The payments are now denominated exclusively in local currency - Yuan, Rupees -, rather
than in widely transferable currency, which is financially detrimental to NIGC since these exports revenues
are illiquid, for the same reason mentioned above about payments in Iraqi Dinars. Moreover, NIGC has no
access to its money so paid as they should be used for the purchase of local goods only.
· Hosseini
· Hosseini
NIGC Main Building,south Aban St.,Karimkhan Zand Ave., Tehran.Iran
NIGC Main Building,south Aban St.,Karimkhan Zand Ave., Tehran.lran
P.O.Box 11365-4694 & 15875-4533, Tel: (+9821)84870, Fax: (+9821)88824750
Internet Site : www.nigc.ir, E-Mail : [email protected]
P.0O.80x 11365-4694 & 15875-4533, Tel: (+9821)84870, Fax: (+9821)88824750
Internet Site : www.nigcir , E-Mail : [email protected]

- 10 -

Annex 207
Witness statement of Mr H. Bovard, Managing Director of Iranian Offshore Oil
Company, 1 May 2019

- 11 -

- 12 -

$
$
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g,
g,
Date : 26\9/05/o1
Date : 26\9/05/o1
Ref. No:
13180
'-2;
Ref. No:
I3180
e'-e;
National Iranian Oil Co.
National Iranian Oil Co.
Enc:
Enc:
IRANIAN OFFSHORE OIL CO.
IRANIAN OFFSHORE OIL CO.
Witness Statement
Witness Statement
I, Hamid Bovard, the Managing Director of Iranian Offshore Oil Company ("IOOC), testify as
follows:
I have been in my current position at IOOC since 2016/08/07. I hold an MBA in Strategic
Management from Islamic Azad University, Tehran Science and Research Branch.
I, Hamid Bovard, the Managing Director of Iranian Offshore Oil Company ("IOOC"), testify as
follows:
I have been in my current position at IOOC since 2016/08/07. I hold an MBA in Strategic
Management from Islamic Azad University, Tehran Science and Research Branch.
Due to my previous positions and my current capacity, I have personal knowledge of the facts
hereinafter stated except where it is indicated that matters are based on information or belief, in
Due to my previous positions and my current capacity, I have personal knowledge of the facts
hereinafter stated except where it is indicated that matters are based on information or belief, in
which case I believe the relevant matters to be true.
which case I believe the relevant matters to be true.
IOOC, its HQ based in Tehran, Iran, with six operational districts in south of Iran (Bahregan. Siri
Island, Lavan Island, Kharg Island, Qeshm Island and Kish Island) and several offshore oil/gas
producing platforms is one of the world's largest offshore oil and gas producing companies. The
company shares a significant amount of Iranian oil export, operating in Iranian side of the
Persian Gulf and Oman Sea.
The re-imposition of the US sanctions against Iran has severely affected IOOC's activities. The
company can no longer procure an important part of the installations, machinery, equipment,
spare parts, and other materials required for its offshore operations in Persian Gulf and Oman
Sea which have to be purchased from European and American sources. Furthermore. IOOC may
not receive from foreign companies the licenses and technical knowledge for keeping the
maximum efficient rate of recovery of Iran's oil and gas reservoirs. As a result of the said
sanctions, IOOC is currently failing to achieve its pre-determined goals including the efficient
exploitation of the oil and gas fields, particularly in the common fields with neighboring
countries. The most significant impacts of the re-imposition of the US sanctions on IOOC are as
follows:
IOOC, its HQ based in Tehran, Iran, with six operational districts in south of Iran (Bahregan, Siri
Island, Lavan Island, Kharg Island, Qeshm Island and Kish Island) and several offshore oil/gas
producing platforms is one of the world's largest offshore oil and gas producing companies. The
company shares a significant amount of Iranian oil export, operating in Iranian side of the
Persian Gulf and Oman Sea.
The re-imposition of the US sanctions against Iran has severely affected IOOC's activities. The
company can no longer procure an important part of the installations, machinery. equipment,
spare parts, and other materials required for its offshore operations in Persian Gulf and Oman
Sea which have to be purchased from European and American sources. Furthermore, IOOC may
not receive from foreign companies the licenses and technical knowledge for keeping the
maximum efficient rate of recovery of Iran's oil and gas reservoirs. As a result of the said
sanctions, 1OOC is currently failing to achieve its pre-determined goals including the efficient
exploitation of the oil and gas fields, particularly in the common fields with neighboring
countries. The most significant impacts of the re-imposition of the US sanctions on IOOC are as
follows:
A- Procurement Sector
A- Procurement Sector
I- Restrictions on the transfers of foreign receivables and debts arising from foreign
purchase orders.
2- Restrictions on purchasing high-tech equipment which leads to the unattainability of
procuring such equipment.
3- Unavailability of providing after sale services by foreign manufacturers.
I- Restrictions on the transfers of foreign receivables and debts arising from foreign
purchase orders.
2- Restrictions on purchasing high-tech equipment which leads to the unattainability of
procuring such equipment.
3- Unavailability of providing after sale services by foreign manufacturers.
s?°
s
NO.12 ,KHAKZAD STREET, TOURAJ STREET ,AFTER BALAL MOSQUE , VALIASRAVE, MODARRE �OSSROAD,
TEHRAN-IRAN , POSTAL CODE:1966653943, P.O.BOX:19395-5591, TEL:(+98)-21-2266 4470 TO 85,TLX: 212598
NO.12 ,KHAKZAD STREET, TOURA.J STREET AFTER BALAL MOSQUE, VALIASRAVE, MODARRE �OSSROAD,
TEHRAN-IRAN , POSTAL CODE:1966653943, P.0.BOX:19395-5591, TEL:(+98)-21-2266 4470 TO 85,TLX: 212598
- 13 -

d
d
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g2,
ch,
Date: 2019/o5/l
Date: 2019/o5/l
ef. No:
13
1o
e!-J;
ef. No:
13
1o
e!-J'
National Iranian Oil Co.
National Iranian Oil Co.
IRANIAN OFFSHORE OIL CO.
Enc:
Enc:
IRANIAN OFFSHORE OIL CO.
4- Restrictions on the purchase of spare parts for machinery which do not have any local
alternatives.
5- Unavailability in procuring primary materials for manufacturing spare parts and
equipment.
6- Excessive delay in the process of manufacturing and delivery of the goods and
equipment.
7- Changes in the price of purchase orders as a result of an extreme increase in the
exchange rate and instability of the market.
8- Undue delay in payments of advance payments, and late settlement of accounts
4- Restrictions on the purchase of spare parts for machinery which do not have any local
alternatives.
5- Unavailability in procuring primary materials for manufacturing spare parts and
equipment.
6- Excessive delay in the process of manufacturing and delivery of the goods and
equipment.
7- Changes in the price of purchase orders as a result of an extreme increase in the
exchange rate and instability of the market.
which dissuade foreign suppliers to work with Iranian individuals and companies.
8- Undue delay in payments of advance payments, and late settlement of accounts
which dissuade foreign suppliers to work with Iranian individuals and companies.
9- Restrictions on taking part in international seminars and on the transfer of technology
which hinders the manufacturing of required goods and equipment.
9- Restrictions on taking part in international seminars and on the transfer of technology
which hinders the manufacturing of required goods and equipment.
IO- Restrictions on the transportation and insurance of the goods destined to or originated
I 0- Restrictions on the transportation and insurance of the goods destined to or originated
from Iran.
from lran.
B- Production Operations Sector
B- Production Operations Sector
I- IOOC possessed a large number of machinery (more than 200) including. submersible
pumps, gas turbine, water injection pumps, gas compressors, etc. The production
operation of the company is directly depended on those pieces of machinery. Most
spare parts and repair & maintenance services for the machinery are directly or
indirectly provided by western companies. Failure in access to these services due to
the re-imposition of the US sanctions is significantly detrimental to the production
operation of this company.
2- IOOC maintains more than 3000 kilometers offshore pipelines which facilitate the
transfer of exploited oil and gas as well as water injection to the wells. A large part of
the pipelines is unfortunately not in good shape and thus require repair or
replacement. The relevant services such as see pad and dynamic positioning (DP) are
mostly offered by international companies. The necessary spare parts including
I- IOOC possessed a large number of machinery (more than 200) including. submersible
pumps, gas turbine, water injection pumps, gas compressors, etc. The production
operation of the company is directly depended on those pieces of machinery. Most
spare parts and repair & maintenance services for the machinery are directly or
indirectly provided by western companies. Failure in access to these services due to
the re-imposition of the US sanctions is significantly detrimental to the production
operation of this company.
2- 1OOC maintains more than 3000 kilometers offshore pipelines which facilitate the
transfer of exploited oil and gas as well as water injection to the wells. A large part of
the pipelines is unfortunately not in good shape and thus require repair or
replacement. The relevant services such as see pad and dynamic positioning (DP) are
mostly offered by international companies. The necessary spare parts including
clamps, smart flanges, etc. are manufactured and provided by Iranian companies only
clamps, smart flanges, etc. are manufactured and provided by Iranian companies only
in a very limited level and scale which does not satisfy even the basic needs of IOOC
in a very limited level and scale which does not satisfy even the basic needs of IOOC
2
2
NO.12 ,KHAKZAD STREET, TOURAJ STREET ,AFTER BALAL MOSQUE, VALIASR AVE, MODARIU�
NO.12 ,KHAKZAD SI'REET, TOURAJ STREET ,AFTER BALAL MOSQUE, VALIASR AVE , MOD�
TEHRAN-IRAN, POSTAL CODE:1966653943, P.O.BOX:19395-5591, TEL:(+98)-21-2266 4470 TO 85, TLX: 212598
TEHRAN-IRAN , POSTAL CODE:1966653943, P.0.BOX:19395-5591, TEL:(+98)-21-2266 4470 TO 85, TLX: 212598
- 14 -

d
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d
-
02,
02,
Date: 20 19/ 05/%I
Date: 2019/·5/%I
Ref. No:
13/8
ev--;
Ref. No:
13/8
e!--f;
Enc:
National Iranian Oil Co.
IRANIAN OFFSHORE OIL CO.
National Iranian Oil Co.
IRANIAN OFFSHORE OIL CO.
Enc:
operational activities. The re-imposition of the US sanctions, therefore, negatively
affected IOOC's ability to perform the relevant repair and maintenance services for
the pipelines.
operational activities. The re-imposition of the US sanctions, therefore, negatively
affected IOOC's ability to perform the relevant repair and maintenance services for
the pipelines.
3- Flexible pipes which can immediately stop the production flow in the event of
perforation or other impairments in the pipelines are only available through
importation to Iran. The re-imposition of the US sanctions, however, has created
severe restrictions and hindrance on the process of importations.
3- Flexible pipes which can immediately stop the production flow in the event of
perforation or other impairments
in the pipelines are only available through
importation to Iran. The re-imposition of the US sanctions, however, has created
severe restrictions and hindrance on the process of importations.
4- The controlling cards of Siemens, Hima, ABB, Yokogawa, Bradly, and the contactors
and electrical relays of ABB, as well as the breakers of L V and MV are also only
available by importation to the country which has been rigorously restricted as a
result of the re-imposition of the US sanctions.
4- The controlling cards of Siemens, Hima, ABB, Yokogawa, Bradly, and the contactors
and electrical relays of ABB, as well as the breakers of L V and MV are also only
available by importation to the country which has been rigorously restricted as a
result of the re-imposition of the US sanctions.
5- The equipment for pipelines' erosion monitoring, and certain chemical materials
including antifoams. Drag-Reducing Agents (DRA), triethylene Glycol with a purity
of 98%, biocide, cationic polyelectrolytes, and tidal zone protection materials which
are the most commonly used materials in offshore industry are only procured from
abroad. The re-imposition of the US sanctions, however, harshly influences on
IOOC's ability to import the materials for maintaining the ongoing operation of oil
fields and the relevant projects.
5- The equipment for pipelines' erosion monitoring, and certain chemical materials
including antifoams, Drag-Reducing Agents (DRA), triethylene Glycol with a purity
of 98%, biocide, cationic polyelectrolytes, and tidal zone protection materials which
are the most commonly used materials in offshore industry are only procured from
abroad. The re-imposition of the US sanctions, however, harshly influences on
IOOCs ability to import the materials for maintaining the ongoing operation of oil
fields and the relevant projects.
6- The _offshore companies are no longer interested in participation in the operational
tenders as a result of the re-imposition of the US sanctions. Moreover, at least six
below vessels have withdrawn the operational tenders for the same reason:
6- The offshore companies are no longer interested in participation in the operational
tenders as a result of the re-imposition of the US sanctions. Moreover, at least six
below vessels have withdrawn the operational tenders for the same reason:
Daily Rate
Daily Rate
No. Company
No.
Company
Vessel
Type of Service
Vessel
Type of Service
(Euro)
(Euro)
l
4292
Linex
l
4292
Line
�
3933
Signet Atlantic
2
3933
Signet Atlantic
ASD Tug
Royal Oyster
ASD Tug
�
Royal Oyster
4117
Orix
3
Orix
4117
4
1700
Saria
4
Marine Services
Saria
1 700
Marine Services
5
4774
Araba Glorv
5
Araba Glorv
4774
Gulf Glory
Gulf Glory
6
ASD Tug
4447
ASD Tug
6
Asib Glory
Asib Glory
4447
7- The transportation of required equipment for oil platforms, wells, and drilling rigs
which used to be sent to the relevant operational zone from UAE has been ceased
7- The transportation of required equipment for oil platforms, wells, and drilling rigs
which used to be sent to the relevant operational zone from UAE has been ceased
3�
MODA�KoAD,
7
NO.12 ,KHAKZAD STREET, TOURAJ STREET ,AFTER DALAL MOSQUE, VALIASR AVE,
TEHRAN-IRAN , POSTAL CODE:1966653943, P.0.BOX:19395-5591, TEL:(+98)-21-2266 4470 TO 85, TLX: 212598
NO.12 ,KHAKZAD STREET, TOURAJ STREET ,AFTER DALAL MOSQUE , VALIASR AVE, MODA�AD,
TEHRAN-IRAN , POSTAL CODE:1966653943, P.0.BOX:19395-5591, TEL:(+98)-21-2266 4470 TO 85,TLX: 212598
- 15 -

d
d
-
-
g,
a,
Date: 2ol9]o5/2l
Date: 2ol9]o5/2l
Ref. No:
13/0
e'--;
Ref. No:
13/0
e-J'
National Iranian Oil Co.
IRANIAN OFFSHORE OIL CO.
National Iranian Oil Co.
IRANIAN OFFSHORE OIL CO.
Enc:
Enc:
because no vessel is allowed to leave the foreign ports for Iranian destinations due to
the re-imposition of the US sanctions.
because no vessel is allowed to leave the foreign ports for Iranian destinations due to
the re-imposition of the US sanctions.
8- The prominent international classification societies including GL, DNV, and Lloyds
have ceased their cooperation with IOOC as a result of the re-imposition of the US
sanctions.
8- The prominent international classification societies including GL, DNV, and Lloyds
have ceased their cooperation with IOOC as a result of the re-imposition of the US
sanctions.
9- A decrease in the number of service and operational vessels and tugs leads to an
excessive delay in the movement of rigs, barges, and mooring of oil tankers which
lead to extra daily freight and charges. It also gives rise to failure in providing the
equipment to satellite platforms and replacement of its personnel in due time leading
to an increase in the risk of disastrous accidents, or reduction or stay in production.
9- A decrease in the number of service and operational vessels and tugs leads to an
excessive delay in the movement of rigs, barges, and mooring of oil tankers which
lead to extra daily freight and charges. It also gives rise to failure in providing the
equipment to satellite platforms and replacement of its personnel in due time leading
to an increase in the risk of disastrous accidents, or reduction or stay in production.
C- Technical Affairs Sector
C- Technical Affairs Sector
1- As regard to technical supports and drilling services, the domestic companies have been
encountered serious difficulties concerning procurement of materials and special
supplements for mud, oil-well cement, procurement of spare parts and consumable
materials for directional drilling tools including MWD System, RSS, MUD Motor of
western brands being of relatively good quality, and this matter has a negative effect on
the efficiency of the drilling sector and the escalation of the respective costs.
1- As regard to technical supports and drilling services, the domestic companies have been
encountered serious difficulties concerning procurement of materials and special
supplements for mud, oil-well cement, procurement of spare parts and consumable
materials for directional drilling tools including MWD System, RSS, MUD Motor of
western brands being of relatively good quality, and this matter has a negative effect on
the efficiency of the drilling sector and the escalation of the respective costs.
2- Certain productive wells have or will become out of the production circuit. Considering
the specific conditions of the well completion and also particular complications of
reservoirs in the oil fields under the control of this company, and based on the previous
experiences, revival of these wells are challenging and requires the utilization of specific
essentials alongside their side services. For instance, the restoration of certain wells
requires Coiled Tubing, Supporting Barge, Snubbing Unit, and also drilling Rig and the
side services. However, the re-imposition of the US sanctions creates restrictions on the
access of IOOC to the above-mentioned equipment and services.
2- Certain productive wells have or will become out of the production circuit. Considering
the specific conditions of the well completion and also particular complications of
reservoirs in the oil fields under the control of this company, and based on the previous
experiences, revival of these wells are challenging and requires the utilization of specific
essentials alongside their side services. For instance, the restoration of certain wells
requires Coiled Tubing, Supporting Barge, Snubbing Unit, and also drilling Rig and the
side services. However, the re-imposition of the US sanctions creates restrictions on the
access of IOOC to the above-mentioned equipment and services.
3- Since 2013, certain items required for the reparation and completion of the wells, in two
categories of well completion equipment and wellhead equipment (X- Tree) are being
manufactured and procured by the local manufacturers. However, primary materials
necessary for the production of goods are not fully procurable within the country, and
thus. domestic manufacturers should inevitably import a portion of the primary materials
3- Since 2013, certain items required for the reparation and completion of the wells, in two
categories of well completion equipment and wellhead equipment (X- Tree) are being
manufactured and procured by the local manufacturers. However, primary materials
necessary for the production of goods are not fully procurable within the country, and
thus. domestic manufacturers should inevitably import a portion of the primary materials
4
NO.12 ,KHAKZAD STREET, TOURAJ STREET ,AFTER BALAL MOSQUE, VALIASR AVE , MODARRES C; SSROAD,
5%a
NO.12 ,KHAKZAD STREET, TOURAJ STREET ,AFTER BALAL MOSQUE, VALIASR AVE, MODARRES ;SSROAD,
TEHRAN-IRAN , POSTAL CODE:1966653943, P.0.BOX:19395-5591, TEL:(+98)-21-2266 4470 TO 85, TLX: 212598
TEHRAN-IRAN , POSTAL CODE:1966653943, P.0.BOX:19395-5591, TEL:(+98)-21-2266 4470 TO 85, TLX: 212598
- 16 -

$
$
-
-
a2,
a2,
Date: 2
0
l9/o
5/ol
Date: 20l9]o5/ol
Ref. No:
13/8o
e'-2
e!--f;
Ref. No:
1318o
National Iranian Oil Co.
National Iranian Oil Co.
IRANIAN OFFSHORE OIL CO.
Enc:
Enc:
IRANIAN OFFSHORE OIL CO.
from abroad. It is obvious that exacerbation of the sanctions in this sector (i.e.
procurement and importation of the primary materials) is effective, and essentially,
causes problems for the domestic manufacturer to deliver the item to its employer.
Eventually, it resulted in the failure in the procurement of the goods, the waiting of digs
and the interruption in the operation of the projects.
from abroad. It is obvious that exacerbation of the sanctions in this sector (i.e.
procurement and importation of the primary materials) is effective, and essentially,
causes problems for the domestic manufacturer to deliver the item to its employer.
Eventually, it resulted in the failure in the procurement of the goods, the waiting of digs
and the interruption in the operation of the projects.
4- With regard to the category of imported items including pumps and downhole motor
(ESP) and Tubing, to which there is no similar domestic production, the participation of
the foreign manufacturers in the tenders has become very limited due to the re-imposition
of the sanctions. Considering the key role of the Tubing in operations for reparation and
completion of the wells, it is obvious that the impossibility of the procurement of these
goods causes the complete shutdown of the drilling rigs.
4- With regard to the category of imported items including pumps and downhole motor
(ESP) and Tubing, to which there is no similar domestic production, the participation of
the foreign manufacturers in the tenders has become very limited due to the re-imposition
of the sanctions. Considering the key role of the Tubing in operations for reparation and
completion of the wells, it is obvious that the impossibility of the procurement of these
goods causes the complete shutdown of the drilling rigs.
D- Engineering and Construction Sector:
D- Engineering and Construction Sector:
The most important impacts of the re-imposition of the US sanctions on the engineering and
construction sector of IOOC's activities may be summarized in the rise of the full project costs
for the following reasons:
The most important impacts of the re-imposition of the US sanctions on the engineering and
construction sector of IOOC's activities may be summarized in the rise of the full project costs
a) The increase in the exchange rate in contrast with the time of contractors' commercial
offer;
for the following reasons:
a) The increase in the exchange rate in contrast with the time of contractors' commercial
offer;
b) The difference between the official exchange rate and the rate in the open market;
c) The costs of transfer of currency.
It should be noted that the prolongation of the projects execution time, in addition to an
increase in the full cost, results in expenses stemming from the lost opportunity.
d) The impossibility of conclusion, by the contractors, of purchase contract with foreign
manufacturers of goods essential for projects, or modification of the existing contracts.
e) The impossibility of the carriage of the manufactured goods from the countries of origin
b) The difference between the official exchange rate and the rate in the open market;
c) The costs of transfer of currency.
It should be noted that the prolongation of the projects execution time, in addition to an
increase in the full cost, results in expenses stemming from the lost opportunity.
d) The impossibility of conclusion, by the contractors, of purchase contract with foreign
manufacturers of goods essential for projects, or modification of the existing contracts.
e) The impossibility of the carriage of the manufactured goods from the countries of origin
by the contractors of the EPC and similar contracts.
by the contractors of the EPC and similar contracts.
f) The problems arising from the transfer of money and the payment to the foreign
manufacturers in the construction projects.
f) The problems arising from the transfer of money and the payment to the foreign
manufacturers in the construction projects.
NO.12 ,KHAKZAD STREET, TOURAJ STREET ,AFTER B:AL MOSQUE, VALIASR AVE, MODARREc;:2
NO.12 ,KHAKZAD STREET, TOURAJ STREET ,AFfER B:LAL MOSQUE, VALIASR AVE, MODARRE�
TEHRAN-IRAN, POSTAL CODE:1966653943, P.0.BOX:19395-5591, TEL:(+98)-21-2266 4470 TO 85,TLX: 212598
TEHRAN-IRAN , POSTAL CODE:1966653943, P0.BOX:19395-5591, TEL:(+98)-21-2266 4470 TO 85,TLX: 212598
- 17 -

$
$
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-
a2,
Date : 2
0
02
l9/o5/
I
Date: 02el/5/5l
e!--;
et. No: 13 120
et. No: 13 120
e!-s
National Iranian Oil Co.
National Iranian Oil Co.
IRANIAN OFFSHORE OIL CO.
Enc:
Enc:
IRANIAN OFFSHORE OIL CO.
E- Other Financial Burdens:
E- Other Financial Burdens:
There are some other important factors which also trigger an increase in IOOC's costs and
expenses as follows:
1- The re-imposition of the US sanctions has caused an escalation of the full cost of the
approved projects and plans of the company, due to the following major reasons:
There are some other important factors which also trigger an increase in IOOCs costs and
expenses as follows:
1- The re-imposition of the US sanctions has caused an escalation of the full cost of the
approved projects and plans of the company, due to the following major reasons:
a) The unavailability of the main supplier of the goods and services required for the
implementation of the projects and plans;
a) The unavailability of the main supplier of the goods and services required for the
implementation of the projects and plans;
b) Recourse to the Iranian and foreign middlemen, and concerns about the lack of on-time
delivery of requested goods and services;
b) Recourse to the Iranian and foreign middlemen, and concerns about the lack of on-time
delivery of requested goods and services:
c) Recourse to less-qualified Iranian or foreign companies and contractors, and reluctantly
acquiescing to their unreasonable conditions;
c) Recourse to less-qualified Iranian or foreign companies and contractors, and reluctantly
acquiescing to their unreasonable conditions;
d) Prolonging the project execution time and long waiting for the project exploitation.
d) Prolonging the project execution time and long waiting for the project exploitation.
2- Inevitable recourse to the non-standard machinery. equipment, spare parts, goods and
materials which are destructive for the installations and impose extra costs compared to the
procurement
of the goods and services from the main manufacturer.
2- Inevitable recourse to the non-standard machinery. equipment, spare parls, goods and
materials which are destructive for the installations and impose extra costs compared to the
procurement
of the goods and services from the main manufacturer.
3- Exacerbation of the financial burden resulting from the late and impaired execution of plans
and projects.
4- Multiplicity
of spare parts and equipment applicable in the installations and factories, and
inevitably use of non-standard brands, and decline of the useful life, due to the inappropriate
work performance by the less professional and unqualified contractor, that impose additional
costs to the company, and consequently waste the financial resources.
3- Exacerbation of the financial burden resulting from the late and impaired execution of plans
and projects.
4- Multiplicity
of spare parts and equipment applicable in the installations and factories, and
inevitably use of non-standard brands, and decline of the useful life, due to the inappropriate
work performance by the less professional and unqualified contractor, that impose additional
costs to the company, and consequently waste the financial resources.
5- The unavailability of opening letters of documentary credit as a result of the banking
sanctions.
6-The failure in the achievement of the intended amount of oil and gas production due to the
above-mentioned restrictions and hindrances that eventually results in deprivation of earning the
income yielded
from oil and gas, and, in the next financial chain, diminishing the financial
resources in multiple ways.
5- The unavailability of opening letters of documentary credit as a result of the banking
sanctions.
6-The failure in the achievement of the intended amount of oil and gas production due to the
above-mentioned restrictions and hindrances that eventually results in deprivation of earning the
income yielded
from oil and gas, and. in the next financial chain, diminishing the financial
resources in multiple ways.
HamidBo�
HamidBo�
6
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aa..
6
c±?>
NO.12 ,KHAKZAD STREET, TOURAJ STREET ,AFTER BALAL MOSQUE, VALIASR AVE, MODARRES �ROAD,
a.a.
NO.12 ,KHAKZAD STREET, TOURAJ STREET ,AFTER BALAL MOSQUE, VALIASR AVE, MODARRES �ROAD,
TEHRAN-IRAN , POSTAL CODE:1966653943, P.0.BOX:19395-5591, TEL:(+98)-21-2266 4470 TO 85,TLX: 212598
TEHRAN-IRAN, POSTAL CODE:1966653943, P.0.BOX:19395-5591, TEL:(+98)-21-2266 4470 TO 85,TLX: 212598

- 18 -

Annex 208
The Oxford Institute for Energy Studies, “Iranian Energy: a comeback with hurdles”,
University of Oxford, January 2017

- 19 -

- 20 -

©
n.n
THE OXFORD
all? THE OXFORD
-
l'-- INSTITUTE
I-
0
.
INSTITUTE
FI FoR ENERGY
=][ FoR ENERGY
0
lI STUDIES
UNIVERSITY OF
<lI STUDIES
UNIVERSITY OF
OXFORD
OXFORD
A RECOGNIZED INDEPENDENT CENTRE OF THE UNIVERSITY OF OXFORD
A RECOGNIZED INDEPENDENT CENTRE OF TH UNIVERSITY OF 0IF0RD
January 2017
January 2017
Iranian Energy:
Iranian Energy:
a comeback with hurdles
a comeback with hurdles
OXFORD ENERGY COMMENT
OXFORD ENERGY COMMENT
David Ramin Jalilvand, Friedrich Ebert Foundation
David Ramin Jalilvand, Friedrich Ebert Foundation
- 21 -

One year ago, on 16 January 2016, the Iran nuclear deal was formally implemented. Officially known
as the Joint Comprehensive Plan of Action (JCPOA), the deal was concluded in July 2015 between
Iran and the 'E3+3', which comprises the European states France, Germany, and Great Britain as well
as the world powers China, Russia, and the United States. In essence, the JCPOA allows for the
lifting of several sanctions against
Iran
in exchange for limitations on, and greater international
One year ago, on 16 January 2016, the Iran nuclear deal was formally implemented. Officially known
as the Joint Comprehensive Plan of Action (JCPOA), the deal was concluded in July 2015 between
Iran and the 'E3+3', which comprises the European states France, Germany, and Great Britain as well
as the world powers China, Russia, and the United States. In essence, the JCPOA allows for the
lifting of several sanctions against
Iran
in exchange for limitations on, and greater international
inspections of, Iran's nuclear programme.
1
inspections of, Iran's nuclear programme.
1
In the
In the
Iranian energy sector, the JCPOA was greeted with hope and expectations of a revival.
Iranian energy sector, the JCPOA was greeted with hope and expectations of a revival.
Sanctions have constrained the industry for several years; amongst other effects they have forced
Western companies to
leave the country and reduced oil production and exports.
Indeed,
Sanctions have constrained the industry for several years; amongst other effects they have forced
Western companies to
leave the country and reduced oil production and exports.
Indeed,
implementation of the JCPOA was accompanied by the lifting of energy sector-related sanctions and
has encouraged several international oil companies (IOCs) to move to Iran to explore the potential for
co-operation.
implementation of the JCPOA was accompanied by the lifting of energy sector-related sanctions and
has encouraged several international oil companies (IOCs) to move to Iran to explore the potential for
co-operation.
Against this backdrop, it is worth examining the merits of the JCPOA for the Iranian energy sector up
to this point -- a year since the beginning of its implementation. It is argued in the following that the
Iranian government has been trying to strike a balance between various competing power centres at
home, while attempting to hedge risks at the international stage. On the ground, however, actual
progress has been rather modest so far.
Iran has increased its oil production to the pre-sanctions
Against this backdrop, it is worth examining the merits of the JCPOA for the Iranian energy sector up
to this point -- a year since the beginning of its implementation. It is argued in the following that the
Iranian government has been trying to strike a balance between various competing power centres at
home, while attempting to hedge risks at the international stage. On the ground, however, actual
progress has been rather modest so far.
Iran has increased its oil production to the pre-sanctions
level but is still waiting to see an expansion of its productive capacity. In the meantime, uncertainty
level but is still waiting to see an expansion of its productive capacity. In the meantime, uncertainty
with regard to the outlook of Iran's energy sector has increased, as the future course of US policy ­
with regard to the outlook of Iran's energy sector has increased, as the future course of US policy ­
incoming President Donald Trump has been an outspoken critic of the JCPOA -- remains unclear.
incoming President Donald Trump has been an outspoken critic of the JCPOA -- remains unclear.
The state of affairs: back to the pre-sanctions position
The state of affairs: back to the pre-sanctions position
Before the implementation of the JCPOA in January 2016, a complex set of sanctions was in place
against Iran, adopted by the European Union (EU), the United Nations (UN), and the United States
(US). Amongst others, sanctions forced European IOCs to leave Iran, limited the international sale of
Iranian oil, prevented American and European investments in the Iranian energy sector, excluded Iran
from the SWIFT banking network, and effectively forced major European banks and insurance
companies to stop dealing with the country.
Before the implementation of the JCPOA in January 2016, a complex set of sanctions was in place
against Iran, adopted by the European Union (EU), the United Nations (UN), and the United States
(US). Amongst others, sanctions forced European IOCs to leave Iran, limited the international sale of
Iranian oil, prevented American and European investments in the Iranian energy sector, excluded Iran
from the SWIFT banking network, and effectively forced major European banks and
insurance
companies to stop dealing with the country.
3
Iran's energy sector was hit hard by these sanctions. Oil
3
Iran's energy sector was hit hard by these sanctions. Oil
production was reduced to 2.7 million barrels per day (mb/d) in 2013, down from 3.7 mb/d in 2011. Oil
exports declined from 2.6 to 1.3 mb/d.
4
While
Iran was able to continue expanding its natural gas
production was reduced to 2.7 million barrels per day (mb/) in 2013, down from 3.7 mb/d in 2011. Oil
exports declined from 2.6 to 1.3 mb/d.
4
While
Iran was able to continue expanding its natural gas
production, sanctions prevented access to the latest LNG technology.
In response to sanctions,
Iran has introduced a number of counter policies, under the umbrella of
production, sanctions prevented access to the latest LNG technology.
In response to sanctions,
Iran has introduced a number of counter policies, under the umbrella of
what was partly labelled the 'resistance economy'. These have been aiming at the expansion of
domestic capabilities and greater autarky from international business and trade which, in light of the
sanctions, were perceived as the country's Achilles heel.
what was partly labelled the 'resistance economy'. These have been aiming at the expansion of
domestic capabilities and greater autarky from international business and trade which, in light of the
sanctions, were perceived as the country's Achilles heel.
5
In the Iranian energy sector, companies ­
5
In the Iranian energy sector, companies ­
especially those affiliated with the Islamic Revolutionary Guard Corps (IRGC), an entity subject to EU
and US sanctions both before and after the JCPOA -- sought to fill the gap
left behind by the
especially those affiliated with the Islamic Revolutionary Guard Corps (IRGC), an entity subject to EU
and US sanctions both before and after the JCPOA -- sought to fill the gap
left behind by the
withdrawal of European IOCs. Although lacking energy industry experience when beginning to move
into the sector in the 2010s (under then President Mahmoud Ahmadinejad), the IRGC managed to
somehow keep maturing oil fields in production and the gas industry growing (although their
performance continued to be rather poor by industry standards). Nevertheless, neither the IRGC nor
the National Iranian Oil Company (NIOC), which is officially in charge of the industry, could make up
for the loss of co-operation with Western partners. Despite some progress, Iran was unable to stop
the decline of its energy industry under sanctions.
withdrawal of European IOCs. Although lacking energy industry experience when beginning to move
into the sector in the 2010s (under then President Mahmoud Ahmadinejad), the IRGC managed to
somehow keep maturing oil fields in production and the gas industry growing (although their
performance continued to be rather poor by industry standards). Nevertheless, neither the IRGC nor
the National Iranian Oil Company (NIOC), which is officially in charge of the industry, could make up
for the loss of co-operation with Western partners. Despite some progress, Iran was unable to stop
the decline of its energy industry under sanctions.
' Samore, Gary: The lran Nuclear Deal: A Definitive Guide, Belfer Center for Science and International Affairs, Harvard
1
Samore, Gary. The Iran Nuclear Deal: A Definitive Guide, Belfer Center for Science and International Affairs, Harvard
University, Cambridge, MA, 2015.
University, Cambridge, MA, 2015.
2
2
Production remains below the officially stated capacity of 4.0 mb/d. Iran's intention is to increase its production capacity to 4.7
Production remains below the officially stated capacity of 4.0 mb/d. Iran's intention is to increase its production capacity to 4.7
mb/d by 2020.
mb/d by 2020.
3
International Crisis Group: 'Spider Web: The Making and Unmaking of Iran Sanctions', 2013.
3
International Crisis Group: 'Spider Web: The Making and Unmaking of Iran Sanctions', 2013.
U.S. Energy Information Administration: 'Iran Country Analysis Brief, Washington, DC, 2015
U.S. Energy Information Administration: 'Iran Country Analysis Brief, Washington, DC, 2015
5
5
Guardian: 'Deciphering the Iranian leader's call for a "resistance economy" 19 April 2016.
Guardian: 'Deciphering the Iranian leader's call for a "resistance economy_'19 April 2016.
2
2
The contents of this paper are the author's sole responsibility. They do not necessarily represent the views
of the Oxford Institute for Energy Studies or any of its Members.
The contents of this paper are the author's sole responsibility. They do not necessarily represent the views
of the Oxford Institute for Energy Studies or any of its Members.
- 22 -

The implementation of the JCPOA in January 2016 has led, amongst other outcomes, to the lifting of
several sanctions and the release of frozen assets. The EU (whose energy and finance sanctions
were particularly painful for Iran) and the UN both terminated sanctions. The US government lifted
nuclear nonproliferation-related secondary sanctions (targeting non-US
individuals outside US
The implementation of the JCPOA in January 2016 has led, amongst other outcomes, to the lifting of
several sanctions and the release of frozen assets. The EU (whose energy and finance sanctions
were particularly painful for Iran) and the UN both terminated sanctions. The US government lifted
nuclear nonproliferation-related secondary sanctions (targeting non-US
individuals outside US
jurisdiction) by issuing so-called presidential waivers; sanctions remain adopted but are not enforced.
US primary sanctions, on the grounds of alleged human rights violations and the support of terrorism,
however, continue to be implemented (US nationals and businesses are still prevented from engaging
in the Iranian energy sector).
jurisdiction) by issuing so-called presidential waivers; sanctions remain adopted but are not enforced.
US primary sanctions, on the grounds of alleged human rights violations and the support of terrorism,
however, continue to be implemented (US nationals and businesses are still prevented from engaging
in the Iranian energy sector).
Many constraints on Iran's energy sector have now gone as a result of JCPOA implementation. There
are no longer any restrictions on exports, investments in the energy sector are possible again, and
European
IOCs are allowed back
into the country. Under European law, banks and insurance
Many constraints on Iran's energy sector have now gone as a result of JCPOA implementation. There
are no longer any restrictions on exports, investments in the energy sector are possible again, and
European
IOCs are allowed back
into the country. Under European law, banks and insurance
companies are also permitted to facilitate business and trade with
Iran again. However, several
companies are also permitted to facilitate business and trade with
Iran again. However, several
contentious issues remain unresolved. These include: a 'snapback' of sanctions (if Iran is perceived
as violating the nuclear deal), the extraterritorial application of US
laws (in the past, US courts
contentious issues remain unresolved. These include: a 'snapback' of sanctions (if Iran is perceived
as violating the nuclear deal), the extraterritorial application of US
laws (in the past, US courts
convicted European banks of Iran-related dealings and subjected them to fines of more than $13
billion), as well as potential new sanctions (the US Congress has already seen several initiatives to
this end°). But, by and large, the JCPOA has opened the door to international co-operation.
convicted European banks of Iran-related dealings and subjected them to fines of more than $13
billion), as well as potential new sanctions (the US Congress has already seen several initiatives to
this end). But, by and large, the JCPOA has opened the door to international co-operation.
The implementation of the JCPOA has attracted the interest of IOCs from around the world.
Throughout 2016, a number of companies moved to
Iran, signing several memoranda of
The implementation of the JCPOA has attracted the interest of IOCs from around the world.
Throughout 2016, a number of companies moved to
Iran, signing several memoranda of
understanding (MoUs). These include, American-Dutch Schlumberger, British-Dutch Shell, Chinese
CNPC, French Total, German Wintershall,
understanding (MoUs). These include, American-Dutch Schlumberger, British-Dutch Shell, Chinese
CNPC, French Total, German Wintershall,
Italian Saipem, Japanese
Italian Saipem, Japanese
Inpex, Norwegian DNO, and
Inpex, Norwegian ONO, and
Russian Gazprom. Up to now, however, no contracts have been inked. The MoUs largely comprise
field studies as preparatory steps. Only one consortium, comprising NIOC, Total, and CNPC, has
signed a 'heads of agreement'; this represents a step forward towards contract finalization. In all
cases, though, final investment decisions and legally binding contracts remain to be concluded (see
Table 1). As a result, Iran is still waiting to see international investment and technology coming to the
country. Effectively, the JCPOA has not yet led to an expansion of capabilities in the Iranian energy
sector.
Russian Gazprom. Up to now, however, no contracts have been inked. The MoUs largely comprise
field studies as preparatory steps. Only one consortium, comprising NIOC, Total, and CNPC, has
signed a 'heads of agreement'; this represents a step forward towards contract finalization.
In all
cases, though, final investment decisions and legally binding contracts remain to be concluded (see
Table 1). As a result, Iran is still waiting to see international investment and technology coming to the
country. Effectively, the JCPOA has not yet led to an expansion of capabilities in the Iranian energy
sector.
The progress Iran has seen so far is, more or less, a return to its pre-sanctions position. Sanctions­
inflicted harm has been undone and oil production and exports are back in the range of pre-sanctions
levels (see Figure 1).
The progress Iran has seen so far is, more or less, a return to its pre-sanctions position. Sanctions­
inflicted harm has been undone and oil production and exports are back in the range of pre-sanctions
levels (see Figure 1).
Figure 1: Iranian Oil Production, million bid
Figure 1: Iranian Oil Production, million b/d
4.0
3.8 la
4.0
3.8 la
3.6
3.6
3.4
3.4
3.2
3.2
3.0
3.0
2.8
2.6
2.8
2.6
2.4
2.4
2.2
2.2
MM
MM
4 et N
4 et N
C
o e e c
iii
ii%
iii3ii3%
iii
Source: MEES
Source: MEES
• These include, for example, the 'Iran Ballistic Missile Sanctions Act of 2016 (March 2016) and the Countering Iranian Threats
• These include, for example, the 'Iran Ballistic Missile Sanctions Act of 2016 (March 2016) and the Countering Iranian Threats
Act of 2016 (Jul 2016).
Act of 2016 (July 2016)
3
3
The contents of this paper are the author's sole responsibility. They do not necessarily represent the views
of the Oxford Institute for Energy Studies or any of its Members.
The contents of this paper are the author's sole responsibility. They do not necessarily represent the views
of the Oxford Institute for Energy Studies or any of its Members.
- 23 -

stream Contracts Awarded, MOUs for Study, and Heads of Agreement 2016
stream Contracts Awarded, MOUs for Study, and Heads of Agreement 2016
Operator
Partners
Field
Date
Type
Lukoil
Lukoil
None
None
24-Jan MoU for stud
24-Jan MoU for stud
24-Mar MoU for stud
Total
Total
None
None
24-Mar MoU for stud
Winters hall
Winters hall
None
None
Four fields in western Iran
Four fields in western Iran
12-Ar MoU for stud
12-Ar MoU for stud
04-Ma
OMV
OMV
None
None
04-Ma
MoU for stud
MoU for stud
Zarubezhneft
Zarubezhnefl
None
None
13-Jul
13-Jul
MoU for stud
MoU for stud
Persia Oil and Gas None
North Yaran Phase 2
North Yaran Phase 2
04-Oct
04-Oct
IPC'
IPC'
Persia Oil and Gas None
Kou al EOR
Kou al EOR
04-Oct
04-Oct
IPC
IPC
Persia Oil and Gas None
Maran EOR
Maran EOR
04-Oct
04-Oct
IPC
IPC
Tatneft
None
Dehloran
Dehloran
08-Oct MoU for stud
08-Oct MoU for stud
Persia Oil and Gas None
Persia Oil and Gas None
Persia Oil and Gas None
Tatneft
None
PGNiG
PGNiG
None
Sumar
Sumar
06-Nov MoU for stud
06-Nov MoU for stud
CNPC
(30%),
Petropars
Heads of
Total 50%
19.5%
South Pars Phase 11
South Pars Phase 11
08-Nov
None
CNPC
(30%),
Petropars
Total 50%
19.5%
ONO
None
16-Nov
Per as consortium None
23-Nov
Shadegan I Rag-e Sefid /
08-Nov
16-Nov
23-Nov
Shadegan I Rag-e Sefid /
Parsi
ONO
None
Per as consortium None
Schlumber er
Schlumber er
None
None
Parsi
27-Nov MoU for stud
27-Nov MoU for stud
Changuleh / Bala I/
Changuleh / Bala I/
PTTEP
PTTEP
None
None
Dalam eri
Dalam eri
06-Dec MoU for stud
06-Dec MoU for stud
South
Azedagan/Yadavaran/Kish
Shell
South
Azedagan/Yadavaran/Kish
Gas
Shell
None
None
Gas
07-Dec MoU for stud
07-Dec MoU for stud
Changuleh / Cheshmeh
Changuleh / Cheshmeh
Khosh
Gaz ram Nefl
Gaz ram Nefl
None
None
Khosh
13-Dec MoU for stud
13-Dec MoU for stud
South Azadegan I
South Azadegan I
Petronas
Petronas
None
None
Cheshmeh Khosh
Cheshmeh Khosh
22-Dec Mou for stud
22-Dec Mou for stud
Source: Energy Aspects
· Iran Petroleum Contract (see below)
Source: Energy Aspects
· Iran Petroleum Contract (see below)
The domestic power play: striking a balance
The domestic power play: striking a balance
The take-off of Iranian energy is hampered by complex politics. as well as low oil prices and ample
supply in international energy. This is the case both domestically and internationally.
The take-off of Iranian energy is hampered by complex politics, as well as low oil prices and ample
supply in international energy. This is the case both domestically and internationally.
The implementation of the JCPOA occurs against the backdrop of intensive political struggle inside
The implementation of the JCPOA occurs against the backdrop of intensive political struggle inside
Iran. Various factions compete over power, as well as over the future course of the country.
Iran. Various factions compete over power, as well as over the future course of the country.
Somewhat simplified, there are two larger groups. On the one hand, President Hassan Rohani and
his rather moderate government aim at the political and economic re-integration of Iran into the
international community. The administration is convinced that isolation and a confrontational stance
towards international powers, which triggered sanctions during the Ahmadinejad presidency, neither
protects the Islamic Republic nor lets
Somewhat simplified, there are two larger groups. On the one hand, President Hassan Rohani and
his rather moderate government aim at the political and economic re-integration of Iran into the
international community. The administration is convinced that isolation and a confrontational stance
towards international powers, which triggered sanctions during the Ahmadinejad presidency, neither
protects the Islamic Republic nor lets ii grasp its economic potential.
it grasp its economic potential.
In the 2013 presidential
In the 2013 presidential
elections, Rohani won on a ticket promising both a nuclear deal as well as economic recovery. On the
other hand there are more conservative actors, who are close to Supreme Leader Ayatollah Ali
Khamenei and the IRGC. Arguing that international powers, in particular the US, are inherently hostile
to the Islamic Republic, this group perceives international co-operation as leading to vulnerability.
elections, Rohani won on a ticket promising both a nuclear deal as well as economic recovery. On the
other hand there are more conservative actors, who are close to Supreme Leader Ayatollah Ali
Khamenei and the IRGC. Arguing that international powers, in particular the US, are inherently hostile
to the Islamic Republic, this group perceives international co-operation as leading to vulnerability.
Energy_Aspects. Middle East and Africa Quarter'y_December issue. 2016
Energy Aspects. Middle East and Africa Quarterly_December issue. 2016
4
4
The contents of this paper are the author's sole responsibility. They do not necessarily represent the views
of the Oxford Institute for Energy Studies or any of its Members.
The contents of this paper are the author's sole responsibility. They do not necessarily represent the views
of the Oxford Institute for Energy Studies or any of its Members.
- 24 -

E3
mI
Accordingly, the 'resistance economy' ought to be expanded and international co-operation should be
limited to the absolute necessary minimum.
Accordingly, the 'resistance economy' ought to be expanded and international co-operation should be
limited to the absolute necessary minimum.
In a sense, the struggle between the two camps is also a reflection of different benefits from sanctions
and from sanctions-relief, respectively, for each side. The Rohani administration
In a sense, the struggle between the two camps is also a reflection of different benefits from sanctions
and from sanctions-relief, respectively, for each side. The Rohani administration
is challenged to
is challenged to
show the Iranian people that the JCPOA is advantageous for the country. In other words, the position
of the government can be expected to strengthen the more the economy grows following sanctions
relief. The conservatives, and especially
show the Iranian people that the JCPOA is advantageous for the country. In other words, the position
of the government can be expected to strengthen the more the economy grows following sanctions
relief. The conservatives, and especially
IRGC-affiliated entities, however, have substantially
IRGC-affiliated entities, however, have substantially
benefited from sanctions.
benefited from sanctions.
In the absence of competition from abroad, their economic -- and
In the absence of competition from abroad, their economic -- and
subsequently also political -- position has improved. This group can only be expected to approve
JCPOA-facilitated international economic co-operation if this does not erode its economic position.
subsequently also political -- position has improved. This group can only be expected to approve
JCPOA-facilitated international economic co-operation if this does not erode its economic position.
As Iran's political system is constraining the authority of the government (there
As Iran's political system is constraining the authority of the government (there
is theologically
is theologically
legitimized oversight of republican-style institutions), the power struggle between the two groups is
essentially affecting all policy fields -- especially the energy sector. Here,
it is further enhanced by
legitimized oversight of republican-style institutions), the power struggle between the two groups is
essentially affecting all policy fields -- especially the energy sector. Here, it is further enhanced by
rivalries for control over the industry as well as by competing economic interests.
rivalries for control over the industry as well as by competing economic interests.
Traditionally, NIOC and its subsidiaries were in charge of running the Iranian energy industry. NIOC is
controlled by the Ministry of Petroleum and thus by the government. During the Ahmadinejad
presidency, however, the IRGC entered the energy sector. In 2011, President Ahmadinejad (himself a
former IRGC member) even appointed Rostam Ghasemi (the head of Khatam-al Anbiya, the IRGC's
business conglomerate) as petroleum minister. Courted by the government, the
Traditionally, NIOC and its subsidiaries were in charge of running the Iranian energy industry. NIOC is
controlled by the Ministry of Petroleum and thus by the government. During the Ahmadinejad
presidency, however, the IRGC entered the energy sector. In 2011, President Ahmadinejad (himself a
former IRGC member) even appointed Rostam Ghasemi (the head of Khatam-al Anbiya, the IRGC's
business conglomerate) as petroleum minister. Courted by the government, the
IRGC sought to
IRGC sought to
replace the void left behind by Western IOCs leaving the country.
By 2013, when President Rohani assumed office, the IRGC had established a strong foothold in the
energy industry. Rohani replaced Ghasemi with the experienced and technocrat-minded Bijan
Zanganeh, who had already served as minister of petroleum (1997--2005) and minister of energy
(1988-97). But the presence of IRGC-affiliated businesses was not easily undone. While trying to
tame the IRGC -- efforts included the use of public pledges to act against corruption in what appeared
to be a reference to the guards
8
- the Rohani administration still had to find a modus vivendi. Some
replace the void left behind by Western IOCs leaving the country.
By 2013, when President Rohani assumed office, the IRGC had established a strong foothold in the
energy industry. Rohani replaced Ghasemi with the experienced and technocrat-minded Bijan
Zanganeh, who had already served as minister of petroleum (1997--2005) and minister of energy
(1988-97). But the presence of IRGC-affiliated businesses was not easily undone. While trying to
tame the IRGC -- efforts included the use of public pledges to act against corruption in what appeared
to be a reference to the guards
8
- the Rohani administration still had to find a modus vivendi. Some
form of consensus, especially in order to realize a new petroleum law, the Iran Petroleum Contract
(IPC), was indispensable. Through the IPC, the Rohani administration
is seeking to offer more
form of consensus, especially in order to realize a new petroleum law, the Iran Petroleum Contract
(IPC), was indispensable. Through the IPC, the Rohani administration
is seeking to offer more
attractive terms to IOCs, which have frequently complained about the commercial unattractiveness of
the existing buyback scheme. The IPC draft, however, required approval by the Par1iament
9
and
attractive terms to IOCs, which have frequently complained about the commercial unattractiveness of
the existing buyback scheme. The IPC draft, however, required approval by the Par1iament
9
and
therefore also by the -- de facto Supreme Leader-controlled -- Guardian Council. Thus, President
Rohani and Petroleum Minister Zanganeh had to strike a balance. Both in terms of policy as well as
business benefits, the interests of the conservative camp and the IRGC needed to be accommodated.
therefore also by the -- de facto Supreme Leader-controlled -- Guardian Council. Thus, President
Rohani and Petroleum Minister Zanganeh had to strike a balance. Both in terms of policy as well as
business benefits, the interests of the conservative camp and the IRGC needed to be accommodated.
The IPC framework legislation, which found parliamentary approval in September 2016, reflects the
attempt to do so. On the one hand, the IPC seeks to offer attractive terms to IOCs. In contrast to the
buyback scheme, the IPC allows for the booking of reserves. Remuneration is more flexible and is
possible not only in cash but also through physical barrels. On the other hand, the IPC takes into
account concerns of the conservatives (as well as the strict Iranian constitution). Foreign ownership of
reserves is still not allowed. In order to boost domestic capacity building, IOCs must partner with an
Iranian company. This, moreover, also ensures that Iranian businesses (and their stakeholders) are
directly involved in the development of Iranian oil and natural gas. As such, the IPC seeks to reconcile
the somewhat conflicting 'international co-operation' and 'resistance economy' agendas.
The IPC framework legislation, which found parliamentary approval in September 2016, reflects the
attempt to do so. On the one hand, the IPC seeks to offer attractive terms to IOCs. In contrast to the
buyback scheme, the IPC allows for the booking of reserves. Remuneration is more flexible and is
possible not only in cash but also through physical barrels. On the other hand, the IPC takes into
account concerns of the conservatives (as well as the strict Iranian constitution). Foreign ownership of
reserves is still not allowed. In order to boost domestic capacity building, IOCs must partner with an
Iranian company. This, moreover, also ensures that Iranian businesses (and their stakeholders) are
directly involved in the development of Iranian oil and natural gas. As such, the IPC seeks to reconcile
the somewhat conflicting 'international co-operation' and 'resistance economy' agendas.
However, beyond the IPC framework legislation, thus far no final contracts have been concluded.
Senior conservatives are accusing the government of harming the 'resistance economy'.19 Tensions
over the matter remain high, as each side jockeys for influence. As of January 2017 it appears as if,
rather than following a single comprehensive approach, the terms will be negotiated separately, case
However, beyond the IPC framework legislation, thus far no final contracts have been concluded.
Senior conservatives are accusing the government of harming the 'resistance economy'.19 Tensions
over the matter remain high, as each side jockeys for influence. As of January 2017 it appears as if,
rather than following a single comprehensive approach, the terms will be negotiated separately, case
8
Karami, Arash: 'Rouhani criticizes consolidation of power in government', Al-Monitor, 2014.
8
Karami, Arash: 'Rouhani criticizes consolidation of power in government', Al-Monitor, 2014.
° In mid-2016, there was a debate in Iran whether the IPC would actually require parliamentary approval. Eventually, the IPC
was presented to the parliament.
9
In mid-2016, there was a debate in Iran whether the IPC would actually require parliamentary approval. Eventually, the IPC
was presented to the parliament.
O
E.g. Mohsen Rezaee, Secretary General of the Expediency Discernment Council, see Mashregh News: 'Rezaee: oil
O
E.g. Mohsen Rezaee, Secretary General of the Expediency Discernment Council, see Mashregh News: 'Rezaee: oil
contracts are against the resistance economy and very dangerous' (in Farsi), 22 August 2016
contracts are against the resistance economy and very dangerous' (in Farsi), 22 August 2016.
5
5
The contents of this paper are the author's sole responsibility. They do not necessarily represent the views
The contents of this paper are the author's sole responsibility. They do not necessarily represent the views
of the Oxford Institute for Energy Studies or any of its Members.
of the Oxford Institute for Energy Studies or any of its Members.
- 25 -

by case. In other words, President Rohani's attempt to strike a balance continues as the government
seeks to reconcile seemingly diverging interests.
by case. In other words, President Rohan i's attempt to strike a balance continues as the government
seeks to reconcile seemingly diverging interests.
Beyond legislation, the Rohani administration is also reaching out to the conservatives in terms of
business. Speaking to an audience of IRGC members, Petroleum Minister Zanganeh suggested that
the IRGC's business holding, Khatam-al Anbiya, could have an 'important position' as part of the IPC.
Next to detailing how the IRGC could be involved, the minister declared that more than half of the new
oil contracts would be awarded to Iranian companies.
11
Beyond legislation, the Rohani administration is also reaching out to the conservatives in terms of
business. Speaking to an audience of IRGC members, Petroleum Minister Zanganeh suggested that
the IRGC's business holding, Khatam-al Anbiya, could have an 'important position' as part of the IPC.
Next to detailing how the IRGC could be involved, the minister declared that more than half of the new
oil contracts would be awarded to Iranian companies.
11
The government's outreach to the conservatives and the IRGC has already translated into action. It
was not an IOC that was awarded the first oil contract after the introduction of the IPC framework
legislation, but a company affiliated with the conservatives -- the Persia Oil and Gas Industry
Development Company (POGIDC). In October 2016, NIOC signed a deal with POGIDC on the
development of four oil fields. POGIDC is a subsidiary of Setade Ejraye Farmane Emam, a business
holding overseen by Supreme Leader Khamenei.
The government's outreach to the conservatives and the IRGC has already translated into action. It
was not an IOC that was awarded the first oil contract after the introduction of the IPC framework
legislation, but a company affiliated with the conservatives -- the Persia Oil and Gas Industry
Development Company (POGIDC). In October 2016, NIOC signed a deal with POGIDC on the
development of four oil fields. POGIDC is a subsidiary of Setade Ejraye Farmane Emam, a business
holding overseen by Supreme Leader Khamenei.
Earlier, in July 2016, the Ministry of Petroleum published a list of local companies eligible to apply for
international co-operation under the IPC. Among the eight companies that received clearance from
the government, three have direct links to conservatives and/or the IRGC (in addition to Khatam-al
Anbiya and POGIDC, the Industrial Development and Renovation Organisation is also included). By
getting the conservatives on board, it appears that the Rohani administration has succeeded in paving
the way for the
IPC to move forward.
Importantly in this context, the
IPC framework
legislation
Earlier, in July 2016, the Ministry of Petroleum published a list of local companies eligible to apply for
international co-operation under the IPC. Among the eight companies that received clearance from
the government, three have direct links to conservatives and/or the IRGC (in addition to Khatam-al
Anbiya and POGIDC, the Industrial Development and Renovation Organisation is also included). By
getting the conservatives on board, it appears that the Rohani administration has succeeded in paving
the way for the
IPC to move forward.
Importantly in this context, the
IPC framework legislation
stipulates that the Ministry of Petroleum will need to approve the credentials of both domestic
companies and IOCs willing to engage in Iran. Thereby, the government will effectively (continue to)
be the gatekeeper of the Iranian energy
industry. While striking a balance to accommodate the
stipulates that the Ministry of Petroleum will need to approve the credentials of both domestic
companies and IOCs willing to engage in Iran. Thereby, the government will effectively (continue to)
be the gatekeeper of the Iranian energy
industry. While striking a balance to accommodate the
interests of the conservatives and the IRGC, the government remains in control.
interests of the conservatives and the IRGC, the government remains in control.
International co-operation: hedging the bets
International co-operation: hedging the bets
This is also the case when it comes to international co-operation. Not dissimilar from the domestic
situation, the Rohani government seeks to balance multiple interests. While pondering political and
economic opportunities and risks, Iran is trying to diversify its commitments.
This is also the case when it comes to international co-operation. Not dissimilar from the domestic
situation, the Rohani government seeks to balance multiple interests. While pondering political and
economic opportunities and risks, Iran is trying to diversify its commitments.
Iran's energy industry is in dire need of investment. The blow from sanctions during recent years was
preceded by, arguably, decades of under investment due to rather unattractive fiscal terms under the
buyback scheme. Petroleum Minister Zanganeh has suggested that Iran's energy industry requires
investments of $100 billion and more."
Iran's energy industry is in dire need of investment. The blow from sanctions during recent years was
preceded by, arguably, decades of under investment due to rather unattractive fiscal terms under the
buyback scheme. Petroleum Minister Zanganeh has suggested that Iran's energy industry requires
investments of $100 billion and more."
The implementation of the JCPOA in January 2016 has opened the door for international co-operation
in Iran's energy sector, as discussed above. In parallel to concluding and implementing the JCPOA,
Iranian officials have invited international businesses to the country. Since the JCPOA was agreed in
July 2015, Tehran has been frequented by multiple high-ranking political and business delegations.
From Europe (amongst others) the EU's Foreign Affairs Representative Federica Mogherini, France's
Foreign and Agriculture Ministers Laurent Fabius and Stephane Le Foll, Germany's Foreign and
Economy Ministers Frank-Walter Steinmeier and Sigmar Gabriel, Italy's then Prime Minister Matteo
Renzi, and the UK's Foreign Secretary Philip Hammond have all visrted Iran. The warming of political
relations has already translated into the signing of several contracts; these include high profile deals
with Airbus, Boeing, Peugeot--Citroen, Renault, and Siemens.
The implementation of the JCPOA in January 2016 has opened the door for international co-operation
in Iran's energy sector, as discussed above. In parallel to concluding and implementing the JCPOA,
Iranian officials have invited international businesses to the country. Since the JCPOA was agreed in
July 2015, Tehran has been frequented by multiple high-ranking political and business delegations.
From Europe (amongst others) the EU's Foreign Affairs Representative Federica Mogherini, France's
Foreign and Agriculture Ministers Laurent Fabius and Stephane Le Foll, Germany's Foreign and
Economy Ministers Frank-Walter Steinmeier and Sigmar Gabriel, Italy's then Prime Minister Matteo
Renzi, and the UK's Foreign Secretary Philip Hammond have all visited Iran. The warming of political
relations has already translated into the signing of several contracts; these include high profile deals
with Airbus, Boeing, Peugeot--Citroen, Renault, and Siemens.
The Iranian energy sector has also attracted worldwide attention. Teheran has received dozens of
IOCs, expressing interest and exploring opportunities. This has resulted in the signing of several
preliminary agreements (see Table 1 ). However, unlike the situation
in other branches of the
The Iranian energy sector has also attracted worldwide attention. Teheran has received dozens of
IOCs, expressing interest and exploring opportunities. This has resulted in the signing of several
preliminary agreements (see Table 1). However, unlike the situation
in other branches of the
economy, no contracts have yet been concluded in the Iranian energy sector. Against this backdrop,
economy, no contracts have yet been concluded in the Iranian energy sector. Against this backdrop,
Fars News: 'Necessity of the presence of the headquarters [short version of Khatam al-Anbiya's full name in Farsi] in new oil
'Fars News: 'Necessity of the presence of the headquarters [short version of Khatam al-Anbiya's full name in Farsi] in new oil
contracts' (in Farsi), 12 December 2016.
contracts' (in Farsi), 12 December 2016.
Upstream 'Iran reveals locals listed for foreign partnerships', 8 July 2016
Upstream. 'ran reveals locals listed for foreign partnerships', 8 July 2016
IRNA 'Zanganeh $100bn investment in upstream oil industry_needed'. 4 October 2016
?IRNA 'Zanganeh $100bn investment in upstream oil industry_needed' 4 October 2016
6
6
The contents of this paper are the author's sole responsibility. They do not necessarily represent the views
of the Oxford Institute for Energy Studies or any of its Members.
The contents of this paper are the author's sole responsibility. They do not necessarily represent the views
of the Oxford Institute for Energy Studies or any of its Members.
- 26 -

Iran seeks to finalize contracts with IOCs, aiming to bring investment and technology to the country. In
doing so, the government seeks to realize several objectives.
Iran seeks to finalize contracts with IOCs, aiming to bring investment and technology to the country. In
doing so, the government seeks to realize several objectives.
Generally, Tehran's approach to
Generally, Tehran's approach to
international co-operation appears to be driven by the desire to
international co-operation appears to be driven by the desire to
diversify engagements: Iran is hedging its bets. Rather than focusing on co-operation with European
IOCs, which are now allowed back to the country and offer the latest technology, Tehran is in talks
with companies from both the East and the West. A list recently released by NIOC details the IOCs
allowed to bid for oil and natural gas projects under the IPC in the upcoming first tender. While
European IOCs (including some majors) are featured, more than half the companies are from Asia
and Russia (see Table 2).
diversify engagements: Iran is hedging its bets. Rather than focusing on co-operation with European
IOCs, which are now allowed back to the country and offer the latest technology, Tehran is in talks
with companies from both the East and the West. A list recently released by NIOC details the IOCs
allowed to bid for oil and natural gas projects under the IPC in the upcoming first tender. While
European IOCs (including some majors) are featured, more than half the companies are from Asia
and Russia (see Table 2).
Table 2: IOCs certified to bid at Iran's upcoming oil and natural gas tender
CNOOC (China)
Lukoil (Russia)
Posco Daewoo (South Korea)
Table 2: IOCs certified to bid at Iran's upcoming oil and natural gas tender
CNOOC (China)
Lukoil (Russia)
Posco Daewoo (South Korea)
CNPC (China)
CNPC (China)
PTTEP (Thailand)
Schlumberger
CNPW (China)
Maersk (Denmark)
Maersk (Denmark)
Mitsubishi (Japan)
(Netherlands/US)
PTTEP (Thailand)
Schlumberger
CNPW (China)
Mitsubishi (Japan)
(Netherlands/US)
ONO (Norway)
Eni (Italy)
Gazprom (Russia)
Inpex (Japan)
ITOCHU (Japan)
Korea Gas Corporation (South
Korea
ONO (Norway)
Eni (Italy)
Gazprom (Russia)
Inpex (Japan)
ITOCHU (Japan)
Korea Gas Corporation (South
Korea
OMV (Austria)
ONGC Videsh (India)
Perenco (France/UK)
Pertamina (Indonesia)
PGNiG (Poland)
Plus Petrol (Argentina)
OMV (Austria)
ONGC Videsh (India)
Perenco (France/UK)
Pertamina (Indonesia)
PGNiG (Poland)
Plus Petrol (Argentina)
Shell (Netherlands/UK)
Sinopec (China)
Total (France)
Wintershall (Germany)
Shell (Netherlands/UK)
Sinopec (China)
Total (France)
Wintershall (Germany)
Source: NIOC
14
Source. NIOC''
In this way, Iran is apparently trying to establish a diversified position in light of complex international
politics. Experience shows that EU sanctions inflicted harm on Iran's energy sector in the early 2010s.
At the time, Chinese companies in particular, remained in Iran. Although complaints about their rather
poor performance can be widely heard
in Iran, Asian companies nevertheless have contributed to
In this way, Iran is apparently trying to establish a diversified position in light of complex international
politics. Experience shows that EU sanctions inflicted harm on Iran's energy sector in the early 201 Os.
At the time, Chinese companies in particular, remained in Iran. Although complaints about their rather
poor performance can be widely heard
in Iran, Asian companies nevertheless have contributed to
keeping the
keeping the
Iranian energy industry going. By inviting them into the energy sector (and to other
Iranian energy industry going. By inviting them into the energy sector (and to other
branches of the economy), Iran is partly honouring these countries' loyalty during the sanctions years.
During a visit to Beijing in April 2015, three months before the JCPOA was agreed, Petroleum
Minister Zanganeh declared that China 'has been greatly cooperating with the Islamic Republic under
branches of the economy), Iran is partly honouring these countries' loyalty during the sanctions years.
During a visit to Beijing in April 2015, three months before the JCPOA was agreed, Petroleum
Minister Zanganeh declared that China 'has been greatly cooperating with the Islamic Republic under
conditions of sanctions and we are willing for that cooperation to continue when sanctions are
conditions of sanctions and we are willing for that cooperation to continue when sanctions are
removed'."°
removed'.
15
The inclusion of China and Russia, however, is more than a mere expression of gratitude.
In both
cases, energy companies are state-owned or closely linked to the state. By bringing in Chinese and
The inclusion of China and Russia, however, is more than a mere expression of gratitude. In both
cases, energy companies are state-owned or closely linked to the state. By bringing in Chinese and
Russian companies, Iran is also deepening relations with the countries' governments. In a broader
Russian companies, Iran is also deepening relations with the countries' governments.
In a broader
sense, the energy sector is thereby included in what can be described as a more fundamental
deepening of Tehran's political and economic relations with Beijing and Moscow -- a major trend in
recent years. This helps Iran to protect itself against a one-sided dependency on Europeans in
particular, and the West in general. As of today, the EU and key member states are fully endorsing
the JCPOA, considering it to be a rare example of successful European diplomacy. With the Trump
sense, the energy sector is thereby included in what can be described as a more fundamental
deepening of Tehran's political and economic relations with Beijing and Moscow -- a major trend in
recent years. This helps Iran to protect itself against a one-sided dependency on Europeans in
particular, and the West in general. As of today, the EU and key member states are fully endorsing
the JCPOA, considering it to be a rare example of successful European diplomacy. With the Trump
administration about to take over in Washington, however, the future of Iran-US relations is unknown.
administration about to take over in Washington, however, the future of Iran-US relations is unknown.
Even if Europe continues supporting the JCPOA there could still be consequences for EU-Iran
business relations, especially in light of possibly increased extraterritorial application of US laws.
There is also the possibility of new US sanctions or, in the worst case, a withdrawal of the US from
the JCPOA. Should Iran and European IOCs co-operate, there would certainly be problems in the
Even if Europe continues supporting the JCPOA there could still be consequences for EU-Iran
business relations, especially in light of possibly increased extraterritorial application of US laws.
There is also the possibility of new US sanctions or, in the worst case, a withdrawal of the US from
the JCPOA. Should Iran and European IOCs co-operate, there would certainly be problems in the
event of worsening
event of worsening
Iran-US relations.
Iran-US relations.
In any such scenario, co-operation with China and Russia,
In any such scenario, co-operation with China and Russia,
which would be affected less, could somehow act as a buffer for Iran.
which would be affected less, could somehow act as a buffer for Iran.
• NIOC: 'List of Qualified Applicants', National Iranian Oil Company, Tehran, 2016
• NIOC 'List of Qualified Applicants', National Iranian Oil Company, Tehran, 2016.
PressT. 'Iran. China to increase energy_ cooperation when sanctions removed Zanganeh', 10 April 2015
•pressTv 'Iran. China to increase energy_cooperation when sanctions removed. Zanganeh', 10 April 2015
7
7
The contents of this paper are the author's sole responsibility. They do not necessarily represent the views
of the Oxford Institute for Energy Studies or any of its Members.
The contents of this paper are the author's sole responsibility. They do not necessarily represent the views
of the Oxford Institute for Energy Studies or any of its Members.
- 27 -

In short, it seems that Tehran is not only considering business variables in the narrow sense of the
term, but is also including geopolitical reasoning in its calculations. As such, European IOCs are
welcomed, albeit not at the expense of recently deepened ties with Asia, China, and Russia, in
particular.
In short, it seems that Tehran is not only considering business variables in the narrow sense of the
term, but is also including geopolitical reasoning
in its calculations. As such, European IOCs are
welcomed, albeit not at the expense of recently deepened ties with Asia, China, and Russia, in
particular.
In terms of concrete goals,
In terms of concrete goals,
in the short term
in the short term
Iran is keen to achieve symbolic successes in
Iran is keen to achieve symbolic successes in
international energy. President Rohani, who is seeking re-election in May 2017, will need to present
the Iranian people with some benefits from the JCPOA. Hardliners have accused the government of
surrendering nuclear rights without adequate compensation. After delivering on the promise of
negotiating a nuclear deal, Rohani will now need to fulfil his second 2013 campaign promise:
economic recovery. While the country is back on the path of growth, and inflation has been somewhat
controlled, most Iranians are still waiting to see their personal situation
international energy. President Rohani, who is seeking re-election in May 2017, will need to present
the Iranian people with some benefits from the JCPOA. Hardliners have accused the government of
surrendering nuclear rights without adequate compensation. After delivering on the promise of
improve. Lasting and
negotiating a nuclear deal, Rohani will now need to fulfil his second 2013 campaign promise:
economic recovery. While the country is back on the path of growth, and inflation has been somewhat
controlled, most Iranians are still waiting to see their personal situation
improve. Lasting and
comprehensive progress will certainly require more time, as the country has only just begun to
comprehensive progress will certainly require more time, as the country has only just begun to
recover from sanctions: symbolic achievements are of great significance
recover from sanctions: symbolic achievements are of great significance
if the government is to
if the government is to
expand international business ties.
In the energy sector, to this end, Iran has quickly sought to re-establish its pre-sanctions position. By
expand international business ties.
In the energy sector, to this end, Iran has quickly sought to re-establish its pre-sanctions position. By
ramping up production, market shares were prioritized over revenue considerations. While
Iran's
ramping up production, market shares were prioritized over revenue considerations. While Iran's
government budget was suffering from low oil prices, it does not appear plausible that the defining
motivation was to increase oil income in the short term. Compared with other oil producers, Iran is in a
somewhat better position to endure low oil prices due to: a smaller share of oil revenue in the
government budget and GDP, a positive non-oil trade balance, and (growing) economic activity
outside the energy sector, as well as access to billions of (previously blocked) US dollars in
international banks, as part of JCPOA implementation."°
government budget was suffering from low oil prices, it does not appear plausible that the defining
motivation was to increase oil income in the short term. Compared with other oil producers, Iran is in a
somewhat better position to endure low oil prices due to: a smaller share of oil revenue in the
government budget and GDP, a positive non-oil trade balance, and (growing) economic activity
outside the energy sector, as well as access to billions of (previously blocked) US dollars in
international banks, as part of JCPOA implementation.
16
Similar to the move back to its pre-sanctions position, Iran's OPEC policy is also of great symbolic
importance. The November 2016 OPEC deal exempted Iran from production cuts and acknowledged
pre-sanctions output levels as Iran's reference production. OPEC thereby implicitly confirmed Iran's
claim that the lower production under sanctions was not normal or, in the Iranians' words, 'unjust'. As
Similar to the move back to its pre-sanctions position, Iran's OPEC policy is also of great symbolic
importance. The November 2016 OPEC deal exempted Iran from production cuts and acknowledged
pre-sanctions output levels as Iran's reference production. OPEC thereby implicitly confirmed Iran's
claim that the lower production under sanctions was not normal or, in the Iranians' words, 'unjust'. As
a result,
a result,
Iran is allowed to slightly increase production while major rival Saudi Arabia, non-OPEC
Iran is allowed to slightly increase production while major rival Saudi Arabia, non-OPEC
producer Russia, and others are cutting output. In Iran, this was celebrated as a major victory for the
Iranian OPEC delegation led by Petroleum Minister Zanganeh. Media outlets even went so far as to
enthusiastically celebrate the OPEC deal as an 'oil JCPOA'.'
producer Russia, and others are cutting output. In Iran, this was celebrated as a major victory for the
Iranian OPEC delegation led by Petroleum Minister Zanganeh. Media outlets even went so far as to
enthusiastically celebrate the OPEC deal as an 'oil JCPOA'.'
For Iran's government, eager to show to the public that the JCPOA is advantageous for Iran, this
outcome of the OPEC deal
For Iran's government, eager to show to the public that the JCPOA is advantageous for Iran, this
outcome of the OPEC deal
is important regardless of its economic merits. The country has
is important regardless of its economic merits. The country has
successfully re-established
successfully re-established
its pre-sanctions position and was able to negotiate an exemption from
its pre-sanctions position and was able to negotiate an exemption from
OPEC, despite months of opposition to this in Riyadh. Thereby, not without grounds, Iran has
demonstrated that it is back in the business of global energy.
OPEC, despite months of opposition to this in Riyadh. Thereby, not without grounds, Iran has
demonstrated that it is back in the business of global energy.
This message is significant for Iran in order to achieve its more long-term objectives. To utilize the full
potential of its energy riches, Tehran will need to attract international investment and technology.
Otherwise, the Iranian energy sector will remain underdeveloped as the country holds the world's
largest combined reserves of oil and natural gas (13 per cent of global total) but only accounts for
some 4.7 per cent of worldwide production."°
This message is significant for Iran in order to achieve its more long-term objectives. To utilize the full
potential of its energy riches, Tehran will need to attract international investment and technology.
Otherwise, the Iranian energy sector will remain underdeveloped as the country holds the world's
largest combined reserves of oil and natural gas (13 per cent of global total) but only accounts for
some 4.7 per cent of worldwide production."°
A comeback with hurdles: the way forward
A comeback with hurdles: the way forward
The implementation of the JCPOA in January 2016 has opened the door for Iran to return to
international energy markets. President Rohani is trying to seize this opportunity. At home, a new
petroleum law was introduced. In parallel, the government seeks to strike a balance in an attempt to
secure the support of the more conservative elements of the Islamic Republic. Internationally, Tehran
The implementation of the JCPOA in January 2016 has opened the door for Iran to return to
international energy markets. President Rohani is trying to seize this opportunity. At home, a new
petroleum law was introduced. In parallel, the government seeks to strike a balance in an attempt to
secure the support of the more conservative elements of the Islamic Republic. Internationally, Tehran
9 Jalilvand, David Ramin: '5 reasons Iran will be able to wait out low oil prices', AL-Monitor, 2016.
9 Jalilvand, David Ramin: '5 reasons Iran will be able to wait out low oil prices', AL-Monitor, 2016.
17
'Barjame nafti'-- in reference to the Iranian acronym for the JCPOA. See Khabar Online: 'Oil diplomacy realised oil Barjam',
17
'Barjame nafti'-- in reference to the Iranian acronym for the JCPOA. See Khabar Online: 'Oil diplomacy realised oil Barjam',
(in Farsi), 1 December 2016
(in Farsi), 1 December 2016
+ Figures for 2015.see BP. BP Statistical Review of World Energy June 2016.London, 2016
• Figures for 2015.see BP. BP Statistical Review of World Energy June 2016.London. 2016
8
8
The contents of this paper are the author's sole responsibility. They do not necessarily represent the views
of the Oxford Institute for Energy Studies or any of its Members.
The contents of this paper are the author's sole responsibility. They do not necessarily represent the views
of the Oxford Institute for Energy Studies or any of its Members.
- 28 -

E3
mI
is hedging its bets. Aiming at the diversification of engagements, Iran is trying to reduce potential
damage in the event of new troubles in its relations with the West.
is hedging its bets. Aiming at the diversification of engagements, Iran is trying to reduce potential
damage in the event of new troubles in its relations with the West.
While doing so, by reaching out to IOCs, Iran's energy policy seeks to realize several objectives.
International co-operation will help to maintain output at oil fields already in production. Many of Iran's
oil fields are mature and require enhanced recovery techniques.
While doing so, by reaching out to IOCs, Iran's energy policy seeks to realize several objectives.
International co-operation will help to maintain output at oil fields already in production. Many of Iran's
oil fields are mature and require enhanced recovery techniques.
19
Furthermore, Iran is keen to ramp
up production at shared oil and natural gas fields.
19
Furthermore, Iran is keen to ramp
up production at shared oil and natural gas fields.
In many cases, neighbouring countries are
In many cases, neighbouring countries are
producing at faster rates thanks to IOC support. At the same time, international co-operation should
also contribute to the transfer of technology and domestic capacity building, both
in upstream and
producing at faster rates thanks to IOC support. At the same time, international co-operation should
also contribute to the transfer of technology and domestic capacity building, both
in upstream and
downstream. These changes are accompanied by the continuation of the increased domestic use of
energy. While trying to expand domestic wealth creation (in other words economic growth) as well as
reducing dependence on international markets and politics, Iran will especially encourage domestic
consumption of natural gas. It is hoped that once domestic consumption is reined in, Iran can also be
expected to attempt to achieve the completion of LNG export terminals, with IOC support.
downstream. These changes are accompanied by the continuation of the increased domestic use of
energy. While trying to expand domestic wealth creation (in other words economic growth) as well as
reducing dependence on international markets and politics, Iran will especially encourage domestic
consumption of natural gas. It is hoped that once domestic consumption is reined in, Iran can also be
expected to attempt to achieve the completion of LNG export terminals, with IOC support.
The comeback of Iran to
The comeback of Iran to
international energy, however, faces hurdles: political and economic
international energy, however, faces hurdles: political and economic
uncertainty is looming.
Domestically, the final design of the
IPC remains unclear until the first contracts with
IOCs are
uncertainty is looming.
Domestically, the final design of the
IPC remains unclear until the first contracts with
IOCs are
eventually signed. Only then will it become clear whether and how the Rohani government's attempt
at striking a balance will succeed. In this context, the involvement of the IRGC, which appears to be a
necessity for domestic political reasons, is raising concerns internationally.
In order not to violate EU
and US sanctions, the government will need to find some modus operandi which allows the IRGC to
have their share in the energy sector without affecting the engagements of IOCs. In other words, the
presence of IOCs and the IRGC will need to be clearly separated -- while both engage in the Iranian
energy sector.
eventually signed. Only then will it become clear whether and how the Rohani government's attempt
at striking a balance will succeed. In this context, the involvement of the IRGC, which appears to be a
necessity for domestic political reasons, is raising concerns internationally. In order not to violate EU
and US sanctions, the government will need to find some modus operandi which allows the IRGC to
have their share in the energy sector without affecting the engagements of IOCs. In other words, the
presence of IOCs and the IRGC will need to be clearly separated -- while both engage in the Iranian
energy sector.
Finally, incoming US President Donald Trump is casting a shadow over Iran's energy sector as part of
a broader uncertainty regarding the future of Iran-US relations and the implementation of the
JCPOA.2 Both before and after the US presidential elections, the current President-elect Trump has
expressed his disapproval of the JCPOA in strong terms. At this point, the actual course of future US
policy towards Iran is unclear and it would be premature to conclude that a fundamental re-orientation
will happen. Nevertheless, uncertainty has significantly increased with regard to the future of the
JCPOA, with potential consequences for Europeans and others engaged in Iran's energy sector.
Finally, incoming US President Donald Trump is casting a shadow over Iran's energy sector as part of
a broader uncertainty regarding the future of Iran-US relations and the
implementation of the
JCPOA.2 Both before and after the US presidential elections, the current President-elect Trump has
expressed his disapproval of the JCPOA in strong terms. At this point, the actual course of future US
policy towards Iran is unclear and it would be premature to conclude that a fundamental re-orientation
will happen. Nevertheless, uncertainty has significantly increased with regard to the future of the
JCPOA, with potential consequences for Europeans and others engaged in Iran's energy sector.
Navigating the complex domestic and international politics which define the framework for Iran's
energy sector and the scope of possible international co-operation, the government of President
Rohani can be expected to keep its current approach. Despite uncertainty over several aspects,
Rohani and Petroleum Minister Zanganeh are fostering Iran's comeback to global energy. While doing
so, they will continue trying to strike a balance at home, while hedging Iran's bets internationally.
Navigating the complex domestic and international politics which define the framework for Iran's
energy sector and the scope of possible international co-operation, the government of President
Rohani can be expected to keep its current approach. Despite uncertainty over several aspects,
Rohani and Petroleum Minister Zanganeh are fostering Iran's comeback to global energy. While doing
so, they will continue trying to strike a balance at home, while hedging Iran's bets internationally.
In Iran, meanwhile, with upcoming presidential elections in May, it remains to be seen if Rohani is
allowed to retain his office and to maintain his approach. Concluding contracts with IOCs, as proof of
the JCPOA's benefits, would certainly help to this end.
In Iran, meanwhile, with upcoming presidential elections in May, it remains to be seen
if Rohani is
allowed to retain his office and to maintain his approach. Concluding contracts with IOCs, as proof of
the JCPOA's benefits, would certainly help to this end.
1e To illustrate this point: in 2011, according to official data, ran re-injected some 31 bcm into maturing oil fields. See OPEC:
1e To illustrate this point: in 2011, according to official data, Iran re-injected some 31 bcm into maturing oil fields. See OPEC:
'Annual Statistical Bulletin', Organization of the Petroleum Exporting Countries, Vienna, 2016.
'Annual Statistical Bulletin', Organization of the Petroleum Exporting Countries, Vienna, 2016.
20
ICG: 'President Trump and the Art of the Iran Nuclear Deal', International Crisis Group, Brussels, 2016.
20
ICG: 'President Trump and the Art of the Iran Nuclear Deal', International Crisis Group, Brussels, 2016.
9
9
The contents of this paper are the author's sole responsibility. They do not necessarily represent the views
The contents of this paper are the author's sole responsibility. They do not necessarily represent the views
of the Oxford Institute for Energy Studies or any of its Members.
of the Oxford Institute for Energy Studies or any of its Members.

- 29 -

- 30 -

Annex 209
Total SA, “Iran: Total and NIOC sign contract for the development of phase 11 of the
giant South Pars gas field”, 3 July 2017

- 31 -

- 32 -

Iran: Total and NIOC sign contract for the development of
phase 11 of the giant South Pars gas field
Iran: Total and NIOC sign contract for the development of
phase 11 of the giant South Pars gas field
total.com/en/media/news/press-releases/iran-total-and-nioc-sign-contract-development-phase-11-giant­
total.com/en/media/news/press-releases/iran-total-and-nioc-sign-contract-development-phase-11-giant­
south-pars-gas-field
south-pars-gas-field
Paris, July 3, 2017- Total and the National Iranian Oil Company (NIOC) have signed a
contract for the development and production of phase 11 of South Pars (SP11), the world's
largest gas field. The project will have a production capacity of 2 billion cubic feet per day or
400,000 barrels of oil equivalent per day including condensate. The produced gas will supply
the Iranian domestic market starting in 2021.
Paris, July 3, 2017 - Total and the National Iranian Oil Company (NIOC) have signed a
contract for the development and production of phase 11 of South Pars (SP11), the world's
largest gas field. The project will have a production capacity of 2 billion cubic feet per day or
400,000 barrels of oil equivalent per day including condensate. The produced gas will supply
the Iranian domestic market starting in 2021.
This contract, which has a 20-year duration, is the first Iranian Petroleum Contract (IPC) and is
based on the technical, contractual and commercial terms as per the Heads of Agreement
signed on November 8, 2016. Total is the operator of the SP11 project with a 50.1 % interest
alongside the Chinese state-owned oil and gas company CNPC (30%), and Petropars (19.9%),
a wholly owned subsidiary of NIOC.
This contract, which has a 20-year duration, is the first Iranian Petroleum Contract (IPC) and is
based on the technical, contractual and commercial terms as per the Heads of Agreement
signed on November 8, 2016. Total is the operator of the SP11 project with a 50.1 % interest
alongside the Chinese state-owned oil and gas company CNPC (30%), and Petropars (19.9%),
a wholly owned subsidiary of NIOC.
'This is a major agreement for Total, which officially marks our return to Iran to open a new page
in the history of our partnership with the country. We are proud and honored to be the first
international company to sign an IPC, which offers an attractive commercial framework, following
the 2015 international nuclear accord (JCPOA) and to therefore contribute to the development of
relations between Europe and Iran. Total will develop the project in strict compliance with
applicable national and international laws", said Patrick Pouyann~, Chairman & CEO of Total.
'This is a major agreement for Total, which officially marks our return to Iran to open a new page
in the history of our partnership with the country. We are proud and honored to be the first
international company to sign an /PC, which offers an attractive commercial framework, following
the 2015 international nuclear accord (JCPOA) and to therefore contribute to the development of
relations between Europe and Iran. Total will develop the project in strict compliance with
applicable national and international laws", said Patrick Pouyann~, Chairman & CEO of Total.
'This project is in line with the Group's strategy to expand its presence in the Middle East and
grow its gas portfolio by adding low cost, long plateau assets."
'This project is in line with the Group's strategy to expand its presence in the Middle East and
grow its gas portfolio by adding low cost, long plateau assets."
SP11 will be developed in two phases. The first phase, with an estimated cost of around 2
billion dollars equivalent, will consist of 30 wells and 2 wellhead platforms connected to
existing onshore treatment facilities by 2 subsea pipelines. At a later stage, once required by
reservoir conditions, a second phase will be launched involving the construction of offshore
compression facilities, a first on the South Pars field.
SP11 will be developed in two phases. The first phase, with an estimated cost of around 2
billion dollars equivalent, will consist of 30 wells and 2 wellhead platforms connected to
existing onshore treatment facilities by 2 subsea pipelines. At a later stage, once required by
reservoir conditions, a second phase will be launched involving the construction of offshore
compression facilities, a first on the South Pars field.
Since the November 2016 HoA signature, Total has been conducting engineering studies on
behalf of the consortium and initiated calls for tender in order to award the contracts
required to develop the project by the end of the year.
Since the November 2016 HoA signature, Total has been conducting engineering studies on
behalf of the consortium and initiated calls for tender in order to award the contracts
required to develop the project by the end of the year.
****
****
Cautionary note
Cautionary note
This press release, from which no legal consequences may be drawn, is for information purposes
only. The entities in which TOTAL S.A. directly or indirectly owns investments are separate legal
entities. TOTAL S.A. has no liability for their acts or omissions. In this document, the terms 'Total"
This press release, from which no legal consequences may be drawn, is for information purposes
only. The entities in which TOTAL S.A. directly or indirectly owns investments are separate legal
entities. TOTAL S.A. has no liability for their acts or omissions. In this document, the terms 'Total"
1/2
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- 33 -

and 'Total Group" are sometimes used for convenience where general references are made to
TOTAL S.A. and/or its subsidiaries. Likewise, the words "we", "us" and "our" may also be used to
refer to subsidiaries in general or to those who work for them.
and "Total Group" are sometimes used for convenience where general references are made to
TOTAL S.A. and/or its subsidiaries. Likewise, the words "we", "us" and "our" may also be used to
refer to subsidiaries in general or to those who work for them.
This document may contain forward-looking information and statements that are based on a
number of economic data and assumptions made in a given economic, competitive and
regulatory environment. They may prove to be inaccurate in the future and are subject to a
number of risk factors. Neither TOTAL S.A. nor any of its subsidiaries assumes any obligation to
update publicly any forward-looking information or statement, objectives or trends contained in
this document whether as a result of new information, future events or otherwise.
This document may contain forward-looking information and statements that are based on a
number of economic data and assumptions made in a given economic, competitive and
regulatory enviranment. They may prave to be inaccurate in the future and are subject to a
number of risk factors. Neither TOTAL S.A. nor any of its subsidiaries assumes any obligation to
update publicly any forward-looking information or statement, objectives or trends contained in
this document whether as a result of new information, future events or otherwise.
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Annex 210
Total SA, “U.S. withdrawal from the JCPOA: Total’s position related to the South
Pars 11 project in Iran”, 16 May 2018

- 35 -

- 36 -

US withdrawal from the JCPOA: Total's position related
to the South Pars 11 project in Iran
US withdrawal from the JCPOA: Total's position related
to the South Pars 11 project in Iran
g total.com/en/media/news/press-releases/us-withdrawal-jcpoa-totals-position-related-south-pars-11-project-iran
g total.com/en/media/news/press-releases/us-withdrawal-jcpoa-totals-position-related-south-pars-11-project-iran
2018/05/16
2018/05/16
Press release
Press release
Paris - On 4 July 2017, Total, together with the other partner Petrochina, executed the
contract related to the South Pars 11 (SP11) project,
in full compliance with UN resolutions
Paris - On 4 July 2017, Total, together with the other partner Petrochina, executed the
contract related to the South Pars 11 (SP11) project,
in full compliance with UN resolutions
and US, EU and French legislation applicable at the time. SP11 is a gas development
project dedicated to the supply of domestic gas to the domestic Iranian market and for
which Total has voluntarily implemented an IRGC-free policy for all contractors participating
in the project, thereby contributing to the international policy to restrain the field of infiuence
of the IRGC.
and US, EU and French legislation applicable at the time. SP11 is a gas development
project dedicated to the supply of domestic gas to the domestic Iranian market and for
which Total has voluntarily implemented an IRGC-free policy for all contractors participating
in the project, thereby contributing to the international policy to restrain the field of infiuence
of the IRGC.
On 8 May 2018, President Donald Trump announced the United States' decision to
withdraw from the JCPOA and to reinstate the US sanctions that were in force before the
JCPOA's implementation, subject to certain wind down periods.
On 8 May 2018, President Donald Trump announced the United States' decision to
withdraw from the JCPOA and to reinstate the US sanctions that were in force before the
JCPOA's implementation, subject to certain wind down periods.
As a consequence and as already explained before, Total will not be in a position to
continue the SP11 project and will have to unwind all related operations before 4
November 2018 unless Total is granted a specific project waiver by the US authorities with
the support of the French and European authorities. This project waiver should include
protection of the Company from any secondary sanction as per US legislation.
As a consequence and as already explained before, Total will not be in a position to
continue the SP11 project and will have to unwind all related operations before 4
November 2018 unless Total is granted a specific project waiver by the US authorities with
the support of the French and European authorities. This project waiver should include
protection of the Company from any secondary sanction as per US legislation.
Total has always been clear that it cannot afford to be exposed to any secondary sanction,
which might include the loss of financing in dollars by US banks for its worldwide
operations (US banks are involved in more than 90% of Total's financing operations), the
loss of its US shareholders (US shareholders represent more than 30% of Total's
shareholding) or the inability to continue its US operations (US assets represent more than
10 billion dollars of capital employed).
Total has always been clear that it cannot afford to be exposed to any secondary sanction,
which might include the loss of financing in dollars by US banks for its worldwide
operations (US banks are involved in more than 90% of Total's financing operations), the
loss of its US shareholders (US shareholders represent rnore than 30% of Total's
shareholding) or the inability to continue its US operations (US assets represent more than
10 billion dollars of capital employed).
In these circumstances, Total will not take any further commitment related to the SP11
project and, in accordance with its contractual commitments vis a vis the Iranian authorities,
is engaging with the French and US authorities to examine the possibility of a project
waiver.
In these circumstances, Total will not take any further commitment related to the SP11
project and, in accordance with its contractual commitments vis a vis the Iranian authorities,
is engaging with the French and US authorities to examine the possibility of a project
waiver.
Total confirms that its actual spending to date with respect to the SP11 contract is less than
40 million euros in Group share. Furthermore, considering the various growth opportunities
which have been captured by Total in recent months, Total confirms that a withdrawal from
SP11 would not impact its production growth target of 5% CAGR between 2016 and 2022.
Total confirms that its actual spending to date with respect to the SP11 contract is less than
40 million euros in Group share. Furthermore, considering the various growth opportunities
which have been captured by Total in recent months, Total confirms that a withdrawal from
SP11 would not impact its production growth target of 5% CAGR between 2016 and 2022.
Total contacts
Total contacts
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1/2
- 37 -

• Media Relations: +33 1 47 44 46 99 [email protected] I @TotalPress
•
• Media Relations: +33 1 47 44 46 99 [email protected] I @TotalPress
•
Investor Relations: +44 (0)207 719 7962 [email protected]
Investor Relations: +44 (0)207 719 7962 [email protected]
Cautionary note
Cautionary note
This press release, from which no legal consequences may be drawn, is for information
purposes only. The entities in which TOTALS.A. directly or indirectly owns investments are
separate legal entities. TOTALS.A. has no liability for their acts or omissions. In this
document, the terms "Total" and "Total Group" are sometimes used for convenience where
general references are made to TOTALS.A. and/or its subsidiaries. Likewise, the words
"we", "us" and "our" may also be used to refer to subsidiaries in general or to those who
work for them.
This press release, from which no legal consequences may be drawn, is for information
purposes only. The entities in which TOTALS.A. directly or indirectly owns investments are
separate legal entities. TOTALS.A. has no liability for their acts or omissions. In this
document, the terms "Total" and "Total Group" are sometimes used for convenience where
general references are made to TOTALS.A. and/or its subsidiaries. Likewise, the words
"we", "us" and "our" may also be used to refer to subsidiaries in general or to those who
work for them.
This document may contain forward-looking information and statements that are based on a
number of economic data and assumptions made in a given economic, competitive and
regulatory environment. They may prove to be inaccurate in the future and are subject to a
number of risk factors. Neither TOTALS.A. nor any of its subsidiaries assumes any
obligation to update publicly any forward-looking information or statement, objectives or
trends contained in this document whether as a result of new information, future events or
otherwise.
This document may contain forward-looking information and statements that are based on a
number of economic data and assumptions made in a given economic, competitive and
regulatory environment. They may prove to be inaccurate in the future and are subject to a
number of risk factors. Neither TOTALS.A. nor any of its subsidiaries assumes any
obligation to update publicly any forward-looking information or statement, objectives or
trends contained in this document whether as a result of new information, future events or
otherwise.
Contact us
Contact us
Mail : [email protected]
Mail : [email protected]
Tel.: +33 1 47 44 46 99
Tel.: +33147444699
Fax : +33 1 4 7 44 58 24
Fax : +33 1 4 7 44 58 24
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212
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- 38 -

Annex 211
U.S. Department of State, “Briefing with an Iran Diplomacy Update”, Special
Briefing, 2 July 2018

- 39 -

- 40 -

U.S. Department of State
U.S. Department of State
(
state.gov/r/pa/prs/ps/2018/07/283669.htm
(
state.gov/r/pa/prs/ps/2018/07/283669.htm
Special Briefing
Brian Hook
Director of Policy Planning
Special Briefing
Brian Hook
Director of Policy Planning
Press Briefing Room
Press Briefing Room
Washington, DC
Washington, DC
July 2, 2018
July 2, 2018
MS NAUERT: Welcome to all of you. and thanks for coming in. I know a lot of you have an
interest in what we're doing with regard to Iran and our diplomatic efforts going forward. So
keeping that in mind, we asked Brian Hook, our director of policy planning, to come down
and give you a few minutes' briefing on where things stand right now.
So I'll welcome Brian Hook. I'll call on you take a few questions and then we'll go on about
our day, and I'll see you tomorrow at our briefing then. Brian, go right ahead.
MS NAUERT: Welcome to all of you. and thanks for coming in. I know a lot of you have an
interest in what we're doing with regard to Iran and our diplomatic efforts going forward. So
keeping that in mind, we asked Brian Hook, our director of policy planning, to come down
and give you a few minutes' briefing on where things stand right now.
So I'll welcome Brian Hook. I'll call on you take a few questions and then we'll go on about
our day, and I'll see you tomorrow at our briefing then. Brian, go right ahead.
MR HOOK: Thank you, Heather. Good morning.
MR HOOK: Thank you, Heather. Good morning.
QUESTION: Morning.
QUESTION: Morning.
MR HOOK: I'd like to update you on the progress we're making to advance the President's
Iran policy. It has been almost two months since President Trump announced our
withdrawal from the Iran deal and a little over one month since Secretary Pompeo laid out a
roadmap for achieving a better deal.
MR HOOK: I'd like to update you on the progress we're making to advance the President's
Iran policy. It has been almost two months since President Trump announced our
withdrawal from the Iran deal and a little over one month since Secretary Pompeo laid out a
roadmap for achieving a better deal.
The Secretary outlined a clear and compelling vision for a better future for the Iranian
people. This future can only be realized, though, if Iran meets 12 demands to become a
normal country. Normal countries don't terrorize other nations, proliferate missiles, and
impoverish their own people.
The Secretary outlined a clear and compelling vision for a better future for the Iranian
people. This future can only be realized, though, if Iran meets 12 demands to become a
normal country. Normal countries don't terrorize other nations, proliferate missiles, and
impoverish their own people.
As Secretary Pompeo has said, this new strategy is not about changing the regime, it is
about changing the behavior of the leadership in Iran to comport with what the Iranian
people really want them to do. A key part of our strategy is a campaign of maximum
economic and diplomatic pressure. The first part of our sanctions will snap back on August
4th[1]. These sanctions will include targeting Iran's automotive sector, trade in gold, and
other key metals. Our remaining sanctions will snap back on November 6th[2]. These
sanctions will include targeting Iran's energy sector and petroleum-related transactions and
transactions with the Central Bank of Iran.
As Secretary Pompeo has said, this new strategy is not about changing the regime, it is
about changing the behavior of the leadership in Iran to comport with what the Iranian
people really want them to do. A key part of our strategy is a campaign of maximum
economic and diplomatic pressure. The first part of our sanctions will snap back on August
4th[1]. These sanctions will include targeting Iran's automotive sector, trade in gold, and
other key metals. Our remaining sanctions will snap back on November 6th[2]. These
sanctions will include targeting Iran's energy sector and petroleum-related transactions and
transactions with the Central Bank of Iran.
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After leaving the deal, Secretary Pompeo and Secretary Mnuchin decided to create joint
teams of senior officials to visit every region of the world. These teams were launched on
June 4th and have already visited 13 countries in Europe and East Asia. Our diplomatic
teams from State and Treasury are bringing with them a message of cooperation and
coordination. Many countries around the world share our interests in countering terrorism,
halting the proliferation of missiles, and promoting peace and stability in the Middle East.
We want to work with these countries to build a strong global effort.
After leaving the deal, Secretary Pompeo and Secretary Mnuchin decided to create joint
teams of senior officials to visit every region of the world. These teams were launched on
June 4th and have already visited 13 countries in Europe and East Asia. Our diplomatic
teams from State and Treasury are bringing with them a message of cooperation and
coordination. Many countries around the world share our interests in countering terrorism,
halting the proliferation of missiles, and promoting peace and stability in the Middle East.
We want to work with these countries to build a strong global effort.
At each stop, the teams from Treasury and State explain the full snapback of our sanctions
and warn governments and the private sector of the risks of continuing to do business with
Iran. More than 50 international firms have already announced their intent to leave the
Iranian market, particularly in the energy and financial sectors.
At each stop, the teams from Treasury and State explain the full snapback of our sanctions
and warn governments and the private sector of the risks of continuing to do business with
Iran. More than 50 international firms have already announced their intent to leave the
Iranian market, particularly in the energy and financial sectors.
We have been clear with countries and companies around the world that we are bringing
severe economic pressure on Iran until the regime changes its destabilizing policies. In the
coming days, Treasury Under Secretary Mandelker and I will lead a delegation to the Gulf
as our global diplomatic efforts continue.
We have been clear with countries and companies around the world that we are bringing
severe economic pressure on Iran until the regime changes its destabilizing policies. In the
coming days, Treasury Under Secretary Mandelker and I will lead a delegation to the Gulf
as our global diplomatic efforts continue.
As I mentioned earlier on the energy front, sanctions are set to be re-imposed on
November 4th. Our focus is on getting as many countries importing Iranian crude down to
zero as soon as possible. We are also working with oil market participants, including
producers and consumers, to ensure market stability. Banking sanctions will also snap
back on November 4th, and we will be aggressively enforcing these provisions to lock up
Iran's assets overseas and deny the Iranian regime access to its hard currency.
As I mentioned earlier on the energy front, sanctions are set to be re-imposed on
November 4th. Our focus is on getting as many countries importing Iranian crude down to
zero as soon as possible. We are also working with oil market participants, including
producers and consumers, to ensure market stability. Banking sanctions will also snap
back on November 4th, and we will be aggressively enforcing these provisions to lock up
Iran's assets overseas and deny the Iranian regime access to its hard currency.
Our sanctions do not now, nor have they ever, targeted humanitarian goods. Our sanctions
pressure the Iranian regime into changing its behavior and they do not target the Iranian
people. The United States does not sanction the export of food or medicine to Iran.
Our sanctions do not now, nor have they ever, targeted humanitarian goods. Our sanctions
pressure the Iranian regime into changing its behavior and they do not target the Iranian
people. The United States does not sanction the export of food or medicine to Iran.
In addition to building a campaign of strong economic pressure, Secretary Pompeo has
also made it a priority to stand with the Iranian people, who are the longest-suffering victims
of the Iranian regime. The average Iranian today is struggling to afford basics like water,
bread, and eggs. At the same time, the Iranian regime is squandering millions of dollars on
violent misadventures abroad. These serve no purpose other than to prolong pain and
suffering of men, women, and children in Iran and elsewhere in the Middle East.
In addition to building a campaign of strong economic pressure, Secretary Pompeo has
also made it a priority to stand with the Iranian people, who are the longest-suffering victims
of the Iranian regime. The average Iranian today is struggling to afford basics like water,
bread, and eggs. At the same time, the Iranian regime is squandering millions of dollars on
violent misadventures abroad. These serve no purpose other than to prolong pain and
suffering of men, women, and children in Iran and elsewhere in the Middle East.
Iran's economy is getting worse. Foreign direct investment is falling, and the rial hit an all­
time high against the dollar last week. On June 28th, the rial was trading at 85,000 to the
dollar on the unofficial market. That is twice the official exchange rate of 42,500. The initial
windfall the regime received after the Iran deal never benefited the Iranian people. The
Iranian economy is too distorted by corruption and the IRGC's pervasive presence in most
key sectors. Rather than create an economy that works for the Iranian people, the regime
refuses to meet standard international banking practices. Iran accordingly remains on the
blacklist for failing to prevent money laundering and terror financing.
Iran's economy is getting worse. Foreign direct investment is falling, and the rial hit an all­
time high against the dollar last week. On June 28th, the rial was trading at 85,000 to the
dollar on the unofficial market. That is twice the official exchange rate of 42,500. The initial
windfall the regime received after the Iran deal never benefited the Iranian people. The
Iranian economy is too distorted by corruption and the IRGC's pervasive presence in most
key sectors. Rather than create an economy that works for the Iranian people, the regime
refuses to meet standard international banking practices. Iran accordingly remains on the
blacklist for failing to prevent money laundering and terror financing.
Supreme Leader Khamenei seems all too aware that economic reform would expose just
how much his economy facilitates war, terrorism, and crime. Since the President's May 8th
announcement, the United States has designated two Iranian financial networks that
support terrorism. One network involved a currency exchange scheme going through the
Supreme Leader Khamenei seems all too aware that economic reform would expose just
how much his economy facilitates war, terrorism, and crime. Since the President's May 8th
announcement, the United States has designated two Iranian financial networks that
support terrorism. One network involved a currency exchange scheme going through the
2/6
216
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UAE, and we worked very closely and very well with the Emirati Government to shut it
down. The other network involved the Iranian central bank governor and an Iraqi bank. It is
no wonder that international banks and firms refuse to enter the Iranian financial system.
UAE, and we worked very closely and very well with the Emirati Government to shut it
down. The other network involved the Iranian central bank governor and an Iraqi bank. It is
no wonder that international banks and firms refuse to enter the Iranian financial system.
The Iranian people are rightly frustrated with the regime, and they are expressing their
frustration in nationwide protests and in smaller acts of defiance throughout the country. As
the regime continues to crack down on these legitimate calls for reform in Tehran,
Khorramshahr, and elsewhere with more repression and even greater violence, the United
States stands with the Iranian people. Since withdrawing from the Iran deal, the United
States has sanctioned 53 individuals and entities for human rights abuses, proliferation
activities, or acts of terrorism, and we will continue to do so. We designated Sadeq Larijani,
the head of the judiciary, which demonstrates that we will target those responsible for
human rights abuses at the highest levels of the Iranian Government. A people with as rich
a history and as deep a culture as the Iranian people deserve a government that treats
them with dignity.
The Iranian people are rightly frustrated with the regime, and they are expressing their
frustration in nationwide protests and in smaller acts of defiance throughout the country. As
the regime continues to crack down on these legitimate calls for reform in Tehran,
Khorramshahr, and elsewhere with more repression and even greater violence, the United
States stands with the Iranian people. Since withdrawing from the Iran deal, the United
States has sanctioned 53 individuals and entities for human rights abuses, proliferation
activities, or acts of terrorism, and we will continue to do so. We designated Sadeq Larijani,
the head of the judiciary, which demonstrates that we will target those responsible for
human rights abuses at the highest levels of the Iranian Government. A people with as rich
a history and as deep a culture as the Iranian people deserve a government that treats
them with dignity.
Lastly, I will be traveling to Europe at the end of this week for meetings with the political
directors from Germany, France, and the United Kingdom, and that will continue very close
consultations we've had with the Europeans. The Secretary is in regular touch with his E3
counterparts, with governments around the world to discuss the way forward on Iran, and
that will continue in the coming weeks. Happy to take any questions. I think Heather's going
to-­
Lastly, I will be traveling to Europe at the end of this week for meetings with the political
directors from Germany, France, and the United Kingdom, and that will continue very close
consultations we've had with the Europeans. The Secretary is in regular touch with his E3
counterparts, with governments around the world to discuss the way forward on Iran, and
that will continue in the coming weeks. Happy to take any questions. I think Heather's going
to-­
MS NAUERT: Yeah. Start with - we'll start with AP. That's our tradition here. Go right
ahead.
MS NAUERT: Yeah. Start with - we'll start with AP. That's our tradition here. Go right
ahead.
QUESTION: Thanks for this briefing. We heard the President Sunday warn the U.S.'s
European allies of sanctions should they continue trade with Iran. I'm just wondering, was
that the tenor of your discussions with the U.S.'s European allies on your recent trip to
Europe, and have you heard back from any of those allies in response to the President's
words yesterday?
QUESTION: Thanks for this briefing. We heard the President Sunday warn the U.S.'s
European allies of sanctions should they continue trade with Iran. I'm just wondering, was
that the tenor of your discussions with the U.S.'s European allies on your recent trip to
Europe, and have you heard back from any of those allies in response to the President's
words yesterday?
MR HOOK: Well, we will not hesitate to take action when we see sanctionable activity, and
that is consistent with our policy of economic and diplomatic isolation against Iran. We do
work --as I said, these road shows of Treasury and State officials, they've been to Europe.
They haven't been to all of Europe, but they've been to part of Europe, been to Asia. Those
will continue. But our teams at Treasury are in very close consultation, we're in close
consultation with not just Europe but with all countries who are affected by the re-imposition
of our sanctions.
MR HOOK: Well, we will not hesitate to take action when we see sanctionable activity, and
that is consistent with our policy of economic and diplomatic isolation against Iran. We do
work --as I said, these road shows of Treasury and State officials, they've been to Europe.
They haven't been to all of Europe, but they've been to part of Europe, been to Asia. Those
will continue. But our teams at Treasury are in very close consultation, we're in close
consultation with not just Europe but with all countries who are affected by the re-imposition
of our sanctions.
MS NAUERT: Lesley from Reuters.
MS NAUERT: Lesley from Reuters.
QUESTION: Yes. Hello, Brian.
QUESTION: Yes. Hello, Brian.
MR HOOK: Hi, Lesley.
MR HOOK: Hi, Lesley.
QUESTION: I was wondering, the President also said over the weekend that he had asked
King Salman of Saudi Arabia to -- that he'd increase --to increase oil production by 2 million
barrels. Can you please give us --have the Saudis agreed to that, number one? Number
QUESTION: I was wondering, the President also said over the weekend that he had asked
King Salman of Saudi Arabia to - that he'd increase --to increase oil production by 2 million
barrels. Can you please give us -- have the Saudis agreed to that, number one? Number
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316
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two, what do you think the market reaction is going to be to that? Would it press down ­
push down prices and will it make up for the shortage coming up? And number two, is that
2 million barrels per day?
two, what do you think the market reaction is going to be to that? Would it press down -­
push down prices and will it make up for the shortage coming up? And number two, is that
2 million barrels per day?
MR HOOK: Well, I'd refer you to the White House for a specific readout on the Saudi
reaction to the phone call the President had with the king. Our goal - with respect to the
energy sanctions, our goal is to increase pressure on the Iranian regime by reducing to
zero its revenue from crude oil sales. Now, we are working to minimize disruptions to the
global market, but we are confident that there is sufficient global spare oil production
capacity.
MR HOOK: Well, I'd refer you to the White House for a specific readout on the Saudi
reaction to the phone call the President had with the king. Our goal - with respect to the
energy sanctions, our goal is to increase pressure on the Iranian regime by reducing to
zero its revenue from crude oil sales. Now, we are working to minimize disruptions to the
global market, but we are confident that there is sufficient global spare oil production
capacity.
MS NAUERT: Next one, Dave from AFP.
MS NAUERT: Next one, Dave from AFP.
QUESTION: Thank you. Thanks, Brian.
QUESTION: Thank you. Thanks, Brian.
MR HOOK: Dave.
MR HOOK: Dave.
QUESTION: India and I believe Turkey have explicitly said that they will continue to import
Iranian oil. Can you be precise about the kind of consequences they will face or their
corporations and banks will face if they do this?
QUESTION: India and I believe Turkey have explicitly said that they will continue to import
Iranian oil. Can you be precise about the kind of consequences they will face or their
corporations and banks will face if they do this?
MR HOOK: We are not looking to grant licenses or waivers, because doing so would
substantially reduce pressure on Iran. And this is a campaign of imposing pressure. And so
we are not looking to grant licenses or waivers broadly on the re-imposition of sanctions,
because we believe pressure is critical to achieve our national security objectives.
MR HOOK: We are not looking to grant licenses or waivers, because doing so would
substantially reduce pressure on Iran. And this is a campaign of imposing pressure. And so
we are not looking to grant licenses or waivers broadly on the re-imposition of sanctions,
because we believe pressure is critical to achieve our national security objectives.
We are prepared to work with countries that are reducing their imports on a case-by-case
basis. But as with our other sanctions, we are not looking to grant waivers or licenses.
We are prepared to work with countries that are reducing their imports on a case-by-case
basis. But as with our other sanctions, we are not looking to grant waivers or licenses.
MS NAUERT: I'm sorry, I forgot your name.
MS NAUERT: I'm sorry, I forgot your name.
QUESTION: Alicia.
QUESTION: Alicia.
MS NAUERT: Alicia Rose, go ahead.
MS NAUERT: Alicia Rose, go ahead.
QUESTION: Sure. Thank you so much. You - on the cutting crude oil from Iran, which
countries have already agreed to cut oil imports from Iran, and what has been the reaction
from countries in your discussions?
QUESTION: Sure. Thank you so much. You -- on the cutting crude oil from Iran, which
countries have already agreed to cut oil imports from Iran, and what has been the reaction
from countries in your discussions?
MR HOOK: Well, the - I gave a statistic earlier about the number of countries that have
announced that. I can get you a specific number, or a more specific description later.
MR HOOK: Well, the - I gave a statistic earlier about the number of countries that have
announced that. I can get you a specific number, or a more specific description later.
QUESTION: (Off-mike.)
QUESTION: (Off-mike.)
MS NAUERT: Nike from VOA.
MS NAUERT: Nike from VOA.
QUESTION: Thank you so much, Heather. If I may, I would like to ask about the diplomatic
efforts to bring China on board after U.S. ended JCPOA. Because China is a signatory of
JCPOA, and the Government of China had expressed opposition of U.S. position to
withdraw from JCPOA. What do you say to the Chinese Government? And would Chinese
companies that continue to do business with Iran or buy oil from Iran be subject to U.S.
sanctions? Thank you.
QUESTION: Thank you so much, Heather. If I may, I would like to ask about the diplomatic
efforts to bring China on board after U.S. ended JCPOA. Because China is a signatory of
JCPOA, and the Government of China had expressed opposition of U.S. position to
withdraw from JCPOA. What do you say to the Chinese Government? And would Chinese
companies that continue to do business with Iran or buy oil from Iran be subject to U.S.
sanctions? Thank you.
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MR HOOK: Our diplomacy has been focused around mostly consultations with Europe,
France, and Germany. Those are our allies. And so we work very closely with allies. We ­
in Secretary Pompeo's speech that he gave about a month ago, he listed all of the
countries that we want to work with. We believe that China and Russia and the other
countries who are part of the Iran deal are tired of the terrorism that Iran is causing. They
don't support the proliferation of missiles around the Middle East. They don't support just
how -- this vast proxy network of terrorism.
MR HOOK: Our diplomacy has been focused around mostly consultations with Europe,
France, and Germany. Those are our allies. And so we work very closely with allies. We­
in Secretary Pompeo's speech that he gave about a month ago, he listed all of the
countries that we want to work with. We believe that China and Russia and the other
countries who are part of the Iran deal are tired of the terrorism that Iran is causing. They
don't support the proliferation of missiles around the Middle East. They don't support just
how -- this vast proxy network of terrorism.
And so we believe that most countries around the world share our goals. If you go through
the list of the 12 objectives that Secretary Pompeo outlined, those objectives were a global
consensus prior to the Iran deal. And so you've seen China vote repeatedly in a number of
UN Security Council resolutions, and those resolutions stated objectives that are perfectly
consistent with the 12 objectives that Secretary Pompeo laid out.
And so we believe that most countries around the world share our goals. If you go through
the list of the 12 objectives that Secretary Pompeo outlined, those objectives were a global
consensus prior to the Iran deal. And so you've seen China vote repeatedly in a number of
UN Security Council resolutions, and those resolutions stated objectives that are perfectly
consistent with the 12 objectives that Secretary Pompeo laid out.
And so when we sit down with countries, we are beginning from a position of broad
agreement on wanting to deter Iran's destabilizing activities in the Middle East and its
support for terrorism. No one supports Iran's terrorism in the world except perhaps Assad.
And so we feel like we have enormous agreement with countries around the world on what
we need to do to deter Iran's violence.
And so when we sit down with countries, we are beginning from a position of broad
agreement on wanting to deter Iran's destabilizing activities in the Middle East and its
support for terrorism. No one supports Iran's terrorism in the world except perhaps Assad.
And so we feel like we have enormous agreement with countries around the world on what
we need to do to deter Iran's violence.
MS NAUERT: Michelle - Michelle -­
MS NAUERT: Michelle -- Michelle --
QUESTION: You mentioned the waivers, case-by-case -­
QUESTION: You mentioned the waivers, case-by-case -­
MS NAUERT: We've got to move on. Sorry. Two questions left. Michelle, go right ahead.
MS NAUERT: We've got to move on. Sorry. Two questions left. Michelle, go right ahead.
QUESTION: Well, it doesn't sound like there's enormous agreement in Europe as to how to
go about this. And you mentioned that you're not looking to grant waivers, but does that
mean that you're not ruling them out as well? And also, with Rouhani in Europe now, what
do you expect will be accomplished in that? I mean, do you think that -- that and the goal of
moving forward with the sanctions on Europeans, is that just solidifying opposition to the
way the U.S. is going about this?
QUESTION: Well, it doesn't sound like there's enormous agreement in Europe as to how to
go about this. And you mentioned that you're not looking to grant waivers, but does that
mean that you're not ruling them out as well? And also, with Rouhani in Europe now, what
do you expect will be accomplished in that? I mean, do you think that -- that and the goal of
moving forward with the sanctions on Europeans, is that just solidifying opposition to the
way the U.S. is going about this?
MR HOOK: President Rouhani, as you've seen reported in the press, will be visiting
Switzerland and Austria as part of their ongoing efforts to work with the Europeans. It is
interesting that he will be traveling to Vienna. This is -- this month of July is the 29th
anniversary that Iranian operatives, using diplomatic cover, assassinated the head of an
Iranian Kurdish dissident group and two others. And so we will be, in the near term,
reminding people of Iran and the violence that they have - a lot of their attacks,
assassinations, bombings, cyber attacks, kidnapping, hostage-takings, hijackings, small
arms attacks, from 1979 to 2018, and we will be discussing that in every region of the
world.
MR HOOK: President Rouhani, as you've seen reported in the press, will be visiting
Switzerland and Austria as part of their ongoing efforts to work with the Europeans. It is
interesting that he will be traveling to Vienna. This is -- this month of July is the 29th
anniversary that Iranian operatives, using diplomatic cover, assassinated the head of an
Iranian Kurdish dissident group and two others. And so we will be, in the near term,
reminding people of Iran and the violence that they have - a lot of their attacks,
assassinations, bombings, cyber attacks, kidnapping, hostage-takings, hijackings, small
arms attacks, from 1979 to 2018, and we will be discussing that in every region of the
world.
And so when you have somebody like Rouhani going to Europe to try to bring the
Europeans, it's a very sad history of violence that Iran has committed against Europe since
1979. And it's important for Europeans to remember the kind of regime that they're dealing
with.
And so when you have somebody like Rouhani going to Europe to try to bring the
Europeans, it's a very sad history of violence that Iran has committed against Europe since
1979. And it's important for Europeans to remember the kind of regime that they're dealing
with.
MS NAUERT: And -­
MS NAUERT: And -­
516
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QUESTION: And you're not ruling out waivers, did you say?
QUESTION: And you're not ruling out waivers, did you say?
MS NAUERT: Michelle, we've got to go. Final question, Nadia.
MS NAUERT: Michelle, we've got to go. Final question, Nadia.
QUESTION: Thank you, Heather. As you just mentioned, a significant component of the
Iran strategy is to counter its activities in the region. Have you seen any change since the
withdrawal from the agreement, especially the support for the Assad regime or their
activities in Yemen?
QUESTION: Thank you, Heather. As you just mentioned, a significant component of the
Iran strategy is to counter its activities in the region. Have you seen any change since the
withdrawal from the agreement, especially the support for the Assad regime or their
activities in Yemen?
MR HOOK: Well, if you look at Iran and Syria, and Iran and Yemen, they are backing all the
wrong people. And by backing them, that has contributed to enormous suffering and
violence in the region. When you - we've put out a number of statements that summarize
what Iran has been doing in Syria. They have been backing -- these Iranian-backed forces
are perpetuating the Assad regime's brutality against the Syrian people, and it's inciting
instability that spills into neighboring countries. And so this is the expansionist sort of policy
that Iran has been pursuing, and a lot of the money that they received under the Iran deal
has been used to fund these activities that has destabilized the Middle East, especially in
Syria and Yemen.
MR HOOK: Well, if you look at Iran and Syria, and Iran and Yemen, they are backing all the
wrong people. And by backing them, that has contributed to enormous suffering and
violence in the region. When you - we've put out a number of statements that summarize
what Iran has been doing in Syria. They have been backing - these Iranian-backed forces
are perpetuating the Assad regime's brutality against the Syrian people, and it's inciting
instability that spills into neighboring countries. And so this is the expansionist sort of policy
that Iran has been pursuing, and a lot of the money that they received under the Iran deal
has been used to fund these activities that has destabilized the Middle East, especially in
Syria and Yemen.
MS NAUERT: Thank you everybody, we've got to go. Thanks, Brian.
MS NAUERT: Thank you everybody, we've got to go. Thanks, Brian.
MR HOOK: Thanks.
MR HOOK: Thanks.
ill The following is on the record to Brian Hook: The first part of our sanctions will snap
back on August 6. These sanctions will include targeting Iran's automotive sector, trade in
gold, and other key metals. The remaining sanctions will snap back on November 4. These
sanctions will include targeting Iran's energy sector and petroleum-based transactions, and
transactions with the Central Bank of Iran.
ill The following is on the record to Brian Hook: The first part of our sanctions will snap
back on August 6. These sanctions will include targeting Iran's automotive sector, trade in
gold, and other key metals. The remaining sanctions will snap back on November 4. These
sanctions will include targeting Iran's energy sector and petroleum-based transactions, and
transactions with the Central Bank of Iran.
2] The following is on the record to Brian Hook: The first part of our sanctions will snap
back on August 6. These sanctions will include targeting Iran's automotive sector, trade in
gold, and other key metals. The remaining sanctions will snap back on November 4. These
sanctions will include targeting Iran's energy sector and petroleum-based transactions, and
transactions with the Central Bank of Iran.
2] The following is on the record to Brian Hook: The first part of our sanctions will snap
back on August 6. These sanctions will include targeting Iran's automotive sector, trade in
gold, and other key metals. The remaining sanctions will snap back on November 4. These
sanctions will include targeting Iran's energy sector and petroleum-based transactions, and
transactions with the Central Bank of Iran.
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Annex 212
U.S. Department of State, “Senior Administration Officials Previewing Iran
Sanctions”, Special Briefing, 6 August 2018

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Senior Administration Officials Previewing Iran Sanctions
Senior Administration Officials Previewing Iran Sanctions
U.S. Department of State
U.S. Department of State
Diplomacy in Action
Senior Administration Officials Previewing Iran Sanctions
Diplomacy in Action
Senior Administration Officials Previewing Iran Sanctions
Special Briefing
Via Teleconference
August 6, 2018
Special Briefing
Via Teleconference
August 6, 2018
MODERATOR: Good morning, thank you. Good morning to everyone and thank you for joining us this morning for a call on the
Iran sanctions. Just want to remind everyone that this call is on background and attribution is to a senior administration official. But
I'd also like to note that the information shared on this call is embargoed until 10:30 this morning. That is an update to the
information provided in the earlier advisory, so I'll just say it again: The contents of this call are embargoed until 10:30 in the
morning.
MODERATOR: Good morning, thank you. Good morning to everyone and thank you for joining us this morning for a call on the
Iran sanctions. Just want to remind everyone that this call is on background and attribution is to a senior adrrinistration official. But
I'd also like to note that the information shared on this call is embargoed until 10:30 this morning. Thal is an update to the
information provided in the earlier advisory, so I'll just say it again: The contents of this call are embargoed until 10:30 in the
morning.
The speakers joining us today are -we have five. We have (Senior Administration Official One]. We have (Senior Administration
The speakers joining us today are -we have five. We have (Senior Administration Official One]. We have [Senior Administration
Official Two]. We have [Senior Administration Official Three]; [Senior Administration Official Four]; and [Senior Administration
Official Five].
Official Two]. We have [Senior Administration Official Three]; [Senior Administration Official Four]; and [Senior Administration
Official Five].
I'll now turn it over to [Senior Administration Official One], who will open our call.
I'll now turn ii over to [Senior Administration Official One], who will open our call.
SENIOR ADMINISTRATION OFFICIAL ONE: Great, thank you, [Moderator). And thank you all for joining us today. I just have
some very brief opening remarks. I just want to point out that what's happening today is part of a big coordinated campaign of
pressuring Tehran that President Trump put in place from day one of his administration. We've - looking at the region from Yemen
to Syria to Gaza, the Iranian regime is using the resources they had gotten from the Joint Comprehensive Plan of Action to spread
human misery across the region instead of investing it in their people at home. We can have no further illusions about their intent.
SENIOR ADMINISTRATION OFFICIAL ONE: Great, thank you, [Moderator]. And thank you all for joining us today. I just have
some very brief opening remarks. I just want to point out that what's happening today is part of a big coordinated campaign of
pressuring Tehran that President Trump put in place from day one of his administration. We've - looking at the region from Yemen
to Syria to Gaza, the Iranian regime is using the resources they had gotten from the Joint Comprehensive Plan of Action to spread
human misery across the region instead of investing it in their people at home. We can have no further illusions about their intent.
And so facing this reality 90 days ago, the President took historic action to withdraw the United States from the JCPOA and put an
end to the fiction that that deal would block Tehran from getting a nuclear weapon. Now, at that time we were warned by experts
from the EU, even from my alma mater of the University of Pennsylvania -- very sad -- that the threat of unilateral sanctions from
the United States would not be an effective tool. But three months out, we have a very different picture in front of us. The riyal is
tanking, unemployment in Iran is rising, and there are widespread protests over social issues and labor unrest.
And so facing this reality 90 days ago, the President took historic action to withdraw the United States from the JCPOA and put an
end to the fiction that that deal would block Tehran from getting a nuclear weapon. Now, at that time we were warned by experts
from the EU, even from my alma mater of the University of Pennsylvania -- very sad -- that the threat of unilateral sanctions from
the United States would not be an effective tool. But three months out, we have a very different picture in front of us. The riyal is
tanking, unemployment in Iran is rising, and there are widespread protests over social issues and labor unrest.
I thought from the Secretary of State's speech at the Reagan Library one of the most telling facts that he presented was that you
would get twice the salary as a fighter for Hizballah in Syria or Lebanon than you would to be a firefighter in Tehran, if you got paid
at all. And we see fires burn (inaudible) city unchecked.
I thought from the Secretary of State's speech at the Reagan Library one of the most telling facts that he presented was that you
would get twice the salary as a fighter for Hizballah in Syria or Lebanon than you would to be a firefighter in Tehran, if you got paid
at all. And we see fires burn (inaudible) city unchecked.
The next 90 days will see increased economic pressure, culminating in the reimposition of petroleum sector sanctions in
The next 90 days will see increased economic pressure, culminating in the reimposition of petroleum sector sanctions in
November, and this will have an exponential effect on Iran's already fragile economy.
November, and this will have an exponential effect on Iran's already fragile economy.
The President has been very clear none of this needs to happen. He will meet with the Iranian leadership at any time to discuss a
The President has been very clear none of this needs to happen. He will meet with the Iranian leadership at any time to discuss a
real comprehensive deal that will contain their regional ambitions, will end their malign behavior, and deny them any path to a
nuclear weapon. The Iranian people should not suffer because of their regime's hegemonic regional ambitions.
real comprehensive deal that will contain their regional ambitions, will end their malign behavior, and deny them any path to a
nuclear weapon. The Iranian people should not suffer because of their regime's hegemonic regional ambitions.
I'd just like to conclude by thanking my interagency colleagues for their strong work on this effort. It's really been a terrific example
I'd just like to conclude by thanking my interagency colleagues for their strong work on this effort. It's really been a terrific example
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Senior Administration Officials Previewing Iran Sanctions
Senior Administration Officials Previewing Iran Sanctions
of the administration pulling together. And I'll turn it over to you, [Senior Administration Official Two].
of the administration pulling together. And I'll turn it over to you, [Senior Administration Official Two].
SENIOR ADMINISTRATION OFFICIAL TWO: Thanks very much. I think as we see the Iranian protests continue now in some
number of days, we hope that the Iranian regime will think seriously about the consequences of their behavior is having on their
own people. We do stand with the Iranian people, who are longing for a country of economic opportunity, transparency, fairness,
and greater liberty. As Iran expends enormous resources on its foreign adventurism, its people are becoming increasingly
frustrated, and we are seeing this frustration expressed in protests across the country.
SENIOR ADMINISTRATION OFFICIAL TWO: Thanks very much. I think as we see the Iranian protests continue now in some
number of days, we hope that the Iranian regime will think seriously about the consequences of their behavior is having on their
own people. We do stand with the Iranian people, who are longing for a country of economic opportunity, transparency, fairness,
and greater liberty. As Iran expends enormous resources on its foreign adventurism, its people are becoming increasingly
frustrated, and we are seeing this frustration expressed in protests across the country.
We are deeply concerned about reports of Iranian regime's violence against unarmed citizens. The United States supports the
Iranian people's right to peacefully protest against corruption and oppression without fear of reprisal.
We are deeply concerned about reports of Iranian regime's violence against unarmed citizens. The United States supports the
Iranian people's right to peacefully protest against corruption and oppression without fear of reprisal.
And two other points. The regime's systematic mismanagement of its economy and its decision to prioritize a revolutionary agenda
over the welfare of the Iranian people has put Iran into a long-term economic tailspin. Widespread government corruption and
extensive intervention in the economy by the Iran Revolutionary Guard Corps make doing business in Iran a losing proposition.
Foreign direct investors in Iran never know whether they are facilitating commerce or terrorism.
And two other points. The regime's systematic mismanagement of its economy and its decision to prioritize a revolutionary agenda
over the welfare of the Iranian people has put Iran into a long-term economic tailspin. Widespread government corruption and
extensive intervention in the economy by the Iran Revolutionary Guard Corps make doing business in Iran a losing proposition.
Foreign direct investors in Iran never know whether they are facilitating commerce or terrorism.
I'd also point out that I ran obviously had a windfall from the Iran nuclear deal. Its increased oil revenues were a consequence of the
nuclear deal. Those revenues could have gone to improve the lives of the Iranian people; instead, terrorists, dictators, proxy
militias, and the regime's own cronies benefitted the most.
I'd also point out that I ran obviously had a windfall from the Iran nuclear deal. Its increased oil revenues were a consequence of the
nuclear deal. Those revenues could have gone to improve the lives of the Iranian people; instead, terrorists, dictators, proxy
militias, and the regime's own cronies benefitted the most.
And now, I'm happy to turn it over to [Senior Administration Official Three].
And now, I'm happy to turn it over to [Senior Administration Official Three].
SENIOR ADMINISTRATION OFFICIAL THREE: Thank you, [Senior Administration Official Three]. So today, I want to briefly
describe the actions that we're taking today. The President has issued a new Iran executive order to reimpose sanctions relating to
Iran, as you know. On May 8th, the President issued a national security presidential memorandum which directed the secretaries of
Treasury and State and others to take a number of actions. And today's announcement is just the next step in implementing the
President's decision.
SENIOR ADMINISTRATION OFFICIAL THREE: Thank you, [Senior Administration Official Three]. So today, I want to briefly
describe the actions that we're taking today. The President has issued a new Iran executive order to reimpose sanctions relating to
Iran, as you know. On May 8th, the President issued a national security presidential memorandum which directed the secretaries of
Treasury and State and others to take a number of actions. And today's announcement is just the next step in implementing the
President's decision.
Specifically, we are reimposing sanctions on Iran that had been lifted under the JCPOA. The snapback of these sanctions, again,
supports the President's decision to impose significant financial pressure on the Iranian regime, to continue to counter Iran's blatant
and ongoing malign activities, and then ultimately to seek a new agreement that addresses the totality of the Iranian threat.
Specifically, we are reimposing sanctions on Iran that had been lifted under the JCPOA. The snapback of these sanctions, again,
supports the President's decision to impose significant financial pressure on the Iranian regime, to continue to counter Iran's blatant
and ongoing malign activities, and then ultimately to seek a new agreement that addresses the totality of the Iranian threat.
During the period of the JCPOA, the Iranian regime demonstrated time and time again that it had no intentions to cease its state
support for terrorism, foreign proxies, and other malign activities. Iran, as has already been stated, has continued to promote
ruthless regimes, destabilize the region, and abuse the human rights of its own people. As our sanctions have been exposing to
fund their illicit activities and to evade sanctions, Iran has systematically exploited the global financial system, and willfully deceived
countries, companies, and financial institutions around the globe.
During the period of the JCPOA, the Iranian regime demonstrated time and time again that it had no intentions to cease its state
support for terrorism, foreign proxies, and other malign activities. Iran, as has already been stated, has continued to promote
ruthless regimes, destabilize the region, and abuse the human rights of its own people. As our sanctions have been exposing to
fund their illicit activities and to evade sanctions, Iran has systematically exploited the global financial system, and willfully deceived
countries, companies, and financial institutions around the globe.
This administration intends to fully enforce our sanctions as they come back into effect in order to impose economic pressure on
the Iranian regime to stop its destabilizing activity, and ultimately chart a new path that will lead to prosperity for the Iranian people.
Specifically, the new Iran EO reimposes relevant provisions of five Iran sanctions executive orders that were revoked or amended
in January 16, 2016 in two phases. The first wind-down period ends at midnight tonight, at which relevant -- at which point relevant
sanctions will be reimposed.
This administration intends to fully enforce our sanctions as they come back into effect in order to impose economic pressure on
the Iranian regime to stop its destabilizing activity, and ultimately chart a new path that will lead to prosperity for the Iranian people.
Specifically, the new Iran EO reimposes relevant provisions offive Iran sanctions executive orders that were revoked or amended
in January 16, 2016 in two phases. The first wind-down period ends at midnight tonight, at which relevant - at which point relevant
sanctions will be reimposed.
At 12:01 a.m. tomorrow, August 7, 2018, sanctions will come back into full effect on the purchase or acquisition of U.S. dollar bank
notes by the Government of Iran; Iran's trade in gold and precious metals; the sale or transfer to or from Iran of graphite and
metals, such as aluminum and steel, coal, and software for integrating industrial processes; certain transactions related to the
Iranian rial; certain transactions related to the issuance of Iranian sovereign debt; and Iran's automotive sector.
At 12:01 a.m. tomorrow, August 7, 2018, sanctions will come back into full effect on the purchase or acquisition of U.S. dollar bank
notes by the Government of I ran; Iran's trade in gold and precious metals; the sale or transfer to or from I ran of graphite and
metals, such as aluminum and steel, coal, and software for integrating industrial processes; certain transactions related to the
Iranian rial; certain transactions related to the issuance of Iranian sovereign debt; and Iran's automotive sector.
2
2
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Senior Administration Officials Previewing Iran Sanctions
Senior Administration Officials Previewing Iran Sanctions
Wind-down authorizations will no longer be valid after August 6th, with respect to the importation into the United States of Iranian
origin carpets and food stuffs, and transactions related to the purchase of commercial passenger aircraft will be prohibited. After
the 180-day wind-down period ends on November 4, 2018, the U.S. Government will reimpose the remaining sanctions that have
been -- had been previously lifted under the JCPOA.
Wind-down authorizations will no longer be valid after August 6th, with respect to the importation into the United States of Iranian
origin carpets and food stuffs, and transactions related to the purchase of commercial passenger aircraft will be prohibited. After
the 180-day wind-down period ends on November 4, 2018, the U.S. Government will reimpose the remaining sanctions that have
been -- had been previously lifted under the JCPOA.
The final round of snapback sanctions, as articulated in the executive order, will include the reimposition of sanctions on Iran's oil
exports and energy sector, financial institutions conducting transactions with the Central Bank of Iran, as well as sanctions related
to Iran's port operators and shipping and ship-building sectors, and sanctions on the provision of insurance and financial
messaging services.
The final round of snapback sanctions, as articulated in the executive order, will include the reimposition of sanctions on Iran's oil
exports and energy sector, financial institutions conducting transactions with the Central Bank of Iran, as well as sanctions related
to Iran's port operators and shipping and ship-building sectors, and sanctions on the provision of insurance and financial
messaging services.
Today's executive order and the snapback of sanctions on Iran, again, is part of the President's broader strategy to apply
unprecedented financial pressure on the Iranian regime. We are intent on cutting off the regime's access to resources that they
have systematically used to finance terror, fund weapons proliferation, and threaten peace and stability in the region. Again, our
actions will continue to severely limit the ability of Iran, which, as you know, is the largest state sponsor of terror, to gain funding to
continue to finance its wide range of malign behavior.
Today's executive order and the snapback of sanctions on Iran, again, is part of the President's broader strategy to apply
unprecedented financial pressure on the Iranian regime. We are intent on cutting off the regime's access to resources that they
have systematically used to finance terror, fund weapons proliferation, and threaten peace and stability in the region. Again, our
actions will continue to severely limit the ability of Iran, which, as you know, is the largest state sponsor of terror, to gain funding to
continue to finance its wide range of malign behavior.
Under this administration, OFAC has issued 17 rounds of sanctions designating 145 I ran-related persons. This includes six rounds
just since the President's decision in May, including actions relating to the finance of the Qods Force and Hizballah, its ballistic
missile program, the Iranian aviation sector, the government's -- the regime's use of front and shell companies and other deceptive
means to gain access to currency for the Qods Force, including in complicity with the Central Bank of Iran. We are fully committed
to rigorously enforcing our sanctions and ensuring that Iran has no path to a nuclear weapon. This economic pressure campaign is
central to our efforts to gain -- to ensure that they change course.
Under this administration, OFAC has issued 17 rounds of sanctions designating 145 Iran-related persons. This includes six rounds
just since the President's decision in May, including actions relating to the finance of the Qods Force and Hizballah, its ballistic
missile program, the Iranian aviation sector, the government's -- the regime's use of front and shell companies and other deceptive
means to gain access to currency for the Qods Force, including in complicity with the Central Bank of Iran. We are fully committed
to rigorously enforcing our sanctions and ensuring that Iran has no path to a nuclear weapon. This economic pressure campaign is
central to our efforts to gain -- to ensure that they change course.
I will just also mention that in addition to the executive order we're going to be publishing a number of FAQs that will provide
answers to specific technical questions.
I will just also mention that in addition to the executive order we're going to be publishing a number of FAQs that will provide
answers to specific technical questions.
Thank you.
Thank you.
MODERATOR: All right, thank you very much. We'll now go to our first question.
MODERATOR: All right, thank you very much. We'll now go to our first question.
OPERATOR: Thank you, ladies and gentlemen. Once again, if you wish to ask a question, please press 1 at this time, and we ask
that you limit yourself to one question. Our first question is from Michael Gordon with Wall Street Journal. Please, go ahead.
OPERATOR: Thank you, ladies and gentlemen. Once again, if you wish to ask a question, please press 1 at this time, and we ask
that you limit yourself to one question. Our first question is from Michael Gordon with Wall Street Journal. Please, go ahead.
QUESTION: Right, thank you. When the previous administration imposed sanctions against Iran prior to the JCPOA, they had
broad international support. In this case, the United States has withdrawn from the agreement but other- Europe and Russia and
China continue to endorse it. China is a large consumer of Iranian oil and does a lot of trade with them. How do you propose to
elicit China's cooperation? And if you fail to do so, aren't your sanctions going to be weaker than the ones the Obama
administration imposed?
QUESTION: Right, thank you. When the previous administration imposed sanctions against Iran prior to the JCPOA, they had
broad international support. In this case, the United States has withdrawn from the agreement but other- Europe and Russia and
China continue to endorse it. China is a large consumer of Iranian oil and does a lot of trade with them. How do you propose to
elicit China's cooperation? And if you fail to do so, aren't your sanctions going to be weaker than the ones the Obama
administration imposed?
SENIOR ADMINISTRATION OFFICIAL THREE: So of course, as I'm sure [Senior Administration Official Two] will tell you, we
are likewise working to build a global coalition to counter Iran's malign activity. What I can tell you very specifically is that we have
made it very clear that we're going to aggressively enforce this executive order and the other authorities that we have pursuant to
statute. We will work with countries around the world to do so. But make no mistake about it, we are very intent on using these
authorities. We will use them aggressively. And as [Senior Administration Official Three] already mentioned, we are already seeing
a very substantial impact.
SENIOR ADMINISTRATION OFFICIAL THREE: So of course, as I'm sure [Senior Administration Official Two] will tell you, we
are likewise working to build a global coalition to counter Iran's malign activity. What I can tell you very specifically is that we have
made it very clear that we're going to aggressively enforce this executive order and the other authorities that we have pursuant to
statute. We will work with countries around the world to do so. But make no mistake about it, we are very intent on using these
authorities. We will use them aggressively. And as [Senior Administration Official Three] already mentioned, we are already seeing
a very substantial impact.
SENIOR ADMINISTRATION OFFICIAL ONE: Yeah, Michael, I would just follow up on that and say if the sanctions were not
SENIOR ADMINISTRATION OFFICIAL ONE: Yeah, Michael, I would just follow up on that and say if the sanctions were not
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Senior Administration Officials Previewing Iran Sanctions
going to be effective, I don't think you would have seen the trajectory of Iran's economy over the last 90 days. I mean, it would have
been the opposite if China were going to rescue them and somehow make this into a big success.
going to be effective, I don't think you would have seen the trajectory of Iran's economy over the last 90 days. I mean, it would have
been the opposite if China were going to rescue them and somehow make this into a big success.
SENIOR ADMINISTRATION OFFICIAL THREE: And of course, in the last 90 days we have seen company after company after
company announce that they are getting out, so there's no question that this pressure is already working.
SENIOR ADMINISTRATION OFFICIAL THREE: And of course, in the last 90 days we have seen company after company after
company announce that they are getting out, so there's no question that this pressure is already working.
SENIOR ADMINISTRATION OFFICIAL TWO: Yeah, this is [Senior Administration Official Two]. We -- the point of our sanctions
pressure, this economic pressure campaign, is to deny the regime the financial resources that it needs to finance terrorism and its
nuclear missile programs and other dangerous activity around the Middle East. And we're very pleased that nearly 100
international firms have announced their intent to leave the Iranian market, particularly in the energy and the finance sectors.
SENIOR ADMINISTRATION OFFICIAL TWO: Yeah, this is [Senior Administration Official Two]. We - the point of our sanctions
pressure, this economic pressure campaign, is to deny the regime the financial resources that it needs to finance terrorism and its
nuclear missile programs and other dangerous activity around the Middle East. And we're very pleased that nearly 100
international firms have announced their intent to leave the Iranian market, particularly in the energy and the finance sectors.
We have had -- State and Treasury officials have been traveling around the world to various regions to coordinate with countries.
That includes China. And so far, we have visited more than 20 countries, and that work will continue for the balance of the year.
We have had -- State and Treasury officials have been traveling around the world to various regions to coordinate with countries.
That includes China. And so far, we have visited more than 20 countries, and that work will continue for the balance of the year.
MODERATOR: Thank you. We'll go to the next question now.
MODERATOR: Thank you. We'll go to the next question now.
OPERATOR: Thank you. Our next question comes from Susannah George with AP. Please, go ahead.
OPERATOR: Thank you. Our next question comes from Susannah George with AP. Please, go ahead.
QUESTION: Hi there, thanks so much for doing this call. I want to ask specifically about this announcement from the EU that they
will protect European firms from the reimposition of U.S. sanctions on Iran, specifically this blocking statute that will take effect
when sanctions are reimposed at midnight. Do you expect that this could weaken U.S. sanctions? Have you responded to this in
any way? Thank you.
QUESTION: Hi there, thanks so much for doing this call. I want to ask specifically about this announcement from the EU that they
will protect European firms from the reimposition of U.S. sanctions on Iran, specifically this blocking statute that will take effect
when sanctions are reimposed at midnight. Do you expect that this could weaken U.S. sanctions? Have you responded to this in
any way? Thank you.
SENIOR ADMINISTRATION OFFICIAL THREE: Look, so I think with respect to the EU blocking the statute, really what you
need to look at is what companies and -- the messages that companies and financial institutions are sending, which is that (a) they
have I think a deep appreciation for what's going on in Iran for the fact that it's very difficult and complicated to know who you're
doing business with in Iran. Are you doing business with the IRGC, the Qods Force? As we've -as has been exposed in our
actions in the last 90 days, we've taken a couple of actions which expose the Central Bank of Iran's complicity in helping to fund
terror. Companies and banks, including central banks, understand that very well. They are taking note and as [Senior
Administration Official Two] mentioned, they are getting out. So we're not -- we are -- this is not something that we're particularly
concerned by.
SENIOR ADMINISTRATION OFFICIAL THREE: Look, so I think with respect to the EU blocking the statute, really what you
need to look at is what companies and -- the messages that companies and financial institutions are sending, which is that (a) they
have I think a deep appreciation for what's going on in Iran for the fact that it's very difficult and complicated to know who you're
doing business with in Iran. Are you doing business with the IRGC, the Qods Force? As we've -- as has been exposed in our
actions in the last 90 days, we've taken a couple of actions which expose the Central Bank of Iran's complicity in helping to fund
terror. Companies and banks, including central banks, understand that very well. They are taking note and as [Senior
Administration Official Two] mentioned, they are getting out. So we're not- we are -- this is not something that we're particularly
concerned by.
MODERATOR: All right, we'll go to the next question now.
MODERATOR: All right, we'll go to the next question now.
OPERATOR: Thank you. Our next question comes from Lesley Wroughton with Reuters. Please go ahead.
OPERATOR: Thank you. Our next question comes from Lesley Wroughton with Reuters. Please go ahead.
QUESTION: Yes, good morning. If you bear with me, just a couple of questions. One is do you - what kind of economic impact in
dollar terms do you believe these initial sanctions will have on the Iranian economy? And number two, is there a danger perhaps
that the Iranians might blame the worsening conditions on foreigners rather than on the regime?
QUESTION: Yes, good morning. If you bear with me, just a couple of questions. One is do you -- what kind of economic impact in
dollar terms do you believe these initial sanctions will have on the Iranian economy? And number two, is there a danger perhaps
that the Iranians might blame the worsening conditions on foreigners rather than on the regime?
SENIOR ADMINISTRATION OFFICIAL ONE: In terms of your second question, I think of course they will blame foreigners.
They've been doing this for almost 40 years now; it's their modus operandi. But I think you could see the Iranian people start to see
through that, that they know that this is the regime's policies. They also know about the President's offer to meet with their
leadership, and they'd like to take him up on that offer to see what the United States has to offer. So I think doing - saying we can't
do something because a rogue regime will blame foreigners, I don't think is a very effective policy for us.
SENIOR ADMINISTRATION OFFICIAL ONE: In terms of your second question, I think of course they will blame foreigners.
They've been doing this for almost 40 years now; it's their modus operandi. But I think you could see the Iranian people start to see
through that, that they know that this is the regime's policies. They also know about the President's offer to meet with their
leadership, and they'd like to take him up on that offer to see what the United States has to offer. So I think doing - saying we can't
do something because a rogue regime will blame foreigners, I don't think is a very effective policy for us.
SENIOR ADMINISTRATION OFFICIAL THREE: Yeah and I would add --I mean, as also --as [Senior Administration Official
SENIOR ADMINISTRATION OFFICIAL THREE: Yeah and I would add - I mean, as also --as [Senior Administration Official
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Two] also mentioned, look, the Iranian people have been protesting for some time. They were protesting well before the President's
decision and they were very specifically protesting about the corruption in their government, the misuse of funds which have not
gone to the Iranian people. It's gone to fund regional proxies, it's gone of course to fund terrorism and terrorist groups. That's what
they've been protesting about for quite some time, and the extraordinary thing about these protests is that these people, the Iranian
people, have -- understand that when they protest in Iran, unfortunately they do so at the risk to their own lives. They're thrown in
prison and all kinds of terrible things happen to them when they are thrown in prison, as our sanctions actions have likewise
exposed in recent months. But they are so fed up with their government, that they have made the decision that they have to protest
against the Iranian regime's ongoing economic and other policies.
Two] also mentioned, look, the Iranian people have been protesting for some time. They were protesting well before the President's
decision and they were very specifically protesting about the corruption in their government, the misuse of funds which have not
gone to the Iranian people. It's gone to fund regional proxies, it's gone of course to fund terrorism and terrorist groups. That's what
they've been protesting about for quite some time, and the extraordinary thing about these protests is that these people, the Iranian
people, have -- understand that when they protest in Iran, unfortunately they do so at the risk to their own lives. They're thrown in
prison and all kinds of terrible things happen to them when they are thrown in prison, as our sanctions actions have likewise
exposed in recent months. But they are so fed up with their government, that they have made the decision that they have to protest
against the Iranian regime's ongoing economic and other policies.
SENIOR ADMINISTRATION OFFICIAL ONE: And I do think it's particularly meaningful that they're protesting against the
expenditures in Syria, the expenditures in Gaza very specifically. And so that's what they're blaming.
SENIOR ADMINISTRATION OFFICIAL ONE: And I do think it's particularly meaningful that they're protesting against the
expenditures in Syria, the expenditures in Gaza very specifically. And so that's what they're blaming.
MODERATOR: All right, we'll go on to the next question now.
MODERATOR: All right, we'll go on to the next question now.
OPERATOR: And our next question is from Carol Morello with Washington Post. Please go ahead.
OPERATOR: And our next question is from Carol Morello with Washington Post. Please go ahead.
QUESTION: Hi. Are you or are you not calling for the Iranian people to do something to bring about regime change in Iran?
QUESTION: Hi. Are you or are you not calling for the Iranian people to do something to bring about regime change in Iran?
SENIOR ADMINISTRATION OFFICIAL ONE: Well, I'll defer to (Senior Administration Official Two], but I mean our stated policy
has not been regime change, it has been to modify the Iranian regime's behavior in the ways that I outlined in my opening remarks.
SENIOR ADMINISTRATION OFFICIAL ONE: Well, I'll defer to [Senior Administration Official Two], but I mean our stated policy
has not been regime change, it has been to modify the Iranian regime's behavior in the ways that I outlined in my opening remarks.
SENIOR STATE DEPARMTENT OFFICAL TWO: Yeah, Carol, I would add to that: We have been -- what we're noticing is that so
many of the things that the protesters are demanding are very similar to the things that the United States and other nations in the
world are demanding. And we have been consistent saying that if Iran will start behaving like a normal country, there are a number
of benefits that will follow from that. But for as long as Iran continues to export revolution around the Middle East and to destabilize
the region and to rob its people to fund these foreign -- to fund all the Shia militias and fund Assad and to fund other dictators in the
region. For as long as that's going on, I think you're going to see the Iranian people continually frustrated, and we support their
claims. We think that they have valid complaints against the regime, that many of them are our complaints. And so we would like to
see a change in the regime's behavior, and I think the Iranian people are looking for the same thing.
SENIOR STATE DEPARMTENT OFFICAL TWO: Yeah, Carol, I would add to that: We have been -- what we're noticing is that so
many of the things that the protesters are demanding are very similar to the things that the United States and other nations in the
world are demanding. And we have been consistent saying that if Iran will start behaving like a normal country, there are a number
of benefits that will follow from that. But for as long as Iran continues to export revolution around the Middle East and to destabilize
the region and to rob its people to fund these foreign --to fund all the Shia militias and fund Assad and to fund other dictators in the
region. For as long as that's going on, I think you're going to see the Iranian people continually frustrated, and we support their
claims. We think that they have valid complaints against the regime, that many of them are our complaints. And so we would like to
see a change in the regime's behavior, and I think the Iranian people are looking for the same thing.
MODERATOR: Thank you. We'll go on to the next question.
MODERATOR: Thank you. We'll go on to the next question.
OPERATOR: Thank you. And our next question is from Eli Lake with Bloomberg. Please, go ahead.
OPERATOR: Thank you. And our next question is from Eli Lake with Bloomberg. Please, go ahead.
QUESTION: Hi. Thanks so much for doing this. Are you going to sanction the entire IRIB, their broadcasting arm?
QUESTION: Hi. Thanks so much for doing this. Are you going to sanction the entire IRIB, their broadcasting arm?
SENIOR ADMINISTRATION OFFICIAL ONE: The IRIB is already sanctioned, and I have no comment beyond that.
SENIOR ADMINISTRATION OFFICIAL ONE: The IRIB is already sanctioned, and I have no comment beyond that.
MODERATOR: Thank you. We'll go to the next question now, please.
MODERATOR: Thank you. We'll go to the next question now, please.
OPERATOR: Next question is from Meghan Gordon with S&P Global Platts. Please, go ahead.
OPERATOR: Next question is from Meghan Gordon with S&P Global Platts. Please, go ahead.
QUESTION: Yeah, hi. Thanks for taking questions. You've said that you're not granting any broad waivers to the oil sanctions that
snap back in November. Have you approved any request allowing limited trades or specific deals to continue after that point, and
have you made a decision on Japan's request to continue importing Iranian oil?
QUESTION: Yeah, hi. Thanks for taking questions. You've said that you're not granting any broad waivers to the oil sanctions that
snap back in November. Have you approved any request allowing limited trades or specific deals to continue after that point, and
have you made a decision on Japan's request to continue importing Iranian oil?
SENIOR ADMINISTRATION OFFICIAL ONE: [Senior Administration Official Two], do you want to take that question?
SENIOR ADMINISTRATION OFFICIAL ONE: [Senior Administration Official Two], do you want to take that question?
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SENIOR ADMINISTRATION OFFICIAL TWO: Well, we don't -- we don't disclose private deliberations with other governments
over these things. As we've said, we - our goal is to get the import of Iranian oil to zero. We are not looking to grant exemptions or
waivers, but we do and are glad to discuss requests and look at requests on a case-by-case basis. But beyond that, we don't
comment on it.
SENIOR ADMINISTRATION OFFICIAL TWO: Well, we don't - we don't disclose private deliberations with other governments
over these things. As we've said, we -- Our goal is to get the import of Iranian oil to zero. We are not looking to grant exemptions or
waivers, but we do and are glad to discuss requests and look at requests on a case-by-case basis. But beyond that, we don't
comment on it.
MODERATOR: Thank you. We'll go on to the next question.
MODERATOR: Thank you. We'll go on to the next question.
OPERATOR: And our next question is from Andrea Mitchell with NBC, MSNBC. Please, go ahead.
OPERATOR: And our next question is from Andrea Mitchell with NBC, MSNBC. Please, go ahead.
QUESTION: Hi there. I'm trying to understand -- to better understand the disconnect between the President's wanting to meet with
Rouhani any time, any place, and these sanctions. How does that -- do you think that the pressure could lead to a meeting or
should lead to a meeting? What would -- what would be the purpose of a meeting given all your objections to this regime and your
- the comments today certainly seem to be encouraging the people of Iran to rise up against their leaders. Isn't that really what
you're doing here?
QUESTION: Hi there. I'm trying to understand --to better understand the disconnect between the President's wanting to meet with
Rouhani any time, any place, and these sanctions. How does that -- do you think that the pressure could lead to a meeting or
should lead to a meeting? What would -- what would be the purpose of a meeting given all your objections to this regime and your
- the comments today certainly seem to be encouraging the people of Iran to rise up against their leaders. Isn't that really what
you're doing here?
SENIOR ADMINISTRATION OFFICIAL ONE: Well, Andrea, I think - I mean, this is completely consistent with what the
President has done with other meetings with what you might refer to as less friendly regimes from North Korea to Russia, which is
not to give a lot of sanction -- any sanctions relief in advance of a meeting to make very clear that the United States will keep the
maximum pressure on these regimes until our goals are achieved. And in standing with the Iranian people, I think we're just -- we're
just standing up for basic human rights, human dignity, and for the economic opportunity they deserve.
SENIOR ADMINISTRATION OFFICIAL ONE: Well, Andrea, I think - I mean, this is completely consistent with what the
President has done with other meetings with what you might refer to as less friendly regimes from North Korea to Russia, which is
not to give a lot of sanction -- any sanctions relief in advance of a meeting to make very clear that the United States will keep the
maximum pressure on these regimes until our goals are achieved. And in standing with the Iranian people, I think we're just -- we're
just standing up for basic human rights, human dignity, and for the economic opportunity they deserve.
MODERATOR: We'll go on to the next question.
MODERATOR: We'll go on to the next question.
OPERATOR: And that's from Nick Schifrin with PBS News. Please, go ahead.
OPERATOR: And that's from Nick Schifrin with PBS News. Please, go ahead.
QUESTION: Hi, everyone. Thanks for taking this. [Senior Administration Official One], you said that the President will meet with
the Iranian leadership at any time to discuss a comprehensive deal. Just trying to understand -- trying to confirm that there are no
preconditions at all for that meeting given what Secretary of State Pompeo said that -- or suggested that the Iranian regime would
have to make some concessions or changes before that. And either to you or to [Senior Administration Official Two] perhaps, do
you believe or are you expecting the Iranian economy to collapse under the weights of these sanctions and the ones that will be -­
that will come back in a few months? Thanks.
QUESTION: Hi, everyone. Thanks for taking this. [Senior Administration Official One], you said that the President will meet with
the Iranian leadership at any time to discuss a comprehensive deal. Just trying to understand -- trying to confirm that there are no
preconditions at all for that meeting given what Secretary of State Pompeo said that -- or suggested that the Iranian regime would
have to make some concessions or changes before that. And either to you or to [Senior Administration Official Two] perhaps, do
you believe or are you expecting the Iranian economy to collapse under the weights of these sanctions and the ones that will be -­
that will come back in a few months? Thanks.
SENOR ADMINISTRATION OFFICIAL ONE: Well, I actually didn't say it. The President said that he'd meet. I just repeated what
he said. And I think I would defer to [Senior Administration Official Two] on the Secretary of State's comments, but what he was
saying there is he is not going to give up anything in advance of the meeting, that there are no preconditions. And so I think that's
really -- really the point.
SENOR ADMINISTRATION OFFICIAL ONE: Well, I actually didn't say it. The President said that he'd meet. I just repeated what
he said. And I think I would defer to [Senior Administration Official Two] on the Secretary of State's comments, but what he was
saying there is he is not going to give up anything in advance of the meeting, that there are no preconditions. And so I think that's
really -- really the point.
QUESTION: Just a few -­
QUESTION: Just a few -­
SENIOR ADMINISTRATION OFFICIAL ONE: Oh, and in terms of economic collapse, I'll hand that over to [Senior Administration
Official Three]. Do we expect the Iranian economy to collapse?
SENIOR ADMINISTRATION OFFICIAL ONE: Oh, and in terms of economic collapse, I'll hand that over to [Senior Administration
Official Three]. Do we expect the Iranian economy to collapse?
SENIOR ADMINISTRATION OFFICIAL THREE: Look, I mean, I'm not going to make any predictions about what's going to
happen to the Iranian economy other than to say that we are very intent on using these finance -- these financial sanctions to great
economic leverage. And -- look, again, the Iranian economy was already on a downward spiral before the President made his
decision, and that's as a result of the policies that the Iranians have espoused for quite some time. But there's no question that
these financial sanctions are going to continue to bring significant financial pressure against the world's largest state sponsor of
SENIOR ADMINISTRATION OFFICIAL THREE: Look, I mean, I'm not going to make any predictions about what's going to
happen to the Iranian economy other than to say that we are very intent on using these finance -- these financial sanctions to great
economic leverage. And -- look, again, the Iranian economy was already on a downward spiral before the President made his
decision, and that's as a result of the policies that the Iranians have espoused for quite some time. But there's no question that
these financial sanctions are going to continue to bring significant financial pressure against the world's largest state sponsor of
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terror.
terror.
MODERATOR: All right, we'll go on to the last question now.
MODERATOR: AII right, we'll go on to the last question now.
OPERATOR: And we'll go to Bahman Kalbasi with BBC News. Please go ahead.
OPERATOR: And we'll go to Bahman Kalbasi with BBC News. Please go ahead.
QUESTION: Thank you for taking this question. Are you saying that U.S. Government will have no responsibility in the misery they
will bring these sanctions on ordinary Iranians? Because you do talk about human rights and human dignity, and among these
sanctions are the fact that Iran will not be getting, for instance, commercial airlines -- new planes for its commercial airline. So - so
far we have had thousands of the Iranians dying in airline accidents throughout the years, and this sanction will make it impossible
for them to buy new ones. Is there not a responsibility here for U.S. Government to look out for the people that it says it wants to
support to lessen their misery, while in reality it is actually increasing it?
QUESTION: Thank you for taking this question. Are you saying that U.S. Government will have no responsibility in the misery they
will bring these sanctions on ordinary Iranians? Because you do talk about human rights and human dignity, and among these
sanctions are the fact that Iran will not be getting, for instance, commercial airlines -- new planes for its commercial airline. So - so
far we have had thousands of the Iranians dying in airline accidents throughout the years, and this sanction will make it impossible
for them to buy new ones. Is there not a responsibility here for U.S. Government to look out for the people that it says it wants to
support to lessen their misery, while in reality it is actually increasing it?
SENIOR ADMINISTRATION OFFICIAL ONE: Absolutely not. I think the blame for the situation is perfectly clear. It lies with the
SENIOR ADMINISTRATION OFFICIAL ONE: Absolutely not. I think the blame for the situation is perfectly clear. It lies with the
Iranian regime that has systematically destroyed that beautiful country over the last four decades.
Iranian regime that has systematically destroyed that beautiful country over the last four decades.
SENIOR ADMINISTRATION OFFICIAL TWO: Yeah this is [Senior Administration Official Two]. In terms of- I'll let [Senior
Adrrinistration Official Three] speak to --a little bit more the commercial aviation. The problem is that Iran does not use its
commercial aviation for commercial purposes. It uses its commercial aviation to carry people and weapons into the gray zone to
help advance the goals of the Shia militias and proxies operating around the region. And so, the burden of responsibility is on Iran
to use its commercial aviation for commercial aviation purposes.
SENIOR ADMINISTRATION OFFICIAL TWO: Yeah this is [Senior Administration Official Two]. In terms of- I'll let [Senior
Administration Official Three] speak to -a little bit more the commercial aviation. The problem is that Iran does not use its
commercial aviation for commercial purposes. It uses its commercial aviation to carry people and weapons into the gray zone to
help advance the goals of the Shia militias and proxies operating around the region. And so, the burden of responsibility is on Iran
to use its commercial aviation for commercial aviation purposes.
SENIOR ADMINISTRATION OFFICIAL THREE: Yeah I would just echo what [Senior State Administration Two] just said. Look,
what we know is that Iran systematically uses its aviation sector, including Mahan Air and a number of other airlines that we have
designated to continue to further its malign activity. I mean, you see these airlines like Mahan traveling back and forth repeatedly to
places like Syria to support the Assad regime and the brutal activities that it's undertaken. So really the pressure is on the regime to
stop engaging in this systematic malign behavior that's destabilizing the region, that's victimizing its own people and that's posing a
threat to some of our closest allies and partners.
SENIOR ADMINISTRATION OFFICIAL THREE: Yeah I would just echo what [Senior State Administration Two] just said. Look,
what we know is that Iran systematically uses its aviation sector, including Mahan Air and a number of other airlines that we have
designated to continue to further its malign activity. I mean, you see these airlines like Mahan traveling back and forth repeatedly to
places like Syria to support the Assad regime and the brutal activities that it's undertaken. So really the pressure is on the regime to
stop engaging in this systematic malign behavior that's destabilizing the region, that's victimizing its own people and that's posing a
threat to some of our closest allies and partners.
MODERATOR: All right, well that will conclude our call this morning. I thank everyone for taking part, for the calling in and to our
speakers for taking the time. Just to remind everyone that we --that this is on background to a senior administration official. The
contents of the call are -- will remain under embargo until 10:30 this morning, eastern time. Thank you everyone; have an enjoyable
day.
MODERATOR: All right, well that will conclude our call this morning. I thank everyone for taking part, for the calling in and to our
speakers for taking the time. Just to remind everyone that we --that this is on background to a senior administration official. The
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- 55 -

Senior Administration Officials Previewing Iran Sanctions
Senior Administration Officials Previewing Iran Sanctions
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- 56 -

Annex 213
U.S. Energy Information Administration, “OPEC Revenues Fact Sheet”, 21 August
2018

- 57 -

- 58 -

Independent Statistics & Analysis
Independent Statistics & Analysis
U.S. Energy Information
Administration
U.S. Energy Information
Administration
OPEC Revenues Fact Sheet
OPEC Revenues Fact Sheet
Last Updated: August 21, 2018
Last Updated: August 21, 2018
OPEC net oil export revenues
OPEC net oil export revenues
• The U.S. Energy Information Administration (EIA) estimates that members of the Organization of
the Petroleum Exporting Countries (OPEC) earned about $567 billion in net oil export revenues
(unadjusted for inflation) in 2017.
• The U.S. Energy Information Administration (EIA) estimates that members of the Organization of
the Petroleum Exporting Countries (OPEC) earned about $567 billion in net oil export revenues
(unadjusted for inflation) in 2017.
• The 2017 net oil export revenues increased by 29% from the $441 billion earned in 2016, mainly
as a result of the increase in average annual crude oil prices during the year and the increase in
OPEC net oil exports.
• The 2017 net oil export revenues increased by 29% from the $441 billion earned in 2016, mainly
as a result of the increase in average annual crude oil prices during the year and the increase in
OPEC net oil exports.
• Saudi Arabia accounted for the largest share of total OPEC earnings, $167 billion in 2017,
representing nearly one-third oftotal OPEC oil revenues.
• Saudi Arabia accounted for the largest share of total OPEC earnings, $167 billion in 2017,
representing nearly one-third of total OPEC oil revenues.
• EIA expects that OPEC net oil export revenues will rise to about $736 billion (unadjusted for
inflation) in 2018, based on forecasts of global oil prices and OPEC production levels in EIA's
August 2018Short-Term Energy Outlook (STEO).
• EIA expects that OPEC net oil export revenues will rise to about $736 billion (unadjusted for
inflation) in 2018, based on forecasts of global oil prices and OPEC production levels in EIA's
August 2018 Short-Term Energy Outlook (STEO).
• On a per capita basis, OPEC net oil export earnings are expected to increase by 27%, from
$1,147 in 2017 to $1,459 in 2018.
• On a per capita basis, OPEC net oil export earnings are expected to increase by 27%, from
$1,147 in 2017 to $1,459 in 2018.
• The expected increase in OPEC's net export earnings is attributed to higher forecast annual
crude oil prices in 2018 compared with 2017 despite expected lower output during 2018.
• The expected increase in OPEC's net export earnings is attributed to higher forecast annual
crude oil prices in 2018 compared with 2017 despite expected lower output during 2018.
• EIA's August 2018 STEO forecasts that OPEC crude oil production will average 32.3 million
barrels per day (b/d) in 2018, 0.3 million b/d lower than in 2017.
• EIA's August 2018 STEO forecasts that OPEC crude oil production will average 32.3 million
barrels per day (b/d) in 2018, 0.3 million b/d lower than in 2017.
• For 2019, OPEC revenues are expected to be $719 billion, as a result of lower forecast crude oil
prices. Slightly lower OPEC production and exports also contribute to the decline in expected
earnings.
• For 2019, OPEC revenues are expected to be $719 billion, as a result of lower forecast crude oil
prices. Slightly lower OPEC production and exports also contribute to the decline in expected
earnings.
Methodology
Methodology
• For each OPEC country, EIA derives net oil exports based on its oil production and consumption
estimates from the August 2018 edition of the STEO.
• For each OPEC country, EIA derives net oil exports based on its oil production and consumption
estimates from the August 2018 edition of the STEO.
• For countries that export several different varieties of crude oil, EIA assumes that the proportion
of total net oil exports represented by each variety is equal to the proportion of the total
domestic production represented by that variety. For example, if Arab Medium represents 20%
of total oil production in Saudi Arabia, the estimate assumes that Arab Medium also represents
20% of total net oil exports from Saudi Arabia.
• For countries that export several different varieties of crude oil, EIA assumes that the proportion
of total net oil exports represented by each variety is equal to the proportion of the total
domestic production represented by that variety. For example, if Arab Medium represents 20%
of total oil production in Saudi Arabia, the estimate assumes that Arab Medium also represents
20% of total net oil exports from Saudi Arabia.
- 59 -

• EIA assumes that these exports are sold at prevailing spot prices. Projected revenues are
estimated using EIA's forecasted for oil prices from the STEO. These forecasts incorporate
historical price differentials between spot prices for the different OPEC crude oil types and the
benchmark crude oil prices forecasted in the STEO (Brent, West Texas Intermediate, and the
average imported refiner crude oil acquisition cost).
• EIA assumes that these exports are sold at prevailing spot prices. Projected revenues are
estimated using EIA's forecasted for oil prices from the STEO. These forecasts incorporate
historical price differentials between spot prices for the different OPEC crude oil types and the
benchmark crude oil prices forecasted in the STEO (Brent, West Texas Intermediate, and the
average imported refiner crude oil acquisition cost).
OPEC net oil export revenues
OPEC net oil export revenues
billion dollars
$1,400
billion dollars
$1,400
$1,200
$1,200
$1,000
$1,000
$800
$800
$600
$600
$400
$400
$200
$200
$0
$0
1996 1998 2000 2002 2004 2006 2008 2010 2012 2014 2016 2018
-Nominal -Real (2017$)
1996 1998 2000 2002 2004 2006 2008 2010 2012 2014 2016 2018
-Nominal -Real (2017$)
-=
-=
Source: U.S. Energy Information Administration, derived from data published in the
August 2018 Short-Term Energy Outlook.
Source: U.S. Energy Information Administration, derived from data published in the
August 2018 Short-Term Energy Outlook.
eia
eia
OPEC per capita net oil export revenues
OPEC per capita net oil export revenues
dollars
$3,500
dollars
$3,500
forecas
forecas
$3,000
$3,000
t
t
$2,500
$2,500
$2,000
$2,000
$1,500
$1,500
$1,000
$1,000
$500
$500
$0
$0
1996 1998 2000 2002 2004 2006 2008 2010 2012 2014 2016 2018
Nominal -Real (2017$)
1996 1998 2000 2002 2004 2006 2008 2010 2012 2014 2016 2018
Nominal -Real (2017S$)
e1a
e1a
Source: U.S. Energy Information Administration, derived from data published in the
August 2018 Short- Term Energy Outlook.
Source: U.S. Energy Information Administration, derived from data published in the
August 2018 Short- Term Energy Outlook.
2
2
- 60 -

OPEC net oil export revenues
OPEC net oil export revenues
Nominal (billion $)
Real (billion 2017$)
Nominal (billion $)
Real (billion 2017$)
Jan­
Jan­
Jan­
Jan­
Jul
Jul
Jul
Jul
Country
Country
2016 2017 2018 2019 2018
2016 2017 2018 2019 2018
2016 2017 2018 2019 2018
2016 2017 2018 2019 2018
Algeria
Algeria
$20
$20
$22
$22
$16
$16
$20
$20
$22
$22
$15
$15
Angola
Angola
$26
$26
$31
$31
$22
$22
$27
$27
$31
$31
$21
$21
Congo (Brazzaville)
Congo (Brazzaville)
$3
$3
$5
$5
$5
$5
$3
$3
$5
$5
$5
$5
Ecuador
$4
$5
$3
$4
$5
$3
Ecuador
$4
$5
$3
$4
$5
$3
Equatorial Guinea
$4
$4
$3
$4
$4
$3
Equatorial Guinea
$4
$4
$3
$4
$4
$3
Gabon
Gabon
$3
$3
$4
$4
$3
$3
$3
$3
$4
$4
$3
$3
ran
Iran
$37
$37
$55
$55
$42
$42
$38
$38
$55
$55
$41
$41
Iraq
$53
$69
$54
$54
Iraq
$53
$69
$54
$54
$69
$69
$52
$52
Kuwait
Kuwait
$37
$37
$46
$46
$35
$35
$38
$38
$46
$46
$34
$34
Libya
Libya
$2
$2
$11
$11
$9
$9
$2
$2
$11
$11
$9
$9
Nigeria
Nigeria
$25
$25
$34
$34
$27
$27
$26
$26
$34
$34
$26
$26
atar
$24
$31
$23
$25
$31
$22
atar
$24
$31
$23
$25
$31
$22
Saudi Arabia
$134 $167
$130
$137
$167
$126
Saudi Arabia
$134 $167
$130
$137
$167
$126
United Arab Emirates
United Arab Emirates
$45
$45
$55
$55
$41
$41
$46
$46
$55
$55
$40
$40
Venezuela
Venezuela
$23
$23
$29
$29
$16
$16
$23
$23
$29
$29
$16
$16
OPEC
$441 $567 $736 $719 $428
$450
$567
$718 $686 $417
OPEC
$441 $567 $736 $719 $428
$450
$567
$718 $686 $417
View nominal or real_data (1996-2019)
View nominal or real data (1996-2019)
Note: Iranian net oil export revenues do not account for any discounts Iran may have offered its oil customers between the end of
Note: Iranian net oil export revenues do not account for any discounts Iran may have offered its oil customers between the end of
2011 and January 2016.
Source· U.S. Energy Information J\dministration, derived from data published in EIA's August 2018 Short-Term Energy Outlook.
2011 and January 2016.
Source: U.S. Energy Information Administration, derived from data published in EIA's August 2018 Short-Term Energy Outlook
OPEC per capita net oil export revenues
OPEC per capita net oil export revenues
Nominal ($)
Real (2017$)
Nominal ($)
Real (2017$)
Jan­
Jan­
Jan­
Jan­
Jul
Jul
Jul
Jul
Country
Country
2016 2017 2018 2019 2018
2016
2017 2018 2019 2018
2016 2017 2018 2019 2018
2016 2017 2018 2019 2018
Algeria
Algeria
$490
$490
$532
$532
$374
$374
$501
$501
$532
$532
$365
$365
Angola
Angola
$906
$906
$1,024
$1,024
$714
$714
$926
$926
$1,024
$1,024
$697
$697
Congo (Brazzaville)
Congo (Brazzaville)
$543
$543
$859
$859
$895
$895
$555
$555
$859
$859
$872
$872
Ecuador
Ecuador
$236
$236
$283
$283
$203
$203
$241
$241
$283
$283
$198
$198
Equatorial Guinea
Equatorial Guinea
$3,017 $3,109
$3,017 $3,109
$2,106
$2,106
$3,081 $3,109
$3,081 $3,109
$2,053
$2,053
Gabon
Gabon
$1,536 $1,753
$1,536 $1,753
$1,289
$1,289
$1,569 $1,753
$1,569 $1,753
$1,257
$1,257
Iran
Iran
$458
$458
$683
$512
$468
$683
$499
$683
$512
$468
$683
$499
Iraq
Iraq
$1,431 $1,815
$1,431 $1,815
$1,366
$1,366
$1,462 $1,815
$1,332
$1,462 $1,815
$1,332
Kuwait
Kuwait
$9,350 $11,303
$9,350 $11,303
$8,432
$8,432
$9,550 $11,303
$9,550 $11,303
$8,223
$8,223
Libya
Libya
$363
$363
$1,701
$1,701
$1,449
$1,449
$371
$371
$1,701
$1,701
$1,413
$1,413
Nigeria
Nigeria
$136
$136
$179
$179
$135
$135
$139
$139
$179
$179
$132
$132
atar
Qatar
$9,586 $11,844
$9,586 $11,844
$8,532
$8,532
$9,791 $11,844
$9,791 $11,844
$8,320
$8,320
Saudi Arabia
Saudi Arabia
$4,167 $5,092
$3,875
$4,256 $5,092
$3,779
$4,167 $5,092
$3,875
$4,256 $5,092
$3,779
United Arab Emirates
United Arab Emirates
$4,856 $5,828
$4,856 $5,828
$4,289
$4,289
$4,960 $5,828
$4,960 $5,828
$4,182
$4,182
Venezuela
Venezuela
$720
$720
$897
$897
$498
$498
$735
$735
$897
$897
$486
$486
OPEC
OPEC
$912
$912
$1,147 $1,459 $1,396 $847
$1,147 $1,459 $1,396 $847
$931
$931
$1,147 $1,423 $1,332 $826
$1,147 $1,423 $1,332 $826
View nominal or real data (1996-2019)
Note: Iranian per capita net oil export revenues do not account for any discounts Iran may have offered its oil customers between
View nominal or real data (1996-2019)
Note: Iranian per capita net oil export revenues do not account for any discounts Iran may have offered its oil customers between
3
3
- 61 -

the end of 2011 and January 2016.
the end of 2011 and January 2016.
Source: U.S. Energy Information Administration, derived from data published in EIA's August 2018 Short-Term Energy Outlook
Source: U.S. Energy Information Administration, derived from data published in EIA's August 2018 Short-Term Energy Outlook
4
4

- 62 -

Annex 214
U.S. Energy Information Administration, “Iran has produced and exported less crude
oil since sanctions announcement”, 23 October 2018

- 63 -

- 64 -

U.S. Energy Information
U.S. Energy Information
Administration
Administration
Today in Energy
Today in Energy
October 23, 2018
October 23, 2018
Iran has produced and exported less crude oil since sanctions
announcement
Iran has produced and exported less crude oil since sanctions
announcement
Iran liquid fuels, crude oil, and condensate production and exports (Jan 2011. Sep 2018)
Iran liquid fuels, crude oil, and condensate production and exports (Jan 2011. Sep 2018)
million barrels per day
million barrels per day
6
6
5
U.S. imposes
sanctions on
Iran's Central
Bank
EU import ban in effect
and sanctions on
shipping insurance in
Iran's oil sector enacted
U.S. announces resumption of
JCPOA Implementation Day
sanctions on Iran
and sanctions
".-+
5
U.S. imposes
sanctions on
Iran's Central
Bank
EU import ban in effect
and sanctions on
shipping insurance in
Iran's oil sector enacted
U.S. announces resumption of
JCPOA Implementation Day
sanctions on Iran
and sanctions
"+
4
4
liquid fuels production
liquid fuels production
3
3
2
2
crude oil and lease
condensate exports
crude oil and lease
condensate exports
1
1
0
0
2011
2012
2013
2014
2015
2016
2017
2011
La
2018
ea
2012
2013
2014
2015
2016
2017
201% e1a
Source: U.S. Energy Information Administration, Short-Term Energy Outlook, October 2018;
ClipperData
Source: U.S. Energy Information Administration, Short-Term Energy Outlook, October 2018;
ClipperData
Note: Liquid fuels production includes crude oil, lease condensate, hydrocarbon gas liquids, biofuels,
and refinery processing gain.
Iran's crude oil exports and production have declined since the May 2018 announcement by the United States
Note: Liquid fuels production includes crude oil, lease condensate, hydrocarbon gas liquids, biofuels,
and refinery processing gain.
Iran's crude oil exports and production have declined since the May 2018 announcement by the United States
that it would withdraw from the Joint Comprehensive Plan of Action (JCPOA) and reinstate sanctions against
Iran.
that it would withdraw from the Joint Comprehensive Plan of Action (JCPOA) and reinstate sanctions against
Iran.
The announcement included two wind-down periods to allow those doing business that involved Iran time to
comply. On August 6, 2018, the first wind-down period ended and triggered the re-imposition of some
sanctions. On November 4, 2018, the second wind-down period will end and trigger the re-imposition of full
sanctions, including a number of measures that target Iran's energy sector.
The announcement included two wind-down periods to allow those doing business that involved Iran time to
comply. On August 6, 2018, the first wind-down period ended and triggered the re-imposition of some
sanctions. On November 4, 2018, the second wind-down period will end and trigger the re-imposition of full
sanctions, including a number of measures that target Iran's energy sector.
According to data from ClipperData, Iran's exports of crude oil and condensate peaked in June at about 2.7
According to data from ClipperData, Iran's exports of crude oil and condensate peaked in June at about 2.7
million barrels per day (bid), more than 300,000 bid higher than the average during the first four months of the
year (before the May announcement of sanctions). In September,
Iran's crude oil and condensate exports fell
million barrels per day (bid), more than 300,000 bid higher than the average during the first four months of the
year (before the May announcement of sanctions). In September,
Iran's crude oil and condensate exports fell
to 1.9 million bid. Although some countries, such as France and South Korea, stopped importing crude oil and
condensate from Iran in July, other countries continue to import from Iran. The United States has not imported
crude oil and condensate from Iran in several decades.
to 1.9 million bid. Although some countries, such as France and South Korea, stopped importing crude oil and
condensate from Iran in July, other countries continue to import from Iran. The United States has not imported
crude oil and condensate from Iran in several decades.
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- 65 -

Monthly Iran crude oil and lease condensate exports (2018)
million barrels per day
- ea
Monthly Iran crude oil and lease condensate exports (2018)
million barrels per day
a
ea
3.0
3.0
2.5
2.5
2.0
other
France
Japan
2.0
other
France
Japan
1.5
1.5
Spain
Spain
United Arab
Emirates
United Arab
Emirates
1.0
1.0
Italy
Turkey
Italy
Turkey
0.5
0.5
South Korea
South Korea
India
India
0.0
China
Jan Feb Mar Apr May
China
0.0
Jun
Jul Aug
Sep
Jan Feb Mar Apr May
Jun
Jul Aug
Sep
Source: U.S. Energy Information Administration, based on ClipperData
ClipperData indicates that China and India collectively received nearly half of Iran's crude oil and condensate
exports in the first half of 2018. During this period, China's imports from Iran averaged 644,000 b/d and India's
imports from Iran averaged 554,000 b/d. In September, China's imports from Iran dropped to 441,000 b/d, the
second lowest level since December 2015, while India's imports from Iran were 576,000 b/d.
Source: U.S. Energy Information Administration, based on ClipperData
ClipperData indicates that China and India collectively received nearly half of Iran's crude oil and condensate
exports in the first half of 2018. During this period, China's imports from Iran averaged 644,000 b/d and India's
imports from Iran averaged 554,000 b/d. In September, China's imports from Iran dropped to 441,000 b/d, the
second lowest level since December 2015, while India's imports from Iran were 576,000 b/d.
Whether Iran's energy exports are declining entirely because of the sanctions or for other reasons is unclear.
Trade press reports indicate a willingness on India's part to at least partially comply with the sanctions, but
China had continued to import from Iran even when previous sanctions were in effect.
Whether Iran's energy exports are declining entirely because of the sanctions or for other reasons is unclear.
Trade press reports indicate a willingness on India's part to at least partially comply with the sanctions, but
China had continued to import from Iran even when previous sanctions were in effect.
In response to the announcement of sanctions by the United States, the European Union passed a statute to
protect European companies doing business in Iran from the effects of U.S. sanctions. Despite this effort, data
from ClipperData indicate that France has not imported any crude oil or condensate from Iran since June. In
addition, Italy's and Spain's imports from Iran in September were 27,000 b/d and 15,000 b/d lower than their
averages for the first half of the year. Some countries could continue to import Iran's crude oil and condensate
until the November 4 deadline, at which point they might stop importing from Iran.
In response to the announcement of sanctions by the United States, the European Union passed a statute to
protect European companies doing business in Iran from the effects of U.S. sanctions. Despite this effort, data
from ClipperData indicate that France has not imported any crude oil or condensate from Iran since June. In
addition, Italy's and Spain's imports from Iran in September were 27,000 b/d and 15,000 b/d lower than their
averages for the first half of the year. Some countries could continue to import Iran's crude oil and condensate
until the November 4 deadline, at which point they might stop importing from Iran.
Iran's exports have fallen at a faster rate than production. Shipping operators have decreased operations with
Iran, but Iran has continued to export largely through the state-run National Iranian Tanker Company (NITC)
and the Islamic Republic of Iran Shipping Lines. Trade press reports indicate that as countries continue to
decrease imports from Iran, some of Iran's shipping fleet is already being used as floating storage, where
crude oil is placed onto ships and stored indefinitely.
Iran's exports have fallen at a faster rate than production. Shipping operators have decreased operations with
Iran, but Iran has continued to export largely through the state-run National Iranian Tanker Company (NITC)
and the Islamic Republic of Iran Shipping Lines. Trade press reports indicate that as countries continue to
decrease imports from Iran, some of Iran's shipping fleet is already being used as floating storage, where
crude oil is placed onto ships and stored indefinitely.
Surplus crude oil production capacity in the Organization of the Petroleum Exporting Countries (OPEC) could
be used to replace some of Iran's crude oil barrels that are coming off the market. Saudi Arabia's Arab Light is
similar in composition to Iran Light crude oil and may provide refiners with a possible crude oil that would not
require refiners to make significant alterations to their crude slates.
Surplus crude oil production capacity in the Organization of the Petroleum Exporting Countries (OPEC) could
be used to replace some of Iran's crude oil barrels that are coming off the market. Saudi Arabia's Arab Light is
similar in composition to Iran Light crude oil and may provide refiners with a possible crude oil that would not
require refiners to make significant alterations to their crude slates.
In addition, trade press reports indicate that Saudi Arabia is offering sales of Khuff condensate. However, the
ex1ent to which Saudi Arabia and other OPEC members offer enough volumes of crude oil and condensate to
replace exports from Iran is unclear. After full sanctions are implemented in November, the total volumes of
crude oil and condensate coming off the market will become more apparent in the following months.
In addition, trade press reports indicate that Saudi Arabia is offering sales of Khuff condensate. However, the
extent to which Saudi Arabia and other OPEC members offer enough volumes of crude oil and condensate to
replace exports from Iran is unclear. After full sanctions are implemented in November, the total volumes of
crude oil and condensate coming off the market will become more apparent in the following months.
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Principal contributor: Matthew French
Principal contributor: Matthew French
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3 sur 3
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- 67 -

- 68 -

Annex 215
OPEC, “Monthly Oil Market Report”, 14 March 2019
Excerpts: p. 1, p. 60

- 69 -

- 70 -

Monthly Oil
M.
ly Oil
14 March 2019
14 March 2019
Feature article:
Feature article:
Review of global economic development
Review of global economic development
Oil market highlights
Feature article
Oil market highlights
Feature article
iii
iii
Crude oil price movements 1
Crude oil price movements 1
Commodity markets 9
Commodity markets 9
World economy 12
World economy 12
World oil demand 33
World oil demand 33
World oil supply 45
World oil supply 45
Product markets and refinery operations 62
Product markets and refinery operations 62
Tanker market 68
Tanker market 68
Oil trade 72
Oil trade 72
Stock movements 78
Stock movements 78
Balance of supply and demand 84
Balance of supply and demand 84
- 71 -

World Oil Supply
World Oil Supply
OPEC crude oil production
OPEC crude oil production
According to secondary sources, total OPEC-14 preliminary crude oil production averaged 30.55 mb/d in
February, a decrease of 221 tb/d over the previous month. Crude oil output decreased mostly in Venezuela,
Saudi Arabia and Iraq, while production inched up in Libya and Angola.
According to secondary sources, total OPEC-14 preliminary crude oil production averaged 30.55 mb/d in
February, a decrease of 221 tb/d over the previous month. Crude oil output decreased mostly in Venezuela,
Saudi Arabia and Iraq, while production inched up in Libya and Angola.
Table 5 - 9: OPEC crude oil production based on secondary sources, tb/d
2017
4Q18 Dec 18 Jan 19 Feb 19 Feb/Jan
Table 5 - 9: OPEC crude oil production based on secondary sources, tb/d
2017
2018
2Q18
3Q18 4Q18 Dec 18 Jan 19 Feb 19 Feb/Jan
Algeria
1,047
1,042
1,031
1,059
1,055
1,051
1,024
1,026
2
Algeria
1,047
1,042
1,031
1,059
1,055
1,051
1,024
1,026
2
Angola
1,634
1,505
1,493
1,470
1,497
1,484
1,435
1,457
22
Angola
1,634
1,505
1,493
1,470
1,497
1,484
1,435
1,457
22
Congo
252
318
324
320
320
327
317
316
0
Congo
252
318
324
320
320
327
317
316
0
Ecuador
530
519
519
526
517
518
517
522
5
Ecuador
530
519
519
526
517
518
517
522
5
Equatorial
Guinea
133
125
127
124
116
103
112
126
14
Equatorial
Guinea
133
125
127
124
116
103
112
126
14
Gabon
200
186
183
184
184
194
197
203
7
Gabon
200
186
183
184
184
194
197
203
7
Iran, I.R.
3,813
3,553
3,818
3,603
2,982 2,724 2,731
2,743
12
Iran, I.R.
3,813
3,553
3,818
3,603
2,982 2,724 2,731
2,743
12
Iraq
4,446 4,549 4,481
4,606 4,664 4,712 4,702 4,633
-70
Iraq
4,446 4,549 4,481
4,606
4,664 4,712 4,702 4,633
-70
Kuwait
2,708 2,746 2,707 2,797
2,774 2,800 2,723 2,709
-14
Kuwait
2,708 2,746 2,707 2,797
2,774 2,800 2,723 2,709
-14
Libya
811
952
883
892
1,059
949
883
906
23
Libya
811
952
883
892
1,059
949
883
906
23
Nigeria
1,658
1,719
1,653
1,704
1,741
1,733
1,731
1,741
10
Nigeria
1,658
1,719
1,653
1,704
1,741
1,733
1,731
1,741
10
Saudi Arabia
9,954
10,311
10,114
10,422
10,749
10,586
10,172
10,087
Saudi Arabia
9,954
10,311
10,114
10,422
10,749
10,586
10,172
10,087
-86
-86
UAE
2,915 2,986 2,873 2,982
3,234
3,238
3,075
3,072
-4
UAE
2,915 2,986 2,873 2,982
3,234
3,238
3,075
3,072
-4
Venezuela
1,911
1,354
1,406
1,272
1,191
1,172
1,150
1,008
-142
Venezuela
1,911
1,354
1,406
1,272
1,191
1,172
1,150
1,008
-142
Total OPEC
Total OPEC
32,013 31,864 31,613 31,961 32,082 31,591 30,770 30,549
-221
32,013 31,864 31,613 31,961 32,082 31,591 30,770 30,549
-221
Notes: Totals may not add up due to independent rounding.
Source: OPEC Secretariat.
Notes: Totals may not add up due to independent rounding.
Source: OPEC Secretariat.
Table 5 -10: OPEC crude oil production based on direct communication, tb/d
2017
2018 2018
Table 5 -10: OPEC crude oil production based on direct communication, tb/d
2017
2018 2Q18
3Q18 4Q18 Dec 18 Jan 19 Feb 19 Feb/Jan
3Q18 4Q18 Dec 18 Jan 19 Feb 19 Feb/Jan
Algeria
1,059
1,041
1,025
1,066
1,067
1,063
1,033
1,025
Algeria
1,059
1,041
1,025
1,066
1,067
1,063
1,033
1,025
-8
-8
Angola
1,632
1,478
1,477
1,475
1,440
1,445
1,470
1,423
-47
Angola
1,632
1,478
1,477
1,475
1,440
1,445
1,470
1,423
-47
Congo
263
327
328
329
330
323
353
367
15
Congo
263
327
328
329
330
323
353
367
15
Ecuador
531
517
516
524
516
520
524
533
10
Ecuador
531
517
516
524
516
520
524
533
10
Equatorial
Guinea
129
120
124
118
112
111
109
101
Equatorial
Guinea
129
120
124
118
112
111
109
101
-8
-8
Gabon
210
194
185
192
206
209
209
Gabon
210
194
185
192
206
209
209
Iran, I.R.
3,867
3,804
3,789
Iran, I.R.
3,867
3,804
3,789
Iraq
4,469 4,410
4,360
4,460
4,460 4,465 4,575
4,545
-30
Iraq
4,469 4,410 4,360 4,460 4,460 4,465 4,575
4,545
-30
Kuwait
Kuwait
2,704 2,737 2,704 2,784 2,755 2,802 2,715 2,707
2,704 2,737 2,704 2,784 2,755 2,802 2,715 2,707
-8
-8
Libya
Nigeria
1,536
1,605
1,526
1,611
1,671
1,797
1,646
1,731
Libya
Nigeria
1,536
1,605
1,526
1,611
1,671
1,797
1,646
1,731
85
85
Saudi Arabia
Saudi Arabia
9,959
9,959
10,317
10,317
10,128
10,128
10,399
10,399
10,790
10,790
10,643
10,643
10,243
10,243
10,136
10,136
-106
-106
UAE
2,967
3,001
2,876 2,998
3,285
3,250
3,070
3,050
-20
UAE
2,967
3,001
2,876 2,998
3,285
3,250
3,070
3,050
-20
Venezuela
2,035
1,516
1,523
1,451
1,469
1,511
1,488
1,432
Venezuela
2,035
1,516
1,523
1,451
1,469
1,511
1,488
-56
1,432
-56
Total OPEC
Total OPEC
Notes: .. Not available.
Totals may not add up due to independent rounding.
Source: OPEC Secretariat.
Notes: .. Not available.
Totals may not add up due to independent rounding.
Source: OPEC Secretariat.
60
60
OPEC Monthly Oil Market Report -- March 2019
OPEC Monthly Oil Market Report - March 2019

- 72 -

Annex 216
International Energy Agency, “IEA statement on global oil markets”, 23 April 2019

- 73 -

- 74 -

IEA statement on global oil markets
IEA statement on global oil markets
iea. org/news roo ml news/201 9/ april/iea-state men t-on-gl o ba 1-o i I-markets. htm I
iea. org/newsroom/ news/201 9/ april/iea-statem en t-on-glo ba 1-o i I-mar kecs. htm I
Home » Newsroom » News » 2019 » April
Home » Newsroom » News » 2019 » April
23 April 2019
23 April 2019
,
�
%
�
----...
The IEA will continue to monitor the oil market closely (Photograph: Shutterstock)
The IEA will continue to monitor the oil market closely (Photograph: Shutterstock)
The International Energy Agency is monitoring developments in global oil markets, and notes
that markets are now adequately supplied, and that global spare production capacity
remains at comfortable levels.
The International Energy Agency is monitoring developments in global oil markets, and notes
that markets are now adequately supplied, and that global spare production capacity
remains at comfortable levels.
Further tightening of sanctions on Iran will have an impact on its export capacity. Iranian
shipments of crude and condensates are running around 1.1 million barrels a day (mb/d) in
April, 300 000 barrels a day lower than March, and 1.7 mb/d lower than May 2018.
Further tightening of sanctions on Iran will have an impact on its export capacity. Iranian
shipments of crude and condensates are running around 1.1 million barrels a day (mb/d) in
April, 300 000 barrels a day lower than March, and 1.7 mb/d lower than May 2018.
As a result of OPE C's high compliance rate with the agreed supply cuts in the OPEC+ group,
global spare production capacity has risen to 3.3 mb/d, with 2.2 mb/d held by Saudi Arabia
and around 1 mb/d by the United Arab Emirates, Iraq and Kuwait.
As a result of OPE C's high compliance rate with the agreed supply cuts in the OPEC+ group,
global spare production capacity has risen to 3.3 mb/d, with 2.2 mb/d held by Saudi Arabia
and around 1 mb/d by the United Arab Emirates, Iraq and Kuwait.
Saudi Arabia's output in March dropped to 9.8 mb/d after it cut far more than required under
the OPEC+ supply cuts. That is more than 1 mb/d below the record high of 11.1 mb/d that
Saudi Arabia pumped last November.
Saudi Arabia's output in March dropped to 9.8 mb/d after it cut far more than required under
the OPEC+ supply cuts. That is more than 1 mb/d below the record high of 11.1 mb/d that
Saudi Arabia pumped last November.
Total oil supplies from the United States are expected to grow by 1.6 mb/d this year.
Furthermore, as infrastructure bottlenecks in the United States are easing, oil exports are
now more able to keep pace with production trends.
Total oil supplies from the United States are expected to grow by 1.6 mb/d this year.
Furthermore, as infrastructure bottlenecks in the United States are easing, oil exports are
now more able to keep pace with production trends.
112
1/2
- 75 -

OECD oil inventories at the end of February 2019 were at 2,871 million barrels, which is
above the five-year average.
OECD oil inventories at the end of February 2019 were at 2,871 million barrels, which is
above the five-year average.
The IEA notes that with global economic growth increasingly fragile, consumers and
producers should take steps to avoid higher oil prices that will prove painful to all alike.
The IEA notes that with global economic growth increasingly fragile, consumers and
producers should take steps to avoid higher oil prices that will prove painful to all alike.
The IEA will continue to monitor the oil market closely, advise member countries, and remain
engaged with major producers and consumers. As ever, the IEA stands ready to act if
necessary to ensure markets remain well supplied.
The IEA will continue to monitor the oil market closely, advise member countries, and remain
engaged with major producers and consumers. As ever, the IEA stands ready to act if
necessary to ensure markets remain well supplied.
2/2
2/2
- 76 -

Annex 217
U.S. Energy Information Administration, “April 2019 Monthly Energy Review”, 25
April 2019
Excerpts: p. 1, pp. 193-194

- 77 -

- 78 -

DO E/EIA-0035(2019/4)
DOE/EIA-0035(2019/4)
April 2019
April 2019
Monthly Energy Review
Monthly Energy Review
hdependent Statistics & Analysis
Independent Statistics & Analysis
U.S. Energy Information
Administration
U.S. Energy Information
Administration
www.eia.gov/mer
www.eia.gov/mer
- 79 -

Figure 11.lb World Crude Oil Production by Selected Countries
Figure 11.lb World Crude Oil Production by Selected Countries
(Million Barrels per Day)
(Million Barrels per Day)
Selected Non-OPEC and OPEC Countries
Selected Non-OPEC and OPEC Countries
January 2018
January 2018
Canada
4131
413
Canada
a January 2019
January 2019
3887
3887
3763
3 763
China
l 3812
l 3812
e
Egypt
Egypt
0 586
e
e!
0 586
1.953
1.953
Me0co
Men0o
1 647
1647
1650
1 650
Norway
1 488
ell1488
Russia
Russia
10 550
10973
United Kingdom
ms
10 550
l10973
United Kingdom
1115
m.
1115
United States
United States
9995
9.995
11.871
11.871
1.282
1.282
Algeria
Algeria
1192
4192
1.632
1.632
Angola
1572
Congo
vs
1572
Congo
0 327
vs
0 327
Ecuador
0513
0524
Ecuador
0513
0524
Gabon
es»
Gabon
0 200
ear
0 200
ran
4617
4617
lran
3401
3401
4445
4445
Iraq
Iraq
4865
4865
2760
2760
Kuwait
Kuwart
2 800
2800
�o'�
Libya
Libya
0 907
�,,.�
0 907
2140
2140
Agena
Agena
1 940
1.940
Saudi Arabia
Saudi Arabia
10.205
10.205
10095
10095
3181
3181
United Arab Emirates
United Arab Emirates
3371
3371
170
170
Venezuela
Venezuela
1261
1261
0
0
2
2
6
6
10
10
12
14
12
14
Note: OPEC is the Organization of the Petroleum Exporting Countries.
Note: OPEC is the Organization of the Petroleum Exporting Countries.
Web Page: http://www.eia.gov/totalenergy/data/monthly/#international.
Sources: Tables 11.1a and 11.1b
Web Page: http://www.eia.gov/totalenergy/data/monthly/#international.
Sources: Tables 11.1a and 11.1b
U. S. Energy Information Administration / Monthly Energy Review April 2019
U. S. Energy Information Administration / Monthly Energy Review April 2019
193
193
- 80 -

Table 11.1a World Crude Oil Production: Selected OPEC Members
Table 11.1a World Crude Oil Production: Selected OPEC Members
(Thousand Barrels per Day)
(Thousand Barrels per Day)
Congo
Congo
United
United
(Brazza- Ecua­
(Brazza­ Ecua­
Saudi Arab Vene- Total
Saudi Arab Vene- Total
Algeria Angola ville)
Algeria Angola ville)
dor Gabon
dor Gabon
Iran
Iran
Iraq Kuwait@ Libya Nigeria Arabia° Emirates zuela OPECb
Iraq Kuwait° Libya Nigeria Arabia Emirates zuela OPECb
1973 Average.
1973 Average
1,097
1,097
162
162
35
35
209
209
150 5,861
150 5,861
2,018 3,020 2,175 2,054
2,018 3,020 2,175 2,054
1975 Average
1975 Average
7,596
7,596
983
983
1,533
1,533
3,366 829,276
3,366 829,276
165
165
37
37
161
161
223 5,350 2,262 2,084
223 5,350 2,262 2,084
1,480
1,480
1980 Average
1980 Average
1,783
1,783
7,075
7,075
1,664
1,664
1,106
1,106
2,346 825,612
2,346 825,612
150
150
65
65
204
204
175
175
1,662 2,514
1,662 2,514
1,656
1,656
1,787 2,055
1,787 2,055
1985 Average.
1985 Average
9,900
9,900
1,709
1,709
1,036
1,036
2,168 825,151
2,168 25,151
231
231
120
120
281
281
172 2,250
172 2,250
1,433
1,433
1,023
1,023
1,059
1,059
1990 Average
1990 Average
1,495
1,495
3,388
3,388
1,180
1,193
1,193
1,180
1,677 15,358
1,677 R 15,358
475
475
165
165
285
285
270 3,088 2,040
1,175
1995 Average
1,375
1,810
6,410
1,162
2,117
270 3,088 2,040
1,175
1995 Average
1,375
1,810
6,410
1,162
2,117
2,137 322,527
646
646
2,137 22,527
188
188
392
392
365 3,643
365 3,643
560 2,057
560 2,057
1,390
1996 Average
1,390
1996 Average
1,993
1,993
8,231
8,231
2,233
1,227
2,233
1,227
2,750 R 25,616
2,750 R 25,616
709
709
201
201
396
396
368 3,686
368 3,686
579 2,062
1,401
1997 Average
2,001
8,218
2,278
579 2,062
1,401
1997 Average
2,001
8,218
2,278
1,259
1,259
2,938 R26,079
2,938 826,079
714
714
253
253
388
388
370 3,664
370 3,664
1,155 2,007
1,155 2,007
1998 Average
1,446 2,132
1998 Average
1,446 2,132
8,362
8,362
1,226
2,316
1,226
2,316
3,280 R27,399
3,280 R 27,399
735
735
265
265
375
375
352 3,634 2,150 2,085
352 3,634 2,150 2,085
1,390 2,153
1999 Average.
1,390 2,153
1999 Average
8,389
8,389
2,345
1,177
2,345
1,177
3,167 R 28,351
745
3,167 28,351
745
270
270
373
373
331 3,557 2,508
331 3,557 2,508
1,898
1,898
1,319
2000 Average.
1,319 2,130
2000 Average
2,130
7,833
7,833
2,169
1,214
2,169
1,214
2,826 R27,237
2,826 27,237
746
746
280
280
395
395
315 3,696 2,571
315 3,696 2,571
2,079
2,079
1,410 2,165
2001 Average
2001 Average
1,410 2,165
8,404
8,404
2,368
1,265
1,265
2,368
3,155 R 28,965
3,155 828,965
742
742
255
255
412
412
270 3,724 2,390
270 3,724 2,390
1,998
1,998
2002 Average
2002 Average
1,367 2,256
1,367 2,256
8,031
8,031
1,349
2,205
2,205
1,349
3,010 R 28,106
3,010 R 28,106
896
896
249
249
393
393
251 3,444 2,023
251 3,444 2,023
1,894
1,894
1,319 2,118
1,319 2,118
2003 Average
2003 Average
7,634
7,634
2,082
2,082
1,516
1,516
2,604 26,469
903
903
2,604 26,469
247
247
411
411
241 3,743
241 3,743
1,308 2,136
1,308 2,136
1,421
1,421
2004 Average
2004 Average
2,275
2,275
8,775
8,775
2,348
2,348
1,582
1,582
2,335 R27,865
2,335 R27,865
1,052
1,052
235
235
528
528
239 4,001
239 4,001
2,011 2,376
2,011 2,376
1,515 2,329
1,515 2,329
2005 Average ..
2005 Average .
9,101
9,101
2,478
2,478
1,692
1,692
2,557 R 30,371
2,557 R 30,371
1,239
1,239
229
229
532
532
266 4,139
266 4,139
1,878 2,529
1,878 2,529
2006 Average.
2006 Average
1,651
1,651
2,627
2,627
9,550
9,550
1,699
1,699
2,535
2,535
2,565 R31,795
2,565 R31,795
1,398
1,398
242
242
536
536
237 4,028
237 4,028
1,996 2,535
1,996 2,535
1,736 2,440
1,736 2,440
2007 Average.
2007 Average
9,152
9,152
2,636
2,636
1,708
1,708
2,511 31,488
2,511 31,488
1,724
1,724
207
207
511
511
244 3,912 2,086 2,464
244 3,912 2,086 2,464
1,787 2,350
1,787 2,350
2008 Average.
2008 Average .
8,722
8,722
2,603
2,603
1,705
1,705
2,490 R31,153
2,490 R31,153
1,951
1,951
233
233
505
505
248 4,050 2,375 2,586
248 4,050 2,375 2,586
2009 Average
2009 Average
1,803 2,165
1,803 2,165
9,261
9,261
1,585
1,585
2,821
2,821
2,510 R32,550
2,510 R 32,550
1,877
1,877
268
268
486
486
242 4,037 2,391
242 4,037 2,391
2,350
2,350
1,696 2,208
1,696 2,208
2010 Average
2010 Average
8,250
8,250
2,560
2,560
1,540
1,540
2,520 R30,791
2,520 R 30,791
1,909
1,909
340
340
486
486
246 4,080 2,399 2,300
246 4,080 2,399 2,300
1,710 2,408
1,710 2,408
2011 Average .
2011 Average .
8,900
8,900
2,570
2,570
1,540
1,540
2,410 R 31,596
2,410 R 31,596
1,756
1,756
288
288
500
500
241 4,054 2,626 2,530
241 4,054 2,626 2,530
485 2,474
485 2,474
2012 Average
2012 Average
9,458
9,458
2,849
2,849
1,532
1,532
2,500 R31,579
2,500 R31,579
1,787
1,787
260
260
504
504
230 3,387 2,983 2,635
230 3,387 2,983 2,635
2013 Average
2013 Average
1,432 2,457
1,432 2,457
9,832
9,832
1,462
1,462
2,994
2,994
2,500 R 32,822
2,500 832,822
1,803
1,803
239
239
526
526
220 3,113 3,054 2,650
220 3,113 3,054 2,650
978 2,307
978 2,307
2014 Average .
2014 Average .
9,693
9,693
2,938
2,938
1,420
1,420
2,500 R 31,754
2,500 R31,754
1,742
1,742
233
233
556
556
220 3,239 3,368 2,642
220 3,239 3,368 2,642
530 2,347
530 2,347
2015 Average
2015 Average
9,735
9,735
3,010
3,010
1,429
1,429
2,500 R 31,803
2,500 R 31,803
1,802
1,802
238
238
543
543
213 3,293 4,045 2,784
213 3,293 4,045 2,784
484 2,171
484 2,171
10,168
10,168
3,149
3,149
2,500 R 33,070
2,500 R33,070
2016 January.
2016 January.
1,350
1,350
1,798
1,798
218
218
534
534
210 3,652 4,467 2,931
210 3,652 4,467 2,931
451
451
February
February
2,159 10,240
2,159 10,240
3,245
3,245
1,350
1,350
2,400 R33,882
2,400 R33,882
1,793
1,793
214
214
540
540
210 3,792 4,217 2,891
210 3,792 4,217 2,891
441
441
March ··········-••··••··
March ··········-••··••··
2,120 10,240
2,120 10,240
3,025
3,025
1,350
1,350
2,400 R 33,460
2,400 R 33,460
1,798
1,798
198
198
552
552
210 4,093 4,217 2,911
210 4,093 4,217 2,911
401
401
April ············-••··••··
April ············-••··••··
1,993 10,240
1,993 10,240
3,050
3,050
1,350
1,350
2,400 R33,640
2,400 R 33,640
1,793
1,793
188
188
555
555
210 4,173 4,467 2,681
210 4,173 4,467 2,681
411
411
May.
May.
2,010 10,240
2,010 10,240
1,350
1,350
3,060
3,060
2,400 R 33,765
1,818
1,818
2,400 33,765
195
195
556
556
210 4,162 4,347 2,891
210 4,162 4,347 2,891
366
366
June ·········-••·····••··
June ·········-••·····••··
1,673
1,673
10,340
10,340
3,240
3,240
1,330
1,330
2,300 R33,675
2,300 R 33,675
1,823
1,823
203
203
550
550
210 4,150 4,397 2,891
210 4,150 4,397 2,891
411
411
July
July
1,811
1,811
10,540
10,540
3,270
3,270
1,350
1,350
2,280 R 34,093
2,280 R 34,093
1,829
1,829
217
217
545
545
210 4,224 4,407 2,931
210 4,224 4,407 2,931
391
391
August
August
1,764
1,764
10,670
10,670
1,350
1,350
3,290
3,290
2,220 R34,275
2,220 R34,275
1,833
1,833
212
212
549
549
210 4,226 4,452
210 4,226 4,452
2,941
2,941
331
331
September
September
1,694
1,694
10,640
10,640
3,320
3,320
1,350
1,350
2,210 R34,195
2,210 R 34,195
1,768
1,768
188
188
560
560
210 4,210 4,472
210 4,210 4,472
2,941
2,941
391
391
October
October
1,726
1,726
10,600
10,600
3,350
3,350
1,350
1,350
2,200 R34,193
2,200 R 34,193
1,618
1,618
176
176
552
552
200 4,312 4,557 2,941
200 4,312 4,557 2,941
631
631
November.
November.
1,854 10,590
1,854
10,590
3,330
3,330
1,350
1,350
2,190 R34,528
2,190 R 34,528
1,698
1,698
168
168
544
544
220 4,356 4,637 2,951
220 4,356 4,637 2,951
661
661
December
December
1,984
1,984
10,640
10,640
1,350
1,350
3,360
3,360
2,180 R34,976
2,180 R34,976
1,668
1,668
197
197
544
544
220 4,450 4,677 2,951
220 4,450 4,677 2,951
701
701
Average
Average
1,684
1,684
10,540
10,540
1,348
3,360
3,360
1,348
2,150 R34,719
2,150 R34,719
1,770
1,770
198
198
548
548
211 4,151 4,444 2,905
211 4,151 4,444 2,905
466
466
1,871
1,871
10,461
10,461
3,243
3,243
2,277 R 34,119
2,277 34,119
2017 January
2017 January
1,340
1,340
1,658
1,658
190
190
536
536
200 4,467 4,553 2,812
200 4,467 4,553 2,812
759
759
February
February
1,849
1,849
10,020
10,020
1,340
1,340
3,205
3,205
2,100 833,891
1,688
1,688
2,100 33,891
198
198
535
535
185 4,405 4,433 2,752
185 4,405 4,433 2,752
769
769
March.
March
1,869
1,869
10,040
10,040
3,185
3,185
1,316
2,090 R33,691
2,090 R 33,691
1,630
160
531
190 4,392 4,418 2,742
669
April
.....
1,730
9,992
3,165
1,306
2,090 R33,227
.....
1,316
1,630
160
531
190 4,392 4,418 2,742
669
April
1,730
9,992
3,165
2,090 R33,227
1,700
171
528
210 4,464 4,413 2,742
614
May
···········••·····••··
1,780
10,022
1,306
3,145
2,080 R 33,361
.......
1,306
1,700
171
528
210 4,464 4,413 2,742
614
May
1,780
10,022
3,145
2,080 R 33,361
1,660
200
533
200 4,464 4,463 2,742
859
June.
1,900
10,093
3,165
1,306
2,080 R 33,851
······················
1,306
1,660
200
533
200 4,464 4,463 2,742
859
June
1,900
··········-··········
10,093
3,165
1,306
2,080 R33,851
1,690
1,690
257
257
540
540
200 4,445 4,478 2,752
200 4,445 4,478 2,752
929
929
July
July
1,945
1,945
10,293
10,293
3,185
3,185
1,306
1,306
2,030 R34,236
2,030 R 34,236
1,670
1,670
278
278
541
541
210 4,495 4,488 2,742
210 4,495 4,488 2,742
1,084 2,022
1,084 2,022
August
August
10,243
10,243
3,185
3,185
1,306
1,306
2,030 R 34,480
2,030 R34,480
1,690
1,690
270
270
536
536
200 4,431
200 4,431
4,513 2,742
4,513 2,742
September
969 2,027
969 2,027
September.
10,183
10,183
1,306
1,306
3,185
3,185
2,025 R34,258
2,025 R34,258
1,670
1,670
273
273
529
529
200 4,490 4,553 2,762
1,004 2,038
October
10,233
3,185
1,256
2,010 34,434
200 4,490 4,553 2,762
1,004 2,038
October
10,233
3,185
1,256
2,010 34,434
1,695
1,695
299
299
526
526
200 4,439 4,403 2,772
1,039 2,021
November
10,204
3,175
200 4,439 4,403 2,772
1,039 2,021
November
10,204
1,276
3,175
1,276
1,960 R34,175
1,960 R34,175
1,600
1,600
310
310
521
521
190 4,532 4,333 2,742
1,059 2,065
December
10,174
3,145
190 4,532 4,333 2,742
1,059 2,065
December
10,174
3,145
1,306
1,306
1,890 R 34,018
1,890 R 34,018
1,640
1,640
321
321
520
520
200 4,596 4,393 2,732
Average
999 2,099
10,105
1,306
3,165
200 4,596 4,393 2,732
Average.
999 2,099
10,105
1,306
3,165
1,710 R33,967
1,666
1,666
1,710 R33,967
244
244
531
531
199 4,469 4,454 2,753
199 4,469 4,454 2,753
897
897
1,946
1,946
10,134
10,134
3,174
3,174
2,007 R 33,967
2,007 R 33,967
2018 January.
2018 January.
1,282
1,282
1,632
1,632
322
322
513
513
200 4,617 4,445 2,760
200 4,617 4,445 2,760
1,092
1,092
February
February
2,140
2,140
10,205
10,205
3,181
1,272
1,272
3,181
1,710 R34,275
1,710 R34,275
1,622
1,622
333
333
513
513
200 4,624 4,485 2,760
200 4,624 4,485 2,760
1,067 2,110
March
.......
1,067 2,110
March
10,145
10,145
1,232
3,141
3,141
1,592
1,670 R34,118
1,670 R 34,118
371
511
200 4,538 4,495 2,770
1,062
April
2,080
10,095
3,121
1,232
1,630 R33,873
......
1,232
1,592
371
511
200 4,538 4,495 2,770
1,062
April
2,080
10,095
3,121
1,232
1,630 R33,873
1,587
1,587
370
370
517
517
190 4,515 4,455 2,760
190 4,515 4,455 2,760
1,082
1,082
May.
May ···········••·····••··
2,060
2,060
10,105
10,105
3,131
3,131
1,262
1,262
1,600 R 33,780
1,600 R 33,780
1,592
1,592
365
365
516
516
200 4,462 4,505 2,760
200 4,462 4,505 2,760
1,067
1,067
June ·········-••·····••··
June ·········-••·····••··
1,880
1,880
10,165
10,165
1,282
1,282
3,111
3,111
1,545 R 33,606
1,545 R 33,606
1,562
1,562
342
342
517
517
200 4,508 4,589 2,770
200 4,508 4,589 2,770
827
827
July.
July .
1,810
1,810
10,465
10,465
3,151
3,151
1,292
1,292
1,485 R33,679
1,485 R 33,679
1,572
1,572
332
332
523
523
180 4,428 4,619 2,850
180 4,428 4,619 2,850
747
747
August
August
1,860
1,860
10,525
10,525
3,181
3,181
1,282
1,282
1,450 R33,735
1,450 R33,735
1,582
1,582
347
347
530
530
200 4,271
200 4,271
4,690 2,850
4,690 2,850
1,067
1,067
September
September
1,930
1,930
10,465
10,465
3,221
3,221
1,242
1,242
1,405 34,016
1,405 R34,016
1,602
1,602
342
342
519
519
200 4,151
200 4,151
4,715 2,850
4,715 2,850
1,157 2,030
1,157
October.
October.
2,030
10,565
10,565
1,242
1,242
3,221
3,221
1,572
1,572
1,371 34,141
1,371 34,141
337
337
514
514
200 4,151
200 4,151
4,745 2,850
4,745 2,850
1,157
1,157
November
November
1,990
1,990
10,765
10,765
3,271
3,271
1,242
1,242
1,341 R34,311
1,341 R34,311
1,622
1,622
307
307
515
515
180 3,451
180 3,451
4,785 2,850
4,785 2,850
1,227 2,000
1,227
December
December
2,000
11,045
11,045
3,411
3,411
1,242
1,242
1,321 R34,117
1,321 R34,117
1,592
1,592
307
307
519
519
200 3,351
200 3,351
4,815 2,850
4,815 2,850
957 2,010
957 2,010
Average
Average
10,545
10,545
3,451
3,451
1,259
1,259
1,291 R33,281
1,29 1 R33,281
1,594
1,594
340
340
517
517
196 4,254 4,613 2,807
196 4,254 4,613 2,807
1,042
1,042
1,991
1,991
10,425
10,425
3,216
3,216
1,484 R 33,909
1,484 33,909
2019 January
2019 January
1,192
1,192
1,572
1,572
327
327
524
524
200 3,401
200 3,401
4,865 2,800
4,865 2,800
907
907
1,940
1,940
10,095
10,095
3,371
3,371
1,261 32,606
1,261 32,606
a Except for the period from August 1990 through May 1991, includes about
a Except for the period from August 1990 through May 1991, includes about
years.
years.
one-half of the production in the Kuwait-Saudi Arabia Neutral Zone. Kuwaiti Neutral
one-half of the production in the Kuwait-Saudi Arabia Neutral Zone. Kuwaiti Neutral
R=Revised.
R=Revised.
Zone output was discontinued following Iraq's invasion of Kuwait on August 2,
Zone output was discontinued following Iraq's invasion of Kuwait on August 2,
Notes: Data are for crude oil and lease condensate; they exclude natural gas
Notes: Data are for crude oil and lease condensate; they exclude natural gas
1990, but was resumed in June 1991. As of July 2015 all Neutral Zone production
1990, but was resumed in June 1991. As of July 2015 all Neutral Zone production
plant liquids. • Monthly data are often preliminary figures and may not average to
plant liquids. • Monthly data are often preliminary figures and may not average to
is offline. Data for Saudi Arabia include approximately 150 thousand barrels per
is offline. Data for Saudi Arabia include approximately 150 thousand barrels per
VEE"4:57.±:::73%:4:{27:corsor«a=
VEE"&4:57.±::3%:4:2:zrsor«a=
the annual totals because of rounding or because updates to the preliminary
the annual totals because of rounding or because updates to the preliminary
monthly data are not available.
Web Page: See http://www.eia.gov/totalenergy/data/monthly/#international
On Tables 11.1a and 11.1b, countries are classified as "OPEC" or "Non-OPEC" in
monthly data are not available.
Web Page: See http://www.eia.gov/totalenergy/data/monthly/#international
On Tables 11.1a and 11.1b, countries are classified as "OPEC" or "Non-OPEC" in
(Excel and CSV files) for all available annual and monthly data beginning in 1973.
(Excel and CSV files) for all available annual and monthly data beginning in 1973.
all years based on their status in the most current year. For example, Equatorial
all years based on their status in the most current year. For example, Equatorial
Sources: See end of section.
Sources: See end of section.
Guinea joined OPEC in May 2017 and is thus included in "Total OPEC" for all
Guinea joined OPEC in May 2017 and is thus included in "Total OPEC" for all
194
194
U.S. Energy Information Administration/ Monthly Energy Review April 2019
U. S. Energy Information Administration/ Monthly Energy Review April 2019

- 81 -

- 82 -

Annex 218
E-mail from Honeywell (China) to Sinopec, 18 May 2018

- 83 -

- 84 -

Statement for ARUP ICSS
Liu,Hong Yang
Statement for ARUP ICSS
Liu,Hong Yang
/A:
/A:
[email protected], [email protected]
2018/05/18 10:23
[email protected], [email protected]
2018/05/18 10:23
ik:
ik:
"Cheng, Wei (Ex CHOI)", "Liu, Hong Liang (Ex CH03)", "Zheng, Gan", "Zhang, Yu
(EX CHO4)", "[email protected]"
"Cheng, Wei (Ex CHOI)", "Liu, Hong Liang (Ex CH03)", "Zheng, Gan", "Zhang, Yu
(EX CHO4", "[email protected]"
I#. #Ali &.
(%#. #Ali
.&.
'Bl A: "Liu,Hong Yang" <[email protected]> 3]###...
Bl A: "Liu,Hong Yang" <Hongyang. [email protected]> Jlk#...
kg4/ A: "[email protected]" <[email protected]>, "[email protected]"
<[email protected]>
kg4/ A: "[email protected]" <[email protected]>, "[email protected]"
<[email protected]>
k: "Cheng, Wei (Ex CHO)" <[email protected]>, "Liu, Hong Liang (Ex
CHO3)" <[email protected]>, "Zheng, Gan"
<[email protected]>, "Zhang, Yu (EX CH04)" <[email protected]>,
"[email protected]" <[email protected]>
k: "Cheng, Wei (Ex CHO)" <[email protected]>, "Liu, Hong Liang (Ex
CHO3)" <[email protected]>, "Zheng, Gan"
<[email protected]>, "Zhang, Yu (EX CH04)" <[email protected]>,
"[email protected],cn" <[email protected]>
R: Et'Bt.8.
RC: EBt.kl..
Dear Mr. Mao,
Dear Mr. Mao,
Pis. kindly note that HON New Iran Policy has been changed and updated as below, in response to US
president Trump's May 8th announcement that he is terminating the United States' participation in the Joint
Comprehensive Plan of Action(the I ran nuclear deal).
Pis. kindly note that HON New Iran Policy has been changed and updated as below, in response to US
president Trump's May 8th announcement that he is terminating the United States' participation in the Joint
Comprehensive Plan of Action(the I ran nuclear deal).
1. Al!Iran orders/Iran business opportunity after May 8" 2018 must STOP or PEND.
1. Al!Iran orders/lran business opportunity after May 8' 2018 must STOP or PEND.
2.
2.
So, we regret to say we have to stop all activities about ARUP with you and end user.
So, we regret to say we have to stop all activities about ARUP with you and end user.
Thanks for your kind attention, and any other question, pis. do feel free to contact us. Thanks.
Thanks for your kind attention, and any other question, pls. do feel free to contact us. Thanks.
Best Regards,
Best Regards,
Liu Hong Yang
Honeywell (China) Ltd., EPC Export
Liu Hong Yang
Honeywell (China) Ltd., EPC Export
A1 Building, C&W Industry Zone, No.14 Jiu Xian Qiao Road, Cha0Yang District, Beijing, 100015
A1 Building, C&W Industry Zone, No.14 Jiu Xian Qiao Road, ChaoYang District, Beijing, 100015
Cell: 13911893856
Cell: 13911893856
Honeywell
Honeywell
'£ tt cot¢to
file:/ //C:/U sers/maosong/AppData/Local/Temp/notes256C9A/-web8302.htm
file:///C:/Users/ma0song/AppData/Local/Temp/notes256C9A/-web8302.htm
2018/7/2
2018/7/2

- 85 -

- 86 -

Annex 219
Letter from EEW China Marketing & Services to Sinopec, 31 May 2018

- 87 -

- 88 -

Ii'
Fw:.AW: AW: Important Re: SEI Abadan - EEW ref. 141221
+ z:er
Fw: AW: AW: Important Re: SEI Abadan - EEW ref. 141221
eewbeijing
&:
chengjie
2018/05/3113:26
chengjie
2018/05/3113:26
±:
±:
"[email protected]"
"land [email protected]"
%s%mi#(±.s5
Bl: "eewbeijing" <[email protected]>
: "chengjie" <[email protected]>
: "[email protected]" <[email protected]>
$%%pl(is3
#: "eewbeijing" <[email protected]>
Hk: "chengjie" <[email protected]>
#): "[email protected]" <[email protected]>
R : EH±HS.
RC: EH±HS.
@#¥ ! <FlLIE, LJ EIS , #RAE HJ FE~SGVSR.± EE I IJ I8RI I #8IE) SHH EDF (9 #l#. i9An
@#¥ ! &FlLISI, LJ EIS . #RA HJ FE~SGWSR.± EE I IJ IBhI A #8IE] HAE0 9%#l#. i#950
F:
F:
Considering current political situation, in case new sanctions will be remitted during project
execution, under the circumstances for this specific project with high sophisticated and critical
material grade involved and by considering the strict terms & conditions we'd better stop to follow it
Considering current political situation, in case new sanctions will be remitted during project
execution, under the circumstances for this specific project with high sophisticated and critical
material grade involved and by considering the strict terms & conditions we'd better stop to follow it
Sorry to say but the potential risk to run into troubles with this kind of project is too high. For sure, as
soon as the political situation becomes clearer for all of us, it is with our top management to decide
and find a proper way to deal with it - for the whole EEW-group.
Best Regards.
Sorry to say but the potential risk to run into troubles with this kind of project is too high. For sure, as
soon as the political situation becomes clearer for all of us, it is with our top management to decide
and find a proper way to deal with it - for the whole EEW-group.
Best Regards.
2018-05-31
2018-05-31
Hannah Wang
Director of Representative Office
Hannah Wang
Director of Representative Office
EEW China Marketing & Services
Address: H805 Fortune Court, Jia 6, Shuguang Xi Road,
Chaoyang Dist Beijing China 100028
EEW China Marketing & Services
Address: H805 Fortune Court, Jia 6, Shuguang Xi Road,
Chaoyang Dist Beijing China 100028
Email [email protected]
Cell: +86 18600659778
Tel: +86-10-8265-7877/6338
+86-10-8444-0038
Fax. +86-10-8265-9242
Email eewbeijing@126 com
Cell: +86 18600659778
Tel: +86-10-8265-7877/6338
+86-10-8444-0038
Fax. +86-10-8265-9242
fi le:///C:/Users/chengj ie.CORP/AppData/Local/Temp/notes256C9 A/~web2 l 66.htm
file:///C:/Users/chengjie.CORP/AppData/Local/Temp/notes256C9A/~web2l66.htm
2018/5/31
2018/5/31
- 89 -

- 90 -

Annex 220
Letter from Phocéenne to Sinopec, 7 June 2018

- 91 -

- 92 -

$
Fwd: {
: [El : ARUP: 1071-S1/O1-EP-PI-IR-5103 Alloy Steel Welded Pipe­
Fwd: {: El: ARUP: 1071-S/O1-EP-PI-IR-5103 Alloy Steel Welded Pipe­
L
Commercial Clarification-Urgent
Karen
f di Commercial Clarification-Urgent
• Karen
w [k{:
('A:.
chengjie
2018/06/07 17.32
chengjie
2018/06/07 17:32
[& # if#.5.
ME. # If#.6.
'B( : Karen <[email protected]>
'g{ A: Karen <[email protected]>
/{i-A: [email protected]
//A: [email protected]
FYI
FYI
~] #8 iPone
~ #8 iPone
B('A: Edit Jermy <[email protected]>
3(A: Edit Jermy <[email protected]>
EH: 2018#5]17H GMT+8 20:00:41
EH#: 2018#5/17H GMT+8 20:00:41
g/±A: "[email protected]" <[email protected]>, "[email protected]"
<[email protected]>
g/± A: "[email protected]" <[email protected]>, "[email protected]"
<[email protected]>
#b): Maryse KERGUEN <[email protected]>
#bi&: Maryse KERGUEN <[email protected]>
kM: ll'. {: El: ARUP: 1071-S1/O1-EP-PI-IR-5103 Alloy Steel Welded
Pipe-Commercial C larification-Urgent D
kEM: [al&i. {S: [Eli: ARUP: 1071-S1/O1-EP-PI-IR-5103 AIloy Steel Welded
Pipe-Commercial Clarification-Urgent□
Dear Mr Cheng
Dear Mr Cheng
Thank you for your continuous trust
Thank you for your continuous trust
Unfortunately following the US sanctions against Iran, we are not able to continue to support
Sinopec
for ABADAN project, as the destination is Iran and also the end user is Iranian (NIOEC)
We regret but we are obliged to leave behind this project therefore please do not consider our
offers anymore
Unfortunately following the US sanctions against Iran, we are not able to continue to support
Sinopec
for ABADAN project, as the destination is Iran and also the end user is Iranian (NIOEC)
We regret but we are obliged to leave behind this project therefore please do not consider our
offers anymore
Thank you for,your understanding and cooperation
Thank you for,your understanding and cooperation
In the meantime we remain at your full disposal for any other request
In the meantime we remain at your full disposal for any other request
Best regards
Best regards
EditJermy
EditJermy
Back Office Sales & Asia area
junior sales
Back Office Sales & Asia area
Junior sales
c
c
PHCCEENNE
PHOCENNE
9/11 rue de Lisbonne
13742 VITROLLES
9/11 rue de Lisbonne
13742 VITRO.LES
Bureau: +33 4 42 79 40 01
Bureau: +33 4 42 79 40 01
Mobile: + 33 611 54 73 22
Mobile: + 33 6 11 54 73 22
file:///C:/Users/chengjie.CORP/AppData/Local/Temp/notes256C9A/--web8786.htmn
file:///C:/Users/chengjie.CORP/AppData/Local/Temp/notes256C9A/--web8786.htmn
2018/6/7
2018/6/7

- 93 -

- 94 -

Annex 221
E-mail from Roots Systems to Sinopec, 18 June 2018

- 95 -

- 96 -

i
">
mazj8sei. com. cn" Gmaz jsei. com. cn,
mazj8sei. com. cn" Gmazj@sei. com. cn,
1ejiadong@sinopec. con <lejiadong@sinopec. com, "hong jun@soi. com. cn"
' %
"1ejiadong@sinopec. com <lejiadong@sinopec. com, "hong jun@soi. com. cn"
<hong jun~sci. com. cm, "liuxin2&sei. com. cn" 'liuxin2@sei. com. cn, Sean Swales
<hong jun@sci. com. cm, "liuxin2@sei. com. cn" 'liuxin2@sei. com. cn, Sean Swales
sean, sales@rotolok. co. uk, Helen Macefield Helen{@roots-blowers. com, Nigel
.
sean, sales@rotolok. co. uk>, Helen Macefield HelenM@roots-blowers. com, Nigel
"
:SE;
RE: ARUP For Quotation I07I-SI PM-RFQ-0I1 435l A0-R00TS S. U. N2
COMPRESSOR (C--5703)-Request on Confirmation
'A,. Graham Hook <Graham@roots-blowers. com) - HJ] - 2018/06/18 19:18
±SE:
RE: ARUP For Quotation I071-SI PM-RFQ-0I1 435l A0-ROOTS S. U. N2
COMPRESSOR (C--5703)-Request on Confirmation
kt,. Graham llook <Graham@roots-blowers. com -HJ/]-- 2018/06/18 19: 18
ili:
tit l {Es#'is.
i1:
t#A lt.{Es#in.
Dear Zhijiao,
Dear Zhijiao,
Qur tender reference E18- 13823 for NIQC Abadan Refinery, Hydrogen Plant SU
Qr tender reference E18- 13823 for NOC Abadan Refinery, lydrogen Plant Su
compressor C-5703
compressor C-5703
t
t
Your e-mail dated 13 June 2018.
Your e-mail dated 13 June 2018.
Subject: The supply of goods to lran as outlined in the commercial letter from David
Subject: The supply of goods to Iran as outlined in the commercial letter from David
Lee.
Lee.
Regrettably we have decided that Roots Systems ltd will withdraw our tender at this
time.
Regrettably we have decided that Roots Systems ltd will withdraw our tender at this
time.
We would very much wish to support Sinopec and NIOC with this project but, as you will
appreciate, there is external pressures bearing down that make such a transaction
difficult to execute with confidence. The last thing we would wish for is to let the
project down.
We would very much wish to support Sinopec and NIOC with this project but, as you will
appreciate, there is external pressures bearing down that make such a transaction
difficult to execute with confidence. The last thing we would wish for is to let the
project down.
Should there be a change in the political atmosphere enabling us to reverse this
sentiment then we will of course be happy to manufacture and supply the compressor.
Should there be a change in the political atmosphere enabling us to reverse this
sentiment then we will of course be happy to manufacture and supply the compressor.
Best regards,
Best regards,
Graham Hook
Graham Hook
From: Nigel Dolphin
From: Nigel Dolphin
Sent: 13 June 2018 09:46
Sent: 13 June 2018 09:46
To: Graham Hook <[email protected]>
To: Graham Hook <[email protected]>
Subject: FW: ARUP For Quotation-1071-S1-PM-RFQ-011-4351-A0-ROOTS S.U.N2
COMPRESSOR(C-5703)-Request on Confirmation
Subject: FW: ARUP For Quotation-1071-$1-PM-RFQ-011-4351-A0-ROOTS S.U.N2
COMPRESSOR(C-5703)-Request on Confirmation
From: [email protected] [mailto:[email protected]]
From: [email protected] [mailto:[email protected]]
Sent: 13 June 2018 06:29
Sent: 13 June 2018 06:29
To: Helen Macefield <[email protected]>
To: Helen Macefield <[email protected]>
Cc: [email protected]; [email protected]; [email protected]
Cc: [email protected]; [email protected]; [email protected]
Subject: ARUP For Quotation-1071-S1-PM-RFQ-011-4351-A0-RO0TS S.U.N2
Subject: ARUP For Quotation-1071-S1-PM-RFQ-011-4351-A0-ROOTS S.U.N2
COMPRESSOR(C-5703)-Request on Confirmation
COMPRESSOR(C-5703)-Request on Confirmation
Dear Sir:
Dear Sir:

- 97 -

- 98 -

Annex 222
Letter from Wuxi Compressor to Sinopec, 19 June 2018

- 99 -

- 100 -

Proeci No.·107f
Proeci No.·107f
Buder s Company Name WIX! CURES.SOR Co1TD
Buder s Company Name WXI CUAESSOR Co1TO
loquiry No 1071-C1-PM-RF0-009-4306-A41
loquiry No 1071-C1-PM-RF0-00-4306-A41
A~dress NQ 199.Xe Road, Machinery, Optical and Electronic Industria' Pae
Aortess NQ,199Xhe Road, Machinery. Optical and Electronic Idustria' Pare
Hongstua, New Distnct Mund, Chin
MR NO: 107144-£9.94-MR--4309
MR NO' 107144£9.PM-MR-4309
Contact in Charge: AMr, Wang Yorgran/ Mr Yi
Hongs-ha, New Dustnct Mord, China
Contact in Charge AMr, Wang Yorgran/ Mr. Yi
Contact E-mail Box wyr@compressor-y corn4 [email protected]
Quotation No.. W7AC043
Quotation No. W7AC043
Contact Email Box [email protected]-y corn / [email protected]
CortactAwatabe Phone 13771065312/ 17701570817
Cortact Aval«atbie Phone 13771065312/ 17701570817
Quotation fRevisin. REV
Quotation Revision. REV O
Subject:Confrmat
i n
instructigng -----·
Dear Mr Ma :
The US sanctions on Iran is a very serious international trade issue that has involved trade between many countries, and
Dear M: Ma :
The US sanctions on Iran is a very serious international trade issue that has involved trade between many countries, and
KOBELCO will also be among them Therefore, we are sorry to inform you that KOBEL CO did not participate in Iranian business
KOBELCO wilt also be among them Therefore, we are sorry to inform you that KOBEL CO did not participate in Iranian business
until the relevant sanctions were cancelled in the United States.
Thank you again for your understanding and support!
until the relevant sanctions were cancelled in the United States.
Thank you again for your understanding and support!
-s K.,
Eider's'Campany Name. WXI COMPRESSOR Co.,LTD
¢ >
J<fliii
Aulilf'od �(Print):
W�
Date. 2018.8.19

- 101 -
G
YONGMAN
TN'
,,
r{stare
+.
'Signature
\.-,..- ... ,,,.Y ···-
.
.
·.g:. rte: vice De
r ot sales
Date 2018.8.19

- 102 -

Annex 223
Letter from Sulzer to Sinopec, 19 June 2018

- 103 -

- 104 -

SULZER
SULZER
J.34%415 ,
.#3#% 415 ,
.81< {{42 43313
+.181< {42 43313
er umw Suh ind
uer ans uh ind
3434 )an5in 3, Nw Dtrket, Sura Ct4#
431 )thin 3, New Drket, Sura Ct#
213151
213151
Date:
Date:
June 19, 2018
June 19, 2018
T:
To:
Sinaper Engineering Incorporation
From.
Re:
From.
Sulzer Pups Suzhou Ltd.
R:
Iran ARUP Project
Sinopec Engineering Incorporation
Sulzer Pups Suzhou Ltd.
Iran ARUP Project
Dear Srs.
Dear Srs.
Thanks for your {undated) letter regarding the Iran ARUP project (sutyect; Request on
Thanks for your {undated) letter regarding
the Ian ARUP project (sutyect; Request on
Con/mation' Suter umps Suzhou Ltd., {"we"). 2s the manufacturer o! VGO Feed umps
Com3tion Suer umps Suzhou Ltd. {"we"}). as the manufacturer oi VGO Feed Fums
(the "Pumg Products"}, are honored te supply the Fump Products through our distributor
(the "Pum Products"}, are honored te supply the Fump Products through our distributor
Beijing Faith Engineering & Technology Co.. Ltd. (Beijing Faith?), which we understand nas
Beijing Faith Engineering & Technology Co.. Ltd (Beijing Faith;), which we understand nas
submitted a bid to you tor the tran ARUP Project. As the Pump Products manufacturer, w
submitted a bi! to you tor the tran ARUP Project. As the Pump Products manufacturer, w
are always dedicated to providing high-quality service and products i accordance with the
are always dedicated to providing high-quality service and products it accordance with the
relevant cuotracts and applicable laws.
relevant cuotracts and applicable laws.
However, we deeply regret we have to withdraw from the putfi tiding for Iran ARUS Frojct.
However, we deeply regret we have to withdraw from the putfi tiding for Iran ARUS Frojct.
Valuing high our longstanding and very successful business relationship to-date, we fest
Valuing high our longstanding and very successful business relationship to-date, we fest
obliged to explain you in more detat - and in person - our reasoning for this very difficult
obliged to explain you in more detail - and in person - our reasoning for this very difficult
decision.
decision.
At the tire the respective project open ths public bidding, cur approach to the iran mark«at
At the tire the respective project open ths public bidding, our approach to the iran mariat
(including the aforementioned cases) was relying an the assessment/ fse: to that date, that al
(including the aforementioned cases) was relying an the assessment' fse; to that date, 1hat al
parties participating 1 tho ±FRAN deal rareir cornnwtted to this deti's obligations, tus enabling
us to engage into the discussed projects as foreseen.
parties participating 1 tho FAN deal rerair cornnwtted to this de#i's obligations, tus enabling
us to engage into the discussed projects as foreseen,
Unfortunately and unoxpactediy, the tS changed their view and exited the
IRAN deal;
Unfortunately and unoxpactediy, the i5 changed their vlew and exited the
IRAN deal;
effectively threatening Mon U' companies with secondary sanctions it tey continue with their
efiectively threatening don US companies with secondary sanctions it they continue with their
'ran activities
'ran activities
Acor<dig#y, we are now farung a sstian wherein we nad z wind down such business by
Accoxdingy, we are naw faring a sBtian wherein we nand z wind down such business by
November 4, 2018.
lovember 4, 2018.
As a result, and considering that the possible new project in this bidding cannot be illy
As a result, and considering that the possible new project in this bidding cannot be illy
executed ! elivered by Movember 4. we must at this point terminate ur manufacturer
authorization granted to Beijing Faith with respect to the ARP Project under tte MMaruracture
executed ! elivered by Movember 4, we must at this point terminate aur manufacturer
authorization granted to Beijing Faith with respect to the AU Project under tte Manufacture
Authorization Lerer dated July 25. 2617. Accordingly, we wit have to discontinue the supp!y to
Beijing Faith si the Pump routs or mny cther Sulzer products ir the ARUP Project
Authorization Letter dated Ju}y 26. 2617. Accordingly, we wit have to discontinue the supp!y to
Beijing Faith si the Pump routs or mny other Sulzer products ir the ARUP Project
- 105 -

f
f
SULZER
SULZER
We would ike to emphasize that that such decision Is for us extremeiy ifficutt and one tat we
We would ike to emphasize that that such decision Is for us extreme?y ifficutt and one tat we
are ettertiveiy forced' tu make
are ettertiveiy forced' to make
We truly count on your uncerstanding under that stats of a mutual trust & appreciation
We truly count on your uncerstanding under that stats of a mutual trust & appreciation
developed in the recent year$.
developed in the recent y6ars.
Regards,
Regards,
Sulzer Pumps Suzhou Ltd.
Sulzer Pumnpa Suzhou Ltd.
(Sea!
(Sea~

- 106 -

Annex 224
Letter from Howden to Sinopec, 19 June 2018

- 107 -

- 108 -

e
e
Howden
Howden
Howden Ha Engineering Co., Ltd.
Howden Ha Engineering Co., Ltd.
Date: [19/0602018]
12EF Jinyu Mansion, No. 123
Date: [19/0602018]
128F Jinyu Mansion, No. 129
To: SINOPEC ENGINEERING INCORPORATION
To: SINOPEC ENGINEERING INCORPORATION
Xuarwurnen Xdajg, Sheng Distict
Xuarwurnen Xdaje, Xcheng Dist»ict
Eeijg 1€0G3t, P. RR. Cira
Eeijg 1€003t, P. RR. Chira
Bldg.21 Anyuan, Anhuibeil Chaoyang District 10010
Beijing City
Bldg.21 Anyuan, Anhuibeil Chaoyang District 10010
Beijing City
Tel: + 86 10 6641 9938
Fax. + 86 10 6641 0071
Tel: + 86 10 8641 9988
Fax. + 86 10 6641 0071
The People's Republic of China
The People's Republic of China
Wab: www.howden.com
Web: www.howden.com
Re: Notice of Termination on Letter of intent("tQl"dated on Dec29, 2017 for ABADAN REFINERY
Re: Notice of Termination on Letter of Intent("tol"dated on Dec29,2017 for ABADAN REFINERY
UPGRADING PROJECT and on Signing of Purchase Qrder (Purchase Order No_;
UPGRADING PROJECT and on Signing of Purchase Qrder (Purchase Order No_;
1071-€1-PM-P9-0034302-A0-0)("Pp"
1071-€1-PM-P9-0034302-A0-0)("Pp"
Dear Sir/Madam,
Dear Sir/Madam,
As a result of President Trump's announcement on May 8",2018 that the United States is
As a result of President Trump's announcement on May 8",2018 that the United States is
withdrawing from the Iran nuclear deal and wii} re-impose primary and secondary sanctions on
withdrawing from the Iran nuclear deal and wii} re-impose primary and secondary sanctions on
Iran, The U.S. Ofice of Foreign Assets Control ("OFAC") issued guidance indicating that General
Iran, The U.S. Ofice of Foreign Assets Control {"OFAC") issued guidance indicating that General
License H {"GLH"), which authorizes non-U.S. subsidiaries of U,S. companles to conduct
commercial business in Iran, will be repealed and that all sanctions on Iran will be fully
re-imposed. Howden Hua Engineering Co. Ltd. ("HHEt
License H ("GLH"), which authorizes non-U.S. subsidiaries of U,S. companles to conduct
commercial business in 1ran, will be repealed and that all sanctions on Iran will be fully

- 109 -
"
), as an affiliate of Colfax Group, a legally
registered U.S: company, is unable to fulfill any obligations nor otherwise legally responsible for
re-imposed. Howden Hua Engineering Co. Ltd. ("HHEt"), as an affiliate of Colfax Group, a legally
registered U.S: company, is unable to fulfill any obligations nor otherwise legally responsible for
any loss or damages because of the sanctions, and/or Force Majeure event and/or any
any loss or damages because of the sanctions, and/or Force Majeure event and/or any
subsequent civil unrest. Accordingly, entering
subsequent civil unrest. Accordingly, entering into any contract/ Purchase Order and/or
performance under contracts with/to the scope/extent shall be frustrated and thus no cause of
action far breach or liability will arise as a consequence of this matter and any subsequent civil
into any contract/ Purchase Order and/or
performance under contracts with/to the scope/extent shall be frustrated and thus no cause of
action far breach or liability will arise as a consequence of this matter and any subsequent civil
unrest.
unrest.
Please allow this letter to serve as a written Notice of Termination on LOI and Termination on
Please allow this letter to serve as a written Notice of Termination on LOI and Termination on
signing the Purchase Order cited above (PO") an the date of [19/06/2018]. As a consequence
signing the Purchase Order cited above ("PO") an the date of [19/06/2018]. As a consequence
thereof, please note that HHEL will not 2) enter into the Purchase Order as LOI mentioned or 2)
thereof, please note that HHEL will not 1) enter into the Purchase Order as LOI mentioned or 2)
generate any further performance on LOI and/or PO; and in accordance with the LOI/ PO and this
generate any further performance on LOI and/or PO; and in accordance with the LOI/ PO and this
Notice of Terminetion, HHEL shall be entitled to be paid for all MATERIAL/Services delivered
Notice af Termination, HHEL shall be entitled to be paid for all MATERIAL/Services delivered
and/or can be delivered or utilized, notwithstanding any other provision in the Purchase Order
and/or can be delivered or utilized, notwithstanding any other provision in the Purchase Order.
We sincerely regret for any inconvenience this sudden event has caused to you due to the
circumstances beyond control. We will work with you to implement the changes and appreciate
We sincerely regret for any inconvenience this sudden event has caused to you due to the
circumstances beyond control. We will work with you to implement the changes and appreciate
your cooperation and patience during this hard time. We hope that we will have other
your cooperation and patience during this hard time. We hope that we will have other
opportunities to work with your company in the future.
opportunities to work with your company in the future.
Sincerely Yours,
Sincerely Yours,
rj%
rj%
Signature.
Signature.
Name: Lin Zheng
Name: Lin Zheng
Title: Petrochemical Oil & Gas Directar/VP
Title: Petrochemical Oil & Gas Directar/VP
aaluin Aer@t V"
aaluin Arnet V"

- 110 -

Annex 225
Letter from GEA to Sinopec, 20 June 2018

- 111 -

- 112 -

To
To
SET
SET
21# Anyuan, Anhui:beili
21# Anyuan, Anhuibeiti
Chaoyang Distnct, Beijing
Post Code: 100101
Chaoyang Distnct, Beijing
Post Code: 100101
Attn
Lucy Liu
Attn
Lucy Liu
Oliver Kuck
Oliver Kuck
tie3; p! APK Cher»wats -Vaur Systems
tie3; ! APK Chere.ats - Vaaur Systems
Tel ·20 7243 705 409
Tel ·10 7243 705 409
ax +49 1243 5 8 4C9
ax +49 243 '5 8 4G9
[email protected]
olive:[email protected]
20.06.2018
20.06.2018
Project
Requisition No.
Project
Requisition No.
Abadan Refinery Upgrading Project - Phase 1
1071-C1-EP-ME-IR-4203-A1
Abadan Refinery Upgrading Project - Phase 1
1071-C1-EP-ME-IR-4203-A1
GEA Wiegand Reference No.
GEA Wiegand Reference No.
53-18-09397
53-18-09397
Dear Sir,
Dear Sir,
Thank you very much for your inquiry.
Thank you very much for your inquiry.
Unfortunately, due to the recent developments in word politics.
Unfortunately, due to the recent developments i world politics.
we are not allowed to follow this project any more.
we are not allowed to follow this project any more.
Thank you for your understanding.
Thank you for your understanding.
·"
Best Rcgard;i
Q
·"
Best Regard;i
I
I
ii�
I
I
lU
lU
.N
.N
Oliver Kuck
Oliver Kuck
GEA Wegar1 Grat
FA Wegar1 Grat!
w +ta:dtw.aid , 782 Einaen, Deutscttand
w +Hardt.aid 1, 782 Einaeo, Deutscttand
Tei. »19 7243 705 , www gea cor; ea·wiegard in#otgea car
Tei. +»19 7243 705 , wwnwgea con; qea·wiegard iogea cam
S:tz aer Geselischa!!: tiger, Hannisregstr Amuser¢ht Mare'er- HE8 302, tSk Ne. DE111534462
S:tz aer Geselischa!!: Etier, Hannisregstr Amuser¢ht Mare'er- HR8 3025, tStk Ne. DE111534462
Get'ts~rang· Dr ug. Gbmstopier &ran {Varsitzemtetj, Gunther +iplirac
Geth'ts~tang· Dr ug. Gbnstopier &ran {Varsitzemtej, Gunther +iplirac'
Jeash Bar Kassruhe ;8:Z +69 709 34, 79 875. Sue:-Nr: +&5 5857 10)0d
Jeash an asruhe ;8:2z +6 700 34, 79 875, Sue:-Nr: +{35 557 10)
tEA! DE9; 6607 0~0 1 «875 , FIC FUT[ESM86
tEA!· DE9; 6607 0~0 19 d875 (H, FIC DTDESM86

- 113 -

- 114 -

Annex 226
E-mail from Kelvion China to Sinopec, 21 June 2018

- 115 -

- 116 -

oic (oolec
oic (oole
,------- ...... !
#th: {: AW: Large Project Approval Application (Two-Pagers)
.Fis
#: {: AN: Large Project Approval Application (Two-Pagers)
#6# 'j # ,: 3]5
2018/08/06 11:07
Rad
#hi#k '- e,: 3a]ff
2018/08/06 11:07
FYI
FYI
ARUP Lead Buyer(ME)
Jaward Yang
Office Tel.: 00 86 10 8487 5018
ARUP Lead Buyer(ME)
Jaward Yang
Office Tel.: 00 86 10 8487 5018
E-mail: [email protected]
Address: 21# Anyuan Anhuibeili, Chaoyang District, Beijing, China. (P.C 100101)
E-mail: [email protected]
Address: 21# Anyuan Anhuibeili, Cha0yang District, Beijing, China. (P.C 100101)
----- #iz #'/3NE/Sei Hf's] 2018/08,'06 11:07 -­
--i #l'/NJ/Sei H '@] 2018/08/06 11:07 ­
A.
.=A:
"Teng, Robin" <Robin. tang@kelvion. com?
A
"Teng, Robin" <Robin. tang@kelvion. com
"yangzh@sei. com. cn" yangzh@sei. com. cn
"yangzh@sei. co. cn" (yangzh@sei. com. cn
A:
£10]:
EE:
2018/06/21 20:07
2018/06/21 20:07
.&:
:.&:
dtk: 3: A: Large Project Approval Application (Two-Pagers)
dtk: : AW: Large Project Approval Application (Two-Pagers)
Dear Mr. Yang,
Dear Mr. Yang,
We just have been informed from our CSO of KELVION GROUP, who has discussed with the other
board members of Kelvion. They have considered the current Europe-America relationship and the
situation of the US administration and regretfully decided that KELVION shall not pursue the Iran
ARUP export business due to the current US government attitude toward Iran may affect the
execution of the order and cause unexpected damages to SEI and Kelvion.
We just have been informed from our CSO of KELVION GROUP, who has discussed with the other
board members of Kelvion. They have considered the current Europe-America relationship and the
situation of the US administration and regretfully decided that KELVION shall not pursue the Iran
ARUP export business due to the current US government attitude toward Iran may affect the
execution of the order and cause unexpected damages to SEI and Kelvion.
We would like to thank SEI, you, your colleagues and ARUP customer for the trust in Kelvion and we
are sorry that we are not able to assist in the ARUP project.
We would like to thank SEI, you, your colleagues and ARUP customer for the trust in Kelvion and we
are sorry that we are not able to assist in the ARUP project.
Best Regards
Robin Tang
Best Regards
Robin Tang
Kelvion China / 21 3if2
Kelvion China / 3i[El
(Formerly GEA HX Holding Group / GEA#}375 2 E)
(Formerly GEA HX Holding Group/ 5GEA#37# • E)
Fax +86 21 6196 0777
Mobile +86 185 5012 0670
[email protected]
Fax +86 21 6196 0777
Mobile +86 185 5012 0670
[email protected]
www.Kelvion.com
www.Kelvion.com
Floor 27, Junyao International Plaza, No. 789, Zhao Jia Barg Road, Shanghai 200032, P.R.China
Floor 27, Junyao International Plaza, No. 789, Zhao Jia Barg Road, Shanghai 200032, P.R.China
00032
00032
Kelvion�
WE ARE KELVION
Kelvion�
WE ARE KELVION
THE NEW BRAND
THE NEW BRAND
IN HEAT EXCHANGE
IN HEAT EXCHANOE
(R&; rw n
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£3! 3 /:
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Confidentiality note
Confidentiality note
This e-maii. including any attachment, may contain confidential and privileged information. If yo nave received t by
mistake, piease nofy us oy reply e-mail an then delete this e-mail and any attachment from your system Thank you!
This e-maii. including any attachment, may contain confide7tat and privileged information. If you have received t by
mistake, piease notfy us boy reply e-mail ana then delete this e-mail and any attachment from your system Thank you!
On Jun 5, 2018, at 18:50, Cheng, Hao <[email protected]> wrote:
On Jun 5, 2018, at 18 :50, Cheng, Hao <[email protected]> wrote:

- 117 -

- 118 -

Annex 227
Letter from EagleBurgmann Dailian Co. Ltd to Sinopec, 26 June 2018

- 119 -

- 120 -

EagleBurgmann.
EagleBurgmann.
Telefax
Telefax
0:iil
1l-ii!
Sinopec Engineering Incor. (SEl)
Sinopec Engineering Incor. (SEl)
8#A
8#A
Campany
Campany
From
4.A
Ms. Charming Yang
t6/1
Rebecca Ruan
Sales
From
4.A
Ms. Charming Yang
16r1
Rebecca Ruan
Sales
Attn.
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Burgmann Dalian Co., Ltd.
Burgmann Dalian Co., Ltd.
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26.06.2018
26.06.2018
Date
Date
Dear Ms. Yang
Dear Ms. Yang
Due to the upcoming Sanction implementation related with Iran business, EagleBurgmann headquarter informed
EagleBurgmann China recently, that all Iran related business must be closed before Nov.,04,2018.
Due to the upcoming Sanction implementation related with Iran business, EagleBurgmann headquarter informed
EagleBurgmann China recently, that all Iran related business must be closed before Nov.,04,2018.
In this case, we have to inform SEI side that EagleBurgman China have to give up all the quotations we've done for Abadan
Refinery Upgrading Project, since we don't have enough time to finish all the pending jobs before this deadline.
In this case, we have to inform SEI side that EagleBurgman China have to give up all the quotations we've done for Abadan
Refinery Upgrading Project, since we don't have enough time to finish all the pending jobs before this deadline.
We're regret that this unpredictable political issue just happened and we have to follow it.
We're regret that this unpredictable political issue just happened and we have to follow it.
Thanks for the opportunities that you offer us and looking forward for other chance of cooperation.
Thanks for the opportunities that you offer us and looking forward for other chance of cooperation.
Sincerely Yours,
Sincerely Yours,
Rebecca Ruan
Rebecca Ruan
EagleBurgman Dalian Co., Ltd.
EagleBurgman Dalian Co., Ltd.
June,26\h ,2018
June,26\h ,2018
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- 121 -

- 122 -

Annex 228
Letter from Beijing Kelitong Instrument Technology Development Co. LTD to
Sinopec, 26 July 2018

- 123 -

- 124 -

Iran ARUP project Confirmation Letter
Iran ARUP project Confirmation Letter
Sinopec Engineering lncorporation(SEI):
Sinopec Engineering lncorporation(SEI):
Dueto the US sanctions, SERVOMEX can't trade with lran, Beijing Kelitong
Dueto the US sanctions, SERVOMEX can't trade with Iran, Beijing Kelitong
Instrument Technology Development Co.LTD as SERVOMEX agent can't
Instrument Technology Development Co.LTD as SERVOMEX agent can't
participate in the ARUP project, we are deeply sorry for not being able to
participate in the ARUP project, we are deeply sorry for not being able to
participate in this project.
participate in this project.
Can't participating the inquiry documents numbers are:
Can't participating the inquiry documents numbers are:
1071-S1-EP-IN-IR-7401/7402
1071-S1-EP-IN-IR-7401/7402
BeijingKelitong Instrument Technology Development Co.LTD
BeijingKelitong Instrument Technology Development Co.LTD
2018 7 26
2018 7 26
48& af
34 «f

- 125 -

- 126 -

Annex 229
F. Mohamedi, “The Oil and Gas Industry”, The Iran Primer, August 2015

- 127 -

- 128 -

The Oil and Gas Industry
The Oil and Gas Industry
iran primer.
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Fareed Mohamedi
Fareed Mohamedi
Lifting sanctions could revive oil and natural gas production in Iran. Foreign private and
national oil companies are looking to invest in the Islamic Republic, particularly in light of
changes to investment terms offered by the Iranian government. Plans for pipelines and
liquid natural gas could also be revived.
Lifting sanctions could revive oil and natural gas production in Iran. Foreign private and
national oil companies are looking to invest in the Islamic Republic, particularly in light of
changes to investment terms offered by the Iranian government. Plans for pipelines and
liquid natural gas could also be revived.
The Iranian economy is heavily dependent on the lucrative oil and gas sector. The vagaries
of oil markets and Iran's reliance on a single resource for most of its income have created
disincentives to develop a more diversified and globally integrated economy. This
weakness has made sanctions more potent. But impaired access to imports may have also
boosted domestic production to some extent. Nonetheless, the oil and gas sector has
been a source of periodic but persistent economic instability.
The Iranian economy is heavily dependent on the lucrative oil and gas sector. The vagaries
of oil markets and Iran's reliance on a single resource for most of its income have created
disincentives to develop a more diversified and globally integrated economy. This
weakness has made sanctions more potent. But impaired access to imports may have also
boosted domestic production to some extent. Nonetheless, the oil and gas sector has
been a source of periodic but persistent economic instability.
Iran's oil and gas sectors have faced key structural problems. On the demand side,
subsidized prices and a population that has doubled since the 1979 revolution have
created excessive demand. On the supply side, an aging oil resource base has been
stymied by financial constraints, technical shortages, sanctions, and using gas to stimulate
oil production.
Iran's oil and gas sectors have faced key structural problems. On the demand side,
subsidized prices and a population that has doubled since the 1979 revolution have
created excessive demand. On the supply side, an aging oil resource base has been
stymied by financial constraints, technical shortages, sanctions, and using gas to stimulate
oil production.
One of the ironies of the oil-rich Gulf states' predicament - Iran's situation is typical of the
region -- is that they are short on hydrocarbon resources. Moreover, as global
environmental concerns mount, Gulf countries are facing pressures to curb their
greenhouse gas emissions. Both factors are pushing the Gulf to explore alternative energy
sources, including nuclear options.
One of the ironies of the oil-rich Gulf states' predicament - Iran's situation is typical of the
region -- is that they are short on hydrocarbon resources. Moreover, as global
environmental concerns mount, Gulf countries are facing pressures to curb their
greenhouse gas emissions. Both factors are pushing the Gulf to explore alternative energy
sources, including nuclear options.
Overview
Overview
In 1908, Iran was the first country in the Persian Gulf to discover oil. Petroleum has been the
primary industry in Iran since the 1920s. Despite Tehran's attempts to diversify the economy,
the oil and gas industry is still the critical engine of economic growth. Oil revenues over the past
few years have accounted for around 60 percent of government revenues. But this figure
dropped to 47 percent in 2015 after low oil prices forced the government to revise the state
budget. Additionally, oil revenues comprised only around 1 O percent of the gross domestic
In 1908, Iran was the first country in the Persian Gulf to discover oil. Petroleum has been the
primary industry in Iran since the 1920s. Despite Tehran's attempts to diversify the economy,
the oil and gas industry is still the critical engine of economic growth. Oil revenues over the past
few years have accounted for around 60 percent of government revenues. But this figure
dropped to 47 percent in 2015 after low oil prices forced the government to revise the state
budget. Additionally, oil revenues comprised only around 1 O percent of the gross domestic
product. This trend has remained fairly steady over the last few decades.
The Iranian government's dependence on oil revenues has resulted in prolonged patterns of
rentierism-or dependence on a single natural resource-in its political economy. Some
analysts have claimed that Iran's "revenue autonomy'' and access to large amounts of foreign
exchange helped fund an eight-year war with Iraq and extremist groups. But historically, oil
attracted external interference by foreign powers, and the sector has suffered in the last several
product. This trend has remained fairly steady over the last few decades.
The Iranian government's dependence on oil revenues has resulted in prolonged patterns of
rentierism-or dependence on a single natural resource-in its political economy. Some
analysts have claimed that Iran's "revenue autonomy'' and access to large amounts of foreign
exchange helped fund an eight-year war with Iraq and extremist groups. But historically, oil
attracted external interference by foreign powers, and the sector has suffered in the last several
1/8
118
- 129 -

decades. Production was acutely affected during the revolution, especially by workers' strikes.
During the Iran-Iraq War, the invasion of oil-rich Khuzestan and the port of Abadan severely
impacted revenues. And Iran's disputes with Western countries led to sanctions that crippled its
ability to buy badly needed equipment and new refineries from the West.
decades. Production was acutely affected during the revolution, especially by workers' strikes.
During the Iran-Iraq War, the invasion of oil-rich Khuzestan and the port of Abadan severely
impacted revenues. And Iran's disputes with Western countries led to sanctions that crippled its
ability to buy badly needed equipment and new refineries from the West.
Vulnerabilities
Vulnerabilities
The revolutionary government has struggled since the 1979 revolution to maintain oil
production above 3.5 million barrels per day-just over one-half of production under the last
shah. Iran produced 6 million barrels per day in the monarchy's final years. Production fell to a
low of 1.5 million barrels per day in 1980. The long period of low oil prices between 1986 and
2000 also crippled Iranian revenues.
The revolutionary government has struggled since the 1979 revolution to maintain oil
production above 3.5 million barrels per day-just over one-half of production under the last
shah. Iran produced 6 million barrels per day in the monarchy's final years. Production fell to a
low of 1.5 million barrels per day in 1980. The long period of low oil prices between 1986 and
2000 also crippled Iranian revenues.
Iran's revenues have fluctuated due to the vagaries of the world's oil markets, periodically
depressing government revenues. The government has often not been able to cut spending for
political reasons and funded its deficits by borrowing from the Central Bank. Periodic bouts of
lower oil prices have also led to foreign exchange shortfalls and a fall in imports, especially
industrial inputs. Excessive domestic demand and disrupted industrial production has led to
periods of high inflation.
Iran's revenues have fluctuated due to the vagaries of the world's oil markets, periodically
depressing government revenues. The government has often not been able to cut spending for
political reasons and funded its deficits by borrowing from the Central Bank. Periodic bouts of
lower oil prices have also led to foreign exchange shortfalls and a fall in imports, especially
industrial inputs. Excessive domestic demand and disrupted industrial production has led to
periods of high inflation.
Misuse of oil revenues has also caused long term-economic problems. After he was first elected
in 2005, former president Mahmoud Ahmadinejad embarked on a populist spending program
encouraged by higher oil prices. But his plan overcommitted the government to support social
welfare, which Tehran could not afford due to sanctions and, later, the drop in oil prices in 2014.
Iran had built up its foreign exchange because of higher oil prices over the past decade, but
portions of the reserves were impounded by foreign countries as part of the sanctions regime.
Misuse of oil revenues has also caused long term-economic problems. After he was first elected
in 2005, former president Mahmoud Ahmadinejad embarked on a populist spending program
encouraged by higher oil prices. But his plan overcommitted the government to support social
welfare, which Tehran could not afford due to sanctions and, later, the drop in oil prices in 2014.
Iran had built up its foreign exchange because of higher oil prices over the past decade, but
portions of the reserves were impounded by foreign countries as part of the sanctions regime.
When President Hassan Rouhani took office in 2013, he prioritized reforming
the oil and gas sector. He appointed Bijan Zanganeh as his oil minister.
Zanganeh, who previously held the post under reformist president
Mohammad Khatami, claimed that "the problem we are facing now in the
petroleum industry is not finance, but management problems." Zanganeh and
Rouhani had some success reforming poor management in the oil industry.
But by 2015, international sanctions still restricted the industry from reaching
its full potential.
When President Hassan Rouhani took office in 2013, he prioritized reforming
the oil and gas sector. He appointed Bijan Zanganeh as his oil minister.
Zanganeh, who previously held the post under reformist president
Mohammad Khatami, claimed that "the problem we are facing now in the
petroleum industry is not finance, but management problems." Zanganeh and
Rouhani had some success reforming poor management in the oil industry.
But by 2015, international sanctions still restricted the industry from reaching
its full potential.
Subsidy Reform
Subsidy Reform
Iran's longstanding subsidies - to support consumption of refined oil products and natural gas
became a huge burden on the Iranian budget and its balance of payments due to runaway
consumption and rising imports of gasoline. Fuel subsidies cost the government $38 billion per
year, or around 20 percent of GDP.
The government began an initial phase of subsidy reform in 2010, initiating a second phase in
2014.
Iran's longstanding subsidies - to support consumption of refined oil products and natural gas
became a huge burden on the Iranian budget and its balance of payments due to runaway
consumption and rising imports of gasoline. Fuel subsidies cost the government $38 billion per
year, or around 20 percent of GDP.
The government began an initial phase of subsidy reform in 2010, initiating a second phase in
2014.
In May 2015, subsidy cuts raised the price per liter of gasoline from 7,000 rials to 10,000
In May 2015, subsidy cuts raised the price per liter of gasoline from 7,000 rials to 10,000
rials - about $1.28 per gallon.
rials - about $1.28 per gallon.
218
2/8
- 130 -

The International Monetary Fund called the subsidy reform program "unprecedented in Iran's
economic history in terms of its scale, preparations and potential implications." The government
used the higher cash earnings from raising product prices for universal cash transfers to
households, direct assistance to public enterprises and budgetary support.
But this move coincided with new sanctions, which led to a deceleration in growth, rise in
inflation and currency devaluation. It also led to a sharp fall in cash needed to fund the subsidy
removal program. Other inflationary policies by the government undermined the program.
The International Monetary Fund called the subsidy reform program "unprecedented in Iran's
economic history in terms of its scale, preparations and potential implications." The government
used the higher cash earnings from raising product prices for universal cash transfers to
households, direct assistance to public enterprises and budgetary support.
But this move coincided with new sanctions, which led to a deceleration in growth, rise in
inflation and currency devaluation. It also led to a sharp fall in cash needed to fund the subsidy
removal program. Other inflationary policies by the government undermined the program.
In fact, the government's efforts did not even reduce refined product consumption. In 2005, Iran
consumed 1.3 million barrels per day (bpd) of refined products, 350,000 of which were
gasoline. Iran imported around 150,000 bpd of gasoline - nearly 45 percent of consumption. By
2014, demand had growth to 1.6 million bpd, a clear indication that subsidy reform had not
been successful in suppressing consumption.
By 2015, Iran had undertaken major efforts to reduce its dependence on foreign imports of
refined products. Iran consumed 437,000 bpd of gasoline in 2014, but imports had fallen to a
mere 25,000 bpd. Increased refining capacity, even in the face of sanctions, led to near self­
sufficiency.
In fact, the government's efforts did not even reduce refined product consumption. In 2005, Iran
consumed 1.3 million barrels per day (bpd) of refined products, 350,000 of which were
gasoline. Iran imported around 150,000 bpd of gasoline - nearly 45 percent of consumption. By
2014, demand had growth to 1.6 million bpd, a clear indication that subsidy reform had not
been successful in suppressing consumption.
By 2015, Iran had undertaken major efforts to reduce its dependence on foreign imports of
refined products. Iran consumed 437,000 bpd of gasoline in 2014, but imports had fallen to a
mere 25,000 bpd. Increased refining capacity, even in the face of sanctions, led to near self­
sufficiency.
Oil
Oil
Iran is the second largest OPEC producer and the fifth largest globally (after Russia, Saudi
Arabia, the United States and China). Its oil sector is one of the oldest in the world. Production
started in 1908 at the Masjid-i-Suleiman oil field. As a result, Iran has one of the world's most
mature oil sectors. About 80 percent of its reserves were discovered before 1965. Iran has
already produced 75 percent of its reserves, so the likelihood of other major discoveries is
low. Iran has made some important new discoveries in the past decade, such as the Yadavaran
and Azadegan fields, but they have not been sufficient to alter the trend in oil reserves
depletion.
Iran is the second largest OPEC producer and the fifth largest globally (after Russia, Saudi
Arabia, the United States and China). Its oil sector is one of the oldest in the world. Production
started in 1908 at the Masjid-i-Suleiman oil field. As a result, Iran has one of the world's most
mature oil sectors. About 80 percent of its reserves were discovered before 1965. Iran has
already produced 75 percent of its reserves, so the likelihood of other major discoveries is
low. Iran has made some important new discoveries in the past decade, such as the Yadavaran
and Azadegan fields, but they have not been sufficient to alter the trend in oil reserves
depletion.
318
318
- 131 -

Iranian Oil Production
Iranian Oil Production
4.5 -----------------------
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9 9 9 9 $' $ $' ' ' $S' $' $' $'$'9'9
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Year
Year
Source: Energy Information Administration
Over the years, Washington has imposed escalating waves of sanctions on Tehran, many of
which targeted the oil and gas industry.
In 2010, it produced some 3.54 million bpd, though by
Source: Energy Information Administration
Over the years, Washington has imposed escalating waves of sanctions on Tehran, many of
which targeted the oil and gas industry.
In 2010, it produced some 3.54 million bpd, though by
early 2015 production had dropped to around 3 million bpd. In 2011 and 2012, the United States
and European Union imposed the harshest round of sanctions to date. By 2014,
Iran's oil
early 2015 production had dropped to around 3 million bpd. In 2011 and 2012, the United States
and European Union imposed the harshest round of sanctions to date. By 2014,
Iran's oil
exports plummeted from 2.5 million bpd to 1.4 million bpd, their lowest levels since 1986. The
limited sanctions relief in the 2013 interim nuclear deal allowed Iran to modestly increase its
export of condensates to China and India, but progress quickly leveled off.
Before the sanctions, the National Iranian Oil Company (NIOC) held crude production around 4
million barrels per day range for several years. This was a major achievement since most oil
sectors with depletion rates of 75 percent usually witness steep declines in production. Indeed,
Iran's base production is declining around 4 percent per year. The recently discovered new
sources allowed Iran to hold oil production relatively steady. They could have even helped
production levels to grow somewhat beyond that, if sanctions had not placed other restraints on
output.
But new sources may not be able to offset natural declines beyond the short-term. As a result,
Iran will have to rely heavily on proven but undeveloped reserves, which will require major new
investments. Production capacity is likely to fall because of geological constraints, the lack of
domestic technical capacity, financial constraints and international sanctions.
exports plummeted from 2.5 million bpd to 1.4 million bpd, their lowest levels since 1986. The
limited sanctions relief in the 2013 interim nuclear deal allowed Iran to modestly increase its
export of condensates to China and India, but progress quickly leveled off.
Before the sanctions, the National Iranian Oil Company (NIOC) held crude production around 4
million barrels per day range for several years. This was a major achievement since most oil
sectors with depletion rates of 75 percent usually witness steep declines in production. Indeed,
Iran's base production is declining around 4 percent per year. The recently discovered new
sources allowed Iran to hold oil production relatively steady. They could have even helped
production levels to grow somewhat beyond that, if sanctions had not placed other restraints on
output.
But new sources may not be able to offset natural declines beyond the short-term. As a result,
Iran will have to rely heavily on proven but undeveloped reserves, which will require major new
investments. Production capacity is likely to fall because of geological constraints, the lack of
domestic technical capacity, financial constraints and international sanctions.
In the 1990s, Iran attempted to attract foreign companies to develop its crude oil reserves,
partly because it lacked the technical and financial resources to develop them. The contract
terms were called Buy-back arrangements, whereby foreign oil companies developed the field
and were paid back in crude oil produced. The field under development was returned to NIOC's
control after repayment was completed. These arrangements were unpopular with foreign
In the 1990s, Iran attempted to attract foreign companies to develop its crude oil reserves,
partly because it lacked the technical and financial resources to develop them. The contract
terms were called Buy-back arrangements, whereby foreign oil companies developed the field
and were paid back in crude oil produced. The field under development was returned to NIOC's
control after repayment was completed. These arrangements were unpopular with foreign
4/8
418
- 132 -

companies, even though several large oil and gas fields were developed. Dissatisfaction with the
contract, along with the threat of renewed sanctions, led most private Western companies to
leave.
companies, even though several large oil and gas fields were developed. Dissatisfaction with the
contract, along with the threat of renewed sanctions, led most private Western companies to
leave.
The final nuclear deal in 2015 generated renewed interest in Iranian oil, in anticipation of
sanctions relief.
The final nuclear deal in 2015 generated renewed interest in Iranian oil, in anticipation of
sanctions relief.
Iran's government also issued a new set of contract terms more favorable to
Iran's government also issued a new set of contract terms more favorable to
foreign companies. Unlike Buy-back contracts, the new Iran Petroleum Contract (IPC) allows
companies to participate in all three stages of an oil or gas field's lifecycle - exploration,
development and production.
foreign companies. Unlike Buy-back contracts, the new Iran Petroleum Contract (IPC) allows
companies to participate in all three stages of an oil or gas field's lifecycle - exploration,
development and production.
In a Buy-back contract, foreign companies had a fixed target and were compensated with a pre­
determined amount, without the opportunity to increase output through sophisticated means
over the field's lifecycle. The IPC allows for contract changes depending on the complexity of the
projects. Other provisions allow foreign companies to participate for up to 25 years - compared
to the five to eight years in the original Buy-backs - which increases incentives to maximize
production. In 2015, European companies, including Total SA of France, ENI of Italy, Royal Dutch
Shell, and British Petroleum (BP), indicated their interest in resuming oil investments in Iran.
In a Buy-back contract, foreign companies had a fixed target and were compensated with a pre­
determined amount, without the opportunity to increase output through sophisticated means
over the field's lifecycle. The IPC allows for contract changes depending on the complexity of the
projects. Other provisions allow foreign companies to participate for up to 25 years - compared
to the five to eight years in the original Buy-backs - which increases incentives to maximize
production. In 2015, European companies, including Total SA of France, ENI of Italy, Royal Dutch
Shell, and British Petroleum (BP), indicated their interest in resuming oil investments in Iran.
Since the end of the 2000s, Tehran has increasingly looked East to attract national oil companies
into the Iranian upstream industry. The greatest activity has been with China, which has held
talks on major projects since Sinopec signed the contract for the Yadavaran field in 2007. But
proceeding to actual development has been slow, even for Yadavaran. The Chinese companies
reduced their activities after new U.N. sanctions were imposed. It remains to be seen whether
these projects will be reactivated in the near term.
Since the end of the 2000s, Tehran has increasingly looked East to attract national oil companies
into the Iranian upstream industry. The greatest activity has been with China, which has held
talks on major projects since Sinopec signed the contract for the Yadavaran field in 2007. But
proceeding to actual development has been slow, even for Yadavaran. The Chinese companies
reduced their activities after new U.N. sanctions were imposed. It remains to be seen whether
these projects will be reactivated in the near term.
Refining capacity
Refining capacity
Iran's refineries are operated by the National Iranian Oil Refining and Distribution Company
(NIORDC). NIORDC operates 15 refineries with a combined crude distillation capacity of 2.04
million barrels per day, according to Facts Global Energy. NIORDC has capacity to produce 1.86
million bpd and has at least nine refineries. Capacity has more than doubled since the early
1990s, and considerable work has been done to upgrade the refineries.
Until recently, Iran primarily refined low-value fuel oil. It relied on imports of higher value-added
refined products, such as gasoline, jet fuel and diesel, to accommodate the growing public
appetite for subsidized fuels, especially gasoline. NIORDC plans to build five more refineries and
three condensate splitters - with the rise in gas production, condensates have become an
important source of liquids output. The project could add 2 million bpd to capacity at a cost of
$27 billion, according to the Middle East Economic Survey. After sanctions, Iranian officials hope
that foreign companies invest in some of this capacity. European and Japanese companies have
shown some interest in both investment and construction in the sector.
Iran's refineries are operated by the National Iranian Oil Refining and Distribution Company
(NIORDC). NIORDC operates 15 refineries with a combined crude distillation capacity of 2.04
million barrels per day, according to Facts Global Energy. NIORDC has capacity to produce 1 .86
million bpd and has at least nine refineries. Capacity has more than doubled since the early
1990s, and considerable work has been done to upgrade the refineries.
Until recently, Iran primarily refined low-value fuel oil. It relied on imports of higher value-added
refined products, such as gasoline, jet fuel and diesel, to accommodate the growing public
appetite for subsidized fuels, especially gasoline. NIORDC plans to build five more refineries and
three condensate splitters - with the rise in gas production, condensates have become an
important source of liquids output. The project could add 2 million bpd to capacity at a cost of
$27 billion, according to the Middle East Economic Survey. After sanctions,
Iranian officials hope
that foreign companies invest in some of this capacity. European and Japanese companies have
shown some interest in both investment and construction in the sector.
Natural gas
Natural gas
518
518
- 133 -

Iran has the second largest gas reserves in the world after the Russian Federation. For two
decades, its production growth has increased by an average of 10 percent, yet Iran has only
depleted five percent of its gas reserves. Iran's problem is that its ability to produce has lagged
behind its domestic needs. Demand has surged because of economic and population growth.
Natural gas has also been liquified and used as a substitute for gasoline and other transport
fuels. As Iran's oil sector has become more mature, the government has had to use more gas
for reinjection into maturing oil fields in order to maintain oil production.
Iran has the second largest gas reserves in the world after the Russian Federation. For two
decades, its production growth has increased by an average of 10 percent, yet Iran has only
depleted five percent of its gas reserves. Iran's problem is that its ability to produce has lagged
behind its domestic needs. Demand has surged because of economic and population growth.
Natural gas has also been liquified and used as a substitute for gasoline and other transport
fuels. As Iran's oil sector has become more mature, the government has had to use more gas
for reinjection into maturing oil fields in order to maintain oil production.
Iranian Natural Gas Production
Iranian Natural Gas Production
6000
6000
5000
5000
4000 %%
..
- 6
4000 %
e
u
5
5
3000 3
3000 3
5
5
2000
2000 E
1000
1000
0
0
Source: Energy Information Administration
Iran must continue to develop its reserves at a rapid rate to meet this demand.
Iran's main asset
Source: Energy Information Administration
Iran must continue to develop its reserves at a rapid rate to meet this demand.
Iran's main asset
is the giant off-shore South Pars field in the Persian Gulf, which it shares with Qatar. It is the
world's largest gas field. Qatar has sped ahead with development of its field, but Iran has lagged
way behind. Tehran has made some progress in developing several phases of the South Pars
gas field in recent years. But achieving full potential of this giant field plus other fields will be a
challenge over the near term because of technical and financial constraints.
is the giant off-shore South Pars field in the Persian Gulf, which it shares with Qatar.
It is the
world's largest gas field. Qatar has sped ahead with development of its field, but Iran has lagged
way behind. Tehran has made some progress in developing several phases of the South Pars
gas field in recent years. But achieving full potential of this giant field plus other fields will be a
challenge over the near term because of technical and financial constraints.
Developing its natural gas sector also requires a heavy commitment to building the necessary
infrastructure. Iran's gas production is in the south of the country, but the bulk of its demand is
in the north. It has built an impressive pipeline network to transport this gas, but growing
demand has increased the need to expand domestic pipelines.
Developing its natural gas sector also requires a heavy commitment to building the necessary
infrastructure. Iran's gas production is in the south of the country, but the bulk of its demand is
in the north. It has built an impressive pipeline network to transport this gas, but growing
demand has increased the need to expand domestic pipelines.
Since it can barely meet domestic demand, Iran has not been able to deliver on its ambitious
gas export program beyond the current pipeline exports to Turkey. Due to sanctions, Iran has
not developed the necessary infrastructure to export liquefied natural gas. Regional pipeline
projects to Oman and the United Arab Emirates have stalled over pricing disputes. And security
Since it can barely meet domestic demand, Iran has not been able to deliver on its ambitious
gas export program beyond the current pipeline exports to Turkey. Due to sanctions, Iran has
not developed the necessary infrastructure to export liquefied natural gas. Regional pipeline
projects to Oman and the United Arab Emirates have stalled over pricing disputes. And security
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concerns have delayed a 2013 plan to build a gas pipeline to Iraq. For its own needs, Iran will
continue to rely on gas imports, mainly from Turkmenistan - which are getting more expensive
because of competition for this gas from China.
concerns have delayed a 2013 plan to build a gas pipeline to Iraq. For its own needs, Iran will
continue to rely on gas imports, mainly from Turkmenistan - which are getting more expensive
because of competition for this gas from China.
Industry structure and control
Industry structure and control
The Ministry of Petroleum, which has control over the National Iranian Oil Company, reports to
the president with oversight from the parliament. But the dividing line between the ministry and
Iran's oil company is often indistinct. The position of NIOC managing director was only
established in 2000 as a separate post. But in reality, as a vestige of the past, the two institutions
still share personnel and offices.
The Ministry of Petroleum, which has control over the National Iranian Oil Company, reports to
the president with oversight from the parliament. But the dividing line between the ministry and
Iran's oil company is often indistinct. The position of NIOC managing director was only
established in 2000 as a separate post. But in reality, as a vestige of the past, the two institutions
still share personnel and offices.
The Ministry also controls the National Iranian Gas Company, the National Iranian Petrochemical
Company, and the National Iranian Oil Refining and Distribution Company. In 2006, the ministry
submitted a bill to parliament proposing that NIOC manage all four companies. But the bill did
not pass because Ahmadinejad's supporters did not want the ministry to create more
autonomous companies.
The Ministry also controls the National Iranian Gas Company, the National Iranian Petrochemical
Company, and the National Iranian Oil Refining and Distribution Company. In 2006, the ministry
submitted a bill to parliament proposing that NIOC manage all four companies. But the bill did
not pass because Ahmadinejad's supporters did not want the ministry to create more
autonomous companies.
For most of the revolution's first three decades, an "oil mafia" under the influence of former
President Akbar Hashemi Rafsanjani controlled both the ministry of petroleum and the National
Iranian Oil Company. Ahmadinejad initially failed to assume control over the sector after his
election in 2005. Parliament rejected his first few choices for oil minister.
In his second term, he
was become more successful in prying control away from the oil mafia, especially after
parliament approved Massoud Mir-Kazemi. He has a strong background in the Revolutionary
Guards (IRGC) and the defense ministry, which reflects the power shift. He was former head of
the IRGC think tank, the Center for Fundamental Studies.
For most of the revolution's first three decades, an "oil mafia" under the influence of former
President Akbar Hashemi Rafsanjani controlled both the ministry of petroleum and the National
Iranian Oil Company. Ahmadinejad initially failed to assume control over the sector after his
election in 2005. Parliament rejected his first few choices for oil minister. In his second term, he
was become more successful in prying control away from the oil mafia, especially after
parliament approved Massoud Mir-Kazemi. He has a strong background in the Revolutionary
Guards (IRGC) and the defense ministry, which reflects the power shift. He was former head of
the IRGC think tank, the Center for Fundamental Studies.
Under Ahmadinejad, the Revolutionary Guards' influence grew within NIOC, as
well as in the service sector. Khatam ul-Anbia, the IRGC construction arm,
strengthened its role throughout the Iranian economy, including the oil and
gas sector. In 2006, it won a contract to develop South Pars Phases 15-16. In
2009, it took over the Sadra Yard, a firm that has built many platforms in the
Persian Gulf and the recently completed Alborz semi-submersible rig which
will drill in the Caspian Sea. While the Revolutionary Guards' profile grew, it
also faced financing difficulties. International sanctions have deterred banks from funding
Phases 15-16 due to its link with Khatam ul-Anbia.
Starting in 2013, President Rouhani and Oil Minister Zanganeh attempted to alter some of the
structural changes undertaken by Ahmadinejad. Zanganeh re-appointed oil ministry managers
removed by his predecessor, and has been at least partially successful at scaling back the
involvement of the IRGC. He also attempted to slow privatization of oil ministry subsidiaries,
though with limited success by 2014.
Trendlines
Under Ahmadinejad, the Revolutionary Guards' influence grew within NIOC, as
well as in the service sector. Khatam ul-Anbia, the IRGC construction arm,
strengthened its role throughout the Iranian economy, including the oil and
gas sector. In 2006, it won a contract to develop South Pars Phases 15-16. In
2009, it took over the Sadra Yard, a firm that has built many platforms in the
Persian Gulf and the recently completed Alborz semi-submersible rig which
will drill in the Caspian Sea. While the Revolutionary Guards' profile grew, it
also faced financing difficulties. International sanctions have deterred banks from funding
Phases 15-16 due to its link with Khatam ul-Anbia.
Starting in 2013, President Rouhani and Oil Minister Zanganeh attempted to alter some of the
structural changes undertaken by Ahmadinejad. Zanganeh re-appointed oil ministry managers
removed by his predecessor, and has been at least partially successful at scaling back the
involvement of the IRGC. He also attempted to slow privatization of oil ministry subsidiaries,
though with limited success by 2014.
Trend lines
The end of international sanctions may revive investment in the oil and gas sector in the
The end of international sanctions may revive investment in the oil and gas sector in the
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short term, which could lead to an increase in oil and gas output.
short term, which could lead to an increase in oil and gas output.
The sharply lower oil price could keep the Iranian economy on the defensive, since Iran
balances its external accounts around $75 per barrel.
The sharply lower oil price could keep the Iranian economy on the defensive, since Iran
balances its external accounts around $75 per barrel.
If sanctions are lifted, higher oil output and exports may increase export earnings. Greater
foreign investment in the oil and gas sector may also help boost economic growth and
improve the liquidity of external accounts.
If sanctions are lifted, higher oil output and exports may increase export earnings. Greater
foreign investment in the oil and gas sector may also help boost economic growth and
improve the liquidity of external accounts.
Fareed Mohamedi has been an oil and gas analyst for 35 years.
Fareed Mohamedi has been an oil and gas analyst for 35 years.
This chapter was originally published in 2010, and is updated as of August 2015.
This chapter was originally published in 2010, and is updated as of August 2015.
PDF Economy_Mohamedi_Oil and Gas.pdf202.89 KB
PDF Economy_Mohamedi_Oil and Gas.pdf202.89 KB
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Annex 230
H. Tunnicliffe, “Sinopec to upgrade Iran’s Abadan refinery”, The Chemical Engineer,
9 July 2018

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- 138 -

Sinopec to upgrade Iran's Abadan refinery
Sinopec to upgrade Iran's Abadan refinery
techemicalengineer.com/news/sinopec-to-upgrade-iran-s-abadan-refinery
techemicalengineer.com/news/sinopec-to-upgrade-iran-s-abadan-refinery
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Monday 9th July 2018
Monday 9th July 2018
Article by Helen Tunnicliffe
Article by Helen Tunnicliffe
SINOPEC ENGINEERING has won an engineering, procurement and construction (EPC)
contract to upgrade Iran's ageing Abadan refinery.
SINOPEC ENGINEERING has won an engineering, procurement and construction (EPC)
contract to upgrade Iran's ageing Abadan refinery.
The Abadan refinery is Iran's oldest, originally built in 1912, and partially rebuilt from the
1980s onward following extensive damage in the Iraq-Iran war. It currently has a capacity of
around 400,000 bbl/d. The National Iranian Oil Engineering and Construction Company,
which owns the refinery, wants to upgrade the refinery, which operates at low efficiencies,
and produces large amounts of mazut, a low-grade fuel oil.
The Abadan refinery is Iran's oldest, originally built in 1912, and partially rebuilt from the
1980s onward following extensive damage in the Iraq-Iran war. It currently has a capacity of
around 400,000 bbl/d. The National Iranian Oil Engineering and Construction Company,
which owns the refinery, wants to upgrade the refinery, which operates at low efficiencies,
and produces large amounts of mazut, a low-grade fuel oil.
The new contract is for Phase II of the upgrade project, and Sinopec says the contract
value is CNY6.858bn (US$1.06bn). Sinopec also carried out Phase I of the upgrade.
The new contract is for Phase II of the upgrade project, and Sinopec says the contract
value is CNY6.858bn (US$1.06bn). Sinopec also carried out Phase I of the upgrade.
Iran is keen to expand and improve its oil production and refining capacity since
international sanctions were lifted in 2016. A number of contracts have been announced for
exploration, field development and refinery building and upgrades, including with Total.
Iran is keen to expand and improve its oil production and refining capacity since
international sanctions were lifted in 2016. A number of contracts have been announced for
exploration, field development and refinery building and upgrades, including with Total.
CNPC, Shell and Daewoo. Most recently, South Korea's Daelim Industrial Company signed
a US$1.9bn contract to expand the Isfahan refinery.
CNPC, Shell and Daewoo. Most recently, South Korea's Daelim Industrial Company signed
a US$1.9bn contract to expand the Isfahan refinery.
Managing director of National Iranian Oil Refining and Distribution Company Abbas Kazem
recently told reporters that upgrading the Tehran, Bandar Abbas, Isfahan, Tabriz and
Abadan refineries would require around US$14bn of investment.
Managing director of National Iranian Oil Refining and Distribution Company Abbas Kazem
recently told reporters that upgrading the Tehran, Bandar Abbas, Isfahan, Tabriz and
Abadan refineries would require around US$14bn of investment.
Article by Helen Tunnicliffe
Article by Helen Tunnicliffe
Senior reporter, The Chemical Engineer
Senior reporter, The Chemical Engineer
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Annex 231
S. Kar-Gupta & J. Irish, “France's Total to quit Iran gas project if no sanctions
waiver”, Reuters, 16 May 2018

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- 142 -

France's Total to quit Iran gas project if no sanctions
waver
France's Total to quit Iran gas project if no sanctions
waver
reuters.com/article/us-iran-nuclear-france-total/frances-total-to-quit-iran-gas-project-if-no-sanctions-waiver­
reuters.com/article/us-iran-nuclear-france-total/frances-total-to-quit-iran-gas-project-if-no-sanctions-waiver­
idUSKCN1IH1XK
idUSKCN1IH1XK
PARIS (Reuters) - Total [OTF.PA) will pull out of a multibillion-dollar gas project in Iran if it
cannot secure a waiver from U.S. sanctions, the French energy company said on
Wednesday.
PARIS (Reuters) - Total (TOTF.PA) will pull out of a multibillion-dollar gas project in Iran if it
cannot secure a waiver from U.S. sanctions, the French energy company said on
Wednesday.
-
-
FILE PHOTO: The logo of French oil giant Total is seen at a gas station in La Defense
business and financial district in Courbevoie, near Paris, France, May 14, 2018.
REUTERS/Charles Platiau
Companies are starting to take matters into their own hands as European and some other
governments struggle to save an international nuclear deal with Iran after the United States
withdrew and said it would reinstate sanctions on Tehran.
FILE PHOTO: The logo of French oil giant Total is seen at a gas station in La Defense
business and financial district in Courbevoie, near Paris, France, May 14, 2018.
REUTERS/Charles Platiau
Companies are starting to take matters into their own hands as European and some other
governments struggle to save an international nuclear deal with Iran after the United States
withdrew and said it would reinstate sanctions on Tehran.
Determined to keep the accord alive, European leaders need to find a way to assure
companies that their investments are beyond Washington's extra-territorial reach.
Determined to keep the accord alive, European leaders need to find a way to assure
companies that their investments are beyond Washington's extra-territorial reach.
They also want to persuade Tehran the 2015 deal - which lifted earlier sanctions on the
Islamic Republic in exchange for it curbing its nuclear ambitions - is worth sticking to.
They also want to persuade Tehran the 2015 deal - which lifted earlier sanctions on the
Islamic Republic in exchange for it curbing its nuclear ambitions - is worth sticking to.
Total signed a contract in 2017 to develop phase 11 of Iran's South Pars field with an initial
investment of $1 billion - a contract Tehran repeatedly hailed as a symbol of the accord's
success.
Total signed a contract in 2017 to develop phase 11 of Iran's South Pars field with an initial
investment of $1 billion - a contract Tehran repeatedly hailed as a symbol of the accord's
success.
"Total will not continue the SP11 (South Pars 11) project and will have to unwind all related
operations before 4 November 2018, unless Total is granted a specific project waiver by
U.S. authorities with the support of the French and European authorities," the French oil
and gas major said in a statement.
"Total will not continue the SP11 (South Pars 11) project and will have to unwind all related
operations before 4 November 2018, unless Total is granted a specific project waiver by
U.S. authorities with the support of the French and European authorities," the French oil
and gas major said in a statement.
Total's announcement comes after German insurer Allianz (ALYG PE) and Danish oil
product tanker operator Maersk Tankers said they were winding down their businesses in
Iran. Joe Kaeser, the CEO of Germany's Siemens (SIEGn.DE), told CNN his company
would not be able to do any new business with Tehran.
Total's announcement comes after German insurer Allianz (ALYG PE) and Danish oil
product tanker operator Maersk Tankers said they were winding down their businesses in
Iran. Joe Kaeser, the CEO of Germany's Siemens {SIEGn.DE), told CNN his company
would not be able to do any new business with Tehran.
Iran has said it may start enriching uranium again if it can no longer see any economic
benefit to the deal.
Iran has said it may start enriching uranium again if it can no longer see any economic
benefit to the deal.
'SUICIDE'
'SUICIDE'
Total said any waiver would need to include protection from secondary sanctions that
Washington might impose on companies that continue to do business with Iran.
Total said any waiver would need to include protection from secondary sanctions that
Washington might impose on companies that continue to do business with Iran.
These might include the loss of financing in dollars by U.S. banks, the loss of U.S.
shareholders and the inability to continue its U.S. operations, it said.
These might include the loss of financing in dollars by U.S. banks, the loss of U.S.
shareholders and the inability to continue its U.S. operations, it said.
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France, Germany and Britain are leading a European effort to safeguard Europe's
economic interests but have few options that pose any threat to the United States.
France, Germany and Britain are leading a European effort to safeguard Europe's
economic interests but have few options that pose any threat to the United States.
"It would be suicide to do any new business or funding for Iran or Iran-related companies
without explicit guarantees from the U.S. government. They have us by the throat because
so much business is conducted and cleared in dollars," one European investment banker
said.
"It would be suicide to do any new business or funding for Iran or Iran-related companies
without explicit guarantees from the U.S. government. They have us by the throat because
so much business is conducted and cleared in dollars," one European investment banker
said.
"The fines are in the multibillions these days so it's just not worth the risk for a small piece
of business and maybe pleasing a (European) government."
"The fines are in the multibillions these days so it's just not worth the risk for a small piece
of business and maybe pleasing a (European) government."
An official in the French finance ministry said "precise requests" were being lodged with the
U.S. authorities, including for Total, and that the company's decision was not a surprise.
An official in the French finance ministry said "precise requests" were being lodged with the
U.S. authorities, including for Total, and that the company's decision was not a surprise.
A European diplomat was more blunt: "We have a situation where there is a will to impose
sanctions on Europeans and a resentment towards European companies who are now
being accused of supporting a terrorist state. With that in mind it's a logical decision."
A European diplomat was more blunt: "We have a situation where there is a will to impose
sanctions on Europeans and a resentment towards European companies who are now
being accused of supporting a terrorist state. With that in mind it's a logical decision."
Total said it had so far spent less than 40 million euros ($47 million) on the project and
withdrawing would not impact the company's production growth targets.
Total said it had so far spent less than 40 million euros ($47 million) on the project and
withdrawing would not impact the company's production growth targets.
Iranian oil minister Bijan Zanganeh said the French firm would not pay a penalty if it pulled
out of the project.
Iranian oil minister Bijan Zanganeh said the French firm would not pay a penalty if it pulled
out of the project.
Italy's Eni (ENI.Ml), which last June signed a provisional agreement with Tehran to conduct
oil and gas feasibility studies, said after Washington's decision to quit the nuclear deal last
week that it had no plans for new projects in Iran.
Italy's Eni (ENI.Ml), which last June signed a provisional agreement with Tehran to conduct
oil and gas feasibility studies, said after Washington's decision to quit the nuclear deal last
week that it had no plans for new projects in Iran.
In an unintended twist, U.S. President Donald Trump's decision to threaten European
companies that continue to invest in Iran may open the door to Chinese rivals.
In an unintended twist, U.S. President Donald Trump's decision to threaten European
companies that continue to invest in Iran may open the door to Chinese rivals.
Industry sources told Reuters this week that China's CNPC, which holds a 30 percent stake
in the South Pars project, was ready to take over Total's majority stake in the project if ii
pulled out.
Industry sources told Reuters this week that China's CNPC, which holds a 30 percent stake
in the South Pars project, was ready to take over Total's majority stake in the project if it
pulled out.
($1= 0.8463 euros)
($1= 0.8463 euros)
Reporting by Sudip Kar-Gupta and John Irish in Paris; Additional reporting by Stephen
Jewkes in Milan Writing by Richard Lough; Editing by Mark Potter
Reporting by Sudip Kar-Gupta and John Irish in Paris; Additional reporting by Stephen
Jewkes in Milan Writing by Richard Lough; Editing by Mark Potter
our Standards:The Thomson Reuters Trust Principles
our Standards:The Thomson Reuters Trust Principles
212
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Annex 232
N. Tzur, “Poland’s PGNiG plans to suspend gas project in Iran because of U.S.
sanctions”, Reuters, 18 May 2018

- 145 -

- 146 -

CORRECTED (OFFICIAL)-Poland's PGNiG plans to suspend gas project
in Iran because of U.S. sanctions
CORRECTED (OFFICIAL)-Poland's PGNiG plans to suspend gas project
in Iran because of U.S. sanctions
reuters.com/article/iran-nuclear-europe-pgnig/corrected-polands-pgnig-plans-to-suspend-gas-project-in-iran-because-of-u-s­
reuters.com/article/iran-nuclear-europe-pgnig/corrected-polands-pgnig-plans-to-suspend-gas-project-in-iran-because-of-u-s­
sanctions-idUSFWN 1 SPOT A
sanctions-idUSFWN1 SPTA
(Corrects to say PGNiG "plans to suspend" instead of "suspends" in line with the intentions of the
deputy chief executive)
(Corrects to say PGNiG "plans to suspend" instead of "suspends" in line with the intentions of the
deputy chief executive)
KRAKOW, Poland, May 18 (Reuters) - Poland's dominant gas firm PGNiG plans to suspend a gas
project in Iran because of the risk from U.S. sanctions, the company's deputy chief executive
said.
KRAKOW, Poland, May 18 (Reuters) - Poland's dominant gas firm PGNiG plans to suspend a gas
project in Iran because of the risk from U.S. sanctions, the company's deputy chief executive
said.
''There is not much we can do about the contract in Iran. Any moment the sanctions will be put
in place and nobody wants to take a risk," Maciej Wozniak of the state-run PGNiG told Reuters.
''There is not much we can do about the contract in Iran. Any moment the sanctions will be put
in place and nobody wants to take a risk," Maciej Wozniak of the state-run PGNiG told Reuters.
"We can take risks when we are drilling and looking for hydrocarbons, but we will not take risks
playing politics," he said, adding the project consisted of providing technical expertise in gas
extraction in Iran. (Reporting by Wojciech Zurawski Writing by Marcin Goettig; Editing by Adrian
Croft)
"We can take risks when we are drilling and looking for hydrocarbons, but we will not take risks
playing politics," he said, adding the project consisted of providing technical expertise in gas
extraction in Iran. (Reporting by Wojciech Zurawski Writing by Marcin Goettig; Editing by Adrian
Croft)
111
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Annex 233
G. De Clercq, “Engie says to end engineering contracts in Iran by November”,
Reuters, 18 May 2018

- 149 -

- 150 -

Engie says to end engineering contracts in Iran by November
Engie says to end engineering contracts in Iran by November
reuters.com/article/us-engie-iran/engie-says-to-end-engineering-contracts-in-iran-by-november-idUSKCN1I[22K
reuters.com/article/us-engie-iran/engie-says-to-end-engineering-contracts-in-iran-by-november-idUSKCN1I]22K
PARIS (Reuters) - French gas and power group Engie ( ENGIE.PA) said on Friday it would end its
engineering contracts in Iran by November.
PARIS (Reuters) - French gas and power group Engie ( ENGIE.PA) said on Friday it would end its
engineering contracts in Iran by November.
President Donald Trump's withdrawal of the United States from the nuclear accord with Iran
and his order that sanctions be reimposed on Tehran have led several European companies to
announce their exit from the country, including French oil major Total (TOTF.PA) earlier this
week.
President Donald Trump's withdrawal of the United States from the nuclear accord with Iran
and his order that sanctions be reimposed on Tehran have led several European companies to
announce their exit from the country, including French oil major Total (TOTF.PA) earlier this
week.
Engie CEO Isabelle Kocher said at a shareholders' meeting that the utility has no infrastructures
in Iran but has engineering teams working there for clients.
Engie CEO Isabelle Kocher said at a shareholders' meeting that the utility has no infrastructures
in Iran but has engineering teams working there for clients.
"We have 180 days to end these contracts, which takes us to November. It will be done," she
said.
"We have 180 days to end these contracts, which takes us to November. It will be done," she
said.
Reporting by Geert De Clercq; Editing by Adrian Croft
Reporting by Geert De Clercq; Editing by Adrian Croft
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Annex 234
V. Soldatkin, “Lukoil puts Iran plans on hold due to threat of U.S. sanctions”, Reuters,
29 May 2018

- 153 -

- 154 -

Lukoil puts Iran plans on hold due to threat of U.S. sanctions
Lukoil puts Iran plans on hold due to threat of U.S. sanctions
re u te rs.com/ article/us-russia-l ukoil-iran/lukoil-puts-i ra n-p Ian s-o n-h old-due- to-threat -o f-u-s-sanctions-idU SK CN 11 U 1 M 7
reuters.com/article/us-russia-lukoil-ir an/lukoil-puts-iran-plans-on-hold-due-to-threat-of-u-s-sanctions-idUSKCN1IU 1M7
MOSCOW (Reuters) - Lukoil, Russia's second biggest oil producer, said on Tuesday it had decided
not to go ahead with plans to develop projects in Iran at the moment due to the threat of U.S.
sanctions, a company official said.
MOSCOW (Reuters) - Lukoil, Russia's second biggest oil producer, said on Tuesday it had decided
not to go ahead with plans to develop projects in Iran at the moment due to the threat of U.S.
sanctions, a company official said.
The United States plans to impose new sanctions on Iran after pulling out of a 2015 agreement
between Iran and major world powers to limit Tehran's nuclear ambitions.
The United States plans to impose new sanctions on Iran after pulling out of a 2015 agreement
between Iran and major world powers to limit Tehran's nuclear ambitions.
"Considering the latest developments, I guess, it's too early to say what our plans (about Iran)
will be. For the moment, basically, we have everything on hold," the official told a conference call
which followed publication of Lukoil's first-quarter results on Monday.
"Considering the latest developments, I guess, it's too early to say what our plans (about Iran)
will be. For the moment, basically, we have everything on hold," the official told a conference call
which followed publication of Lukoil's first-quarter results on Monday.
Lukoil said on Monday its first-quarter net profit rose to 109.1 billion rubles ($1.8 billion), up 75
percent on the previous year with the help of rising oil prices.
Lukoil said on Monday its first-quarter net profit rose to 1 09.1 billion rubles ($1.8 billion), up 75
percent on the previous year with the help of rising oil prices.
The official said that company's focus remained on its domestic business. "We don't plant to do
anything material on the international M&A side," he said.
The official said that company's focus remained on its domestic business. "We don't plant to do
anything material on the international M&A side," he said.
Lukoil has been in talks with Iran over development of Abe Timur and Mansuri oilfields.
Lukoil has been in talks with Iran over development of Abe Timur and Mansuri oilfields.
Reporting by Vladimir Soldatkin. Editing by Jane Merriman
Reporting by Vladimir Soldatkin. Editing by Jane Merriman
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Annex 235
H. Choi, “South Korea's Daelim industrial says $2.08 billion order from Iran
cancelled”, Reuters, 1 June 2018

- 157 -

- 158 -

South Korea's Daelim industrial says $2.08 billion order from Iran
canceled
South Korea's Daelim industrial says $2.08 billion order from Iran
canceled
reuters.com/article/us-daelim-ind-iran/south-koreas-daelim-industrial-says-2-08-billion-order-from-ir an-canceled­
reuters.com/article/us-daelim-ind-iran/south-koreas-daelim-industrial-says-2-08-billion-order-from-iran-canceled­
idUSKCN1 IX44G
idUSKCN1 IX44G
SEOUL (Reuters) - South Korea's Daelim Industrial said on Friday that a contract worth 2.23
trillion won ($2.08 billion) for a refinery project in Iran was canceled.
SEOUL (Reuters) - South Korea's Daelim Industrial said on Friday that a contract worth 2.23
trillion won ($2.08 billion) for a refinery project in Iran was canceled.
The order was canceled as the Esfahan Refinery Upgrading Project failed to procure financing
because of economic sanctions imposed on Iran, Daelim said in a regulatory filing.
The order was canceled as the Esfahan Refinery Upgrading Project failed to procure financing
because of economic sanctions imposed on Iran, Daelim said in a regulatory filing.
Reporting by Haejin Choi; Editing by Vyas Mohan
Reporting by Haejin Choi; Editing by Vyas Mohan
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Annex 236
“European refiners winding down purchases of Iranian oil”, Reuters, 6 June 2018

- 161 -

- 162 -

European refiners winding down purchases of Iranian oil
European refiners winding down purchases of Iranian oil
reuters.com/article/us-iran-oil-europe/european-refiners-winding-down-purchases-of-iranian-oil-idUSKCN1,J21F0
reuters.com/article/us-iran-oil-europe/european-refiners-winding-down-purchases-of-iranian-oil-idUSKCN1J21F0
LONDON (Reuters) - European refiners are winding down oil purchases from Iran, closing
the door on a fifth of the OPEC member's crude exports after the United States imposed
sanctions on Tehran, company and trading sources said.
LONDON (Reuters) - European refiners are winding down oil purchases from Iran, closing
the door on a fifth of the OPEC member's crude exports after the United States imposed
sanctions on Tehran, company and trading sources said.
m
m
FILE PHOTO: Fuel nozzles are seen at a petrol station in Madrid, Spain, May 29, 2018.
REUTERS/Sergio Perez/File Photo
Although European governments have not followed Washington by creating new sanctions,
banks, insurers and shippers are gradually severing ties with Iran under pressure from the
U.S. restrictions, making trade with Tehran complicated and risky.
FILE PHOTO: Fuel nozzles are seen at a petrol station in Madrid, Spain, May 29, 2018.
REUTERS/Sergio Perez/File Photo
Although European governments have not followed Washington by creating new sanctions,
banks, insurers and shippers are gradually severing ties with Iran under pressure from the
U.S. restrictions, making trade with Tehran complicated and risky.
U.S. President Donald Trump on May 4 announced his decision to quit a landmark 2015
nuclear deal between Iran and world powers and reimposed sanctions on Tehran. The
sanctions on Iran's petroleum sector will take effect after a 180-day "wind-down period"
ending on Nov. 4.
U.S. President Donald Trump on May 4 announced his decision to quit a landmark 2015
nuclear deal between Iran and world powers and reimposed sanctions on Tehran. The
sanctions on Iran's petroleum sector will take effect after a 180-day "wind-down period"
ending on Nov. 4.
"We cannot defy the United States," said a senior source at Italy's Saras, which operates
the 300,000-barrels-per-day (bpd) Sarroch refinery in Sardinia.
"We cannot defy the United States," said a senior source at Italy's Saras, which operates
the 300,000-barrels-per-day (bpd) Sarroch refinery in Sardinia.
Saras is determining how best to halt its purchasing of Iranian oil within the permitted 180
days, the source said, adding: "It is not clear yet what the U.S. administration can do but in
practice we can get into trouble."
Saras is determining how best to halt its purchasing of Iranian oil within the permitted 180
days, the source said, adding: "It is not clear yet what the U.S. administration can do but in
practice we can get into trouble."
A drop in crude trading between Iran and Europe could complicate efforts by the European
signatories of the nuclear deal - France, Germany and Britain - to salvage the agreement.
A drop in crude trading between Iran and Europe could complicate efforts by the European
signatories of the nuclear deal - France, Germany and Britain - to salvage the agreement.
Refiners including France's Total, Italy's Eni and Saras, Spain's Repsol and Cepsa as well
as Greece's Hellenic Petroleum are preparing to halt purchases of Iranian oil once
sanctions bite, the sources said.
Refiners including France's Total, Italy's Eni and Saras, Spain's Repsol and Cepsa as well
as Greece's Hellenic Petroleum are preparing to halt purchases of Iranian oil once
sanctions bite, the sources said.
These refiners account for most of Europe's purchases of Iranian crude, which represent
around a fifth of the country's oil exports.
These refiners account for most of Europe's purchases of Iranian crude, which represent
around a fifth of the country's oil exports.
Iran's crude sales to foreign buyers averaged around 2.5 million bpd in recent months,
according to data collected by Reuters and EU statistics office Eurostat. The bulk of the
exports go to Asia.
Iran's crude sales to foreign buyers averaged around 2.5 million bpd in recent months,
according to data collected by Reuters and EU statistics office Eurostat. The bulk of the
exports go to Asia.
(For a graphic on 'Iranian crude exports' clikc reut.rs/2Jw4ehD)
(For a graphic on 'Iranian crude exports' clikc reut.rs/2Jw4ehD)
The companies, most of which have long-term contracts with Iran's national oil company,
will continue to purchase cargoes until the sanctions take effect, the sources said.
The companies, most of which have long-term contracts with Iran's national oil company,
will continue to purchase cargoes until the sanctions take effect, the sources said.
1/2
1/2
- 163 -

Total, Europe's largest refiner, does not intend to request a waiver to continue crude oil
trading with Iran after Nov. 4, according to people with direct knowledge of the matter. That
effectively means it will be unable to keep purchasing crude.
Total, Europe's largest refiner, does not intend to request a waiver to continue crude oil
trading with Iran after Nov. 4, according to people with direct knowledge of the matter. That
effectively means it will be unable to keep purchasing crude.
Eni said it had an oil supply contract outstanding for the purchase of 2 million barrels per
month, expiring at the end of the year.
Eni said it had an oil supply contract outstanding for the purchase of 2 million barrels per
month, expiring at the end of the year.
Repsol and Hellenic Petroleum declined to comment.
Repsol and Hellenic Petroleum declined to comment.
"Our trading activity (remains) business as usual ... We continue to strictly conform with
European Union and international laws and regulations," a Cepsa spokesman said.
"Our trading activity (remains) business as usual ... We continue to strictly conform with
European Union and international laws and regulations," a Cepsa spokesman said.
Iranian crude can be substituted by Russian Ural grades, whose prices have risen following
the U.S. announcement, as well as crude from Saudi Arabia, trading sources said.
Iranian crude can be substituted by Russian Ural grades, whose prices have risen following
the U.S. announcement, as well as crude from Saudi Arabia, trading sources said.
(For a graphic on 'Iran's crude oil trade' click reut.rs/2Lq7 Jnh)
(For a graphic on 'Iran's crude oil trade' clickreut.rs/2Lq7Jnh)
WAIVER
WAIVER
Some of the refiners, including Cepsa, are considering whether to request a waiver from
U.S. authorities to continue buying beyond the November deadline in order to complete
their term agreements.
Some of the refiners, including Cepsa, are considering whether to request a waiver from
U.S. authorities to continue buying beyond the November deadline in order to complete
their term agreements.
"With a longer-term contract in place, we're hoping to get a six-month waiver," an industry
source close to Cepsa said. "From November, we don't know if any cuts will have to be
partial or total."
"With a longer-term contract in place, we're hoping to get a six-month waiver," an industry
source close to Cepsa said. "From November, we don't know if any cuts will have to be
partial or total."
Crude trade between Iran and Europe has risen sharply since the lifting of tough sanctions
on Tehran in 2015.
Crude trade between Iran and Europe has risen sharply since the lifting of tough sanctions
on Tehran in 2015.
But banks, shipping firms and insurance companies are now distancing themselves from
the Islamic republic, leaving Europe's refiners few options but to stop oil purchases.
But banks, shipping firms and insurance companies are now distancing themselves from
the Islamic republic, leaving Europe's refiners few options but to stop oil purchases.
"It's a matter of finding a tanker and an insurer that will cover it. It's definitely not easy right
now," a source at Repsol said.
"It's a matter of finding a tanker and an insurer that will cover it. It's definitely not easy right
now," a source at Repsol said.
Hellenic had to stop imports because the Swiss bank that it used was no longer processing
payments to Iran, an industry source familiar with the situation said.
Hellenic had to stop imports because the Swiss bank that it used was no longer processing
payments to Iran, an industry source familiar with the situation said.
Asian buyers are also expected to reduce their purchases. India's Reliance Industries Ltd,
owner of the world's biggest refining complex, plans to halt oil imports from Iran, two
sources familiar with the matter said last week.
Asian buyers are also expected to reduce their purchases. India's Reliance Industries Ltd,
owner of the world's biggest refining complex, plans to halt oil imports from Iran, two
sources familiar with the matter said last week.
Additional reporting by Ahmad Ghaddar in London, Stephen Jewkes in Milan and Angeliki
Koutantou in Athens; Editing by Dale Hudson
Additional reporting by Ahmad Ghaddar in London, Stephen Jewkes in Milan and Angeliki
Koutantou in Athens; Editing by Dale Hudson
Our Standards:The Thomson Reuters Trust Principles.
Our Standards:The Thomson Reuters Trust Principles.
212
2/2

- 164 -

Annex 237
T. Di Christopher & S. Sedgwick, “U.S. sanctions mean no big oil company can risk
doing business with Iran, Total CEO says”, CNBC, 20 June 2018

- 165 -

- 166 -

US sanctions mean no big oil company can risk doing business with
Iran, Total CEO says
US sanctions mean no big oil company can risk doing business with
Iran, Total CEO says
di cnbc.com/2018/06/20/no-big-oil-company-can-risk-doing-business-with-iran-total-ceo-says.html
Tom DiChristopher I Steve Sedgwick
June 20, 2018
di cnbc.com/2018/06/20/no-big-oil-company-can-risk-doing-business-with-iran-total-ceo-says.html
Tom DiChristopher I Steve Sedgwick
June 20, 2018
French energy giant Total has yet to permanently pull out of Iran following the renewal of U.S.
sanctions, but CEO Patrick Pouyanne on Wednesday sounded a pessimistic note about his
company's prospects in the country.
French energy giant Total has yet to permanently pull out of Iran following the renewal of U.S.
sanctions, but CEO Patrick Pouyanne on Wednesday sounded a pessimistic note about his
company's prospects in the country.
Total positioned itself to develop a portion of the world's largest natural gas field after the 2015
Iran nuclear deal lifted punishing sanctions on the Iranian economy. However, the company is
now preparing to abandon the Persian Gulf project unless the U.S. government issues the
company a sanctions waiver.
Total positioned itself to develop a portion of the world's largest natural gas field after the 2015
Iran nuclear deal lifted punishing sanctions on the Iranian economy. However, the company is
now preparing to abandon the Persian Gulf project unless the U.S. government issues the
company a sanctions waiver.
That would protect Total from so-called secondary sanctions, which the United States can use to
punish foreign companies that engage in prohibited activity with Iran. Washington gave firms 90
to 180 days to wind down their business in the country after President Donald Trumpwithdrew
the United States from the nuclear deal last month.
That would protect Total from so-called secondary sanctions, which the United States can use to
punish foreign companies that engage in prohibited activity with Iran. Washington gave firms 90
to 180 days to wind down their business in the country after President Donald Trumpwithdrew
the United States from the nuclear deal last month.
"There's not a single international company like Total who can work in any country with
secondary sanctions. I don't have the right. It's just the reality of the world," Pouyanne told CNBC
at an OPEC seminar in Vienna.
"There's not a single international company like Total who can work in any country with
secondary sanctions. I don't have the right. It's just the reality of the world," Pouyanne told CNBC
at an OPEC seminar in Vienna.
Pouyanne acknowledged that his position probably does not sit well with Europe's leaders. The
European Union has attempted to salvage the nuclear deal by passing measures aimed at
protecting the bloc's firms that have business dealings in Iran.
Pouyanne acknowledged that his position probably does not sit well with Europe's leaders. The
European Union has attempted to salvage the nuclear deal by passing measures aimed at
protecting the bloc's firms that have business dealings in Iran.
But Pouyanne told CNBC he must be pragmatic and face reality.
But Pouyanne told CNBC he must be pragmatic and face reality.
"The reality is that the capital of the world today is in the hands of the U.S.," he said. "Is it right
that in this world the U.S. [is] using that ... to impose some rules for other countries? That's a
debate."
"The reality is that the capital of the world today is in the hands of the U.S.," he said. "Is it right
that in this world the U.S. [is] using that ... to impose some rules for other countries? That's a
debate."
Secondary sanctions are particularly perilous for multinationals like Total. Engaging in
sanctioned activity with Iran could prompt the American government to cut Total off from the
massive U.S. financial system and force the firm to wind down its operations in the States,
Secondary sanctions are particularly perilous for multinationals like Total. Engaging in
sanctioned activity with Iran could prompt the American government to cut Total off from the
massive U.S. financial system and force the firm to wind down its operations in the States.
"The U.S. could decide that I could not have access to any U.S. financing," Pouyanne said. "It's
impossible, let me be clear, to run an international company like Total without having access to
U.S. financing or to U.S. shareholding."
"The U.S. could decide that I could not have access to any U.S. financing," Pouyanne said. "It's
impossible, let me be clear, to run an international company like Total without having access to
U.S. financing or to U.S. shareholding."
Total says U.S. banks are involved in about 90 percent of the company's financing operations,
while American investors account for more than 30 percent of its shareholding. The company
has more than $10 billion deployed in U.S. operations.
Total says U.S. banks are involved in about 90 percent of the company's financing operations,
while American investors account for more than 30 percent of its shareholding. The company
has more than $10 billion deployed in U.S. operations.
112
112
- 167 -

By comparison, Total spent less than 40 million euros, or roughly $46 million, on its project
developing the massive South Pars natural gas field in Iranian waters.
By comparison, Total spent less than 40 million euros, or roughly $46 million, on its project
developing the massive South Pars natural gas field in Iranian waters.
2/2
212

- 168 -

Annex 238
“U.S. Toughens Stance on Future Iran Oil Exports”, The Wall Street Journal, 26 June
2018

- 169 -

- 170 -

THE WALL STREET JOURNAL.
THE WALL STREET JOURNAL.
This copy is for your personal, non-commercial use only To order presentation-ready copies for distribution to your colleagues, clients or customers visit
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https. //www.dreprints.com
https./www.dreprints.com
https./www.wsj.com/articles/u-s-signals-zero-tolerance-on-future-iran-oil-expo…
https /www.wsj.com/articles/u-s-signals-zero-tolerance-on-future-iran-oil-expo…
WORLD
WORLD
U.S. Toughens Stance on Future Iran Oil
Exports
U.S. Toughens Stance on Future Iran Oil
Exports
Senior official says any country that imports Iranian oil after November risks sanctions
Senior official says any country that imports Iranian oil after November risks sanctions
A gas flare on an Iranian oil-production platform in Soroush oil fields in the Persian Gulf. PHOTO: RAH EB
A gas flare on an Iranian oil-production platform in Soroush oil fields in the Persian Gulf. PHOTO: RAH EB
HOMAVANDI/REUTERS
HOMAVANDI/REUTERS
By Ian Talley
By Ian Talley
Updated June 26, 2018 724 p.m. ET
Updated June 26, 2018 724 p.m. ET
WASHINGTON-The U.S. threatened to slap sanctions on countries that don't cut oil
imports from Iran to "zero" by Nov. 4, part of the Trump administration's push to
further isolate Tehran both politically and economically, a senior U.S. State
Department official said.
WASHINGTON-The U.S. threatened to slap sanctions on countries that don't cut oil
imports from Iran to "zero" by Nov. 4, part of the Trump administration's push to
further isolate Tehran both politically and economically, a senior U.S. State
Department official said.
Buyers oflranian crude had expected the U.S. would allow them time to reduce their oil
imports over a much longer period, by issuing sanctions waivers for nations that made
significant efforts to cut their purchases. That expectation was partly based on
previous comments from top Trump officials, as well as the Obama administration's
earlier effort to wean the world off Iranian oil over several years.
Buyers of Iranian crude had expected the U.S. would allow them time to reduce their oil
imports over a much longer period, by issuing sanctions waivers for nations that made
significant efforts to cut their purchases. That expectation was partly based on
previous comments from top Trump officials, as well as the Obama administration's
earlier effort to wean the world off Iranian oil over several years.
- 171 -

But the senior State Department official said on Tuesday that President Donald
Trump's administration doesn't plan to issue any waivers and would instead be asking
other Middle Eastern crude exporters over the coming days to ensure oil supply to
global markets.
But the senior State Department official said on Tuesday that President Donald
Trump's administration doesn't plan to issue any waivers and would instead be asking
other Middle Eastern crude exporters over the coming days to ensure oil supply to
global markets.
The tactic is likely to further escalate geopolitical tensions between the U.S. and other
nations as the Trump administration pits itself against its allies and other major
economies over its nearly unilateral policy toward Iran and a host of challenges on
trade.
The tactic is likely to further escalate geopolitical tensions between the U.S. and other
nations as the Trump administration pits itself against its allies and other major
economies over its nearly unilateral policy toward Iran and a host of challenges on
trade.
Oil prices immediately jumped on the news, with West Texas Intermediate crude for
August delivery ending 3.6% higher at $70.53 a barrel on the New York Mercantile
Exchange. That marked the highest level since May, when the White House said it
would pull out of the 2015 Iran nuclear accord-which the U.S. and other major
countries reached with Tehran to curb its nuclear development-and would reimpose
crushing sanctions on one of the world's largest oil suppliers.
Oil prices immediately jumped on the news, with West Texas Intermediate crude for
August delivery ending 3.6% higher at $70.53 a barrel on the New York Mercantile
Exchange. That marked the highest level since May, when the White House said it
would pull out of the 2015 Iran nuclear accord-which the U.S. and other major
countries reached with Tehran to curb its nuclear development-and would reimpose
crushing sanctions on one of the world's largest oil suppliers.
MORE
• The World Suddenly Needs a Lot More Oil After U.S. Move on Iran Sanctions
• Oil Climbs on Supply Risks
• King Dollar Tightens Noose on Iran Economy
• Small U.S. Towns Are Booming, Thanks to Rising Crude Prices
"We will certainly be
requesting that their oil
imports go to zero
without question by Nov.
4th," the official said of
other countries'
purchases of Iranian oil.
MORE
• The World Suddenly Needs a Lot More Oil After U.S. Move on Iran Sanctions
• Oil Climbs on Supply Risks
• King Dollar Tightens Noose on Iran Economy
• Small U.S. Towns Are Booming, Thanks to Rising Crude Prices
"We will certainly be
requesting that their oil
imports go to zero
without question by Nov.
4th," the official said of
other countries'
purchases of Iranian oil.
While the administration won't rule out issuing sanctions waivers in the future, the
official said, its predisposition is: "No, we're not going to do waivers."
While the administration won't rule out issuing sanctions waivers in the future, the
official said, its predisposition is: "No, we're not going to do waivers."
"We view this as one of our top national-security priorities," the official said.
"We view this as one of our top national-security priorities," the official said.
The move is likely designed to spur greater global compliance with U.S. sanctions. Most
major importers oflranian crude have balked at Washington's new economic offensive
against Tehran.
The move is likely designed to spur greater global compliance with U.S. sanctions. Most
major importers oflranian crude have balked at Washington's new economic offensive
against Tehran.
Two weeks ago, Andrew Peek, deputy assistant secretary of State for Iran and Iraq,
said the U.S. was prepared to issue waivers if countries made major reductions in
Two weeks ago, Andrew Peek, deputy assistant secretary of State for Iran and Iraq,
said the U.S. was prepared to issue waivers if countries made major reductions in
Iran oil imports. "It needs to be significant but will probably vary from country to
country," he said then.
Iran oil imports. "It needs to be significant but will probably vary from country to
country," he said then.
Top administration officials from the State and Treasury departments have jetted
around the world in recent days to persuade other countries to cut use of Iranian crude
and warn them that any companies, banks or traders that handle Iranian oil face U.S.
penalties, including the risk of being frozen out of U.S. markets. The senior State
Department official said allies in Europe and Asia already had been warned, and trips to
China, India and Turkey were in the works.
Top administration officials from the State and Treasury departments have jetted
around the world in recent days to persuade other countries to cut use of Iranian crude
and warn them that any companies, banks or traders that handle Iranian oil face U.S.
penalties, including the risk of being frozen out of U.S. markets. The senior State
Department official said allies in Europe and Asia already had been warned, and trips to
China, India and Turkey were in the works.
- 172 -

Governments are being cautioned that Secretary of State Mike Pompeo and the White
House "aren't kidding about this," the official said. China and India, two of the largest
buyers of Iranian crude, "will be subject to the same sanctions that everybody else is if
they engage in those sectors of the economy."
Governments are being cautioned that Secretary of State Mike Pompeo and the White
House "aren't kidding about this," the official said. China and India, two of the largest
buyers of Iranian crude, "will be subject to the same sanctions that everybody else is if
they engage in those sectors of the economy."
The Trump administration, in pulling out of the nuclear accord and reimposing
economywide sanctions on Iran that hit not just the oil sector, but also the banking,
shipping, trade and insurance markets, said it wants to force Tehran to radically
overhaul its nuclear and military posture in the region.
The Trump administration, in pulling out of the nuclear accord and reimposing
economywide sanctions on Iran that hit not just the oil sector, but also the banking,
shipping, trade and insurance markets, said it wants to force Tehran to radically
overhaul its nuclear and military posture in the region.
A crew member working in the engine room of the oil tanker 'Devon' in March as it prepared to sail to to pick up
crude oil in Iran for export. PHOTO: ALI MOHAMMADI/BLOOMBERG NEWS
A crew member working in the engine room of the oil tanker 'Devon' in March as it prepared to sail to to pick up
crude oil in Iran for export. PHOTO: ALI MOHAMMADI/BLOOMBERG NEWS
Banks' reluctance to deal with Iran is already taking its toll on Tehran's oil exports.
Exports have fallen to an average of 2.2 million barrels a day this month, compared
with 2.7 million barrels a day in May, according to data from London-based consulting
firm Vortexa. Earlier this month, Indian Oil Corp., the country's largest refiner, said it
was considering cutting Iran crude imports after a decision by government-run State
Bank of India to stop dealing with Tehran.
Banks' reluctance to deal with Iran is already taking its toll on Tehran's oil exports.
Exports have fallen to an average of 2.2 million barrels a day this month, compared
with 2.7 million barrels a day in May, according to data from London-based consulting
firm Vortexa. Earlier this month, Indian Oil Corp., the country's largest refiner, said it
was considering cutting Iran crude imports after a decision by government-run State
Bank ofindia to stop dealing with Tehran.
European refiners, which buy around a third of Iran's oil exports, are also dropping out.
Italy's Saras is considering no longer buying Iranian oil because its banks don't want to
finance such trades even before the Nov. 4 deadline, according to company officials. The
company said last week it had made no final decision. European refiners say they have
already started buying more oil from Saudi Arabia, Russia and Iraq to make up for
upcoming reductions in Iranian oil.
European refiners, which buy around a third of Iran's oil exports, are also dropping out.
Italy's Saras is considering no longer buying Iranian oil because its banks don't want to
finance such trades even before the Nov. 4 deadline, according to company officials. The
company said last week it had made no final decision. European refiners say they have
already started buying more oil from Saudi Arabia, Russia and Iraq to make up for
upcoming reductions in Iranian oil.
Meanwhile, economic woes have triggered a new round of protests in Iran, posing a
challenge to President Hassan Rouhani's government as it struggles to tackle
persistent double-digit inflation and unemployment. Economic concerns in the country
have been aggravated by the Trump administration's exit from the 2015 nuclear
accord.
Meanwhile, economic woes have triggered a new round of protests in Iran, posing a
challenge to President Hassan Rouhani's government as it struggles to tackle
persistent double-digit inflation and unemployment. Economic concerns in the country
have been aggravated by the Trump administration's exit from the 2015 nuclear
accord.
- 173 -

Mr. Pompeo warned last month that Tehran would face "the strongest sanctions in
history" if it didn't yield to U.S. demands that it temper its nuclear and regional
ambitions. He also suggested the Iranian public could take matters into its own hands.
Mr. Pompeo warned last month that Tehran would face "the strongest sanctions in
history" if it didn't yield to U.S. demands that it temper its nuclear and regional
ambitions. He also suggested the Iranian public could take matters into its own hands.
The administration's more aggressive stance on sanctions could bolster its leverage
over Tehran, but it also complicates the White House's other diplomatic and political
priorities.
The administration's more aggressive stance on sanctions could bolster its leverage
over Tehran, but it also complicates the White House's other diplomatic and political
priorities.
The move puts particular pressure on major trans-Atlantic allies that import hefty
amounts of crude from Iran at a time when Mr. Trump is ratcheting up tensions with
European nations over trade and seeking their support for his North Korea pressure
campaign and other foreign-policy goals.
The move puts particular pressure on major trans-Atlantic allies that import hefty
amounts of crude from Iran at a time when Mr. Trump is ratcheting up tensions with
European nations over trade and seeking their support for his North Korea pressure
campaign and other foreign-policy goals.
European officials said in recent weeks they expected oil imports would have to start
gradually falling after the November deadline, giving them time to explore how to keep
Iran in the nuclear deal and prevent it from resuming its nuclear activities.
European officials said in recent weeks they expected oil imports would have to start
gradually falling after the November deadline, giving them time to explore how to keep
Iran in the nuclear deal and prevent it from resuming its nuclear activities.
Tuesday's announcement could deflate those hopes. "This is really unhelpful and part
of an escalation plan. We strongly disagree with this plan," a senior European diplomat
said.
Tuesday's announcement could deflate those hopes. "This is really unhelpful and part
of an escalation plan. We strongly disagree with this plan," a senior European diplomat
said.
Many in Europe had been hoping the administration might continue the Obama-era
practice of giving sanction waivers for 20% reductions in imports.
Many in Europe had been hoping the administration might continue the Obama-era
practice of giving sanction waivers for 20% reductions in imports.
Another senior European official cautioned that the U.S. policy may turn out to be more
bark than bite, particularly as Washington will likely struggle to persuade other
countries to accede to their demands on such a sensitive issue as energy imports.
"They will not succeed," the person said.
Another senior European official cautioned that the U.S. policy may turn out to be more
bark than bite, particularly as Washington will likely struggle to persuade other
countries to accede to their demands on such a sensitive issue as energy imports.
"They will not succeed," the person said.
Separately, European officials have said they would try to maintain banking channels to
ensure continued trade and investment, including energy imports, though many
analysts question whether they will be able to do so.
Separately, European officials have said they would try to maintain banking channels to
ensure continued trade and investment, including energy imports, though many
analysts question whether they will be able to do so.
In Asia, the U.S. is relying on China to help it keep pressure on North Korea by cutting
the financial and economic ties vital to Pyongyang. Some analysts say China's
government will likely keep importing Iranian crude, banking on Washington's desire
for its cooperation on North Korea.
In Asia, the U.S. is relying on China to help it keep pressure on North Korea by cutting
the financial and economic ties vital to Pyongyang. Some analysts say China's
government will likely keep importing Iranian crude, banking on Washington's desire
for its cooperation on North Korea.
And as the administration's Iran policy risks pushing up oil prices as the U.S. heads into
elections this year, the White House could face its own domestic political backlash.
And as the administration's Iran policy risks pushing up oil prices as the U.S. heads into
elections this year, the White House could face its own domestic political backlash.
The more aggressive policy could push oil prices past $85 a barrel by the third quarter
of the year, said Frank Verrastro, a top energy expert at the Center for Strategic and
International Studies in Washington.
The more aggressive policy could push oil prices past $85 a barrel by the third quarter
of the year, said Frank Verrastro, a top energy expert at the Center for Strategic and
International Studies in Washington.
While oil from other suppliers can fit the refining specifications set for Iranian crude
While oil from other suppliers can fit the refining specifications set for Iranian crude
- 174 -

and Russia and other major producers have signaled they will increase output, other
production squeezes could exacerbate the upward price pressure sanctions are putting
on markets.
and Russia and other major producers have signaled they will increase output, other
production squeezes could exacerbate the upward price pressure sanctions are putting
on markets.
Mr. Verrastro said the International Energy Agency was too optimistic in its recent
estimate that the world has around 3.5 million barrels a day of spare production
capacity that could offset Iran's 2.4 million in daily exports. That assumes nearly all of
the spare capacity currently offiine in Saudi Arabia and other major exporters could
come back online and run smoothly, he said, noting that hurricanes, labor strikes,
technical problems and political turmoil often tighten the spigot on global oil supplies.
Mr. Verrastro said the International Energy Agency was too optimistic in its recent
estimate that the world has around 3.5 million barrels a day of spare production
capacity that could offset Iran's 2.4 million in daily exports. That assumes nearly all of
the spare capacity currently offline in Saudi Arabia and other major exporters could
come back online and run smoothly, he said, noting that hurricanes, labor strikes,
technical problems and political turmoil often tighten the spigot on global oil supplies.
"I would guess they reassess in November, when prices are rising heading into the
election season," Mr. Verrastro said.
"I would guess they reassess in November, when prices are rising heading into the
election season," Mr. Verrastro said.
-Benoit Faucon in London, Laurence Norman in Brussels, Michael R. Gordon in
Washington and Aresu Eqbali in Tehran contributed to this article.
-Benoit Faucon in London, Laurence Norman in Brussels, Michael R. Gordon in
Washington and Aresu Eqbali in Tehran contributed to this article.
Write to Ian Talley at [email protected]
Write to Ian Talley at [email protected]
Copyright© 2019 Dow Jones & Company,
Inc. ANI Rights Reserved
Copyright O 2019 Dow Jones & Company,
Inc. ANI Rights Reserved
This copy is for your personal, non-commercial use only. To order presentation-ready copies for distribution to your colleagues, clients or customers visit
https://www.djreprints.com.
This copy is for your personal, non-commercial use only. To order presentation-ready copies for distribution to your colleagues, clients or customers visit
https://www.djreprints.com.

- 175 -

- 176 -

Annex 239
R. Valdmanis, “Indonesia's Pertamina says Iran oil field deal frozen over U.S.
sanctions”, Reuters, 26 June 2018

- 177 -

- 178 -

Indonesia's Pertamina says Iran oil field deal frozen over
US sanctions
Indonesia's Pertamina says Iran oil field deal frozen over
US sanctions
6 reuters.com/article/gas-conference-pertamina/indonesias-pertamina-says-iran-oil-field-deal-frozen-over-us-sanctions­
4 reuters.com/article/gas-conference-pertamina/indonesias-pertamina-says-iran-oil-field-deal-frozen-over-us-sanctions­
idUSL8N1TS5UJ
idUSL8N1TS5UJ
WASHINGTON, June 26 (Reuters) - Indonesia's government decided last month to freeze
Pertamina's deal to operate the Mansouri oil field in Iran because it wanted to preserve the
country's "good relationship" with the United States, Pertamina's Acting Chief Executive
Nicke Widyawati said on Tuesday.
WASHINGTON, June 26 (Reuters) - Indonesia's government decided last month to freeze
Pertamina's deal to operate the Mansouri oil field in Iran because it wanted to preserve the
country's "good relationship" with the United States, Pertamina's Acting Chief Executive
Nicke Widyawati said on Tuesday.
"We have a good relationship with the United States, and so, it is on hold," Widyawati told
Reuters, adding that the decision came after consultations between Indonesia's
presidency, energy and mines ministry, and Pertamina.
"We have a good relationship with the United States, and so, it is on hold," Widyawati told
Reuters, adding that the decision came after consultations between Indonesia's
presidency, energy and mines ministry, and Pertamina.
Widyawati made the comments at an event on the sidelines of a global natural gas
conference in Washington. She would not say whether the Mansouri project was likely to be
revived in the future.
Widyawati made the comments at an event on the sidelines of a global natural gas
conference in Washington. She would not say whether the Mansouri project was likely to be
revived in the future.
The U.S. State Department on Tuesday said it was pushing allies to cut their crude imports
from Iran to zero as part of renewed sanctions it is imposing after President Donald Trump
abandoned a deal reached in late 2015 that limited Tehran's nuclear ambitions.
The U.S. State Department on Tuesday said it was pushing allies to cut their crude imports
from Iran to zero as part of renewed sanctions it is imposing after President Donald Trump
abandoned a deal reached in late 2015 that limited Tehran's nuclear ambitions.
Indonesia, a former OPEC member, is becoming a growing energy trading partner with the
United States, with a 20-year liquefied natural gas supply deal with U.S. exporter Cheniere
Energy that begins this year.
Indonesia, a former OPEC member, is becoming a growing energy trading partner with the
United States, with a 20-year liquefied natural gas supply deal with U.S. exporter Cheniere
Energy that begins this year.
Widyawati said some portion of early deliveries from that deal would likely be resold by
Pertamina's trading operation, since Indonesia's own gas production will likely meet
domestic demand until at least 2020.
Widyawati said some portion of early deliveries from that deal would likely be resold by
Pertamina's trading operation, since Indonesia's own gas production will likely meet
domestic demand until at least 2020.
"Yes, some of it will be resold," she said.
"Yes, some of it will be resold," she said.
She said, however, Indonesian gas demand would rise sharply in the coming years due to
new petrochemicals facilities and a gas-fired power plant coming on line. (Reporting by
Richard Valdmanis; Editing by David Gregorio)
She said, however, Indonesian gas demand would rise sharply in the coming years due to
new petrochemicals facilities and a gas-fired power plant coming on line. (Reporting by
Richard Valdmanis; Editing by David Gregorio)
Our Standards:The Thomson Reuters Trust Principles.
Our Standards:The Thomson Reuters Trust Principles.
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- 180 -

Annex 240
“U.S. pushes allies to halt Iran oil imports, waivers unlikely”, Reuters, 27 June 2018

- 181 -

- 182 -

U.S. pushes allies to halt Iran oil imports, waivers unlikely
U.S. pushes allies to halt Iran oil imports, waivers unlikely
reuters.com/article/us-usa-iran/u-s-pushes-allies-to-halt-iran-oil-imports-waivers-unlikely-idUSKBN 1JM26Q
reuters.com/article/us-usa-iran/u-s-pushes-allies-to-halt-iran-oil-imports-waivers-unlikely-idUSKBN 1JM26Q
WASHINGTON (Reuters) - The United States has told countries to cut all imports of Iranian oil
from November and is unlikely to offer any exemptions, a senior State Department official said
on Tuesday as the Trump administration ramps up pressure on allies to cut off funding to Iran.
WASHINGTON (Reuters) - The United States has told countries to cut all imports of Iranian oil
from November and is unlikely to offer any exemptions, a senior State Department official said
on Tuesday as the Trump administration ramps up pressure on allies to cut off funding to Iran.
U.S. President Donald Trump in May said his administration was withdrawing from the
"defective" nuclear deal agreed between Iran and six world powers in July 2015, aimed at
curbing Tehran's nuclear capabilities in exchange for the lifting of some sanctions, and ordered
the reimposition of U.S. sanctions against Tehran that were suspended under the accord.
U.S. President Donald Trump in May said his administration was withdrawing from the
"defective" nuclear deal agreed between Iran and six world powers in July 2015, aimed at
curbing Tehran's nuclear capabilities in exchange for the lifting of some sanctions, and ordered
the reimposition of U.S. sanctions against Tehran that were suspended under the accord.
"Yes, we are asking them to go to zero," the official said when asked if the United States was
pushing allies, including China and India, to cut oil imports to zero by November.
''Yes, we are asking them to go to zero," the official said when asked if the United States was
pushing allies, including China and India, to cut oil imports to zero by November.
"We're going to isolate streams of Iranian funding and looking to highlight the totality of Iran's
malign behavior across the region," the official, speaking on condition of anonymity, told
reporters.
"We're going to isolate streams of Iranian funding and looking to highlight the totality of Iran's
malign behavior across the region," the official, speaking on condition of anonymity, told
reporters.
The official said a U.S. delegation was headed to the Middle East next week to urge Gulf
producers to ensure global oil supplies as Iran is cut out of the market starting on Nov. 4 when
U.S. sanctions are reimposed.
The official said a U.S. delegation was headed to the Middle East next week to urge Gulf
producers to ensure global oil supplies as Iran is cut out of the market starting on Nov. 4 when
U.S. sanctions are reimposed.
Officials have yet to hold talks with China and India, among the largest importers of Iran's oil, as
well as Turkey and Iraq.
Officials have yet to hold talks with China and India, among the largest importers of Iran's oil, as
well as Turkey and Iraq.
Benchmark U.S. oil futures rose more than $2 on Tuesday, topping $70 a barrel for the first time
since May 25 as the threat that the United States would push buyers to limit Iranian oil imports
added to concerns about tightening supplies.
Benchmark U.S. oil futures rose more than $2 on Tuesday, topping $70 a barrel for the first time
since May 25 as the threat that the United States would push buyers to limit Iranian oil imports
added to concerns about tightening supplies.
Asked if any waivers were expected to be granted in the process, the official said the position of
the administration was that no exemptions would be permitted. He added: "I would be hesitant
to say zero waivers ever."
Asked if any waivers were expected to be granted in the process, the official said the position of
the administration was that no exemptions would be permitted. He added: "I would be hesitant
to say zero waivers ever."
Senior State Department and Treasury officials are pressing allies in Europe, Asia and the
Middle East to adhere to the sanctions, which are aimed at pressuring Iran to negotiate a follow­
up agreement to halt its nuclear programs.
Senior State Department and Treasury officials are pressing allies in Europe, Asia and the
Middle East to adhere to the sanctions, which are aimed at pressuring Iran to negotiate a follow­
up agreement to halt its nuclear programs.
Iran has met with Chinese oil buyers to ask them to maintain imports of its oil, although it failed
to secure guarantees from China, sources familiar with the matter told Reuters in May.
Iran has met with Chinese oil buyers to ask them to maintain imports of its oil, although it failed
to secure guarantees from China, sources familiar with the matter told Reuters in May.
"We will be engaging in the next segment coming up in a week or so with our Middle Eastern
partners to ensure the global supply of oil is not adversely affected by these sanctions," the
official said.
"We will be engaging in the next segment coming up in a week or so with our Middle Eastern
partners to ensure the global supply of oil is not adversely affected by these sanctions," the
official said.
112
112
- 183 -

China, the world's top crude oil buyer, imported around 655,000 barrels a day on average from
Iran in the first quarter of this year, according to official Chinese customs data, equivalent to
more than a quarter of Iran's total exports.
China, the world's top crude oil buyer, imported around 655,000 barrels a day on average from
Iran in the first quarter of this year, according to official Chinese customs data, equivalent to
more than a quarter of Iran's total exports.
Oil analysts said there are concerns that OPEC producers will not be able to fully supply the
market after Iranian oil is cut from the market.
Oil analysts said there are concerns that OPEC producers will not be able to fully supply the
market after Iranian oil is cut from the market.
''There is real concern on whether the 'OPEC Plus' will have enough spare capacity to balance
potential drops in oil production from Venezuela and Iran," said Abhishek Kumar, Senior Energy
Analyst at lnterfax Energy's Global Gas Analytics in London.
''There is real concern on whether the 'OPEC Plus' will have enough spare capacity to balance
potential drops in oil production from Venezuela and Iran," said Abhishek Kumar, Senior Energy
Analyst at lnterfax Energy's Global Gas Analytics in London.
European powers have vowed to keep the 2015 deal alive without the United States by trying to
keep Iran's oil and investment flowing, but have acknowledged that U.S. sanctions would make it
difficult to give Tehran guarantees.
European powers have vowed to keep the 2015 deal alive without the United States by trying to
keep Iran's oil and investment flowing, but have acknowledged that U.S. sanctions would make it
difficult to give Tehran guarantees.
"For the vast majority of countries they are willing to adhere and support our approach to this
because they also view' Iran's behavior as a threat, the official added.
"For the vast majority of countries they are willing to adhere and support our approach to this
because they also view" Iran's behavior as a threat, the official added.
Iranian President Hassan Rouhani on Tuesday promised Iranians the government would be able
to handle the economic pressure of new U.S. sanctions amid reports of a second day of
demonstrations in protest at financial hardship and a weakening rial.
Iranian President Hassan Rouhani on Tuesday promised Iranians the government would be able
to handle the economic pressure of new U.S. sanctions amid reports of a second day of
demonstrations in protest at financial hardship and a weakening rial.
Fars news agency reported that parts of Tehran's Grand Bazaar were on strike for a second
straight day. Reuters was not immediately able to confirm the report.
Fars news agency reported that parts of Tehran's Grand Bazaar were on strike for a second
straight day. Reuters was not immediately able to confirm the report.
Washington has sought to emphasize that the protests are part of rising economic discontent in
Iran hoping it will force the government to negotiate a new nuclear deal to avoid sanctions.
Washington has sought to emphasize that the protests are part of rising economic discontent in
Iran hoping it will force the government to negotiate a new nuclear deal to avoid sanctions.
''There is a level of frustration that people have with regard to the regime activity and behavior,
the enrichment of the military and clerical elite and the squeezing out of the life of the
economy," the senior State Department official said.
''There is a level of frustration that people have with regard to the regime activity and behavior,
the enrichment of the military and clerical elite and the squeezing out of the life of the
economy," the senior State Department official said.
"Iranians are tired of this situation," the official added.
"Iranians are tired of this situation," the official added.
Reporting by Lesley Wroughton and Daina Chia cu; Editing by James Dalgleish
Reporting by Lesley Wroughton and Doina Chiacu; Editing by James Dalgleish
212
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Annex 241
“India’s HPCL cancels Iran oil shipment after insurer excludes coverage”, Reuters,
26 July 2018

- 185 -

- 186 -

Exclusive: India's HPCL cancels Iran oil shipment after
insurer excludes coverage: sources
Exclusive: India's HPCL cancels Iran oil shipment after
insurer excludes coverage: sources
6 reuters.com/article/us-india-iran-oil-exclusive/exclusive-indias-hpcl-cancels-iran-oil-shipment-after-insurer-excludes­
6 reuters.com/article/us-india-iran-oil-exclusive/exclusive-indias-hpcl-cancels-iran-oil-shipment-after-insurer-excludes­
coverage-sources-idUSKBN1KG180
coverage-sources-idUSKBN1KG180
NEW DELHI (Reuters) - India's Hindustan Petroleum Corp (HPCL) canceled the purchase
of an Iranian oil cargo earlier this month after its insurance company refused to provide
coverage for the crude because of U.S. sanctions, three sources with knowledge of the
matter said.
NEW DELHI (Reuters) - India's Hindustan Petroleum Corp (HPCL) canceled the purchase
of an Iranian oil cargo earlier this month after its insurance company refused to provide
coverage for the crude because of U.S. sanctions, three sources with knowledge of the
matter said.
HPCL, India's third-biggest state-owned refiner, renewed its installation insurance, which
protects against any accidents at its refinery or storage sites, in early July. However, the
new policy would not protect against any incidents involving Iranian oil processed or stored
at its refineries, the sources said.
HPCL, India's third-biggest state-owned refiner, renewed its installation insurance, which
protects against any accidents at its refinery or storage sites, in early July. However, the
new policy would not protect against any incidents involving Iranian oil processed or stored
at its refineries, the sources said.
The refiner had planned to load 1 million barrels of Iranian crude onto the Suezmax tanker
Ankaleshwar in early July but canceled the purchase after it was unable to sell it on to
another buyer, said the sources who declined to be identified because of the sensitivity of
the matter.
The refiner had planned to load 1 million barrels of Iranian crude onto the Suezmax tanker
Ankaleshwar in early July but canceled the purchase after it was unable to sell it on to
another buyer, said the sources who declined to be identified because of the sensitivity of
the matter.
India is the second-biggest buyer of Iranian crude after China and without insurance
coverage to protect their plants, the country's refineries may have to cut off their imports
earlier than anticipated.
India is the second-biggest buyer of Iranian crude after China and without insurance
coverage to protect their plants, the country's refineries may have to cut off their imports
earlier than anticipated.
The United States said in May it plans to re-impose some sanctions against Iran starting in
August, with full sanctions in place by November, after withdrawing from a 2015 accord with
Iran limiting its nuclear program.
The United States said in May it plans to re-impose some sanctions against Iran starting in
August, with full sanctions in place by November, after withdrawing from a 2015 accord with
Iran limiting its nuclear program.
"HPCL faced problems in lifting cargo from Iran because its annual insurance policy was
renewed in July after the U.S. pulled out of the nuclear deal in May," said one of the
sources, adding the company will not be able to lift any Iranian oil.
"HPCL faced problems in lifting cargo from Iran because its annual insurance policy was
renewed in July after the U.S. pulled out of the nuclear deal in May," said one of the
sources, adding the company will not be able to lift any Iranian oil.
HPCL's Iranian imports account for only 20,000 barrels per day (bpd) of its full demand of
316,000 bpd but other Indian refiners that take larger volumes are likely to face the same
problem if their annual policy is up for renewal before November.
HPCL's Iranian imports account for only 20,000 barrels per day (bpd) of its full demand of
316,000 bpd but other Indian refiners that take larger volumes are likely to face the same
problem if their annual policy is up for renewal before November.
HPCL did not respond to requests from Reuters for a comment.
HPCL did not respond to requests from Reuters for a comment.
Companies have until Nov. 4 to fully wind down activities with Iran or risk exclusion from
the U.S. financial system. However, banks, shipping firms and insurance companies are
already cutting ties with Iran and without financing or insurance coverage refiners will have
to halt their purchases.
Companies have until Nov. 4 to fully wind down activities with Iran or risk exclusion from
the U.S. financial system. However, banks, shipping firms and insurance companies are
already cutting ties with Iran and without financing or insurance coverage refiners will have
to halt their purchases.
Iran had hoped to sell more than 500,000 bpd of oil to India during the current fiscal year
that started in April, Oil Minister Bijan Zanganeh said in February.
Iran had hoped to sell more than 500,000 bpd of oil to India during the current fiscal year
that started in April, Oil Minister Bijan Zanganeh said in February.
However, the insurance issues may mean a reduction in imports even as India is intent on
continuing dealings with Iran.
However, the insurance issues may mean a reduction in imports even as India is intent on
continuing dealings with Iran.
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"The problem in procuring Iranian barrels appears to be happening much before the Nov. 4
deadline," said Senthil Kumaran, a senior analyst at consultants FGE. "Most of the
reinsurance market is based in the U.S. so without the blessing of the U.S., Iranian oil
buyers will find it almost impossible to take and process Iranian cargoes."
'The problem in procuring Iranian barrels appears to be happening much before the Nov. 4
deadline," said Senthil Kumaran, a senior analyst at consultants FGE. "Most of the
reinsurance market is based in the U.S. so without the blessing of the U.S., Iranian oil
buyers will find it almost impossible to take and process Iranian cargoes."
Indian insurers rely on state-run General Insurance Corp for reinsurance, which depends
on western re-insurers to hedge its risk. General Insurance did not reply to a request for
comment.
Indian insurers rely on state-run General Insurance Corp for reinsurance, which depends
on western re-insurers to hedge its risk. General Insurance did not reply to a request for
comment.
Reporting by Nidhi Verma; Editing by Christian Schmollinger
Reporting by Nidhi Verma; Editing by Christian Schmollinger
Our Standards:The Thomson Reuters Trust Principles.
Our Standards:The Thomson Reuters Trust Principles.
212
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- 188 -

Annex 242
J. Lee & I. Garcia Perez, “Buyers of Iranian Oil Get Waivers: Sanctions Wrap”,
Bloomberg, 6 August 2018

- 189 -

- 190 -

Buyers of Iranian Oil to Get W
ivers: Sanctions Wrap
- 191 -
a
Buyers of Iranian Oil to Get W
ivers: Sanctions Wrap
Buyers of Iranian Oil to Get Waivers: Sanctions Wrap
Bu Julian Lee and Irene Garcia Perez
markets
Days before the deadline, the Trump administration is offering sanctions waivers to buyers of Iranian oil
August 6, 2018, 6:00 AM GMT +2 Updated on November 2, 2018, 6:21 PM GMT+1
Days before the deadline, the Trump administration is offering sanctions waivers to buyers of Iranian oil
By and
August 6, 2018, 6:00 AM GMT+2
Photographer: Ali Mohammadi/ Bloomberg
Photographer: Ali Mohammadi/ Bloomberg
With fewer than three days to go until US. sanctions hit Iran's oil exports, Donald Trump's administration is offering waivers to eight
buyers of the Persian Gulf state's barrels - effectively allowing them to continue some form of purchases.
The critical question now is scale. How much crude and condensates will keep flowing from the Middle East country? The eight nations
include Japan, India, Turkey and South Korea, according to a U.S. official. Secretary of State Michael Pompeo announces said details about
the waivers will be provided on Monday.
Combined exports of crude and condensates, a light form of oil extracted from gas fields, have already dropped by around 4o percent since
April, the last month before the resumption of gurbs was announced. Meanwhile Saudi Arabia, Iran's rival across the Persian Gulf, is
ramping up shipments to its customers
The threat of sanctions already had an impact on Iran's oil business. The Islamic Republic lost key buyers and is having to rely
mor on its
own fleet of tankers to carry oil to its customers, according to ship-tracking data compiled by Bloomberg
a
Buyers of Iranian Oil to Get Waivers: Sanctions Wrap
B Julian Lee and Irene Garcia Perez
markets
Days before the deadline, the Trump administration is offering sanctions waivers to buyers of Iranian oil
August 6, 2018, 6:00 AM GMT +2 Updated on November 2, 2018, 6:21 PM GMT+1
Days before the deadline, the Trump administration is offering sanctions waivers to buyers of Iranian oil
By and
August 6, 2018, 6:00 AM GMT+2
Photographer: Ali Mohammadi/ Bloomberg
Photographer: Ali Mohammadi/ Bloomberg
With fewer than three days to go until US. sanctions hit Iran's oil exports, Donald Trump's administration is offering waivers to eight
buyers of the Persian Gulf state's barrels - effectively allowing them to continue some form of purchases.
The critical question now is scale. How much crude and condensates will keep flowing from the Middle East country? The eight nations
include Japan, India, Turkey and South Korea, according to a U.S, official. Secretary of State Michael Pompoo announces said details about
the waivers will be provided on Monday.
Combined exports of crude and condensates, a light form of oil extracted from gas fields, have already dropped by around 4o percent since
April, the last month before the resumption of gurbs was announced. Meanwhile Saudi Arabia, Iran's rival across the Persian Gulf, is
ramping up shipments to its customers
The threat of sanctions already had an impact on Iran's oil business. The Islamic Republic lost key buyers and is having to rely
mor on its
own fleet of tankers to carry oil to its customers, according to ship-tracking data compiled by Bloomberg.

Buyers of Iranian Oil to Get Waivers: Sanctions Wrap
Buyers of Iranian Oil to Get Waivers: Sanctions Wrap
Iranian Crude Outflows
Iranian Crude Outflows
Destination of exports by share
Destination of exports by share
European
Union
European
Union
South Japan
Korea
South Japan
Korea
Turkey
Turkey
China
China
India
India
Source: Bloomberg tanker tracking and JODI
Average export data January-June 2018.
Source: Bloomberg tanker tracking and JODI
Average export data January-June 2018.
Bloomberg
Bloomberg
Bloomberg tanker tracking and JODI
A summary of the main Iranian oil importers' reactions and positions is set out below. This story was first published in mid August, and
again on Oct. 18. Observed flows and exports are for combined crude and condensate from tanker tracking data compiled by Bloomberg,
and are recorded on the date at which the vessel left the loading terminal. To calculate what that equates to as a share of each country's
overall purchases, import data from the Riyadh-based Joint Organisations Data Initiative were used.
Bloomberg tanker tracking and JODI
A summary of the main Iranian oil importers' reactions and positions is set out below. This story was first published in mid August, and
again on Oct. 18. Observed flows and exports are for combined crude and condensate from tanker tracking data compiled by Bloomberg,
and are recorded on the date at which the vessel left the loading terminal. 'To calculate what that equates to as a share of each country's
overall purchases, import data from the Riyadh-based Joint Organisations Data Initiative were used.
China
China
• Observed flow (Oct.): 742,000 b/d
• Observed flow (Oct.): 742,000 b/d
• Observed flow (Jan.-June): 675,000 b/d
• Observed flow (Jan.-June): 675,000 b/d
Share of observed Iranian exports (Oct.): 44%
• Share of observed Iranian exports (Jan.-June); 26%
• Share of Chinese imports (Jan.-June): 7%
Share of observed Iranian exports (Oct.): 44%
• Share of observed Iranian exports (Jan.-June); 226%
• Share of Chinese imports (Jan.-June): 7%
What government has said: Late last month, China's government told at least two of its state oil companies to avoid purchasing
Iranian oil, according to people with knowledge of the matter. 'The freeze on imports by China National Petroleum Corp.
What government has said: Late last month, China's government told at least two of its state oil companies to avoid purchasing
Iranian oil, according to people with knowledge of the matter. 'The freeze on imports by China National Petroleum Corp.
and Sinopec is temporary and purchases may resume depending on the outcome of negotiations with the U.S. 'The sanctions presented
China with an opportunity to take the lead in a project to develop Iran's biggest gas deposit after France's Total SA had to halt its
operations there. CNPC is now expected to take the lead on the $5 billion project to develop the South Pars field.
What companies have said and done: Sinopec reportedly halved loadings of Iranian crude in September, after senior U.S.
officials visited the company in Beijing and demanded "steep cutbacks."
and Sinopec is temporary and purchases may resume depending on the outcome of negotiations with the U.S. 'The sanctions presented
China with an opportunity to take the lead in a project to develop Iran's biggest gas deposit after France's Total SA had to halt its
operations there. CNPC is now expected to take the lead on the $5 billion project to develop the South Pars field.
What companies have said and done: Sinopec reportedly halved loadings of Iranian crude in September, after senior U.S.
officials visited the company in Beijing and demanded "steep cutbacks."
India
India
• Observed flow (Oct.): 355,000 b/d
• Observed flow (Jan.-June): 592,000 b/d
• Share of observed Iranian exports (Oct.): 221%
• Observed flow (Oct.): 355,000 b/d
• Observed flow (Jan.-June): 592,000 b/d
• Share of observed Iranian exports (Jan.-June): 23%
• Share of Indian imports (Jan.-Apr.): 133%
• Share of observed Iranian exports (Oct.): 21%
• Share of observed Iranian exports (Jan.-June): 29%
• Share of Indian imports (Jan.-Apr.): 133%
• What government has said: The country will get some form of waiver, according to the U.S. official. It was in talks in September
with the European Union for an alternative system to make payments to Iran.
• What government has said: The country will get some form of waiver, according to the U.S. official. It was in talks in September
with the European Union for an alternative system to make payments to Iran.
What companies have said and done: India's oil importers wer planning to buy as much as o million barrels, or about 300,000
barrels a day, of Iranian crude in November, having earlier suggested that they wouldn't purchase any. Saudi Aramco is to supply
around 4 million barrels of additional crude to Indian customers for this month.
What companies have said and done: India's oil importers wer planning to buy as much as o million barrels, or about 300,000
barrels a day, of Iranian crude in November, having earlier suggested that they wouldn't purchase any. Saudi Aramco is to supply
around 4 million barrels of additional crude to Indian customers for this month.
South Korea
South Korea
• Observed flow (Oct.): o b/d
• Observed flow (Oct.): o b/d
• Observed flow (Jan.-June): 285,000 b/d
• Observed flow (Jan.-June): 285,000 b/d
2
2
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Buyers of Iranian Oil to Get W
ivers: Sanctions Wrap
- 193 -
a
Buyers of Iranian Oil to Get W
ivers: Sanctions Wrap
• Share of observed Iranian exports (Oet.): 0%
• Share of observed Iranian exports (Jan. -June); 11%
• Share of South Korean imports (Jan.-June): 9%
• What government has said: South Korean Foreign Minister Kang Kyung-wha had asked Pompeo for "maximum flexibility"in
mnlin a Waiver from sanctions to minimize damage to South Korean companies.
What companies have said and done: Refiners haven't bought any crude or condensate from Iran sine ·dune, with the last cargo
arriving in the country in July. They turned to other suppliers of condensate to make up for lost flows from Iran, sometimes involving
transport over much greater distances. SK Innovation Co., the Asian country's top processor, bought a can;o of Russian Sbetta
condensate for November arrival in Incheon. efiner are also substituting condensate from lrun with a processed fuel known as
napht ha from elsewhere
Japan
• Observed flow (Oct.): o b/d
• Observed flow (Jan.-June): 125,000 b/d
• Share of observed Iranian exports (Oct.): 0%
• Share of observed Iranian exports (Jan. -June): 5%
• Share of Japanese imports (Jan. -June): 4%
• What government has said: Like India and South Korea, it appears Japan will get a waiver of some sort from the measures.
Japan's Finance Minister Taro Aso in June akc\the US, to give more clarity and reassurance to Japanese firms. Talks have
continued and Japanese government officials agreed with their US. counterparts to continue dis8Sons after a 3rd round of
meetings was held on Sept. 1o in Washington.
• What companies have said and done: Japan's crude imports from Iran fell g2 perent year on year to around 706,0oo kiloliters,
or approximately 143,000 barrels a day, in August according to data from the Ministry of Finance. Tanker tracking also shows a
plunge. No ships were seen departing Iran for Japan in October.
Exports Under Threat
Iran's key oil trading relationships
China
India
lran's crude oil
accounted for 48%
of Turkey's imports
South Korea
Turkey
Japan
Source: Bloomberg tanker tracking and JODI
Bloomberg
Bloomberg tanker tracking and JODI
United Arab Emirates
• Observed flow (Sept.): 129,000 b/d
• Observed flow (Jan.-June): 127,000 b/d
• Share of observed Iranian exports (Oct,): 8%
• Share of observed Iranian exports (Jan. -June): 5%
What government has said: The U.A.E is committed to abiding by the sanctions and will look for condensate supplies from
countries other than Iran, Energy Minister Su hail Al Mazrouei said in early October. Dubai, the U.A.E's trade hub, does business with
Iranian merchants and purchases condensate for its refineries. There were signs of flows from other countries rising in July at Iran's
expense. The Port of Fujairah was asked by U.A.E customs department to rquir Certificate of origin documentation with an official
stamp from all tankers bringing oil to the terminal and its storage tanks.
• What companies have said and done: Dubai-based Emirates National Oil Co. is trying alternatives to cargoes from the Islamic
Republie, according to traders with knowledge of the matter. However, the Suezmax Falcon Pride continued to shuttle between Iran's
Assaluyeh condensate terminal and Dubai's Jebel Ali port in October.
3
a
• Share of observed Iranian exports (Oct.): 0%
• Share of observed Iranian exports (Jan. June); 11%
• Share of South Korean imports (Jan.-June): 9%
• What government has said: South Korean Foreign Minister Kang Kyung-wha had asked Pompeo for "maximum flexibility"in
Bantin a Waiver from sanctions to minimize damage to South Korean companies.
What companies have said and done: Refiners haven't bought any crude or condensate from Iran sine ·dune. with the last cargo
arriving in the country in July. They turned to other suppliers of condensate to make up for lost flows from Iran, sometimes involving
transport over much greater distances. SK Innovation Co., the Asian country's top processor, bought a can;o of
Russian Sbetta
condensate for November arrival in Incheon. Refiner are also substituting condensate from lrun with a processed fuel known as
na pht ha from elsewhere.
Japan
• Observed flow (Oct.): o b/d
• Observed flow (Jan.-June): 125,000 b/d
• Share of observed Iranian exports (Oet.): 0%
• Share of observed Iranian exports (Jan. -June): 5%
• Share of Japanese imports (Jan. -June): 4%
• What government has said: Like India and South Korea, it appears Japan will get a waiver of some sort from the measures.
Japan's Finance Minister Taro Aso in June asked the US to give more clarity and reassurance to Japanese firms. Talks have
continued and Japanese government officials agreed with their U.S. counterparts to continue discussions after a 3rd round of
meetings was held on Sept. 1o in Washington.
What companies have said and done: Japan's crude imports from Iran fell 32 percent year on year to around 706,0oo kiloliters,
or approximately 143,000 barrels a day, in August according to data from the Ministry of Finance. Tanker tracking also shows a
plunge. No ships were seen departing Iran for Japan in October.
Exports Under Threat
Iran's key oil trading relationships
China
India
lran's crude oil
accounted for 48%
of Turkey's imports
South Korea
Turkey
Japan
Source: Bloomberg tanker tracking and JODI
Bloomberg
Bloomberg tanker tracking and JODI
United Arab Emirates
• Observed flow (Sept.): 129,000 b/d
• Observed flow (Jan.-June): 127,000 b/d
• Share of observed Iranian exports (Oct,): 8%
• Share of observed Iranian exports (Jan. -June): 5%
• What government has said: The U.A.E is committed to abiding by the sanctions and will look for condensate supplies from
countries other than Iran, Energy Minister Su hail Al Mazrouei said in early October. Dubai, the U.A.E's trade hub, does business with
Iranian merchants and purchases condensate for its refineries. There were signs of flows from other countries rising in July at Iran's
expense. The Port of Fujairah was asked by U.A.E customs department to pair Certificate of origin documentation with an official
stamp from all tankers bringing oil to the terminal and its storage tanks.
• What companies have said and done: Dubai-based Emirates National Oil Co. is trying alternatives to cargoes from the Islamic
Republie, according to traders with knowledge of the matter. However, the Suezmax Falcon Pride continued to shuttle between Iran's
Assaluyeh condensate terminal and Dubai's Jebel Ali port in October.
3

Buyers of Iranian Oil to Get W
ivers: Sanctions Wrap
- 194 -
a
Buyers of Iranian Oil to Get W
ivers: Sanctions Wrap
European Union
• Observed flow (oet.): 97,000 b/d
• Observed flow (Jan.-June): 483,000 b/d
• Share of observed Iranian exports (Oct.): 6%
• Share of observed Iranian exports (Jan. -June): 19%
• Share of EU imports (Jan.-June): 4%
• What public authorities have said: EU foreign-policy chief Federica Mogherini said back in July that the bloc was determined to
preserve the Iran nuclear deal and considers that the consequences of abandoning it could be catastrophic," A month earlier, she
stressed the most important challenge was to find solutions on banking and finance to support "legitimate trade and investment." In
July, the U.S. rejected Erench, British and German requests to grant waivers or exemptions to companies seeking to do business in
Iran. Mogherini announced in September that the EU, China and Russia backed a mechanism to allow. legitimate business to
continue with Iran. "In practical terms this will mean that EU member states will set up a legal entity to facilitate legitimate financial
transactions with Iran, and this will allow European companies to continue trade with Iran," she said after meeting with
representatives of the other signatories: the U.K., France, Germany, Russia, China plus Iran. This will be "in accordance with
European Union law, and could be opened to other partners in the world," she added. The mechanism will be provided with a banking
license "as soon as possible, " German newspaper Handelsblatt reported. However, legal sanctions experts and oil traders said the
creation of a special purpose vehicle and payments channel would still leave trder buying or selling Iranian
punitive actions by the U,S. Treasury Department.
crude vulnerable to
• What companies have said and done: The lack of clarity on the scale of the reductions sought by the Trump administration left
some customers continuing to buy Iranian crude while others cut back. France's Total SA failed to secure a waiver from the US. to
exempt Phase n of the South Pars gas field in Iran from sanctions, and notified Iran it will withdraw from the project. "Within the U.S.
legal framework, we can't work in Iran," Total CEO Patrick Pouyanne said in July.
Italy
Observed flow (Oct.): 65,000 b/d
• Observed flow (Jan.-June): 168,000 b/d
• Share of observed Iranian exports (Oct.): 4%
• Share of observed Iranian exports (Jan. -June): 7%
• Share of Italian imports (Jan.-June): 14%
What companies have said: Iran has been an important supplier to Saras SpA, but the refiner isn't concerned about sourcing
crude due to flexibility of operations, according to CEO Dario Scaffardi. The company is awaiting guidance from Italian and European
authorities. Suezmax tanker Kriti Spirit discharged a cargo of Iranian crude at Saras's Sarroch refinery in late October.
• Eni SpA said in May that the company has no material exposure to Iran and will not be affected by the sanctions. Tankers hauling
Iranian crude continued to discharge at ports near to the company's Italian refineries in October, with the Suezmax Delta Med calling
at Milazzo and Genoa and the Marathi discharging at Taranto and Genoa.
Spain
• Observed flow (Oct.): o b/d
• Observed flow (Jan.-June): 119,000 b/d
• Share of observed Iranian exports (Oet.): 0%
• Share of observed Iranian exports (Jan.-June): 5%
• Share of Spanish imports (Jan. -June);: 9%
• Compania Espanola de Petroleos SAU, or Cepsa, said in an 1PO prospectus that it took the "final shipment" of Iranian crude in
September. The Suezmax tanker Monte Udala loaded a cargo of around 1 million barrels of Iranian crude on Sept. 29, which it
delivered to Cepsa's Huelva refinery about three weeks later, according to tanker tracking data compiled by Bloomberg,
• Repsol SA took the first spot cargo of crude from Iran's West Karoun oil region in June, 5oo,0oo barrels of Pars crude. The last
observed delivery of Iranian crude to a Repsol refinery was from the Suezmax tanker Ottoman Nobility, which discharged at Cartagena
in late August, according to tanker tracking data compiled by Bloomberg
ranee
• Observed flow (Oct.): ob/d
• Observed flow (Jan.-June); 94,000 b/d
• Share of observed Iranian exports (Oet.); 0%
• Share of observed Iranian exports (Jan. -June): 4%
• Share of French imports (Jan.-June): 9%
• Total SA stopped buying Iranian crude in July, Pouyanne said at the Oil & Money conference in London. That was the same month a
tanker was last observed delivering Iranian crude to France.
Greece
• Observed flow (oet.): 32,000 b/d
• Observed flow (Jan. -June); 66,000 b/d
• Share of observed Iranian exports (Oct.); 2%
• Share of observed Iranian exports (Jan. -June); 3%
• Share of Greek imports (Jan.-June): 14%
e Hellenic Petroleum SA said in May it was assessing its position and commercial arrangements following the U.S. decision. The refiner
said it will "comply with the applicable international regulatory framework," and that it didn't expect any significant effeet on its
operations. The last tanker carrying Iranian crude discharged at the company's Pachi, Megara terminal in June.
• Motor Oil (Hellas) Corinth Refineries SA has continued to receive Iranian crude at its Agioi Theodoroi terminal near Corinth at a rate
of around one Suezmax tanker per month, or approximately 33,ooo barrels a day. The most recent tanker, the Kriti Diamond,
discharged at the end of October, according to tanker tracking data compiled by Bloomberg.
Turkey
• Observed flow (Oct.): 129,000 b/d
• Observed flow (Jan.-June): 182,000 b/d
4
a
European Union
• Observed flow (Oet.): 97,000 b/d
• Observed flow (Jan.-June): 483,000 b/d
• Share of observed Iranian exports (Oet.): 6%
• Share of observed Iranian exports (Jan. June); 19%
• Share of EU imports (Jan.-June): 4%
• What public authorities have said: EU foreign-policy chief Federica Mogherini said back in July that the bloc was determined to
preserve the Iran nuclear deal and considers that the consequences of abandoning it could be "catastrophic," A month earlier, she
stressed the most important challenge was to find solutions on banking and finance to support "legitimate trade and investment." In
July, the U.S. rjexted French, British and German requests to grant waivers or exemptions to companies seeking to do business in
Iran. Mogherini announced in September that the EU, China and Russia backed a mechanism to allow. "legitimate business to
continue with Iran. "In practical terms this will mean that EU member states will set up a legal entity to facilitate legitimate financial
transactions with Iran, and this will allow European companies to continue trade with Iran," she said after meeting with
representatives of the other signatories: the U.K., France, Germany, Russia, China plus Iran. This will be "in accordance with
European Union law, and could be opened to other partners in the world," she added. The mechanism will be provided with a banking
License "as soon as possible," German newspaper Handelsblatt reported. However, legal sanctions experts and oil traders said the
creation of a special purpose vehicle and payments channel would still leave lrder buying or selling Iranian crude vulnerable to
punitive actions by the US. Treasury Department.
• What companies have said and done: The lack of clarity on the scale of the reductions sought by the Trump administration left
some customers continuing to buy Iranian crude while others cut back. France's Total SA failed to secure a waiver from the US. to
exempt Phase n of the South Pars gas field in Iran from sanctions, and notified Iran it will withdraw from the project. "Within the U.S.
legal framework, we can't work in Iran," Total CEO Patrick Pouyanne said in July.
Italy
• Observed flow (Oct.): 65,000 b/d
• Observed flow (Jan.-June): 168,000 b/d
• Share of observed Iranian exports (Oct.): 4%
• Share of observed Iranian exports (Jan. -June);: 7%
• Share of Italian imports (Jan.-June): 14%
• What companies have said: Iran has been an important supplier to Saras Sp\, but the refiner isn't onred about sourcing
crude due to flexibility of operations, according to CEO Dario Scaffardi. The company is awaiting guidance from Italian and European
authorities. Suezmax tanker Kriti Spirit discharged a cargo of Iranian crude at Saras's Sarroch refinery in late October.
Eni SpA said in May that the company has no material exposure to Iran and will not be affected by the sanctions. Tankers hauling
Iranian crude continued to discharge at ports near to the company's Italian refineries in October, with the Suezmax Delta Med calling
at Milazzo and Genoa and the Marathi discharging at Taranto and Genoa.
Spain
• Observed flow (Oct.): ob/d
• Observed flow (Jan. -June): 119,000 b/d
• Share of observed Iranian exports (Oet.): 0%
• Share of observed Iranian exports (Jan. -June): 5%
• Share of Spanish imports (Jan.-June); 9%
• Compania Espanola de Petroleos SAU, or Cepsa, said in an 1PO prospectus that it took the "final shipment" of Iranian crude in
September. The Suezmax tanker Monte Udala loaded a cargo of around 1 million barrels of Iranian crude on Sept. 29, which it
delivered to Cepsa's Huelva refinery about three weeks later, according to tanker tracking data compiled by Bloomberg
• Repsol SA took the first spot cargo of crude from Iran's West Karoun oil region in June, 5oo,0oo barrels of Pars crude. The last
observed delivery of Iranian crude to a Repsol refinery was from the Suezmax tanker Ottoman Nobility, which discharged at Cartagena
in late August, according to tanker tracking data compiled by Bloomberg
Franee
• Observed flow (Oct.): ob/d
• Observed flow (Jan.-June): 94,000 b/d
• Share of observed Iranian exports (Oet.): 0%
• Share of observed Iranian exports (Jan. -June): 4%
• Share of French imports (Jan.-June): 9%
• Total SA stopped buying Iranian crude in July, Pouyanne said at the Oil & Money conference in London. That was the same month a
tanker was last observed delivering Iranian crude to France.
Greeee
• Observed flow (oet.): 32,000 b/d
• Observed flow (Jan.-June): 66,000 b/d
• Share of observed Iranian exports (Oct.): 2%
• Share of observed Iranian exports (Jan. -June); 3%
• Share of Greek imports (Jan.-June): 14%
• Hellenic Petroleum SA said in May it was assessing its position and commercial arrangements following the U.S. decision. The refiner
said it will "comply with the applicable international regulatory framework," and that it didn't expect any significant effeet on its
operations. The last tanker carrying Iranian crude discharged at the company's Pachi, Megara terminal in June.
• Motor Oil (Hellas) Corinth Refineries SA has continued to receive Iranian crude at its Agioi Theodoroi terminal near Corinth at a rate
of around one Suezmax tanker per month, or approximately 33,00o barrels a day. The most recent tanker, the Kriti Diamond,
discharged at the end of October, according to tanker tracking data compiled by Bloomberg.
Turkey
• Observed flow (Oct.): 129,000 b/d
• Observed flow (Jan.-June): 182,000 b/d
4

Buyers of Iranian Oil to Get Waivers: Sanctions Wrap
Buyers of Iranian Oil to Get Waivers: Sanctions Wrap
Share of observed Iranian exports (Oct.); 8%
• Share of observed Iranian exports (Jan-June): 7%
Share of observed Iranian exports (Oct,);: 8%
• Share of observed Iranian exports (Jan. -June): 7%
• Share of Turkish imports (Jan. -June): 48%
• Share of Turkish imports (Jan. -June): 48%
• What government has said and done: 'The country's biggest refiner, Tupras Turkiye Petrol Rafinerileri AS, is expected to get a
• What government has said and done: 'The country's biggest refiner, Tuprs lurkiye Petrol Rafinerileri AS, is expected to get a
waiver from the I.S., allowing it to continue to buy crude oil from Iran, according to two people familiar with the matter. In pure
volume terms, Turkey is more reliant on Iranian oil than any other country, according to data compiled by Bloomberg.
waiver from the .S., allowing it to continue to buy crude oil from Iran, according to two people familiar with the matter. In pure
volume terms, Turkey is more reliant on Iranian oil than any other country, according to data compiled by Bloomberg.

5
5
- 195 -

- 196 -

Annex 243
“Exclusive: UK’s Quercus pulls plug on $570 million Iran solar plant as sanctions
bite”, Reuters, 14 August 2018

- 197 -

- 198 -

Exclusive: UK's Quercus pulls plug on $570 million Iran solar plant..
Exclusive: UK's Quercus pulls plug on $570 million Iran solar plant..
Exclusive: UK's Quercus pulls plug on $570 million Iran
solar plant ...
Exclusive: UK's Quercus pulls plug on $570 million Iran
solar plant ...
Lefteris Karagiannopolos
Lefteris Karagiannopolos
OSLO (Reuters) - British renewable energy investor Quercus said it will halt the construction of a 5oo million
euro (8570 million) solar power plant in Iran due to recently imposed U.S. sanctions on Tehran.
OSLO (Reuters) - British renewable energy investor Quereus said it will halt the construction of a 5oo million
euro ($8570 million) solar power plant in Iran due to recently imposed U.S. sanctions on Tehran.
FILE PHOTO: Solar panels to produce renewable energy in Gardanne, France, June 25, 2018. REUTERS/Jean­
Paul Pelissier/File Photo
FILE PHOTO: Solar panels to produce renewable energy in Gardanne, France, June 25, 2018. REUTERS/Jean­
Paul Pelissier/File Photo
The solar plant in Iran would have been the first renewable energy investment outside Europe by Quereus and
the world's sixth largest, with a 6o0 megawatt (MW) capacity.
The solar plant in Iran would have been the first renewable energy investment outside Europe by Quereus and
the world's sixth largest, with a 6oo megawatt (MW) capacity.
Iran has been trying to increase the share of renewable-produced electricity in its energy mix, partly due to air
pollution and to meet international commitments, hoping to have about 5 gigawatt in renewables installed by
2022.
Iran has been trying to increase the share of renewable-produced electricity in its energy mix, partly due to air
pollution and to meet international commitments, hoping to have about 5 gigawatt in renewables installed by
2022.
In June, before the U.S.-imposed sanctions, more than 250 companies had signed agreements to add and sell
power from about 4 gigawatt of new renewables in the country, which has only 602 MW installed, Iranian
energy ministry data showed.
In June, before the U.S.-imposed sanctions, more than 250 companies had signed agreements to add and sell
power from about 4 gigawatt of new renewables in the country, which has only 602 MW installed, Iranian
energy ministry data showed.
Washington reimposed sanctions last week after pulling out of a 2o15 international deal aimed at curbing
Iran's nuclear program in return for an easing of economic sanctions.
Washington reimposed sanctions last week after pulling out of a 2o15 international deal aimed at curbing
Iran's nuclear program in return for an easing of economic sanctions.
U.S. president Donald Trump has also threatened to penalize companies that continue to operate in Iran,
which led banks and many companies around the world to scale back their dealings with Tehran.
U.S. president Donald Trump has also threatened to penalize companies that continue to operate in Iran,
which led banks and many companies around the world to scale back their dealings with Tehran.
Following the U.S. sanctions on Iran, we have decided to cease all activities in the country, including our 600
MW project. We will continue to monitor the situation closely," Quereus chief executive Diego Biasi said in an
email on Tuesday.
Following the U.S. sanctions on Iran, we have decided to cease all activities in the country, including our 600
MW project. We will continue to monitor the situation closely," Quereus chief executive Diego Biasi said in an
email on Tuesday.
- 199 -

Exclusive: UK's Quercus pulls plug on $570 million Iran solar plant...
Exclusive: UK's Quercus pulls plug on $570 million Iran solar plant...
The firm will continue to monitor the situation closely, said Biasi, who declined to comment further.
Last year Quercus said it would set up a project company and sell shares via a private placement after attracting
interest from private and institutional investors, including sovereign wealth funds.
Construction was expected to take three years, with each 100 MW standalone lot becoming operational and
connecting to the grid every six months.
The firm will continue to monitor the situation closely, said Biasi, who declined to comment further.
Last year Quercus said it would set up a project company and sell shares via a private placement after attracting
interest from private and institutional investors, including sovereign wealth funds.
Construction was expected to take three years, with each 100 MW standalone lot becoming operational and
connecting to the grid every six months.
SANCTIONS BITE
SANCTIONS BITE
Independently-owned Quercus has a portfolio of around 28 renewable energy plants and 235 MW of installed
capacity.
Independently-owned Quercus has a portfolio of around 28 renewable energy plants and 235 MW of installed
capacity.
The firm, founded by Biasi and Simone Borla in 2o1o, controls five investment funds and has a network of
"highly regarded external partners," it says on its website.
The firm, founded by Biasi and Simone Borla in 2010, controls five investment funds and has a network of
"highly regarded external partners," it says on its website.
The 600 MW plant it aimed to construct in Iran would be the firm's largest investment. Quercus declined to
comment on the details of its decision to cease the plan and on any financial losses that could result from it.
The 600 MW plant it aimed to construct in Iran would be the firm's largest investment. Quercus declined to
comment on the details of its decision to cease the plan and on any financial losses that could result from it.
Fearing the consequences of the U.S. embargo, a string of European companies have recently announced they
would scale back their business in Iran.
Fearing the consequences of the U.S. embargo, a string of European companies have recently announced they
would scale back their business in Iran.
On Tuesday, German engineering group Bilfinger, said it did not plan to sign any new business in the country,
while automotive supplier Duerr on Aug. 11 said it had halted activities in Iran.
On Tuesday, German engineering group Bilfinger, said it did not plan to sign any new business in the country,
while automotive supplier Duerr on Aug. 11 said it had halted activities in Iran.
2
2
- 200 -

Exclusive: UK's Quercus pulls plug on $570 million Iran solar plant..
Exclusive: UK's Quercus pulls plug on $570 million Iran solar plant..
FILE PHOTO: A general view shows solar panels to produce renewable energy in Gardanne, France, June 25,
2018. REUTERS/Jean-Paul Pelissier/File Photo
FILE PHOTO: A general view shows solar panels to produce renewable energy in Gardanne, France, June 25,
2018. REUTERS/Jean-Paul Pelissier/File Photo
Another project, planned by Norway's Saga Energy, which said last October it aimed to build 2 GW of new solar
energy capacity in Iran and to start construction by the end of 2o18, has also stalled.
Another project, planned by Norway's Saga Energy, which said last October it aimed to build 2 GW of new solar
energy capacity in Iran and to start construction by the end of 2o18, has also stalled.
Saga Energy's chief of operations Rune Haaland told Reuters it was still working on getting the funding, which
is more complicated since recent developments, and although it aimed to push on with its plans, construction
could be delayed.
Saga Energy's chief of operations Rune Haaland told Reuters it was still working on getting the funding, which
is more complicated since recent developments, and although it aimed to push on with its plans, construction
could be delayed.
Editing by Terje Solsvik and Alexander Smith
Editing by Terje Solsvik and Alexander Smith
3
3

- 201 -

- 202 -

Annex 244
“Iran’s Oil Market Realities: How India, Others Are Preparing for U.S. Sanctions”,
The Times of India, 16 August 2018

- 203 -

- 204 -

Iran's oil market realities: How India, others are preparing for US sanctions - Times of India
Iran's oil market realities: How India, others are preparing for US sanctions - Times of India
Pnnted from
Pnoted from
THE TIMES OF INDIA
THE TIMES OF INDIA
Iran's oil market realities: How India, others are
preparing for US sanctions
Iran's oil market realities: How India, others are
preparing for US sanctions
Bloomberg /Aug 16, 2018, 01.18 PM IST
Bloomberg /Aug 16, 2018, 01.18 PM IST
NEW DELHI: In November, US sanctions on Iran are due to enter Into force
that could drive down the Persian Gulf nation's exports and upend the
global oil market. There are already signs that it will be harder for the
country to export, as some International Insurers stop covering shipments.
NEW DELHI: In November, US sanctions on Iran are due to enter Into force
that could drive down the Persian Gulf nation's exports and upend the
global oil market. There are already signs that It wlll be harder for the
country to export, as some lnternatlonal Insurers stop covering shipments.
The US measures require buyers to cut purchases or run the risk of their
banks being excluded from the American financial system. If they do scale
back, then there's a risk of spiraling crude prices.
The US measures require buyers to cut purchases or run the risk of their
banks being excluded from the American financial system. If they do scale
back, then there's a risk of spiraling crude prices.
President Donald Trump's national security adviser, John Bolton, says
waivers from sanctions on buying Iranian oil will be "few and far between".
The US says It will persuade countries which currently buy Iranian ofl to
President Donald Trump's national security adviser, John Bolton, says
waivers from sanctions on buying Iranian oil will be "few and far between".
The US says it will persuade countries which currently buy Iranian oll to
cut Imports by as much as 1 mlllion barrels a day when the sanctions take effect In early November. While this would be a
significant reduction in Iran's crude sales, it is far less severe than the Trump administration's previously stated aim of halting all
sales of Jranlan crude.
cut Imports by as much as 1 mllllon barrels a day when the sanctions take effect In early November. While this would be a
significant reduction in Iran's crude sales, it is far less severe than the Trump administration's previously stated aim of halting all
sales of lranlan crude.
Meanwhlle, Iran's Foreign Minister Mohammad Javad Zarif says European countries, which are party to the Iran nuclear deal,
have held talks separately with other countries to lobby them to continue buying Iranian oil. But the looming threat of sanctions
has already started to have an Impact on Iran's oil business. The lslamlc republlc's crude outflows have fallen and It Is having to
rely more on Its own fleet of tankers to carry oil to Its customers, according to ship-tracking data compiled by Bloomberg. Iran
has responded by lowering the sales price for Its 11ght crude for delivery in September to the cheapest level in 14 years.
Meanwhlle, Iran's Foreign Minister Mohammad Javad Zartf says European countries, which are party to the Iran nuclear deal,
have held talks separately with other countries to lobby them to continue buying Iranian oil. But the looming threat of sanctions
has already started to have an Impact on Iran's oil business. The ls1amlc republlc's crude outflows have fallen and It Is having to
rely more on Its own fleet of tankers to carry oll to Its customers, according to ship-tracking data compiled by Bloomberg. Iran
has responded by lowering the sales price for its light crude for delivery In September to the cheapest level in 14 years.
A summary of the main Iranian oil importers' reactions and positions is set out below. Observed flows and exports are from
tanker tracking data complied by Bloomberg. To calculate what that equates to as a share of each country's overall purchases,
Import data from the Riyadh-based Joint Organisations Data lnltfattve were used.
A summary of the main Iranian oil importers' reactions and positions is set out below. Observed flows and exports are from
tanker tracking data complied by Bloomberg. To calculate what that equates to as a share of each country's overall purchases,
Import data from the Riyadh-based Joint Organisations Data Initiative were used.
INDIA
INDIA
Observed flows (January-June): 597,000 barrels per day (bpd)
Observed flows (January-June): 597,000 barrels per day (bpd)
Share of observed exports (January-June): 23 per cent
Share of observed exports (January-June): 23 per cent
Share of imports (November-April): 11 per cent
Share of Imports (November-April): 11 per cent
What government has said: The country is currently said to be mulling a 50 per cent cut in lts oil imports from the Islamic
republic to secure a waiver from the US to continue buying crude from the Islamic Republic. But in the first two weeks of
August observed Iranian crude shipments to India fell by 95 per cent, compared to the same period In July, according to ship­
tracking data compiled by Bloomberg.
What government has said: The country Is currently sald to be mulling a 50 per cent cut In Its oil imports from the Islamic
republic to secure a waiver from the US to continue buying crude from the Islamic Republic. But in the first two weeks of
August observed Iranian crude shipments to lndla fell by 95 per cent, compared to the same period In July, according to ship­
tracking data compiled by Bloomberg.
What companies have said: Indian Oil Corp. Chairman Sanjiv Singh said in July that Saudi Arabia alone can cover most of the
world's supply shortfall If Iran's oll exports dry up. "We have Plan B, Plan C, Plan D. We are fully prepared," he said. IOC and
Bharat Petroleum Corp. kept buying Iranian crude In July and have contracted oil from the Persian Gulf country for August
deliveries. Hindustan Petroleum Corp., the third biggest state refiner, is unlikely to buy any more lranlan oil untll lndla gets a
waiver from the US, since its new insurance cover for its refineries would be invalidated by processing Iranian oil, according to
What companies have said: Indian Oil Corp. Chairman Sanjiv Singh said in July that Saudi Arabia alone can cover most of the
world's supply shortfall If Iran's oll exports dry up. "We have Plan B, Plan C, Plan D. We are fully prepared," he said. IOC and
Bharat Petroleum Corp. kept buying Iranian crude In July and have contracted oil from the Persian Gulf country for August
deliveries. Hindustan Petroleum Corp., the third biggest state refiner, ls unlikely to buy any more lranlan oil until India gets a
waiver from the US, since its new insurance cover for its refineries would be invalidated by processing Iranian oil, according to
- 205 -

Iran's oil market realities: How India, others are preparing for US sanctions - Times of India
Iran's oil market realities: How India, others are preparing for US sanctions - Times of India
a person familiar with the matter.
a person familiar with the matter.
Mangalore Refinery and Petrochemicals Ltd. said in its annual report that it's looking at alternative sources like Australia, West
Africa and South America to supplement any reduction from the Persian Gulf nation, which supplied a quarter of its oil needs.
Shipping data compiled by Bloomberg show Reliance Industries Ltd., India's largest petrochemical firm, cut Iranian oil imports in
June, although month-on-month flows are prone to big swings.
Mangalore Refinery and Petrochemicals Ltd. said in its annual report that it's looking at alternative sources like Australia, West
Africa and South America to supplement any reduction from the Persian Gulf nation, which supplied a quarter of its oil needs.
Shipping data compiled by Bloomberg show Reliance Industries Ltd., India's largest petrochemical firm, cut Iranian oil imports in
June, although month-on-month flows are prone to big swings.
CHINA
CHINA
Observed flows (January-June): 675,000 bpd
Observed flows (January-June): 675,000 bpd
Share of observed exports (January-June): 26 per cent
Share of observed exports (January-June): 26 per cent
Share of imports (December-May): 7 per cent
Share of imports (December-May): 7 per cent
What government has said: While Beijing has agreed to not ramp up purchases from Iran, China has rejected a US request to
cut them, according to two officials familiar with negotiations. China will continue to cooperate with Iran without violating
international obligations, foreign ministry spokeswoman Hua Chunying said back in June. In July, China continued to pay for
Iranian crude Imports In yuan.
What government has said: While Beijing has agreed to not ramp up purchases from Iran, China has rejected a US request to
cut them, according to two officials familiar with negotiations. China will continue to cooperate with Iran without violating
international obligations, foreign ministry spokeswoman Hua Chunying said back in June. In July, China continued to pay for
Iranian crude imports in yuan.
The sanctions have also presented China with an opportunity to take the lead In a project to develop Iran's biggest gas deposit
after France's Total SA had to halt its operations there. State-owned China National Petroleum Corp. is now expected to take
the lead on the $5 billion project to develop the South Pars Gas field.
The sanctions have also presented China with an opportunity to take the lead In a project to develop Iran's biggest gas deposit
after France's Total SA had to halt its operations there. State-owned China National Petroleum Corp. is now expected to take
the lead on the $5 billion project to develop the South Pars Gas field.
What companies have said: Nothing.
What companies have said: Nothing.
SOUTH KOREA
SOUTH KOREA
Observed flows (January-June): 286,000 bpd
Observed flows (January-June): 286,000 bpd
Share of observed exports (January-June): 11 per cent
Share of observed exports (January-June): 11 per cent
Share of imports (December-May): 10 per cent
Share of imports (December-May): 10 per cent
What government has said: South Korea is waiting for an official response from the US on whether its refiners can continue
importing Iranian crude and condensate during the 180-day wind-down period, an official from the nation's energy ministry said
in early July. The country already put some imports on hold in June.
What government has said: South Korea is waiting for an official response from the US on whether its refiners can continue
importing Iranian crude and condensate during the 180-day wind-down period, an official from the nation's energy ministry said
In early July. The country already put some Imports on hold In June.
What companies have said: Refiners are substituting condensate from Iran with a processed fuel known as naphtha from
elsewhere. SK Innovation Co., the Asian country's top processor, Hanwha Total Petrochemical Co. and Hyundai Oilbank Co. all
rushed to procure supply for July and August from other suppliers. Refiners didn't buy supplies for July and will only decide
whether to buy Iran's South Pars condensate for the rest of the third quarter after negotiations between their government and
the US administration.
What companies have said: Refiners are substituting condensate from Iran with a processed fuel known as naphtha from
elsewhere. SK Innovation Co., the Asian country's top processor, Hanwha Total Petrochemical Co. and Hyundai Oilbank Co. all
rushed to procure supply for July and August from other suppliers. Refiners didn't buy supplies for July and will only decide
whether to buy Iran's South Pars condensate for the rest of the third quarter after negotiations between their government and
the US administration.
JAPAN
JAPAN
Observed flows (January-June): 125,000 bpd
Observed flows (January-June): 125,000 bpd
Share of observed exports (January-June): 5 per cent
Share of observed exports (January-June): 5 per cent
Share of imports (December-May): 4 per cent
Share of imports (December-May): 4 per cent
2
2
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Iran's oil market realities: How India, others are preparing for US sanctions - Times of India
Iran's oil market realities: How India, others are preparing for US sanctions - Times of India
What government has said: Since the US pulled out of the Iran nuclear deal, Japan has sought a waiver from the US measures.
Japan's Finance Minister Taro Aso in June asked the US to give more clarity and reassurance to Japanese firms. Talks will
continue, Japan's foreign ministry said in early August.
What government has said: Since the US pulled out of the Iran nuclear deal, Japan has sought a waiver from the US measures.
Japan's Finance Minister Taro Aso in June asked the US to give more clarity and reassurance to Japanese firms. Talks will
continue, Japan's foreign ministry said in early August.
What companies have said: Japan's refining industry wants the government to "tenaciously hold talks" with the US to get a
waiver on America's renewed sanctions on Iran, Takashi Tsukioka, chairman of refiner Idemitsu and of the Petroleum
Association of Japan, said last month. The executive sees it as "unreasonable" for Japan to be impacted in the same way as
countries that have boosted Iranian oil imports. Japanese shipping companies and major banks, such as MUFG Bank and
Mizuho Bank, have told oil distributors they may soon halt transactions with Iran.
What companies have said: Japan's refining industry wants the government to "tenaciously hold talks" with the US to get a
waiver on America's renewed sanctions on Iran, Takashi Tsukioka, chairman of refiner Idemitsu and of the Petroleum
Association of Japan, said last month. The executive sees it as "unreasonable" for Japan to be impacted in the same way as
countries that have boosted Iranian oil imports. Japanese shipping companies and major banks, such as MUFG Bank and
Mizuho Bank, have told oil distributors they may soon halt transactions with Iran.
Refiners were told that the banks won't handle transactions for Iran-related deals that were signed on or after May 8, and that
those signed before that period will be dealt with "on case-by-case basis". Idemitsu declined to comment on what the company
will do in response. Fuji Oil is considering halting crude imports from Iran earlier than it expected. The firm hasn't determined a
deadline yet and is still processing oil supplied under long-term contract. Cosmo Energy said it will likely halt Iranian crude
imports after taking July-loading cargoes-If Japan doesn't receive waiver, according to people with knowledge of the matter.
Refiners were told that the banks won't handle transactions for Iran-related deals that were signed on or after May 8, and that
those signed before that period will be dealt with "on case-by-case basis". Idemitsu declined to comment on what the company
will do in response. Fuji Oil is considering halting crude imports from Iran earlier than it expected. The firm hasn't determined a
deadline yet and is still processing oil supplied under long-term contract. Cosmo Energy said it will likely halt Iranian crude
imports after taking July-loading cargoes-if Japan doesn't receive waiver, according to people with knowledge of the matter.
UNITED ARAB EMIRATES
UNITED ARAB EMIRATES
Observed flows (January-June): 127,000 bpd
Observed flows (January-June): 127,000 bpd
Share of observed exports (January-June): 5 per cent
Share of observed exports (January-June): 5 per cent
What government has said: Not much. The U.A.E. has limited diplomatic relations with Iran, and withdrew its ambassador in
Tehran in 2016. Abu Dhabi's crown prince, the country's de facto ruler, is a close US ally and supports efforts to curb Iran's
influence in the region. Dubai, the U.A.E's trade hub, does business with Iranian merchants and purchases condensate for its
refineries. There were signs of flows from other countries rising In July at Iran's expense.
What government has said: Not much. The U.A.E. has limited diplomatic relations with Iran, and withdrew its ambassador in
Tehran in 2016. Abu Dhabi's crown prince, the country's de facto ruler, is a close US ally and supports efforts to curb Iran's
influence in the region. Dubai, the U.A.E.'s trade hub, does business with Iranian merchants and purchases condensate for its
refineries. There were signs of flows from other countries rising In July at Iran's expense.
What companies have said: Dubai-based Emirates National Oil Co. Is trying alternatives to cargoes from the Islamic Republic,
according to traders with knowledge of the matter.
What companies have said: Dubai-based Emirates National Oil Co. Is trying alternatives to cargoes from the Islamic Republic,
according to traders with knowledge of the matter.
EUROPEAN UNION
EUROPEAN UNION
Observed flows (January-June): 516,000 bpd
Observed flows (January-June): 516,000 bpd
Share of observed exports (January-June): 20 per cent
Share of observed exports (January-June): 20 per cent
Share of imports (December-May): 5 per cent
Share of imports (December-May): 5 per cent
What public authorities have said: The bloc is determined to preserve the Iran nuclear deal and considers that the
consequences of abandoning it could be "catastrophic," according to the EU foreign-policy chief Federica Mogherini. In June,
she stressed that the most important challenge was to find solutions on banking and finance to support "legitimate trade and
investment." In July, the US rejected French, British and German demands to grant waivers or exemptions to companies
seeking to do business in Iran.
What public authorities have said: The bloc Is determined to preserve the Iran nuclear deal and considers that the
consequences of abandoning it could be "catastrophic," according to the EU foreign-policy chief Federica Mogherini. In June,
she stressed that the most important challenge was to find solutions on banking and finance to support "legitimate trade and
investment.'' In July, the US rejected French, British and German demands to grant waivers or exemptions to companies
seeking to do business In Iran.
What companies have said: The lack of clarity on the scale of the reductions sought by the Trump administration has left
several customers continuing to buy Iranian crude, although some showed less interest in resuming business with Iran.
Austria's OMV AG has suspended investment projects in Iran, but still has made no decision on imports, CEO Rainer Seele said
in an interview with Tass news agency. Swiss lender Banque de Commerce et de Placements SA told customers that it would
stop financing Iranian oil cargoes by June 30, Reuters reported. Vital Group's chairman, Ian Taylor, said in May it will be near
impossible to avoid the sanctions.
What companies have said: The lack of clarity on the scale of the reductions sought by the Trump administration has left
several customers continuing to buy Iranian crude, although some showed less interest in resuming business with Iran.
Austria's OMV AG has suspended investment projects in Iran, but still has made no decision on imports, CEO Rainer Seele said
in an interview with Tass news agency. Swiss lender Banque de Commerce et de Placements SA told customers that it would
stop financing Iranian oil cargoes by June 30, Reuters reported. Vital Group's chairman, Ian Taylor, said in May it will be near
impossible to avoid the sanctions.
3
3
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Iran's oil market realities: How India, others are preparing for US sanctions - Times of India
Iran's oil market realities: How India, others are preparing for US sanctions - Times of India

4
4
- 208 -

Annex 245
“L’Iran annonce officiellement que Total a quitté le projet South Pars”, L’Usine
Nouvelle, 20 August 2018

- 209 -

- 210 -

L'lran annonce officiellement que Total a quitt~ le projet South Pars
L'lran annonce officiellement que Total a quitt~ le projet South Pars
a usinenouvelle.com/article/l-iran-annonce-que-total-a-quitte-le-projet-south-pars.N731559
a usinenouvelle.com/article/l-iran-annonce-que-total-a-quitte-le-projet-south-pars.N731559
August 20, 2018
August 20, 2018
C'est d~sormais officiel : le groupe fran~ais Total a bien quitt~ l'Iran, confirme ce 20 ao~t le
ministre du P~trole. "Total s'est officiellement retir~ du contrat pour le d~veloppement de la
phase 11 du projet South Pars (...) Le processus de remplacement par une autre soci~t~ est en
cours", selon les propos du ministre rapport~s par la t~l~vision. Sollicit~ par Reuters ~ Paris,
Total n'a pas r~pondu dans l'imm~diat ~ une demande de commentaire.
C'est d~sormais officiel : le groupe fran~ais Total a bien quitt~ l'Iran, confirme ce 20 ao~t le
ministre du P~trole. "Total s'est officiellement retir~ du contrat pour le d~veloppement de la
phase 11 du projet South Pars (...) Le processus de remplacement par une autre soci~t~ est en
cours", selon les propos du ministre rapport~s par la t~l~vision. Sollicit~ par Reuters ~ Paris,
Total n'a pas r~pondu dans l'imm~diat ~ une demande de commentaire.
Un groupe chinois en embuscade
Un groupe chinois en embuscade
L'agence de presse iranienne Irna a rapport~ le 11 a0~t que la compagnie nationale chinoise
CNPC avait repris la part de Total dans le gisement gazier mais un responsable de la compagnie
p~troli~re nationale iranienne (NIOC) a rapidement d~menti ces propos.
L'agence de presse iranienne lrna a rapport~ le 11 aoOt que la compagnie nationale chinoise
CNPC avait repris la part de Total dans le gisement gazier mais un responsable de la compagnie
p~troli~re nationale iranienne (NIOC) a rapidement d~menti ces propos.
Le contrat sign~ en 2017 en vue du d~veloppement de la phase 11 de South Pars attribuait ~
Le contrat sign~ en 2017 en vue du d~veloppement de la phase 11 de South Pars attribuait ~
Total une part de 50, 1 % dans ce qui appara1t com me le plus grand gisement gazier au monde,
avec un investissement initial d'un milliard de dollars.
Total une part de 50, 1 % dans ce qui appara1t com me le plus grand gisement gazier au monde,
avec un investissement initial d'un milliard de dollars.
Avec Reuters (Parisa Hafezi, avec Sudip Kar-Gupta ~ Paris, Juliette Rouil/on pour le service
fran~ais, ~dit~ par Marc Angrand)
Avec Reuters (Parisa Hafezi, avec Sudip Kar-Gupta ~ Paris, Juliette Rouil/on pour le service
fran~ais, ~dit~ par Marc Angrand)
1/1
1/1

- 211 -

- 212 -

Annex 246
J. Park and H. Yang, “South Korea's Hyundai E&C cancels $521 million
petrochemicals deal, cites Iran financing failure”, Reuters, 29 October 2018

- 213 -

- 214 -

Discover Thomson Reuters
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COMMODITIES OCTOBER 29, 2018 / 8:59 AM / 5 MONTHS AGO
COMMODITIES OCTOBER 29, 2018 / 8:59 AM / 5 MONTHS AGO
South Korea's Hyundai E&C cancels
$521 million petrochemicals deal,
cites Iran financing failure
South Korea's Hyundai E&C cancels
$521 million petrochemicals deal,
cites Iran financing failure
1 MIN READ
f
1 MIN READ
f
SEOUL (Reuters) - South Korea's Hyundai Engineering &
Construction said on Monday that it scrapped a 595 billion won ($521
million) deal to build a petrochemicals complex in Iran, saying the
Iranian customer's ability to fund it had been hit by the prospect of
U.S. economic sanctions against Tehran.
SEOUL (Reuters) - South Korea's Hyundai Engineering &
Construction said on Monday that it scrapped a 595 billion won ($521
million) deal to build a petrochemicals complex in Iran, saying the
Iranian customer's ability to fund it had been hit by the prospect of
U.S. economic sanctions against Tehran.
In a regulatory filing, Hyundai E&C said the consortium it led for the
project's construction canceled the contract on Sunday.
In a regulatory filing, Hyundai E&C said the consortium it led for the
project's construction canceled the contract on Sunday.
"The contract was canceled because financing is not complete, which
"The contract was canceled because financing is not complete, which
was a prerequisite for the validity of the contract, as external factors
worsened such as economic sanctions against Iran," Hyundai E&C
said in its filing.
was a prerequisite for the validity of the contract, as external factors
worsened such as economic sanctions against Iran," Hyundai E&C
said in its filing.
From Nov. 4, the United States will re-impose sanctions against
Iranian crude oil exports as part of President Donald Trump's efforts
to force Tehran to accede to a more restrictive deal on limiting its
nuclear and missile programs.
From Nov. 4, the United States will re-impose sanctions against
Iranian crude oil exports as pan of President Donald Trump's efforts
to force Tehran to accede to a more restrictive deal on limiting its
nuclear and missile programs.
Reporting by Ju-min Park and Heekyong Yang; Editing by Kenneth Maxwell
Reporting by Ju-min Park and Heekyong Yang; Editing by Kenneth Maxwell
Our Standards: The Thomson Reuters Trust Principles.
Our Standards: The Thomson Reuters Trust Principles,
https://www.reuters.com/article/us-hyundaie-c-iran/south-koreas-hyundai… 1-million-petrochemicals-deal-cites-i..
https://www.reuters.com/article/us-hyundaie-c-iran/south-koreas-hyundai… 1-million-petrochemicals-deal-cites-i..

- 215 -

- 216 -

Annex 247
B. Scheid, “Questions remain over UAE imports of Iranian condensate amid US
sanctions”, S&P Global, 15 November 2018

- 217 -

- 218 -

Questions remain over UAE imports of Iranian condensate amid US sanctions
I
S&P Global Platts
Questions remain over U AE imports of Iranian condensate amid US sanctions I S&P Global Platts
OIL --- 15Nov2018]20:05 UTC Washington
OIL -15Nov2018]20:05 UTC -- Washington
Questions remain over
UAE imports of Iranian
condensate amid US
sanctions
Questions remain over
UAE imports of Iranian
condensate amid US
sanctions
Author
Author
Brian Scheid
Brian Scheid ■
Editor
Editor
Derek Sands
Derek Sands
Commodity Oil
Commodity Oil
Washington - There was some surprise among analysts when the UAE did
not receive a waiver from the US State Department last week from
reimposed sanctions on Iranian crude, but sources said this week that they
likely never requested one.
Washington -There was some surprise among analysts when the UAE did
not receive a waiver from the US State Department last week from
reimposed sanctions on Iranian crude, but sources said this week that they
likely never requested one.
As a US ally and supporter of the
US taking a tougher stance on Iran,
sources said that the UAE never
considered a waiver since they
were among the biggest advocates
of a reimposition of sanctions,
behind only Saudi Arabia and
Israel, sources said.
As a US ally and supporter of the
US taking a tougher stance on I ran,
sources said that the UAE never
considered a waiver since they
were among the biggest advocates
of a reimposition of sanctions,
behind only Saudi Arabia and
Israel, sources said.
A State Department official told S&P Global Platts this week on condition of
A State Department official told S&P Global Platts this week on condition of
https ://www.spglobal.com/platts/en/market-insights/latest-news/oil/ 111518-questions-remain-over-uae-imports-of-iranian-condensate-arnid-us-sanctions
https ://www.spglobal.com/platts/en/market-insights/latest-news/oil/ 111518-questions-remain-over-uae-imports-of-iranian-condensate-amid-us-sanctions
- 219 -

Questions remain over UAE imports of Iranian condensate amid US sanctions [ S&P Global Platts
Questions remain over UAE imports of Iranian condensate amid US sanctions [ S&P Global Platts
anonymity that the administration's goal remained to get to "zero oil
purchases from Iran as quickly as possible" and restated the goal of
"maximum economic pressure" on Iran. The official declined to comment
on the UAE specifically, but said that a future waiver may be possible.
anonymity that the administration's goal remained to get to "zero oil
purchases from Iran as quickly as possible" and restated the goal of
"maximum economic pressure" on Iran. The official declined to comment
on the UAE specifically, but said that a future waiver may be possible.
"We will continue working with countries that are reducing their imports on
a case-by-case basis," the official said. "We continue to work with partners,
friends, and allies across the world in a global effort."
"We will continue working with countries that are reducing their imports on
a case-by-case basis," the official said. "We continue to work with partners,
friends, and allies across the world in a global effort."
The UAE is a significant consumer of Iran's South Pars condensate,
importing about 152,000 b/d in October, up from about 107,000 b/d in
September, according to cFlow, S&P Global Platts trade-flow software.
The UAE is a significant consumer of Iran's South Pars condensate,
importing about 152,000 b/d in October, up from about 107,000 b/d in
September, according to cFlow, S&P Global Platts trade-flow software.
The Emirates National Oil, which operates the 140,000 b/d Jebel Ali Refinery
is the UAE's primary importer of Iranian condensate.
The Emirates National Oil, which operates the 140,000 b/d Jebel Ali Refinery
is the UAE's primary importer of Iranian condensate.
There are expectations that the UAE will stop importing Iranian condensate
entirely this month. The country reduced, but did not stop, importing Iranian
condensate when sanctions on Iran were previously in place during the
Obama administration.
There are expectations that the UAE will stop importing Iranian condensate
entirely this month. The country reduced, but did not stop, importing Iranian
condensate when sanctions on Iran were previously in place during the
Obama administration.
The UAE may begin importing condensate from new markets, including
Australia, Equatorial Guinea and the Eagle Ford in the US, sources said.
The UAE may begin importing condensate from new markets, including
Australia, Equatorial Guinea and the Eagle Ford in the US, sources said.
US sanctions on Iranian crude exports went back into effect Monday, but
the US has given temporary waivers to China, India and Turkey-- Iran's top
buyers -- as well as Japan, South Korea, Italy, Greece and Taiwan. S&P
Global Platts Analytics forecasts Iran crude exports to fall to about 1 million
b/d by May 3, when these waivers are set to expire, a decline of about 1.7
million b/d in about a year.
US sanctions on Iranian crude exports went back into effect Monday, but
the US has given temporary waivers to China, India and Turkey-- Iran's top
buyers -- as well as Japan, South Korea, Italy, Greece and Taiwan. S&P
Global Platts Analytics forecasts Iran crude exports to fall to about 1 million
b/d by May 3, when these waivers are set to expire, a decline of about 1.7
million b/d in about a year.
-- Brian Scheid, [email protected]
-- Brian Scheid, [email protected]
-- Edited by Derek Sands, [email protected]
-- Edited by Derek Sands, [email protected]
https://www.spglobal.com/platts/en/market-insights/latest-news/oil/1115…
https://www.spglobal.com/platts/en/market-insights/latest-news/oil/1115…

- 220 -

Annex 248
D. Hudson, “Despite sanctions, Iran’s oil exports rise in early 2019: sources”, Reuters,
19 February 2019

- 221 -

- 222 -

Despite sanctions, Iran's oil exports rise in early 2019: sources
Despite sanctions, Iran's oil exports rise in early 2019: sources
reuters.com/ article/us-i ran-o il-exports/despite-sanctio ns-i rans-oi I-exports-rise-i n-early-201 9-so urces-id USKCN 10818X
reuters.com/article/us-iran-oil-expo rts/despite-sa nctions-irans-oil-exports-rise-in-early-2019-sources-idUSKCN 1Q818X
LONDON (Reuters) - Iran's exports of crude oil were higher than expected in January and are
at least holding steady this month, according to tanker data and industry sources, as some
customers have increased purchases due to waivers from U.S. sanctions.
LONDON (Reuters) - Iran's exports of crude oil were higher than expected in January and are
at least holding steady this month, according to tanker data and industry sources, as some
customers have increased purchases due to waivers from U.S. sanctions.
Shipments are averaging 1.25 million barrels per day (bpd) in February, Refinitiv Eikon data
showed and a source at a company that tracks Iranian exports said. They were between 1.1
and 1.3 million bpd in January, higher than first thought.
Shipments are averaging 1.25 million barrels per day (bpd) in February, Refinitiv Eikon data
showed and a source at a company that tracks Iranian exports said. They were between 1.1
and 1.3 million bpd in January, higher than first thought.
A high rate of Iranian shipments would weigh on oil prices and work against a global push to
cut supply in 2019 led by the Organization of the Petroleum Exporting Countries. OPEC
member Iran negotiated an exemption from the production-cutting pact.
A high rate of Iranian shipments would weigh on oil prices and work against a global push to
cut supply in 2019 led by the Organization of the Petroleum Exporting Countries. OPEC
member Iran negotiated an exemption from the production-cutting pact.
''We think people are taking more ahead of the deadline," said the industry source who
tracks Iranian exports, referring to the scheduled end of U.S. sanctions waivers in May.
"We think people are taking more ahead of the deadline," said the industry source who
tracks Iranian exports, referring to the scheduled end of U.S. sanctions waivers in May.
Increased exports from the Islamic Republic might prompt renewed U.S. efforts to clamp
down on flows. However, this would run the risk of driving up oil prices as Washington is also
seeking to curtail exports from another foe, Venezuela.
Increased exports from the Islamic Republic might prompt renewed U.S. efforts to clamp
down on flows. However, this would run the risk of driving up oil prices as Washington is also
seeking to curtail exports from another foe, Venezuela.
Iran's exports have become more opaque since U.S. sanctions on the country's oil sector
took effect in November. While most agree they have dropped steeply, views on flows can
differ by as much as several hundred thousand barrels per day - enough to affect prices.
Iran's exports have become more opaque since U.S. sanctions on the country's oil sector
took effect in November. While most agree they have dropped steeply, views on flows can
differ by as much as several hundred thousand barrels per day - enough to affect prices.
The February shipments are up from January's 1.1 million bpd, according to Refinitiv. The
industry source estimated January exports at 1.3 million bpd, close to February's level.
The February shipments are up from January's 1.1 million bpd, according to Refinitiv. The
industry source estimated January exports at 1.3 million bpd, close to February's level.
In any case, the January figures are higher than initial estimates. Some had predicted Iranian
crude exports would stay below 1 million bpd last month, a similar rate to that in December.
In any case, the January figures are higher than initial estimates. Some had predicted Iranian
crude exports would stay below 1 million bpd last month, a similar rate to that in December.
A source at a second company that tracks Iranian exports said shipments in the first 10 days
of February were above 1.1 million bpd and on a rising trend - higher than the source
expected.
A source at a second company that tracks Iranian exports said shipments in the first 10 days
of February were above 1.1 million bpd and on a rising trend - higher than the source
expected.
Washington gave waivers to eight buyers - including China, India, Japan and South Korea,
which were all purchasing Iranian crude in February, according to Refinitiv.
Washington gave waivers to eight buyers - including China, India, Japan and South Korea,
which were all purchasing Iranian crude in February, according to Refinitiv.
The rise in shipments raises the prospect of less generous waivers, should Washington
renew such exemptions when those in place expire. The U.S. special representative for Iran
said last month there would be a much deeper reduction in Iranian exports.
The rise in shipments raises the prospect of less generous waivers, should Washington
renew such exemptions when those in place expire. The U.S. special representative for Iran
said last month there would be a much deeper reduction in Iranian exports.
Shipments have dropped steeply from at least 2.5 million bpd in April 2018, the month
before U.S. President Donald Trump withdrew the United States from a 2015 nuclear deal
with Iran and reimposed sanctions.
Shipments have dropped steeply from at least 2.5 million bpd in April 2018, the month
before U.S. President Donald Trump withdrew the United States from a 2015 nuclear deal
with Iran and reimposed sanctions.
Tehran has vowed to keep exporting oil despite U.S. efforts to reduce its shipments to zero.
Tehran has vowed to keep exporting oil despite U.S. efforts to reduce its shipments to zero.
1/2
1/2
- 223 -

Editing by Dale Hudson
Editing by Dale Hudson
2/2
2/2

- 224 -

Annex 249
F. Tan, “U.S. says Iran has lost $10 billion in oil revenue due to sanctions”, Reuters,
13 March 2019

- 225 -

- 226 -

U.S. says Iran has lost $10 billion in oil revenue due to sanctions
U.S. says Iran has lost $10 billion in oil revenue due to sanctions
reuters.com/article/us-ceraweek-energy-iran-idUSKBN 1 QU21 X
reuters.com/article/us-cer aweek-energy-iran-idUSKBN1QU21X
HOUSTON (Reuters) - Iran has lost $10 billion in revenue since U.S. sanctions in November have
removed about 1.5 million barrels per day (bpd) of Iranian crude from global markets, a U.S.
State Department official said on Wednesday.
HOUSTON (Reuters) - Iran has lost $10 billion in revenue since U.S. sanctions in November have
removed about 1.5 million barrels per day (bpd) of Iranian crude from global markets, a U.S.
State Department official said on Wednesday.
Brian Hook, the State Department's special representative on Iran, said in remarks at the
CERAWeek energy conference that due to a global oil surplus - in part due to record U.S.
production - the United States is accelerating its plan of bringing Iranian crude exports to zero.
Brian Hook, the State Department's special representative on Iran, said in remarks at the
CERAWeek energy conference that due to a global oil surplus- in part due to record U.S.
production - the United States is accelerating its plan of bringing Iranian crude exports to zero.
U.S. sanctions on Iran and Venezuela, two of the largest oil producers in the Organization of the
Petroleum Exporting Countries, and production cuts by OPEC and Russia have boosted global oil
prices to near four-month highs.
U.S. sanctions on Iran and Venezuela, two of the largest oil producers in the Organization of the
Petroleum Exporting Countries, and production cuts by OPEC and Russia have boosted global oil
prices to near four-month highs.
Iran reached an agreement with world powers in 2015 over its nuclear program which led to the
lifting of sanctions in 2016 but U.S. President Donald Trump pulled out of the deal in May last
year and reimposed restrictions in November.
Iran reached an agreement with world powers in 2015 over its nuclear program which led to the
lifting of sanctions in 2016 but U.S. President Donald Trump pulled out of the deal in May last
year and reimposed restrictions in November.
Trump "has made it very clear that we need to have a campaign of maximum economic
pressure" on Iran, Hook said, "but he also doesn't want to shock oil markets, he wants to ensure
a stable and well-supplied oil market. That policy has not changed."
Trump "has made it very clear that we need to have a campaign of maximum economic
pressure" on Iran, Hook said, "but he also doesn't want to shock oil markets, he wants to ensure
a stable and well-supplied oil market. That policy has not changed."
The global oil market is looking for signs that Washington may extend sanctions waivers for
Iran's key customers in early May. The United States surprised the market in November last year
by allowing eight countries to keep importing Iranian oil - in part causing Brent crude futures,
the international benchmark, to fall to near $50 a barrel in late December after surpassing $86 a
barrel in October.
The global oil market is looking for signs that Washington may extend sanctions waivers for
Iran's key customers in early May. The United States surprised the market in November last year
by allowing eight countries to keep importing Iranian oil - in part causing Brent crude futures,
the international benchmark, to fall to near $50 a barrel in late December after surpassing $86 a
barrel in October.
The U.S. Energy Information Administration (EIA) has projected that world supply will exceed
demand in 2019 by 440,000 bpd, Hook said.
The U.S. Energy Information Administration (EIA) has projected that world supply will exceed
demand in 2019 by 440,000 bpd, Hook said.
"When you have a better supplied oil market it enables us to accelerate our path to zero. But we
also know that there are a lot of variables that go into a well-supplied and stable oil market,"
said Hook, a senior policy adviser to U.S. Secretary of State Mike Pompeo.
"When you have a better supplied oil market it enables us to accelerate our path to zero. But we
also know that there are a lot of variables that go into a well-supplied and stable oil market,"
said Hook, a senior policy adviser to U.S. Secretary of State Mike Pompeo.
Washington sanctioned Venezuelan oil exports in January in an effort to oust President Nicolas
Maduro and a massive power outage since last week halted crude exports from its primary port,
essentially crippling the South American country's principal industry.
Washington sanctioned Venezuelan oil exports in January in an effort to oust President Nicolas
Maduro and a massive power outage since last week halted crude exports from its primary port,
essentially crippling the South American country's principal industry.
'We are aware that our diplomatic and economic pressure, the timing and the pace of that
affects Venezuela's oil industry," Hook said.
"We are aware that our diplomatic and economic pressure, the timing and the pace of that
affects Venezuela's oil industry," Hook said.
He said the United States is monitoring global supplies for impact from sanctions. "I've met a
few times with (Saudi Energy Minister) Khalid al-Falih over the last year when we knew we were
He said the United States is monitoring global supplies for impact from sanctions. "I've met a
few times with (Saudi Energy Minister) Khalid al-Falih over the last year when we knew we were
112
112
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taking a lot of oil, we wanted to ensure that we're doing this in a responsible way," he said.
taking a lot of oil, we wanted to ensure that we're doing this in a responsible way," he said.
Falih said on Sunday that OPEC's production-curbing agreement likely would last until at least
June. OPEC and its allies agreed late in 2018 to cut output by 1.2 million bpd.
Falih said on Sunday that OPEC's production-curbing agreement likely would last until at least
June. OPEC and its allies agreed late in 2018 to cut output by 1.2 million bpd.
Reporting by Florence Tan; Editing by Marguerita Choy and David Gregorio
Reporting by Florence Tan; Editing by Marguerita Choy and David Gregorio
212
2/2

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Annex 250
“Sources: Iran's Oil Exports Hit 2019 Low in April”, Reuters, 16 April 2019

- 229 -

- 230 -

Sources: Iran's Oil Exports Hit 2019 Low in April
Sources: Iran's Oil Exports Hit 2019 Low in April
MIDDLE EAST
MIDDLE EAST
Sources: Iran's Oil Exports Hit 2019 Low in
April
Sources: Iran's Oil Exports Hit 2019 Low in
April
April 16, 2019 11:03 AM Reuters
April 16, 2019 11.03 AM Reuters
FILE - A picture shows export oil pipelines at an oil facility in Iran's Kharg Island, on
the shore of the Persian Gulf, Feb. 23, 2016.
FILE - A picture shows export oil pipelines at an oil facility in Iran's Kharg Island, on
the shore of the Persian Gulf, Feb. 23, 2016.
LONDON -Iran's crude oil exports have dropped in April to their lowest daily level
this year, tanker data showed and industry sources said, suggesting buyers are
curbing purchases before Washington clamps down further on Iranian shipments as
expected next month.
LONDON -Iran's crude oil exports have dropped in April to their lowest daily level
this year, tanker data showed and industry sources said, suggesting buyers are
curbing purchases before Washington clamps down further on Iranian shipments as
expected next month.
The United States reimposed sanctions on Iran in November after pulling out of a
2015 nuclear accord between Tehran and six world powers. Those sanctions have
already more than halved Iranian oil exports, the country's main source of revenue.
The United States reimposed sanctions on Iran in November after pulling out of a
2015 nuclear accord between Tehran and six world powers. Those sanctions have
already more than halved Iranian oil exports, the country's main source of revenue.
https://www.voanews.com/a/iran-oil-exports/4878139.html
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- 231 -

Sources: Iran's Oil Exports Hit 2019 Low in April
Sources: Iran's Oil Exports Hit 2019 Low in April
Shipments are averaging below 1 million barrels per day (bpd) so far this month,
according to Refinitiv Eikon data and two other companies that track such exports
and declined to be identified. That's lower than at least 1.1 million bpd as estimated
for March.
Shipments are averaging below 1 million barrels per day (bpd) so far this month,
according to Refinitiv Eikon data and two other companies that track such exports
and declined to be identified. That's lower than at least 1.1 million bpd as estimated
for March.
The latest drop deepens supply losses resulting from an OPEC- led global agreement
to cut oil production and U.S. sanctions on another OPEC member, Venezuela.
Supported by those moves, oil prices have risen 30% this year to $71 a barrel.
The latest drop deepens supply losses resulting from an OPEC- led global agreement
to cut oil production and U.S. sanctions on another OPEC member, Venezuela.
Supported by those moves, oil prices have risen 30% this year to $71 a barrel.
"Collapsing Venezuelan oil output and sanctioned Iranian exports have put a big
question mark over supply,
11
Norbert Ruecker of Swiss bank Julius Baer said.
"Collapsing Venezuelan oil output and sanctioned Iranian exports have put a big
question mark over supply," Norbert Ruecker of Swiss bank Julius Baer said.
While exports could rise later in the month, the drop so far suggests Washington is
making progress towards its goal of curtailing shipments to below 1 million bpd from
May.
While exports could rise later in the month, the drop so far suggests Washington is
making progress towards its goal of curtailing shipments to below 1 million bpd from
May.
The United States, seeking to avoid an increase in oil prices, granted sanctions
waivers to China, India, Greece, Italy, Taiwan, Japan, Turkey and South Korea that
allowed them to keep buying some Iranian crude. Those exemptions expire in May
and analysts expect a new round to be less generous.
The United States, seeking to avoid an increase in oil prices, granted sanctions
waivers to China, India, Greece, Italy, Taiwan, Japan, Turkey and South Korea that
allowed them to keep buying some Iranian crude. Those exemptions expire in May
and analysts expect a new round to be less generous.
The U.S. government is considering more sanctions against Iran and has the ability
not to give waivers at all, a senior Trump administration official said this month.
The U.S. government is considering more sanctions against Iran and has the ability
not to give waivers at all, a senior Trump administration official said this month.
"We think there are very high chances that China and India and perhaps Turkey will
receive (fresh) waivers, but with further cuts,
11
said Sara Vakhshouri of energy
consultant SVB Energy International.
"We think there are very high chances that China and India and perhaps Turkey will
receive (fresh) waivers, but with further cuts," said Sara Vakhshouri of energy
consultant SVB Energy International.
There is no definitive figure on how much oil Iran exported in March. Shipments
have become more opaque since sanctions returned, and Iran no longer reports its
production figures to the Organization of the Petroleum Exporting Countries.
There is no definitive figure on how much oil Iran exported in March. Shipments
have become more opaque since sanctions returned, and Iran no longer reports its
production figures to the Organization of the Petroleum Exporting Countries.
One of the two companies that tracks shipments estimated Iran exported 1.1 million
bpd of crude last month, while the other company put the number at 1.3 million bpd.
Kpler, another company that tracks Iranian exports, estimated March shipments of
crude and condensate at 1.29 million bpd.
One of the two companies that tracks shipments estimated Iran exported 1.1 million
bpd of crude last month, while the other company put the number at 1.3 million bpd.
Kpler, another company that tracks Iranian exports, estimated March shipments of
crude and condensate at 1.29 million bpd.
Still, there is general agreement that crude shipments have dropped from at least 2.5
million bpd in April 2018, the month before U.S. President Donald Trump withdrew
the United States from the nuclear deal with Iran.
Still, there is general agreement that crude shipments have dropped from at least 2.5
million bpd in April 2018, the month before U.S. President Donald Trump withdrew
the United States from the nuclear deal with Iran.
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Sources: Iran's Oil Exports Hit 2019 Low in April
Sources: Iran's Oil Exports Hit 2019 Low in April
Tehran has vowed to keep exporting oil despite U.S. efforts to reduce its shipments
eventually to zero.
Tehran has vowed to keep exporting oil despite U.S. efforts to reduce its shipments
eventually to zero.
Reuters
Reuters
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- 233 -

- 234 -

Annex 251
J. Rogin, “No more waivers: The United States will try to force Iranian oil exports to
zero”, Washington Post, 21 April 2019

- 235 -

- 236 -

No more waivers: The United States will try to force Iranian oil
exports to zero
No more waivers: The United States will try to force Iranian oil
exports to zero
wash ingtonpost.com/opi nions/2019/04/21 /no-more-waivers-u nited-states-wil
1-try-fo
rce-irania n-oi
I-exports-zero
wash ingtonpost.com/opi nio ns/201 9/04/21 /no-more-waivers-u nited-states-wil I-try-fo rce-i ra nia n-oi I-exports-zero
By Josh Rogin
Columnist
By [osh Rogin
Columnist
April 21
About one year after the United States decided to leave the Iran nuclear deal. the State
Department is set to announce that all countries will have to completely end their imports of
Iranian oil or be subject to U.S. sanctions. This is an escalation of the Trump administration's
"maximum pressure" campaign, which seeks to force Tehran to end its illicit behavior around
the world.
April 21
About one year after the United States decided to leave the Iran nuclear deal. the State
Department is set to announce that all countries will have to completely end their imports of
Iranian oil or be subject to U.S. sanctions. This is an escalation of the Trump administration's
"maximum pressure" campaign, which seeks to force Tehran to end its illicit behavior around
the world.
On Monday morning, Secretary of State Mike Pompeo will announce to the media that, as of
May 2, the State Department will no longer grant sanctions waivers to any country that is
currently importing Iranian crude or condensate, two State Department officials told me. Last
November, the State Department issued 180-day waivers to eight countries to give them
more time to find alternative sources of oil. Now, their time is running out.
On Monday morning, Secretary of State Mike Pompeo will announce to the media that, as of
May 2, the State Department will no longer grant sanctions waivers to any country that is
currently importing Iranian crude or condensate, two State Department officials told me. Last
November, the State Department issued 180-day waivers to eight countries to give them
more time to find alternative sources of oil. Now, their time is running out.
The decision to end waivers has implications for world oil markets, which have been eagerly
anticipating President Trump's decision on whether to extend waivers. The officials said
market disruption should be minimal for two reasons: supply is now greater than demand
and Pompeo is also set to announce offsets through commitments from other suppliers
such as Saudi Arabia and the United Arab Emirates. Trump spoke about the issue Thursday
with the UAE's Crown Prince Mohammed bin Zayed al-Nahyan.
The decision to end waivers has implications for world oil markets, which have been eagerly
anticipating President Trump's decision on whether to extend waivers. The officials said
market disruption should be minimal for two reasons: supply is now greater than demand
and Pompeo is also set to announce offsets through commitments from other suppliers
such as Saudi Arabia and the United Arab Emirates. Trump spoke about the issue Thursday
with the UAE's Crown Prince Mohammed bin Zayed al-Nahyan.
The decision to stop the waivers - called significant reduction exceptions, or SREs - has
also become political in Washington, with hawkish officials and lawmakers publicly
advocating their discontinuation. Pompeo last week accused lawmakers of" grandstanding"
on the issue. Officials said Pompeo always intended to end the waivers when market
conditions allowed.
The decision to stop the waivers -called significant reduction exceptions, or SREs has
also become political in Washington, with hawkish officials and lawmakers publicly
advocating their discontinuation. Pompeo last week accused lawmakers of" grandstanding"
on the issue. Officials said Pompeo always intended to end the waivers when market
conditions allowed.
'The policy of zero Iranian imports originated with Secretary Pompeo," a senior State
Department official said. "He has executed this policy in tight coordination with the president
every step of the way. Because the conditions to not grant any more SR Es have now been
met, we can now announce zero imports."
"The policy of zero Iranian imports originated with Secretary Pompeo," a senior State
Department official said. "He has executed this policy in tight coordination with the president
every step of the way. Because the conditions to not grant any more SREs have now been
met, we can now announce zero imports."
Officials also pointed to recent comments by U.S. special representative for Iran Brian Hook,
who said earlier this month that waivers were appropriate last year due to concern over oil
prices that was publicly expressed by Trump.
Officials also pointed to recent comments by U.S. special representative for Iran Brian Hook,
who said earlier this month that waivers were appropriate last year due to concern over oil
prices that was publicly expressed by Trump.
This year, he said, is different. "Because [in] 2019 we forecast more supply than demand,
there are better market conditions for us to accelerate our path to zero," said Hook. "We are
not looking to grant any waivers or exceptions to our sanctions regime."
This year, he said, is different. "Because [in] 2019 we forecast more supply than demand,
there are better market conditions for us to accelerate our path to zero," said Hook. "We are
not looking to grant any waivers or exceptions to our sanctions regime."
1/3
1/3
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Three of the eight countries that received U.S. waivers last November have already reduced
Three of the eight countries that received U.S. waivers last November have already reduced
their Iranian oil imports to zero: Greece, Italy and Taiwan. The other countries that will now
have to cut off Iranian oil imports or be subject to U.S. sanctions are China, India, Turkey,
Japan and South Korea.
their Iranian oil imports to zero: Greece, Italy and Taiwan. The other countries that will now
have to cut off Iranian oil imports or be subject to U.S. sanctions are China, India, Turkey,
Japan and South Korea.
China and India are currently the largest importers of Iranian oil. If they don't go along with
Trump's demands, that could cause tensions in both bilateral relationships and spill over into
other issues, like trade. South Korea and Japan are relatively less dependent on Iranian oil
and have already been treading lightly. A Turkish official has said the country is "expecting"
another waiver, but it isn't getting one.
China and India are currently the largest importers of Iranian oil. If they don't go along with
Trump's demands, that could cause tensions in both bilateral relationships and spill over into
other issues, like trade. South Korea and Japan are relatively less dependent on Iranian oil
and have already been treading lightly. A Turkish official has said the country is "expecting"
another waiver, but it isn't getting one.
Trump has said he wants the Iranian regime to come back to the negotiating table and strike
a better deal than the one President Barack Obama signed. The Iranian regime has said it
has no intention of doing that. Either way, the administration's ramping up of its "maximum
pressure" campaign is meant to starve the regime of the cash it needs to perpetrate its
malign activities around the world.
Trump has said he wants the Iranian regime to come back to the negotiating table and strike
a better deal than the one President Barack Obama signed. The Iranian regime has said it
has no intention of doing that. Either way, the administration's ramping up of its "maximum
pressure" campaign is meant to starve the regime of the cash it needs to perpetrate its
malign activities around the world.
"The goal of the policy is to drive up the costs of Iran's malign behavior and more strongly
address the broad range of threats to peace and security their regime presents," the State
Department official said.
"The goal of the policy is to drive up the costs of Iran's malign behavior and more strongly
address the broad range of threats to peace and security their regime presents," the State
Department official said.
Although the U.S. government's internal data tracking Iranian oil exports is not public,
reports from private analysts note that Iranian oil exports rose in early 2019 perhaps as
countries stocked up ahead of the cutoff, and then fell in March as countries likely sought to
wean themselves off Iranian oil.
Although the U.S. government's internal data tracking Iranian oil exports is not public,
reports from private analysts note that Iranian oil exports rose in early 2019, perhaps as
countries stocked up ahead of the cutoff, and then fell in March as countries likely sought to
wean themselves off Iranian oil.
Public estimates put the approximate amount of Iranian oil exports in March at about 1
million barrels per day, down from about 2.5 million barrels per day in April 2018, the month
before Trump announced that the United States was withdrawing from the Iran nuclear deal.
Public estimates put the approximate amount of Iranian oil exports in March at about 1
million barrels per day, down from about 2.5 million barrels per day in April 2018, the month
before Trump announced that the United States was withdrawing from the Iran nuclear deal.
There are some signs the pressure is having an effect. Iran has been unable to deliver oil to
Syria since January due to international enforcement of the sanctions, the Wall Street Journal
reported last month, which has increased pressure on the regime of Bashar al-Assad. In
March, Pompeo pointed to Hezbollah's reported cash shortages as additional evidence that
Iran's coffers were being squeezed, with positive results for regional security.
There are some signs the pressure is having an effect. Iran has been unable to deliver oil to
Syria since January due to international enforcement of the sanctions. the Wall Street Journal
reported last month. which has increased pressure on the regime of Bashar al-Assad. In
March, Pompeo pointed to Hezbollah's reported cash shortages as additional evidence that
Iran's coffers were being squeezed. with positive results for regional security.
The use of sanctions threats to pressure adversaries and allies alike is not without risk.
European allies have been working with Tehran to devise methods to circumvent U.S.
sanctions as part of their effort to save the Iran deal. But for now, the United States is still big
and strong enough economically that companies and governments have little choice but to
comply.
The use of sanctions threats to pressure adversaries and allies alike is not without risk.
European allies have been working with Tehran to devise methods to circumvent U.S.
sanctions as part of their effort to save the Iran deal. But for now. the United States is still big
and strong enough economically that companies and governments have little choice but to
comply.
It's unlikely the Iranian regime will ever sit down with the Trump administration to negotiate
a better deal or fundamentally change its behavior. Starting next month, though, it will at
least have less oil money to spread terrorism and mischief around the Middle East and the
world.
It's unlikely the Iranian regime will ever sit down with the Trump administration to negotiate
a better deal or fundamentally change its behavior. Starting next month, though. it will at
least have less oil money to spread terrorism and mischief around the Middle East and the
world.
losh Rogin
losh Rogin
2/3
2/3

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Annex 252
D. Zhdannikov, “Iran's oil exports to slide in May, but not to zero: sources”, Reuters,
3 May 2019

- 239 -

- 240 -

Iran's oil exports to slide in May, but not to zero: sources
Iran's oil exports to slide in May, but not to zero: sources
Iran's oil exports to slide in May, but not to
zero: sources
Iran's oil exports to slide in May, but not to
zero: sources
Dmitry Zhdannikov
Dmitry Zhdannikov
LONDON (Reuters) - Iranian oil exports will slide in May as the United States
tightens the screws on Tehran's main source of income, industry sources said,
deepening global supply losses caused by U.S. sanctions on Venezuela and OPEC-led
cuts.
LONDON (Reuters) - Iranian oil exports will slide in May as the United States
tightens the screws on Tehran's main source of income, industry sources said,
deepening global supply losses caused by U.S. sanctions on Venezuela and OPEC-led
cuts.
FILE PHOTO: Oil tankers pass through the Strait of Hormuz, December 21, 2018.
FILE PHOTO: Oil tankers pass through the Strait of Hormuz, December 21, 2018.
REUTERS/Hamad I Mohammed/File Photo
The United States reimposed sanctions on Iran in November after pulling out of a
REUTERS/Hamad I Mohammed/File Photo
The United States reimposed sanctions on Iran in November after pulling out of a
2015 nuclear accord between Tehran and six world powers. Those sanctions have
already more than halved Iranian oil exports to 1 million barrels per day (bpd) or
less.
2015 nuclear accord between Tehran and six world powers. Those sanctions have
already more than halved Iranian oil exports to 1 million barrels per day (bpd) or
less.
Washington, aiming to cut Iran's sales to zero, said all sanctions waivers for those
Washington, aiming to cut Iran's sales to zero, said all sanctions waivers for those
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- 241 -

Iran's oil exports to slide in May, but not to zero: sources
Iran's oil exports to slide in May, but not to zero: sources
FILE PHOTO: The logo of the Organization of the Petroleum Exporting Countries
(OPEC) is seen inside their headquarters in Vienna, Austria December 7, 2018.
FILE PHOTO: The logo of the Organization of the Petroleum Exporting Countries
(OPEC) is seen inside their headquarters in Vienna, Austria December 7, 2018.
REUTERS/Leonhard Foeger/File Photo
"The uncertainty band around the decline reflects residual uncertainty about the
exact number of Iranian tankers that have been operating under the radar," Kayrros
said in a report.
The oil industry has for some years used tanker-tracking to work out actual supplies
in the absence of timely official information. While easier than in the past due to
satellite information, tanker tracking is still both art and science.
Tankers loading Iranian crude sometimes switch off their AIS signal, an automatic
tracking system used on ships, only to switch it back on at a later stage of their
journey, according to oil industry source, making it harder to see actual volumes.
Still, there is general agreement that crude shipments have dropped from at least 2.5
million bpd in April 2018, the month before President Donald Trump withdrew the
United States from the nuclear deal with Iran.
Editing by Alexander Smith
REUTERS/Leonhard Foeger/File Photo
"The uncertainty band around the decline reflects residual uncertainty about the
exact number of Iranian tankers that have been operating under the radar," Kayrros
said in a report.
The oil industry has for some years used tanker-tracking to work out actual supplies
in the absence of timely official information. While easier than in the past due to
satellite information, tanker tracking is still both art and science.
Tankers loading Iranian crude sometimes switch off their AIS signal, an automatic
tracking system used on ships, only to switch it back on at a later stage of their
journey, according to oil industry source, making it harder to see actual volumes.
Still, there is general agreement that crude shipments have dropped from at least 2.5
million bpd in April 2018, the month before President Donald Trump withdrew the
United States from the nuclear deal with Iran.
Editing by Alexander Smith
https://www.reuters.com/article/us-oil-iran-exports/irans-oil-exports-t… -but-not-to-zero-sources-idUSKCNIS911W
https://www.reuters.com/article/us-oil-iran-exports/irans-oil-exports-t… -but-not-to-zero-sources-idUSKCNIS911W
- 242 -

Iran's oil exports to slide in May, but not to zero: sources
Iran's oil exports to slide in May, but not to zero: sources
importing Iranian oil would end this week. Iran says this will not happen, although
its officials are bracing for a drop in supplies.
importing Iranian oil would end this week. Iran says this will not happen, although
its officials are bracing for a drop in supplies.
One Iranian official familiar with oil policy said exports could drop to 700,000 bpd
and as low as 500,000 bpd from May onwards. An OPEC source said Iranian exports
would likely continue at about 400,000 to 600,000 bpd.
One Iranian official familiar with oil policy said exports could drop to 700,000 bpd
and as low as 500,000 bpd from May onwards. An OPEC source said Iranian exports
would likely continue at about 400,000 to 600,000 bpd.
Iran would likely be able to maintain some shipments for debt repayment to China
and India, and into storage in China, and smuggle a limited extra amount as it did
under previous sanctions, analyst Sara Vakhshouri said.
Iran would likely be able to maintain some shipments for debt repayment to China
and India, and into storage in China, and smuggle a limited extra amount as it did
under previous sanctions, analyst Sara Vakhshouri said.
"It's important to note that zero oil sales in May doesn't mean that there will not be
oil deliveries to China or India in the month," she said.
"It's important to note that zero oil sales in May doesn't mean that there will not be
oil deliveries to China or India in the month," she said.
"In total, Iran could export between 200,000 to 550,000 of oil. of which not all is
sold oil."
"In total, Iran could export between 200,000 to 550,000 of oil. of which not all is
sold oil."
Analysts at Energy Aspects expect a drop in Iranian shipments to around 600,000
Analysts at Energy Aspects expect a drop in Iranian shipments to around 600,000
bpd from May onwards.
Iranian exports have become more opaque since U.S. sanctions returned in
November. Tehran no longer reports its production figures to the Organization of the
Petroleum Exporting Countries and there is no definitive information on exports.
Some of Iran's oil exports are already under the radar, making it harder to assess the
actual volume.
The OPEC member exported between 1.02 million bpd and 1.30 million bpd of crude
and condensate in April, Refinitiv Eikon and Kpler, a company that tracks oil flows,
estimate.
bpd from May onwards.
Iranian exports have become more opaque since U.S. sanctions returned in
November. Tehran no longer reports its production figures to the Organization of the
Petroleum Exporting Countries and there is no definitive information on exports.
Some of Iran's oil exports are already under the radar, making it harder to assess the
actual volume.
The OPEC member exported between 1.02 million bpd and 1.30 million bpd of crude
and condensate in April, Refinitiv Eikon and Kpler, a company that tracks oil flows,
estimate.
OPEC HEADACHE
OPEC HEADACHE
The dearth of information is a headache for other OPEC members and allies, which
meet to set oil supply policy in June. OPEC canceled an April meeting, partly due to
this uncertainty.
The dearth of information is a headache for other OPEC members and allies, which
meet to set oil supply policy in June. OPEC canceled an April meeting, partly due to
this uncertainty.
Saudi Aramco, expected to be the main source of any extra oil to replace Iranian
volumes, has been asking around in the market for estimates of Iranian exports,
industry sources said.
Saudi Aramco, expected to be the main source of any extra oil to replace Iranian
volumes, has been asking around in the market for estimates of Iranian exports,
industry sources said.
Iranian oil officials have welcomed this opacity. Tehran insists it will keep selling oil
and is examining new ways of doing so, Iranian oil minister, Bijan Zanganeh, was
quoted as saying on Wednesday.
Iranian oil officials have welcomed this opacity. Tehran insists it will keep selling oil
and is examining new ways of doing so, Iranian oil minister, Bijan Zanganeh, was
quoted as saying on Wednesday.
Kayrros, a company that tracks oil flows, put Iranian crude exports in March at 1.40
Kayrros, a company that tracks oil flows, put Iranian crude exports in March at 1.40
million to 1.65 million bpd.
million to 1.65 million bpd.
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- 244 -

Annex 253
Witness statement by Mr M. Asaadi Samani, Secretary of the Association of Iranian
Airlines (AIA), 18 August 2018

- 245 -

- 246 -

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ASSOCIATION of IRANIAN AIRLINES
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ASSOCIATION of IRANIAN AIRLINES
Witness Statement
Witness Statement
I, Maghsoud Asaadi Samani, the Secretary of Association of Iranian Airlines
("Association"), testify as follows:
I, Maghsoud Asaadi Samani, the Secretary of Association of Iranian Airlines
("Association"), testif
as follows:
I- I have been the Secretary of Association since 2014. I hold a B.S.degree in
Insurance from college of Insurance Tehran.
I was employed by the
Association in 2014.
2- The Association is a non-governmental organization which consists of 15
Iranian airlines as its members. The main task of the Association is
negotiation with the government, parliament, and other official authorities
for securing the syndicate interests of the Iranian airlines and rendering
expert opinion in several aspects of aviation industry. Further purposes of
the Association are, inter alia, providing solutions for alleviating the
burdens and problems imposed on the Iranian airlines due to the sanctions,
enhancement of the services rendered by the airlines and organizing the
cooperation between them. Given my previous positions and my current
capacity, I have personal knowledge of the facts hereinafter stated except
where it is indicated that matters are based on information or belief, in
which case I believe the relevant matters to be true.
3- The U.S. withdrawal from the JCPOA on 8 May 2018 and re-imposition of
sanctions on 6 August 2018 are having the following harmful effects on
Iranian airlines and civil aviation. The Aircraft operations, engineering and
maintenance, commercial and financial activities and providing foreign
airport services to the the airlines would be rigorously affected.
4- Following the JCPOA, Iranian airlines were hopeful that their ageing fleet
would be renewed by purchasing more than 320 new commercial aircraft
based on the contracts and MOUs with major aircraft manufacturers
including Airbus. Boeing, A TR, etc.
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1- I have been the Secretary of Association since 20 I 4. I hold a B.S.degree in
Insurance from college of Insurance Tehran.
I was employed by the
Association in 2014.
2- The Association is a non-governmental organization which consists of 15
Iranian airlines as its members. The main task of the Association is
negotiation with the government, parliament, and other official authorities
for securing the syndicate interests of the Iranian airlines and rendering
expert opinion in several aspects of aviation industry. Further purposes of
the Association are, inter alia, providing solutions for alleviating the
burdens and problems imposed on the Iranian airlines due to the sanctions.
enhancement of the services rendered by the airlines and organizing the
cooperation between them. Given my previous positions and my current
capacity, I have personal knowledge of the facts hereinafter stated except
where it is indicated that matters are based on information or belief, in
which case I believe the relevant matters to be true.
3- The U.S. withdrawal from the JCPOA on 8 May 2018 and re-imposition of
sanctions on 6 August 2018 are having the following harmful effects on
Iranian airlines and civil aviation. The Aircraft operations, engineering and
maintenance, commercial and financial activities and providing foreign
airport services to the the airlines would be rigorously affected.
4- Following the JCPOA, Iranian airlines were hopeful that their ageing fleet
would be renewed by purchasing more than 320 new commercial aircraft
based on the contracts and MOUs with major aircraft manufacturers
including Airbus. Boeing, A TR, etc.
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ASSOCIATION of IRANIAN AIRLINES
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5- However, the Statement of Licensing Policy for activities related to the
export or re-export to Iran of commercial passenger aircraft and related parts
and services (JCPOA SLP) was revoked immediately by OFAC as of8 May
2018. This revocation will have destructive impacts on the several aspects
of Iranian airlines' operations, especially on the safety of their flights.
5- However, the Statement of Licensing Policy for activities related to the
export or re-export to Iran of commercial passenger aircraft and related parts
and services (JCPOA SLP) was revoked immediately by OFAC as of 8 May
2018. This revocation will have destructive impacts on the several aspects
of Iranian airlines' operations, especially on the safety of their flights.
6- Based on our experience of the sanctions imposed on Iranian airlines before
JCPOA, the most important harmful impacts of the re-imposition of the U.S.
sanctions are as follows:
6- Based on our experience of the sanctions imposed on Iranian airlines before
JCPOA, the most important harmful impacts of the re-imposition of the U.S.
sanctions are as follows:
- Operation Section
- Operation Section
a) Inaccessibility to the Lufthansa System's services in the procurement of
LIDO (Lufthansa Integrated Dispatch Operation) which is necessary for air
a) Inaccessibility to the Lufthansa System's services in the procurement of
LIDO (Lufthansa Integrated Dispatch Operation) which is necessary for air
navigation,
navigation,
b) Blockage in receiving and updating the Flight Management System
Database which is extremely crucial for all aircraft navigation all around the
world.
c) The impossibility of fuelling particularly in foreign destinations which leads
to the reduction in passenger and cargo capacity for the fleet and give rise
to extra landing and take-off for fuelling in secondary airports.
d) In addition, more cost will be incurred by the airlines due to the necessity
of the de-icing process in winter.
e) Implementation of the Regulation on Air Operations by Iran Civil Aviation
Organisation concerning flight duty period and an increase in flight hours
due to extra landing and take-off will result in major problems for Iranian
airlines.
b) Blockage in receiving and updating the Flight Management System
Database which is extremely crucial for all aircraft navigation all around the
world.
e) The impossibility of fuelling particularly in foreign destinations which leads
to the reduction in passenger and cargo capacity for the fleet and give rise
to extra landing and take-off for fuelling in secondary airports.
d) In addition, more cost will be incurred by the airlines due to the necessity
of the de-icing process in winter.
e) Implementation of the Regulation on Air Operations by Iran Civil Aviation
Organisation concerning flight duty period and an increase in flight hours
due to extra landing and take-off will result in major problems for Iranian
airlines.
) Restriction or impossibility of using the simulators made by major
companies and consequently harming preliminary and periodical pilot
training necessary for issuance and renewing of the flight licenses.
g) Non-receiving necessary data for updating flight books and relevant
checklists such as QRH, FCOM, etc. from the aircraft manufacturer which
has a direct impaet on Safety oftlight.
f) Restriction or impossibility of using the simulators made by major
companies and consequently harming preliminary and periodical pilot
training necessary for issuance and renewing of the flight licenses.
g) Non-receiving necessary data for updating flight books and relevant
checklists such as QRH, FCOM, etc. from the aircraft manufacturer which
has a direct impaet on Safety offlight.
h) Restriction on using the critical applications for assessment of the aircraft's
flying function such as SPS, FAS, PEP, AB. Which is necessary for every
commercial flight all around the world.
h) Restriction on using the critical applications for assessment of the aircraft's
flying function such as SPS, FAS, PEP, AB. Which is necessary for every
commercial flight all around the world.
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ASSOCIATION of IRANIAN AIRLINES
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i) Extreme limitation in access to airworthiness data and flight operation data
which put passengers in danger.
i) Extreme limitation in access to airworthiness data and flight operation data
which put passengers in danger.
j) Aircraft is a package of systems and integrated technologies which will
remain operative when all associated services and linked matters provided.
Therefore, failure to access each of the above-mentioned items makes the
aircraft inoperative.
j) Aircraft is a package of systems and integrated technologies which will
remain operative when all associated services and linked matters provided.
Therefore, failure to access each of the above-mentioned items makes the
aircraft inoperative,
- Commercial and Financial Sections
a) Sharp reduction in ticket sales and foreign tourism.
b) Extreme difficulties in access to the relevant services and requirements in
cargo air transportation including but not limited to Cargo Spot GSA. Cargo
Account Settlement Systems (CASS), correspondent banking services,
inspections reservation system, communication software, and acceptance of
cargos under the Iranian airway bill prefix.
c) Closing Iranian airlines' bank account in foreign banks and refusing lo
render any banking services to them.
d) Extreme difficulties in payment of expenses through banking system.
selling tickets and transferring the yielded income to Iran.
- Commercial and Financial Sections
a) Sharp reduction in ticket sales and foreign tourism.
b) Extreme difficulties in access to the relevant services and requirements in
cargo air transportation including but not limited to Cargo Spot GSA. Cargo
Account Settlement Systems (CASS), correspondent banking services,
inspections reservation system, communication software, and acceptance of
cargos under the Iranian airway bill prefix.
c) Closing Iranian airlines' bank account in foreign banks and refusing to
render any banking services to them.
d) Extreme difficulties in payment of expenses through banking system.
selling tickets and transferring the yielded income to Iran.
- Airport Services Section
a) Restriction on securing certain technical parts and aircraft auxiliary
equipment including air conditioner, air starter, de-icing sprayer machines,
container/pallet loader, truck, grand power, transporter and push truck.
b) Restriction on or impossibility of providing aircraft de-icing fluid.
- Airport Services Section
a) Restriction on securing certain technical parts and aircraft auxiliary
equipment including air conditioner, air starter, de-icing sprayer machines,
container/pallet loader, truck, grand power, transporter and push truck.
b) Restriction on or impossibility of providing aircraft de-icing fluid.
- Engineering and Repairing Sections
a) Restrictions on purchasing aircraft spare parts from or repairing them by the
- Engineering and Repairing Sections
a) Restrictions on purchasing aircraft spare parts from or repairing them by the
main sources.
main sources.
b) Inaccessibility of the aircraft's technical and expertise documents and
publications.
e)
b) Inaccessibility of the aircraft's technical and expertise documents and
publications.
e)
Impossibility in purchasing aircraft engine, landing gear, auxiliary power
unit, and propeller for aircraft.
d) Restriction on updating the aircraft systems in order to make them
compatible with the Airworthiness Directives. Continuing airworthiness of
aircraft and its operation are completely dependent on the mandatory
modifications (Airworthiness Directives) and well performance of required
Impossibility in purchasing aircraft engine, landing gear, auxiliary power
unit, and propeller for aircraft.
d) Restriction on updating the aircraft systems in order to make them
compatible with the Airworthiness Directives. Continuing airworthiness of
aircraft and its operation are completely dependent on the mandatory
modifications (Airworthiness Directives) and well performance of required
maintenance and inspections.
maintenance and inspections.
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ASSOCIATION of IRANIAN AIRLINES
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e) Exacerbation of customs restrictions on shipping the aircraft's spare-parts
and materials from other countries.
e) Exacerbation of customs restrictions on shipping the aircraft's spare-parts
and materials from other countries.
f) No access to essential training for new aircraft.
7- Due to the U.S. sanctions it is even impossible for Iranian airlines to lease
an aircraft from foreign companies which is a real impediment on the
operation and expansion of the airline's flight destinations.
8- Considering the international logic of aviation industry, safety enhancement
is subject to countries' close cooperation. Such cooperation has been
extremely limited for Iranian airlines due to the re-imposition of the U.S.
sanctions. If the international community fails to prevent the U.S. from
giving full effect to its sanctions, the lives of Iranian passengers and crew
and other customers of Iranian airlines will be placed in danger.
D) No access to essential training for new aircraft.
7- Due to the U.S. sanctions it is even impossible for Iranian airlines to lease
an aircraft from foreign companies which is a real impediment on the
operation and expansion of the airline's flight destinations.
8- Considering the international logic of aviation industry, safety enhancement
is subject to countries' close cooperation. Such cooperation has been
extremely limited for Iranian airlines due to the re-imposition of the U.S.
sanctions. If the international community fails to prevent the U.S. from
giving full effect to its sanctions, the lives of Iranian passengers and crew
and other customers of Iranian airlines will be placed in danger.
STATEMENT OF TRUTH
STATEMENT OF TRUTH
I believe that the facts stated in this witness statement are true.
I believe that the facts stated in this witness statement are true.
Name: Maghsoud Asaadi Samani
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Name: Maghsoud Asaadi Samani
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Annex 254
Witness statement of Mr A. Abedzade, President of the Civil Aviation Organization of
Iran, 24 April 2019

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Civil Aviation Organizioe
Civil Aviation Organizioe
Witness Statement on the Effects of the Sanctions Imposed on Iran's
Aviation Industry
Witness Statement on the Effects of the Sanetions Imposed on Iran's
Aviation Industry
April 24, 2019
April 24, 2019
1. I am Ali Abedzade, a graduate of aircraft engineering and an M.S holder
in engineering management from the University of the Philippines. I have
started my professional career at the Civil Aviation Organization of Iran
since 1980 and have experience of working in various fields like aircraft
maintenance, technical supervision at Aseman Airlines, and held positions
like the Managing Director of Aseman Airlines and the Vice President of
Meraj Airlines. J am currently working as the Vice Minister of Roads and
Urban Development and President of Civil Aviation Organization of lran.
I. I am Ali Abedzade, a graduate of aircrait engineering and an M.S holder
in engineering management from the University of the Philippines. I have
started my professional career at the Civil Aviation Organization of Iran
since 1980 and have experience of working in various fields like aircraft
maintenance, technical supervision at Aseman Airlines, and held positions
like the Managing Director of Aseman Airlines and the Vice President of
Meraj Airlines. Jam currently working as the Vice Minister of Roads and
Urban Development and President of Civil Aviation Organization of Iran.
2. I hereby declare that the Civil Aviation Organization as the government
representative to exercise sovereignty in Iran's air transport industry
assumes the following major responsibilities:
2-1. Policymaking, planning and shaping technical, economic,
commercial and international policies of the State air transport
2-2. Developing flight standards, overseeing airline companies in terms
2. I hereby declare that the Civil Aviation Organization as the government
representative to exercise sovereignty in Iran's air transport industry
assumes the following major responsibilities:
2-1. Policymaking, planning and shaping technical, economic,
commercial and international policies of the State air transport
2-2. Developing flight standards, overseeing airline companies in terms
of airworthiness verification and compliance with safety issues and
standards, issuing licenses, developing and making the associated
regulations
of airworthiness verification and compliance with safety issues and
standards, issuing licenses, developing and making the associated
regulations
2-3. Verifying the types of aircraft authorized to engage in air transport
2-3. Verifying the types of aircraft authorized to engage in air transport
in Iran
in Iran
2-4. Preparing and developing security directives in compliance with the
2-4. Preparing and developing security directives in compliance with the
associated international and domestic regulations and standards in
addition to overseeing their enforcement
associated international and domestic regulations and standards in
addition to overseeing their enforcement
2-5. Policymaking and planning for educating and training skilled
2-5. Policymaking and planning for educating and training skilled
aviation personnel for all aviation institutes
aviation personnel for all aviation institutes
2-6. Holding membership and communicating with the International
Civil Aviation Organization (CAO) and other global affiliated
2-6. Holding membership and communicating with the International
Civil Aviation Organization (ICAO) and other global affiliated
organizations in compliance with the related regulations
organizations in compliance with the related regulations
2-7. Investigating the aviation incidents and accidents and imposing the
2-7. Investigating the aviation incidents and accidents and imposing the
necessary penalties in accordance with the related regulations
necessary penalties in accordance with the related regulations
Page 1 of S
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3. Given my previous responsibilities and experience, and available
information at hand, I declare that following the Joint Comprehensive Plan
of Action (JCPOA), an opportunity presented itself through which global
air service suppliers could establish an easier connection with Iran's
3. Given my previous
responsibilities and experience, and available
information at hand, 1 declare that following the Joint Comprehensive Plan
of Action (JCPOA), an opportunity presented itself through which global
air service suppliers could establish an easier connection with Iran's
aviation industry. Consequently, Iranian airline companies and airports
gained an opportunity to have a direct connection with aircraft and spare
aviation industry. Consequently, Iranian airline companies and airports
gained an opportunity to have a direct connection with aircraft and spare
parts manufacturers, and with those of airport equipment. Moreover, access
to information related to aviation industry was gained more easily to
facilitate aeronautical issues, which in turn resulted in purchasing the
aircraft required by Iranian airline companies and some equipment needed
at airports in Iran.
parts manufacturers, and with those of airport equipment. Moreover, access
to information related to aviation industry was gained more easily to
facilitate aeronautical issues, which in turn resulted in purchasing the
aircraft required by Iranian airline companies and some equipment needed
at airports in Iran.
4. I also declare that the re-imposition of the U,S. sanctions have directly
4. I also declare that the re-imposition of the US. sanctions have directly
affected Iran's aviation industry in different forms, which are as follows:
affected Iran's aviation industry in different forms, which are as follows:
4-1. The connection between Iranian airline companies and airports with
major suppliers of aircraft together with their spare parts and
repairers has been broken in the international arena. Similarly, even
some restrictions regarding the Iranian airlines' access to processes
leading to providing the flight safety have been imposed. One of the
factors causing such disconnection is the cut of financial ties, which
has created more restrictions. For example, following the contracts
already signed, the deposits paid by Iranian parties were blocked by
4-1. The connection between Iranian airline companies and airports with
major suppliers of aircraft together with their spare parts and
repairers has been broken in the international arena. Similarly, even
some restrictions regarding the Iranian airlines' access to processes
leading to providing the flight safety have been imposed. One of the
factors causing such disconnection is the cut of financial ties, which
has created more restrictions. For example, following the contracts
already signed, the deposits paid by Iranian parties were blocked by
foreign manufacturing companies due to the re-imposition of
sanctions, causing Iranian companies to incur heavy
losses.
foreign manufacturing companies due to the re-imposition of
sanctions, causing Iranian companies to
incur heavy
losses.
Annexed to this Witness Statement is the Rolls Royce's letter dated
August 6, 2018, to Iran Aseman Airlines with reference number R­
R/JCPOAIAA/180806 regarding the notification on blocking the
deposits already paid.
4-2. Iranian airlines companies have been barred or restricted from
Annexed to this Witness Statement is the Rolls Royce's letter dated
August 6, 2018, to Iran Aseman Airlines with reference number R­
R/JCPOA/IAA/180806 regarding the notification on blocking the
deposits already paid.
4-2. Iranian airlines companies have been barred or restricted from
access to services and parts including the updated books and related
access to services and parts including the updated books and related
checklists of aircraft manufactures as well as the technical and
specialized documents, necessary for the safety and airworthiness of
the aircraft of their fleets; a situation that led the Civil Aviation
Organization of Iran to request the grounding of a growing number
of these aircraf
checklists of aircraft manufactures as well as the technical and
specialized documents, necessary for the safety and airworthiness of
the aircraft of their fleets; a situation that led the Civil Aviation
Organization of Iran to request the grounding of a growing number
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of these aircraf
, impeding the capacity of Iranian airlines to meet
the need for air transportation services, not only for international
flights but also for domestic flights.
Page 2of 5
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, impeding the capacity of Iranian airlines to meet
the need for air transportation services, not only for international
flights but also for domestic flights.
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4-3. Imposing restrictions on purchasing aircraft engine, landing gear,
APU and propeller, spare parts, and or repairing them by major
companies has crippled the operational activities of the fleet. Also,
4-3. Imposing restrictions on purchasing aircraft engine, landing gear,
APU and propeller, spare parts, and or repairing them by major
companies has crippled the operational activities of the fleet. Also,
access to technical services and information necessary to operate
access to technical services and information necessary to operate
aircraft and maintain their airworthiness has been terminated.
4-4. Restrictions on access to simulator by large companies has damaged
both the pilot courses and the initial training for issuing and
aircraft and maintain their airworthiness has been terminated.
4-4. Restrictions on access to simulator by large companies has damaged
both the pilot courses and the initial training for issuing and
renewing their licenses.
renewing their licenses.
4-5. The negative growth in cargo capacity by 14% and passenger
numbers by 17% has been brought about by different factors such as
refusal of refueling at foreign destinations, forcing extra landings
and a rise in flight hours, as well as the need for carrying f
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4-5. The negative growth in cargo capacity by 14% and passenger
numbers by 17% has been brought about by different factors such as
refusal of refueling at foreign destinations, forcing extra landings
and a rise in flight hours, as well as the need for carrying f
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return flights, all of which have caused the number of passengers
and or cargo to drop considerably.
4-6. The number of flights, in particular the ones at level-2 and level-3
airports in Iran, has decreased. Evidence to this is the 14 percent fall
in the number of landings and takeoffs at domestic airports during
the eleven-month period i.e. March 2018- February 2019, compared
to the similar period: March 2017 to February 2018.
4-7. Following the JCPOA, Iranian airlines began to purchase aircraft
from large aircraft manufacturing companies to renew their fleet, but
the signed contracts were canceled by foreign companies once the
U.S. re-imposed the sanctions, causing Iranian airlines to suffer
heavy losses.
4-8. Restrictions on sales and barter systems, such as lack of access to
IATA clearing house for financial bartering of Iranian airline
companies with foreign airline companies which are members of
IATA.
4-9. Problems connected with using reservation systems, including the
restrictions created by SITA company for Mahan and Meraj airline
companies.
4-10. Problems connected with access to services and requirements for
cargo air transport, including DH L's ending cooperation with Iran.
4-11. Problems connected with paying Iran's membership fee to the
International Civil Aviation Organization due to the imposed
banking restrictions following the re-imposition of sanctions, which,
in turn has weakened Iran's position in the mentioned organization.
Page 3of 5
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return flights, all of which have caused the number of passengers
and or cargo to drop considerably.
4-6. The number of ilights, in particular the ones at level-2 and level-3
airports in Iran, has decreased. Evidence to this is the 14 percent fall
in the number of landings and takeoffs at domestic airports during
the eleven-month period i.e. March 2018- February 2019, compared
to the similar period: March 2017 to February 20 18.
4-7. Following the JCPOA, Iranian airlines began to purchase aircraft
from large aircraft manufacturing companies to renew their fleet, but
the signed contracts were canceled by foreign companies once the
U.S. re-imposed the sanctions, causing Iranian airlines to suffer
heavy losses.
4-8. Restrictions on sales and barter systems, such as lack of access to
IATA clearing house for financial bartering of Iranian airline
companies with foreign airline companies which are members of
IATA.
4-9. Problems connected with using reservation systems, including the
restrictions created by SITA company for Mahan and Meraj airline
companies.
4-10. Problems connected with access to services and requirements for
cargo air transport, including DHL's ending cooperation with Iran.
4-11. Problems connected with paying Iran's membership fee to the
International Civil Aviation Organization due to the imposed
banking restrictions following the re-imposition of sanctions, which,
in turn has weakened Iran's position in the mentioned organization.
Page 3of 5

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4-12. Withdrawal of foreign airliners from the Iranian air passenger
4-12. Withdrawal of foreign airliners from the Iranian air passenger
market including major international airlines companies, such as
KLM, Air France,; British Airways, Air Astana, Germania and
Alitalia limits the offer for Iranian population wishing to travel
market including major international airlines companies, such as
KLM, Air France; British Airways, Air Astana, Germania and
Alitalia limits the offer for Iranian population wishing to travel
abroad or for foreigners wishing to come to Iran, and also restricted
the offer in terms of point to point flights, as Iranian airlines are not
in capacity to take over all the flight routes previously operated by
abroad or for foreigners wishing to come to lran, and also restricted
the offer in terms of point to point flights, as Iranian airlines are not
in capacity to take over all the flight routes previously operated by
foreign airliners. Annexed to this Witness Statement is the table
foreign airliners. Annexed to this Witness Statement is the table
providing some statistical data relevant to the list of foreign
companies which have reduced or stopped their flight operations in
Iran."
providing some statistical data
relevant to the
list of foreign
companies which have reduced or stopped their flight operations in
Iran."
4-13. Restrictions imposed on financial transactions of Iranian companies
and or blocking their bank accounts.
4-13. Restrictions imposed on financial transactions of Iranian companies
and or blocking their bank accounts.
4-14. By May 8, 2018, Iran's air passenger transportation had been
experiencing a growth of 10 % per year, while after the decision of
the United States to re-impose the sanctions, statistics now show a
decrease of 13 %.
4-14. By May 8, 2018, Iran's air passenger transportation had been
experiencing a growth of l 0% per year, while after the decision of
the United States to re-impose the sanctions, statistics now show a
decrease of 13 %.
4-15. More delays, lower operational capability and reliability of Iranian
4-15. More delays, lower operational capability and reliability of Iranian
airlines have caused a sharp decline
airlines have caused a sharp decline in Iranian passengers'
in Iranian passengers'
satisfaction level.
satisfaction level.
5. In light of the spirit of the Chicago convention, in particular, the articles
5. ln light of the spirit of the Chicago convention, in particular, the articles
stated in the introduction and articles 4 and 44, all the contracting states are
obliged to respect all nations' right to access safe, regular, efficient and
economical air transport and refrain from
stated in the introduction and articles 4 and 44, all the contracting states are
obliged to respect all nations' right to access safe, regular, efficient and
economical air transport and refrain from
imposing any restriction on
imposing any restriction on
nations' access to air transport which would lead to immediate and
irreparable consequences. However, the re-imposition of U.S sanctions has
deprived Iranian people of such equal and inalienable rights, which is itself
a blatant violation of the Chicago Convention.
nations' access to air transport which would lead to immediate and
irreparable consequences. However, the re-imposition of U.S sanctions has
deprived Iranian people of such equal and inalienable rights, which is itself
a blatant violation of the Chicago Convention.
6. In our capacity as the Iranian civil aviation authority, we do all we can to
maintain the safety of the air transportation taking place within the Iranian
6. In our capacity as the Iranian civil aviation authority, we do all we can to
maintain the safety of the air transportation taking place within the Iranian
airspace or with the aircraft listed on the Iranian aviation registry.
However, due to the re-imposition of the U.S. sanctions, maintaining the
safety has become very difficult, very complicated and very cxpensive for
our administration and for Iranian airlines companies. For instance, when
airspace or with the aircraft listed on the Iranian aviation registry.
However, due to the re-imposition of the U.S. sanctions, maintaining the
safety has become very difficult, very complicated and very expensive for
our administration and for Iranian airlines companies. For instance, when
we receive an airworthiness directive f
- 256 -
r
we receive an airworthiness directive f
om an aircraft manufacturer
Page 4 of s
r
om an aircraft manufacturer
Page4of 5

.·-seer'­
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Civil aviation Or gar»ration
Civil aviation Orgar»ration
regarding a specific type of aircraft, and we find that Iranian airlines do not
have access to the parts, tools or services necessary to ensure its
implementation on their fleet, the Civil Aviation Organization oflran has
regarding a specific type of aircraft, and we find that Iranian airlines do not
have access to the parts, tools or services necessary to ensure its
implementation on their fleet, the Civil Aviation Organization of Iran has
to initiate a very expensive process in order to determine the issue that was
to be addressed by this directive and then design and engineer an
alternative means for Iranian airline companies to address the issue, so that
we may certify the airworthiness. And in some cases, we only receive
information about the issuance of new airworthiness directives being
issued from aircraft manufacturers to modify a certain type of aircraft but
cannot get access to the service bulletins and the modification kits and
to initiate a very expensive process in order to determine the issue that was
to be addressed by this directive and then design and engineer an
alternative means for Iranian airline companies to address the issue, so that
we may certify the airworthiness. And in some cases, we only receive
information about the issuance of new airworthiness directives being
issued from aircraft manufacturers to modify a certain type of aircraft but
cannot get access to the service bulletins and the modification kits and
therefore cannot even implement the requested modifications. In such case,
the Civil Aviation Organization of Iran is sometimes left with no option
but to limit the scope of operations of the relevant type of aircraft.
therefore cannot even implement the requested modifications. In such case,
the Civil Aviation Organization of Iran is sometimes left with no option
but to limit the scope of operations of the relevant type of aircraft.
7. Considering the above-mentioned issues, the U.S. sanctions are directly
impeding the Civil Aviation Organization of Iran to guarantee and ensure
the safety of the lives of passengers, crews and other customers of Iranian
airlines. Finally, it should be borne in mind that the issues stated above are
simply the initial impacts of the U.S. measures and their full effect has yet
7. Considering the above-mentioned issues, the U.S. sanctions are directly
impeding the Civil Aviation Organization of Iran to guarantee and ensure
the safety of the lives of passengers, crews and other customers of Iranian
airlines. Finally, it should be borne in mind that the issues stated above are
simply the initial impacts of the U.S. measures and their full effect has yet
to become clear. Therefore, we will provide a more comprehensive report
to become clear. Therefore, we will provide a more comprehensive report
in due course.
in due course.
Ai Abed»ade )
Ali AbedzadeK)
Vice Minister ofkoads and Urban Development and
President of Ci
il Aviation Organization of Islamic Republic of Iran
- 257 -
v
Vice Minister'ofkoads and Urban Development and
President of Gil Aviation Organization of Islamic Republic of Iran
/v
­
Page 5 of 5
Page 5 of 5

·.1
- 258 -
�
·.1
.·
tr17313
lran Aseman Airlines
ref: -R/JCPOA/IAA/180806
Mehrabad International Airport
PO Box No. 13145-1476
Tehran
Islamic Republic of Iran
For The attention of Mr. Gorji
impact of US withdrawal from Joint Comprehensive Plan of Action.
----------
6th August 2018
Dear Mr. Gorjj,
As yau are aware, on 20 July 2015,the UN Security Council passed resolution 2231 endorsing the
Joint Comprehensive Plan of Action (JCPOA), Subsequently, the JCPOA came into force in the US
. and the EU on 18 October 2015. However, on the 8th of Mey 2018, the United States announced 'ts
withdrawal from the JCPOA and simultaneously instructed a ninety (90) day "wind-down" period for
all commercial aviation activity with this period ending on August 6", 2018.
Since the May 8" announcement, olls-Royce has been investigating what this policy change means
for us and assessing how it will impact our business relationshlp with ran Aseman Airlines.
Unfortunately, we have concluded that our ability to support Iran Aseman's operation of its Tay­
powered Fokker alrcraft will be directly impacted.
In short, with effect from 6 August 2018, we will
cease lo transact any business with Iran Aseman Airlines and will not provide any ongoing technical
support. It remains the responsibility of Iran Aseman Airlines to ensure that it operates and maintains
its Fokker aircraft and its TAY engines in accordance with all applicable requirements.
Since I am fully aware of your recent requests (i) to purchase spare parts in support ol your TAY
powered Fokker aircraft and (ii) that Rolls-Royce should refund the remaining amount of
GBP180,000.00 that it received in respect of previous activity under Contract G2578 (the "Deposit")
I want to take a moment to specifically address those two points.
'
(i)
purchase of spare parts; The "wind-down" period regulations prevent us from contracting
any new business and the delivery of spare parts for iran Aseman Airlines' TAY powered
Fokker aircraft would be subject to this restriction. We therefore cannot proceed to
accept or deliver any spare parts orders.
(i)
Deposit; our intent was to pay Iran Aseman an amount equal to the Deposit prior to Aug
6"2018; however, we have established that we have no means of doing so as we no
longer have a bank that will carry out a funds transfer nor can we exchange the value tor
any alternative goods, such as spare parts, as this would be construed as new business
and therefore in violation cf the "wind-down" period regulations. Therefore, to the extent
we are legally permitted to do so, we wi'! continue to hold tho Deposit.
�
.·
(Ex7313
lran Aseman Airlines
ref: R-R/JCPOA/IAA/'180806
Mehrabad International Airport
PO Box No. 13145-1476
Tehran
Islamic Republic of Iran
For The attention of Mr. Gorji
impact of US withdrawal from Joint Comprehensive Plan of Action.
----------
6th August 2018
Dear Mr. Gorji,
As yau are aware, on 20 July 2015,the UN Security Council passed resolution 2231 endorsing the
Joint Comprehensive Plan of Action (CPOA"), Subsequently, the JCPOA came into force in the US
. and the EU on 18 October 2015. However, on the 8th of May 2018, the United States announced 'ts
withdrawal from the JCPOA and simultaneously instructed a ninety (90) day "wind-down" period for
all commercial aviation activity with this period ending on August 6", 2018.
Since the May 8" announcement, olls-Royce has been investigating what this policy change means
for us and assessing how it will impact our business relationshlp with ran Aseman Airlines.
Unfortunately, we have concluded that our ability to support Iran Aseman's operation of its Tay­
powered Fokker alrcraft will be directly impacted.
In short, with effect from 6 August 2018, we will
cease lo transact any business with Iran Aseman Airlines and will not provide any ongoing technical
support. It remains the responsibility of Iran Aseman Airlines to ensure that it operates and maintains
its Fokker aircraft and its TAY engines in accordance with all applicable requirements.
Since I am fully aware of your recent requests (i) to purchase spare parts in support ol your TAY
powered Fokker aircraft and (ii) that Rolls-Royce should refund the remaining amount of
GBP180,000.00 that it received in respect of previous activity under Contract G2578 (the "Deposit")
I want to take a moment to specifically address those two points.
'
(l)
purchase of spare parts:; The "wind-down" period regulations prevent us from contracting
any new business and the delivery of spare parts for iran Aseman Airlines' TAY powered
Fokker aircraft would be subject to this restriction. We therefore cannot proceed to
accept or deliver any spare parts orders.
(i)
Deposit; our intent was to pay Iran Aseman an amount equal to the Deposit prior to Aug
6"2016; however, we have established that we have no means of doing so as we no
longer have a bank that will carry out a funds transfer nor can we exchange the value tor
any alternative goods, such as spare parts, as this would be construed as new business
and therefore in violation cf the "wind-down" period regulations. Therefore, to the extent
we are legally permitted to do so, we wi'! continue to hold tho Deposit.

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- 259 -

-·
--·--- -- --------------�
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o?'
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Islamic Republic of Iran
Islamic Republic of Iran
CivlI Aviation Organizatlon
CivlI Aviation Organizatlon
List of foreign companies which have reduced or stopped their flight operations in
Iran
List of foreign companies which have reduced or stopped their flight operations in
Iran
Company
The number of The Date of Stopping or Further Details
Company The number of The Date of Stopping or Further Details
Flights per Week:
Flights per Week:
Reduction of Flight
Reduction of Flight
Summer
Summer
Operations
Operations
L KLM
3
September 24, 2018
1 KLM
3
September 24, 2018
2 Air France
2 Air France
3
3
September 24. 2018
September 24. 2018
3 British
s
3 British
September 24, 2018
s
September 24, 2018
Airways
Airways
4 Air Astana
4 Air Astana
3
3
October 1, 2018
October 1, 2018
Stopped operations
Stopped operations
on August 4. 2018
on August 4. 2018
s Ge rmania
3
February, 2019
s Germania
3
February, 2019
6 Alitalia
7
December 31, 2018
6 Alitalia
7
December 31, 2018

- 260 -

Annex 255
Witness statement of Mr M. Mahini, Director General of Legal Department of Iran
Air, 30 April 2019

- 261 -

- 262 -

t
t
OUR REF.
OUR REF.
10401/HKH
€
10401/HKH
5
lranAir
YOUR REF.
YOUR REF.
DATE
"
lran Air
2019/04/30
The Alrtine of the
Islamic Republic of iran
DATE
2019/04/30
The Alrtine of the
Islamic Republic of iran
Witness Statement
Witness Statement
I, Majid Mahini, acting as Director General of Legal Department of lranAir, the Airline of the
Islamic Republic of Iran, with registered office at Mehrabad Airport, Tehran, Iran ,having
occupied the aforesaid position since May 2016 and managing the legal and contractual
affairs of lranAir, testify that I have personal and direct knowledge of the facts hereinafter
stated except where it is indicated that matters are based on information or belief, in which
case I believe the relevant matters to be true:
I, Majid Mahini, acting as Director General of Legal Department of lranAir, the Airline of the
Islamic Republic of Iran, with registered office at Mehrabad Airport, Tehran, ran ,having
occupied the aforesaid position since May 2016 and managing the legal and contractual
affairs of lranAir, testify that I have personal and direct knowledge of the facts hereinafter
stated except where it is indicated that matters are based on information or belief, in which
case I believe the relevant matters to be true:
1.
IranAir as a flag carrier is the 1 airline of Iran in terms of fleet and operates both
domestic and international routes. About 22 to 25 percent of its flights take place to
and from foreign destinations, with flights to most important cities in Europe, the
Middle East and the Indian subcontinent.
1.
IranAir as a flag carrier is the 1 airline of Iran in terms of fleet and operates both
domestic and international routes. About 22 to 25 percent of its flights take place to
and from foreign destinations, with flights to most important cities in Europe, the
Middle East and the Indian subcontinent.
2.
2.
IranAir has a fleet of around 53 aircraft, but, due to the maintenance and
airworthiness issues resulting notably from the US sanctions, only 20 are presently in
operation, 19 in passenger configuration and 1 in cargo configuration.
lranAir has a fleet of around 53 aircraft, but, due to the maintenance and
airworthiness issues resulting notably from the US sanctions, only 20 are presently in
operation, 19 in passenger configuration and 1 in cargo configuration.
3.
3.
IranAir has a payroll of around 22,000 persons, 10,000 as actual employees and
12,000 as retired employees.
IranAir has a payroll of around 22,000 persons, 10,000 as actual employees and
12,000 as retired employees.
4. After the implementation of the JCPOA, lranAir could manage to negotiate sale and
purchase agreements with the main international aircraft manufacturers. During this
period lranAir signed:
4. After the implementation of the JCPOA, IranAir could manage to negotiate sale and
purchase agreements with the main international aircraft manufacturers. During this
period IranAir signed:
i. 2 contractual documents with Airbus for the purchase of 100 new aircraft
(the OFAC issued 2 specific licences in relation to this transaction);
i. 2 contractual documents with Airbus for the purchase of 100 new aircraft
(the OFAC issued 2 specific licences in relation to this transaction);
ii. 4 contractual documents with Boeing for the purchase of 80 new aircraft (the
OFAC issued 1 specific license in relation to this transaction); and
ii. 4 contractual documents with Boeing for the purchase of 80 new aircraft (the
OFAC issued 1 specific license in relation to this transaction); and
iii. 2 contractual documents with ATR, for the purchase of 20 aircraft with an
option for 20 more (the OFAC issued 2 specific licenses in relation to this
transaction, including one issued in July 2018, to allow for the delivery before
August 6", 2018 of 5 of the purchased aircraft).
iii. 2 contractual documents with ATR, for the purchase of 20 aircraft with an
option for 20 more (the OFAC issued 2 specific licenses in relation to this
transaction, including one issued in July 2018, to allow for the delivery before
August 6", 2018 of 5 of the purchased aircraft).
::,
::,
Save for the 20 additional ATR aircraft, all these agreements were firm sale and
purchase agreements .
-,
Save for the 20 additional ATR aircraft, all these agreements were firm sale and
purchase agreements .
....
or
­
....
or
3
3
)
)
The objective of the acquisition program was twofold for lranAir:
5 .
5.
The objective of the acquisition program was twofold for lranAir:
.,
'"'
7
7
1
1
IRAN AIR H.Q MEHRABAD AIRPORT TEHRAN - IRAN
IRAN AIR H.Q. MEHRABAD AIRPORT TEHRAN - IRAN
':i
':i
3
3
P.O. BOX:13185-775
P.0. BOX:13185-775
Page 1 out of 4
Page 1 out of 4
- 263 -

--· ·- ·--··
·-· ----------------.
r
r
OUR REF.
OUR REF.
YOUR REF.
-�
DATE
- 264 -
·
�
iranAir
YOUR REF.
lranAir
The Airtine of the
Islamic Republic of Iran
DATE
The Airtine of the
Islamic Republic of Iran
i. To resume the flight routes that had been suspended due to lack of available
aircraft and increase the frequency of the flights to each existing destination;
and
i. To resume the flight routes that had been suspended due to lack of available
aircraft and increase the frequency of the flights to each existing destination;
and
ii. To expand the network served by lranAir, according to lranAir's then business
model.
ii. To expand the network served by lranAir, according to lranAir's then business
model.
6. The acquisition program also induced a necessity for lranAir to increase the capacity
of its Maintenance Department in order to meet with the expected requirements of
the future fleet.
lranAir invested to this end, to increase its staff dedicated to
maintenance services and acquire the additional infrastructures and resources to
sustain a fleet of more than 250 aircraft. Actually, the agreements executed with
Airbus for the purchase of the new aircraft included cooperation with IranAir to
increase the capacity of its Maintenance Department. lranAir also established
business relationships with:
6. The acquisition program also induced a necessity for lranAir to increase the capacity
of its Maintenance Department in order to meet with the expected requirements of
the future fleet. lranAir invested to this end, to increase its staff dedicated to
maintenance services and acquire the additional infrastructures and resources to
sustain a fleet of more than 250 aircraft. Actually, the agreements executed with
Airbus for the purchase of the new aircraft included cooperation with IranAir to
increase the capacity of its Maintenance Department. lranAir also established
business relationships with:
i. Major international maintenance operators, such as Lufthansa Technik or
MTU which operate an engine shop, both for maintenance services in their
facilities, as well as increasing lranAir's own capacities;
i. Major international maintenance operators, such as Lufthansa Technik or
MTU which operate an engine shop, both for maintenance services in their
facilities, as well as increasing lranAir's own capacities;
ii. Major parts and components suppliers, such as Panasonic, for equipment
needed for maintenance purposes;
ii. Major parts and components suppliers, such as Panasonic, for equipment
needed for maintenance purposes;
iii. And training suppliers, such as vendors of aircraft simulators, to ensure the
training of its pilots on the new aircraft that were to be delivered to lranAir.
iii. And training suppliers, such as vendors of aircraft simulators, to ensure the
training of its pilots on the new aircraft that were to be delivered to lranAir.
7. All these investments represented a program of Approximately 16 Billion Euros for
different types of airplanes including Airbus, Boeing and ATR.
7. All these investments represented a program of Approximately 16 Billion Euros for
different types of airplanes including Airbus, Boeing and ATR.
h
I
8. As a result of the re-imposition of the US sanctions, all the developments and
investments made after the implementation of the JCPOA came to an abrupt halt. All
the licenses issued by the OFAC in relation to the purchases of lranAir after the
JCPOA, were revoked by this U.S. administration and secondary sanctions were re­
imposed or later introduced. The suppliers who were either U.S. or U.S.-controlled
companies or which products included more than 10% of U.S. contents - Airbus or
Boeing - terminated or suspended their agreements with lranAir immediately after
the 8 May 2018. For the other suppliers and based on the re-imposition of secondary
sanctions, such as Rolls Royce, termination or suspension of the agreements took
place, at the latest on 4" of November 2018, when IranAir and IranAir's aircraft were
listed on the OFAC's SDN
h
I
a.ll.d->
8. As a result of the re-imposition of the US sanctions, all the developments and
investments made after the implementation of the JCPOA came to an abrupt halt. All
the licenses issued by the OFAC in relation to the purchases of lranAir after the
JCPOA, were revoked by this U.S. administration and secondary sanctions were re­
imposed or later introduced. The suppliers who were either U.S. or U.S.-controlled
companies or which products included more than 10 % of U.S. contents - Airbus or
Boeing - terminated or suspended their agreements with lranAir immediately after
the 8 May 2018. For the other suppliers and based on the re-imposition of secondary
sanctions, such as Rolls Royce, termination or suspension of the agreements took
place, at the latest on 4" of November 2018, when IranAir and IranAir's aircraft were
listed on the OFAC's SDN list.
/'
}J..JAh:
IRAN AIR H.Q. MEHRABAD AIRPORT TEHRAN-IRAN k"
IRAN AIR H.Q MEHRABAD AIRPORT TEHRAN -IRAN k"
P.0. BOX: 13185-775
Page 2 out of 4
P.O. BOX: 13185-775
Page 2 out of 4
�--------------------------------·
·-
�--------------------------------·
·-

...
OUR REF.
YOUR REF.
�
�
DATE

- 265 -
·
' OUR REF.
YOUR REF.
lranAir
lranAir
DATE
The Alrtine of the
Islamic Republic of ran
The Alrline ot the
Islamic Republic of lran
9. Consequences were dire for the acquisition program of lranAir:
i.
9. Consequences were dire for the acquisition program of lranAir:
i.
lranAir has only received 3 new Airbus aircraft and 13 new ATR aircraft out of
the 200 aircraft for which firm purchases had been concluded. After the 8
May 2018, all the licenses issued by the OFAC for the delivery of the aircraft
purchased by lranAir before that date, and notably those not yet delivered,
were terminated. And although ATR and Airbus have informed lranAir that
they were trying to obtain new licenses from the OFAC in order to deliver the
remaining aircraft, no information has been provided as to a positive return
from this US administration;
lranAir has only received 3 new Airbus aircraft and 13 new ATR aircraft out of
the 200 aircraft for which firm purchases had been concluded. After the 8
May 2018, all the licenses issued by the OFAC for the delivery of the aircraft
purchased by lranAir before that date, and notably those not yet delivered,
were terminated. And although ATR and Airbus have informed lranAir that
they were trying to obtain new licenses from the OFAC in order to deliver the
remaining aircraft, no information has been provided as to a positive return
from this US administration;
ii. As a result of revocation of OFAC licenses issued with regard to such
agreements, provision of support services and spare parts by Airbus and ATR
to the aircraft delivered under valid OFAC licenses has been suspended:
ii. As a result of revocation of OFAC licenses issued with regard to such
agreements, provision of support services and spare parts by Airbus and ATR
to the aircraft delivered under valid OFAC licenses has been suspended:
iii. Representatives of foreign manufacturers, some of which had been present
in Iran for more 30 years, left after the 8 May 2018:
iii. Representatives of foreign manufacturers, some of which had been present
in Iran for more 30 years, left after the 8 May 2018:
iv. None of the suppliers of lranAir, such as Honeywell, Raytheon, THALES,
Zodiac Aerospace and main engine manufacturers that had been applying for
licenses from the OFAC before the 8 May 2018, received an answer:
iv. None of the suppliers of lranAir, such as Honeywell, Raytheon, THALES,
Zodiac Aerospace and main engine manufacturers that had been applying for
licenses from the OFAC before the 8 May 2018, received an answer:
v. And even suppliers or vendors that have indicated to lranAir that they had
applied to Of AC for specific licenses justified to safety issues, have received
no answers from this U.S. administration:
v. And even suppliers or vendors that have indicated to lranAir that they had
applied to OFAC for specific licenses justified to safety issues, have received
no answers from this U.S. administration:
10. But the re-imposition of the US sanctions after the 8 May 2018 also had adverse
consequences on the operations of lranAir:
10. But the re-imposition of the US sanctions after the 8 May 2018 also had adverse
consequences on the operations of lranAir:
i.
i.
IranAir can no longer receive operational information regarding the aircraft
of its fleets from the manufacturers which has been already delivered under
a valid OFAC license
IranAir can no longer receive operational information regarding the aircraft
of its fleets from the manufacturers which has been already delivered under
a valid OFAC license
ii. ranAir has had issues to obtain refueling in some of its main destinations
abroad as well as maintenance services
ii.
lranAir has had issues to obtain refueling in some of its main destinations
abroad as well as maintenance services
These issues resulted in additional costs for IranAir's operations {for instance, for
carrying additional fuel to be able to fly the return flight, without any refueling, or for
carrying technicians to perform usual maintenance check abroad), restriction on
possible destinations for lranAir and additional constraints on the safety of lranAir's
flights (for instance, when an aircraft is grounded for a technical reason abroad and
spare parts, maintenance equipment and technicians have to be flown from Iran).
/ ••
These issues resulted in additional costs for IranAir's operations {for instance, for
carrying additional fuel to be able to fly the return flight, without any refueling, or for
carrying technicians to perform usual maintenance check abroad), restriction on
possible destinations for lranAir and additional constraints on the safety of lranAir's
flights (for instance, when an aircraft is grounded for a technical reason abroad and
spare parts, maintenance equipment and technicians have to be flown from Iran).
/ ••
�
�
!RAN AJR H.Q. MEHRABAD AIRPORT TEHRAN - JRAN
IRAN AIR H.Q. MEHRABAD AIRPORT TEHRAN - IRAN
PO. BOX:I3185-775
PO. BOX:I3185-775
Page 3 out of 4
Page 3 out of 4

«
«
OUR REF.
YOUR REF.
DATE
OUR REF.
YOUR REF.
wan.A»$'
wan.Ai,3$
DATE
The Airline of the
The Airline of the
stamic Republic ot lran
stamic Republic ot lran
11. In addition, even with its foreign counterparts that have accepted to pursue their
relationships, lranAir is experiencing serious difficulties because of problems related
to payments given the restriction on the Iranian banking system.
11. In addition, even with its foreign counterparts that have accepted to pursue their
relationships, lranAir is experiencing serious difficulties because of problems related
to payments given the restriction on the Iranian banking system.
12. As a result of the above-mentioned consequences, not only lranAir has not been able
to implement its development plan, but the operation of its existing fleet is becoming
more expensive and complicated, with less aircraft in serviceable conditions and less
sources for parts and maintenance services.
12. As a result of the above-mentioned consequences, not only lranAir has not been able
to implement its development plan, but the operation of its existing fleet is becoming
more expensive and complicated, with less aircraft in serviceable conditions and less
sources for parts and maintenance services.
28 April 2019
d-
Majid Mahini
c-
28 April 2019
de
Majid Mahini
M.'
Director General, Legal
Director General, Legal
lranAir, the Airline of the Isl
epublic of Ir
lranAir, the Airline of the Isl
epublic of Ir
AN A!
AN A!
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Lr Or
IRAN AIR H.Q. MEHRABAD AIRPORT TEHRAN - IRAN
IRAN AIR H.Q. MEHRABAD AIRPORT TEHRAN - IRAN
P.O BOX:13185-775
P.O BOX: 13185-775
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Annex 256
ICAO, “Continuity of the US trade embargo on the civil aviation of the Islamic
Republic of Iran and the safety deficiencies arising out of it”, Information Paper,
15 March 2006

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DGCA/06-IP/31
DGCA/06-JP/3 I
International Civil Aviation Organization
15/3/06
International Civil Aviation Organization
15/3/06
INFORMATION PAPER
INFORMATION PAPER
¢,
+
%.,
DIRECTORS GENERAL OF CIVIL AVIATION CONFERENCE
ON A GLOBAL STRATEGY FOR AVIATION SAFETY
DIRECTORS GENERAL OF CIVIL AVIATION CONFERENCE
ON A GLOBAL STRATEGY FOR AVIATION SAFETY
Montr~al, 20 to 22 March 2006
Montr~al, 20 to 22 March 2006
Theme 2: Improving aviation safety
Topic 2.3: Unified strategy to resolve Safety-related deficiencies
Theme 2: Improving aviation safety
Topic 2.3: Unified strategy to resolve Safety-related deficiencies
CONTINUITY OF THE UNITED STATES TRADE EMBARGO ON
CONTINUITY OF THE UNITED STATES TRADE EMBARGO ON
THE CIVIL AVIATION OF THE ISLAMIC REPUBLIC OF IRAN AND
THE SAFETY DEFICIENCIES ARISING OUT OF IT
THE CIVIL AVIATION OF THE ISLAMIC REPUBLIC OF IRAN AND
THE SAFETY DEFICIENCIES ARISING OUT OF IT
(Presented by the Islamic Republic of Iran)
(Presented by the Islamic Republic of Iran)
SUMMARY
SUMMARY
This paper presents the historical background of the imposed embargo on (sanctions against) the
Islamic Republic of Iran (LR.of Iran) Civil Aviation before the ICAO. It provides the proceedings of
the issue in Economic Commission (EC) of the Assembly 35, a few Hearings before the U.S. Senate
Foreign Relations Committee as reasoning for the foundation of ICAO, some of the minutes of the
founding body of ICAO in the United States, and the applicable provisions of Chicago Convention
to this issue. The paper further demonstrates the applicable Iranian Sanctions Regulations and
highlights the paramount importance of ICAO for the safety of civil aviation. They are followed by
an update concerning the measures, which the Assembly 35 took, based on A35- WP/297, "Adverse
Effects of U.S. Trade Embargo on Civil Aviation Activities of the l.R. of Iran", and then the views
and proposals of EC expressed in A35-WP/31 I are represented. Furthermore, the paper gives an
account of the independent technical report on civil aviation of the l.R.oflran.
This paper presents the historical background of the imposed embargo on (sanctions against) the
Islamic Republic of Iran (1.R.oflran) Civil Aviation before the ICAO. It provides the proceedings of
the issue in Economic Commission (EC) of the Assembly 35, a few Hearings before the U.S. Senate
Foreign Relations Committee as reasoning for the foundation of !CAO, some of the minutes of the
founding body of ICAO in the United States, and the applicable provisions of Chicago Convention
to this issue. The paper further demonstrates the applicable Iranian Sanctions Regulations and
highlights the paramount importance of !CAO for the safety of civil aviation. They are followed by
an update concerning the measures, which the Assembly 35 took, based on A35- WP/297, "Adverse
Effects of U.S. Trade Embargo on Civil Aviation Activities of the I.R. of Iran", and then the views
and proposals of EC expressed in A35-WP/3 I I are represented. Furthermore, the paper gives an
account of the independent technical report on civil aviation of the I.R.oflran.
The findings of the audit report July 17, 2005-TC4/3.33-13 as 'The Report on Safety: The Effects of
Economic Sanctions on the l.R. of Iran Civil Aviation", May 9, 2005, is briefly presented. In the
light of discussions, the paper concludes that the spare parts and services essential to civil aviation
safety have been denied, and such a denial is an obvious non-conformity to the letter and spirit of the
Chicago Convention, which is actually used as an instrument for foreign policy.
The findings of the audit report July 17, 2005-TC4/3.33-13 as "The Report on Safety: The Effects of
Economic Sanctions on the I.R. of Iran Civil Aviation", May 9, 2005, is briefly presented. In the
light of discussions, the paper concludes that the spare parts and services essential to civil aviation
safety have been denied, and such a denial is an obvious non-conformity to the letter and spirit of the
Chicago Convention, which is actually used as an instrument for foreign policy.
Action bv the Conference is in paragraph 5.
Action bv the Conference is in paragraph 5.
REFERENCES
REFERENCES
Doc7300/8
A35-WP/297
A35-WP/31 I-EC/48
ICAO Mission Report on the audit of the Civil Aviation and Air Carriers of the l.R. of Iran, July 17,
2005,TC4/3.33-13
Doc7300/8
A35-WP/297
A35-WP/31 I-EC/48
!CAO Mission Report on the audit of the Civil Aviation and Air Carriers of the I.R. of Iran, July 17,
2005,TC4/3.33-13
(6 pages)
DGCA.06.IP.031.2.en.doc
(6 pages)
DGCA.06.IP.031.2.en.doc
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DGCA/06-WP/3 l
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DGCA/06-WP/3 l
- 2­
1.
1.
INTRODUCTION
INTRODUCTION
1.1
HISTORICAL BACKGROUND OF THE ISSUE BEFORE THE ICAO
1.1
HISTORICAL BACKGROUND OF THE ISSUE BEFORE THE ICAO
1.2
1.2
In Assembly 35, the I.R. of Iran provided the Assembly with A35- WP/297, "Adverse
In Assembly 35, the I.R. of Iran provided the Assembly with A35- WP/297, "Adverse
Effects of the U.S. Trade Embargo on Civil Aviation Activities of the I.R. of Iran." The working paper
demonstrated that the United States imposed trade embargo on the I.R. oflran civil aviation, is contrary to
the aims and objectives of Article 44 of the Chicago Convention for which the United States of America
is not only a party but is also a founder. Moreover, the paper stressed that the civil aviation safety of the
Contracting States, which are subject to embargo, has been and will be at stake.
Effects of the U.S. Trade Embargo on Civil Aviation Activities of the I.R. of Iran." The working paper
demonstrated that the United States imposed trade embargo on the I.R. of Iran civil aviation, is contrary to
the aims and objectives of Article 44 of the Chicago Convention for which the United States of America
is not only a party but is also a founder. Moreover, the paper stressed that the civil aviation safety of the
Contracting States, which are subject to embargo, has been and will be at stake.
1.3
1.3
The I.R. of Iran's paper drew the attention of the Assembly 35 to the imposed embargo
The I.R. of Iran's paper drew the attention of the Assembly 35 to the imposed embargo
and requested the Assembly to consider the issue thoroughly, and then take any necessary measures in
order that the ground is prepared for the lifting of embargo.
and requested the Assembly to consider the issue thoroughly, and then take any necessary measures in
order that the ground is prepared for the lifting of embargo.
1.4
1.4
The draft report, A35-WP/311, EC/48 issued by ICAO on October 4, 2004, includes the
The draft report, A35-WP/31 l, EC/48 issued by ICAO on October 4, 2004, includes the
arguments and the consideration of the EC, under Agenda Item 27:30, addressed the U.S. embargo, as
may affect aviation safety, is a complex, delicate and sensitive issue and the EC could not resolve it. It
was therefore decided that the views expressed to be brought to the attention of the President of the
Council to follow up the issue through his "good offices".
arguments and the consideration of the EC, under Agenda Item 27:30, addressed the U.S. embargo, as
may affect aviation safety, is a complex, delicate and sensitive issue and the EC could not resolve it. It
was therefore decided that the views expressed to be brought to the attention of the President of the
Council to follow up the issue through his "good offices".
1.5
1.5
According to the report, para. 27:32, the I.R. oflran's requests and views were discussed
According to the report, para. 27:32, the I.R. oflran's requests and views were discussed
and a number of delegations stated their support for the positions taken by Cuba and Iran, and for actions
proposed in their papers. In their view, the trade embargo was considered to have an adverse safety and
security impact on the participation of these States in international air transport. It also affected their
ability to fulfill their safety obligations under the Chicago Convention. While the issue was one with
political origins, it was considered by the sponsors of the two papers [Cuba and Iran] to be essentially a
safety and technical issue and, therefore, one within the ambit of ICAO as a multilateral technical
agency..
and a number of delegations stated their support for the positions taken by Cuba and Iran, and for actions
proposed in their papers. In their view, the trade embargo was considered to have an adverse safety and
security impact on the participation of these States in international air transport. It also affected their
ability to fulfill their safety obligations under the Chicago Convention. While the issue was one with
political origins, it was considered by the sponsors of the two papers [Cuba and Iran] to be essentially a
safety and technical issue and, therefore, one within the ambit of ICAO as a multilateral technical
agency..
1.6
1.6
In response to the positions taken, ICAO assisted to identify technical experts to assess
In response to the positions taken, ICAO assisted to identify technical experts to assess
independently the charges of the I.R. oflran that the U.S. embargo was adversely affecting the safety of
its civil aviation.
independently the charges of the I.R. oflran that the U.S. embargo was adversely affecting the safety of
its civil aviation.
1.7
1.7
Following the assessment of ICAO, a report was issued on May 9, 2005 stating that, in
Following the assessment of ICAO, a report was issued on May 9, 2005 stating that, in
fact, the U.S. embargo on the I.R. of Iran had endangered the safety of civil aviation in Iran, and it is
contrary to the provisions and objectives of the Chicago Convention. Among other recommendations,
ICAO recommended, "the United States should recommit to the Chicago Convention." (See the Report of
the fact-finding mission to the I.R. oflran on 17 July 2005-TC4/3.33-13).
fact, the U.S. embargo on the I.R. of Iran had endangered the safety of civil aviation in Iran, and it is
contrary to the provisions and objectives of the Chicago Convention. Among other recommendations,
ICAO recommended, "the United States should recommit to the Chicago Convention." (See the Report of
the fact-finding mission to the I.R. oflran on 17 July 2005-TC4/3.33-13).
2.
2.
DISCUSSION
DISCUSSION
2.1
2.1
The Applicable Provisions of the Chicago Convention to This Issue
The Applicable Provisions of the Chicago Convention to This Issue
2.1.1
2.1.1
The United States was one of the principal architects of the Chicago Convention.
The United States was one of the principal architects of the Chicago Convention.
Secretary of State Dean Acheson, Assistant Secretary of State Adolph Berle and L. Welch Pogue,
Chairman of the Civil Aeronautics Board, were among the United States leaders in support of this Treaty.
Under this Treaty, the International Civil Aviation Organization (ICAO) was created to carry out the aims
and objectives of the Chicago Convention.
Secretary of State Dean Acheson, Assistant Secretary of State Adolph Berle and L. Welch Pogue,
Chairman of the Civil Aeronautics Board, were among the United States leaders in support of this Treaty.
Under this Treaty, the International Civil Aviation Organization (ICAO) was created to carry out the aims
and objectives of the Chicago Convention.
2.1.2
2.1.2
Said Chairman Pogue at Hearings before the U.S. Senate Foreign Relations Committee in
Said Chairman Pogue at Hearings before the U.S. Senate Foreign Relations Committee in
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1945, "In order to secure the establishment of minimum safety requirements in international operations,
international cooperation is essential. The world organization established by the proposed treaty, which is
before you, is an attempt to provide that international cooperation so absolutely essential to safety"
(Convention on International Civil Aviation [Hearings before the Committee on Foreign Relations, 79"
Cong. 183, (1945)], [Statement of Chairman L. Welch Pogue]).
1945, "In order to secure the establishment of minimum safety requirements in international operations,
international cooperation is essential. The world organization established by the proposed treaty, which is
before you, is an attempt to provide that international cooperation so absolutely essential to safety"
(Convention on International Civil Aviation [Hearings before the Committee on Foreign Relations, 79"
Cong. 183, (1945)], [Statement of Chairman L. Welch Pogue]).
2.1.3
2 .1. 3
In the Preamble to the Chicago Convention, it is recited, "...the undersigned governments
In the Preamble to the Chicago Convention, it is recited, "...the undersigned governments
having agreed on certain principles and arrangements in order that international civil aviation may be
developed in a safe and orderly manner and that international air transport services may be established on
the basis of equality of opportunity and operated soundly and economically; ...."
having agreed on certain principles and arrangements in order that international civil aviation may be
developed in a safe and orderly manner and that international air transport services may be established on
the basis of equality of opportunity and operated soundly and economically; ....
2.1.4
2.1.4
The United States, the United Kingdom and Canada proposed the Conference for the
The United States, the United Kingdom and Canada proposed the Conference for the
Member States make certain undertakings that "Each member state rejects the use of civil air transport as
an instrument of national policy in international relations .
Member States make certain undertakings that "Each member state rejects the use of civil air transport as
an instrument of national policy in international relations ... [and that] each member state shall carry out
in good faith the undertakings which it has freely accepted in this Convention" (Proceedings of the
International Civil Aviation Conference, VOL. 1, Document 358 418 [U.S. Gov't Printing Office, ed.,
1948]).
[and that] each member state shall carry out
in good faith the undertakings which it has freely accepted in this Convention" (Proceedings of the
International Civil Aviation Conference, VOL. 1, Document 358 418 [U.S. Govt Printing Office, ed.,
1948]).
2.1.5
2.1.5
The joint proposal of the United States, the United Kingdom and Canada was
The joint proposal of the United States, the United Kingdom and Canada was
incorporated in substance in Article 4 of the Chicago Convention, ratified by the United States on August
9, 1946, by Iran on April 19, 1950, and by virtually every other nation of the world.
incorporated in substance in Article 4 of the Chicago Convention, ratified by the United States on August
9, 1946, by Iran on April 19, 1950, and by virtually every other nation of the world.
2.1.6
2.1.6
Furthermore, Article 4 states, "Each contracting State agrees not to use civil aviation for
Furthermore, Article 4 states, "Each contracting State agrees not to use civil aviation for
any purpose inconsistent with the aims of this Convention."
any purpose inconsistent with the aims of this Convention."
2.1.7
2.1.7
Part II of the Chicago Convention established this body, the International Civil Aviation
Part II of the Chicago Convention established this body, the International Civil Aviation
Organization to carry out the "aims and objectives" of the Chicago Convention, as set forth in Article 44
which encompasses in brief, inter alia, the respect to the rights of Contracting Sates, avoidance of
discrimination, promotion of safety and development of all aspects of International civil aeronautics.
Organization to carry out the "aims and objectives" of the Chicago Convention, as set forth in Article 44
which encompasses in brief, inter alia, the respect to the rights of Contracting Sates, avoidance of
discrimination, promotion of safety and development of all aspects of International civil aeronautics.
3.
3.
The Applicable Iranian Sanctions Regulations Imposed by the United States
The Applicable Iranian Sanctions Regulations Imposed by the United States
2.2.1
2.2.1
The United States has imposed comprehensive sanctions against the I.R. of Iran by the
The United States has imposed comprehensive sanctions against the I.R. of Iran by the
issued Executive Orders dated March 15, 1995, and May 6, 1995. As it was recited, "these sanctions were
(and continue to be) imposed by the United States for foreign policy reasons". As indicated above, it is a
mere nonconformity to the Chicago Convention and has proved to be detrimental to the I.R. of Iran civil
aviation safety.
issued Executive Orders dated March 15, 1995, and May 6, 1995. As it was recited, "these sanctions were
(and continue to be) imposed by the United States for foreign policy reasons". As indicated above, it is a
mere nonconformity to the Chicago Convention and has proved to be detrimental to the I.R. of Iran civil
aviation safety.
2.2.2
2.2.2
The United States Iranian Sanctions Regulation reads, in brief, that the United States
The United States Iranian Sanctions Regulation reads, in brief, that the United States
manufacturers or firms cannot sell and export aircraft, engines and spare parts, CNS equipment etc... to
Iranian air carriers, companies or government agencies, whether the equipment is new or used. Nor can
firms in Europe, the Middle East and other countries worldwide re-sell (re-export) most U.S.-origin
equipment to Iranian air carriers. Firms (including airlines in Europe), which provide maintenance for
Iranian air carriers cannot provide such maintenance if it involves the installation or replacement of U.S.­
origin parts.
manufacturers or firms cannot sell and export aircraft, engines and spare parts, CNS equipment etc... to
Iranian air carriers, companies or government agencies, whether the equipment is new or used. Nor can
firms in Europe, the Middle East and other countries worldwide re-sell (re-export) most U.S.-origin
equipment to Iranian air carriers. Firms (including airlines in Europe), which provide maintenance for
Iranian air carriers cannot provide such maintenance if it involves the installation or replacement of U.S.­
origin parts.
2.2.3
2.2.3
The United States has promulgated a colorable exception for "aircraft safety", which has
The United States has promulgated a colorable exception for "aircraft safety", which has
not in fact been honored, to permit equipment, engines, parts and support to be sold to Iranian air carriers
and aviation related entities in the interest of civil aviation safety. However, the Aircraft Safety Provision
has not been effectively implemented to promote and ensure the safety of civil aviation in the I.R. of Iran.
not in fact been honored, to permit equipment, engines, parts and support to be sold to Iranian air carriers
and aviation related entities in the interest of civil aviation safety. However, the Aircraft Safety Provision
has not been effectively implemented to promote and ensure the safety of civil aviation in the I.R. of Iran.
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2.2.4
2.2.4
The Aircraft Safety Provision provides that "[s]pecific licenses may be issued on a case­
The Aircraft Safety Provision provides that [specific licenses may be issued on a case­
by-case basis for the exportation of goods, services, and technology to insure the safety of civil aviation
and safe operation of U.S.-origin commercial passenger aircraft" 31 C.ER. $ 560.528 (2005).
by-case basis for the exportation of goods, services, and technology to insure the safety of civil aviation
and safe operation of U.S.-origin commercial passenger aircraft" 31 C.FR. $ 560.528 (2005).
2.2.5
2.2.5
This construction would enable U.S.-origin aircraft parts and components to be exported
This construction would enable U.S.-origin aircraft parts and components to be exported
to Iran direct or via third party, not only for Boeing aircraft, but also for non-U.S. assembled aircraft.
to Iran direct or via third party, not only for Boeing aircraft, but also for non-U.S. assembled aircraft.
2.2.6
2.2.6
The narrow construction of the Office of Foreign Assets Control (OFAC) is that the
The narrow construction of the Office of Foreign Assets Control (OFAC) is that the
phrase "the safety of civil aviation" qualifies "the safe operation of U.S.-origin commercial passenger
aircraft" with the result that OFAC will "consider" licenses for the exportation of U.S.-origin aircraft
parts and components for use in U.S. made aircraft.
phrase "the safety of civil aviation" qualifies "the safe operation of U.S.-origin commercial passenger
aircraft" with the result that OFAC will "consider" licenses for the exportation of U.S.-origin aircraft
parts and components for use in U.S. made aircraft.
4.
4.
THE REPORT ON SAFETY: THE EFFECTS OF EMBARGO ON (SANCTIONS
AGAINST) THE ISLAMIC REPUBLIC OF IRAN CIVIL AVIATION, MAY 9, 2005
THE REPORT ON SAFETY: THE EFFECTS OF EMBARGO ON (SANCTIONS
AGAINST) THE ISLAMIC REPUBLIC OF IRAN CIVIL AVIATION, MAY 9, 2005
3.1
3 .1
In fulfilling its obligations under the Chicago Convention, ICAO sent a fact-finding
In fulfilling its obligations under the Chicago Convention, ICAO sent a fact-finding
mission to the I.R. of Iran from April 9-14, 2005 to review and audit, inter alia, the effects of the U.S.
economic sanctions against the civil aviation safety.
mission to the I.R. of Iran from April 9-14, 2005 to review and audit, inter alia, the effects of the U.S.
economic sanctions against the civil aviation safety.
3.2
3.2
In sum, the independent experts found that the U.S. embargo placed on the I.R. oflran
In sum, the independent experts found that the U.S. embargo placed on the I.R. of Iran
has adversely affected the safety of civil aviation. Some of the findings of the report dated May 9, 2005
are as follows:
has adversely affected the safety of civil aviation. Some of the findings of the report dated May 9, 2005
are as follows:
a) The United States denied export licenses to the Boeing Company to permit Boeing to modify
struts on the five Boeing 747 cargo aircraft being operated by SAHA Airlines, an Iranian airline.
The ICAO[independent experts] report stated that the airline "will have to put them back into
operation even without the struts modification, which will be detrimental to the safety of flights in
Iran and other countries to where these aircraft fly or that they over fly"( ICAO Report Overview,
a) The United States denied export licenses to the Boeing Company to permit Boeing to modify
struts on the five Boeing 747 cargo aircraft being operated by SAHA Airlines, an Iranian airline.
The ICAO[independent experts] report stated that the airline "will have to put them back into
operation even without the struts modification, which will be detrimental to the safety of flights in
Iran and other countries to where these aircraft fly or that they over fly"( ICAO Report Overview,
p. 1).
p. 1).
b) The radars for terminal approach in Tehran and Shiraz, the two largest airports in Iran, need space
parts for continued safe operation. The principal radars are Raytheon ASR/SSR, a U.S.-origin
product. "The present condition of the radars represents a substantial threat for the operations of
these two largest airports in the country" inasmuch as only one channel out of two is currently
working and the U.S. sanctions prevent the acquisition of the parts necessary to repair the radars
(ibid.).
b) The radars for terminal approach in Tehran and Shiraz, the two largest airports in Iran, need space
parts for continued safe operation. The principal radars are Raytheon ASR/SSR, a U.S.-origin
product. "The present condition of the radars represents a substantial threat for the operations of
these two largest airports in the country" inasmuch as only one channel out of two is currently
working and the U.S. sanctions prevent the acquisition of the parts necessary to repair the radars
(ibid.).
Not only are the flights oflranian airlines [air carriers] at risk because of the U.S. sanctions, but
also numerous other international airlines.. [ such as] Air France, Alitalia, Austrian Airlines,
British Mediterranean Airways (BeeMed), Emirates, Lufthansa, Malaysia[n] Airlines, Royal
Dutch Airlines, Qatar Airways [ and so]...as well.
Not only are the flights of Iranian airlines [ air carriers] at risk because of the U.S. sanctions, but
also numerous other international airlines.. [ such as] Air France, Alitalia, Austrian Airlines,
British Mediterranean Airways (BeeMed), Emirates, Lufthansa, Malaysia[n] Airlines, Royal
Dutch Airlines, Qatar Airways [ and so]...as well.
c) As the ICAO [independent experts] report shows, these safety concerns are not theoretical. ICAO
found that these economic sanctions have resulted in reduced safety of flights. "In April 2005, a
B- 707 operated by SAHA Airlines had a technical failure (broken landing gear during landing),
with the consequence that a child died and several people were injured. In view of the restrictions
on the maintenance of the aircraft... it is likely that similar unfortunate events will occur" (Ibid.).
c) As the ICAO [independent experts] report shows, these safety concerns are not theoretical. ICAO
found that these economic sanctions have resulted in reduced safety of flights. "In April 2005, a
B- 707 operated by SAHA Airlines had a technical failure (broken landing gear during landing),
with the consequence that a child died and several people were injured. In view of the restrictions
on the maintenance of the aircraft... it is likely that similar unfortunate events will occur" (Ibid.).
d) Because of the sanctions, some U.S. equipment and parts manufacturers do not provide technical
d) Because of the sanctions, some U.S. equipment and parts manufacturers do not provide technical
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support and publications, including Service Bulletins and Modification Kits, and other
instructions such as the cockpit door modification in Boeing aircraft.
support and publications, including Service Bulletins and Modification Kits, and other
instructions such as the cockpit door modification in Boeing aircraft.
e) The use of simulators operated by an American company outside the United States was barred to
Iranian pilots by the economic sanctions with the result that "all Falcon 20 training and
proficiency checks for Iranian pilots [and navigation facilities] were suspended."
e) The use of simulators operated by an American company outside the United States was barred to
Iranian pilots by the economic sanctions with the result that "all Falcon 20 training and
proficiency checks for Iranian pilots [and navigation facilities] were suspended."
f) The Civil Aviation Organization of Iran needs avionic equipment for their Falcon 20 aircraft,
which are used to calibrate landing systems. This required equipment is of American origin and
cannot be obtained because of the sanctions. These landing systems are being used by twenty­
three foreign airlines as well as Iranian airlines (ibid., p. 11).
f) The Civil Aviation Organization of Iran needs avionic equipment for their Falcon 20 aircraft,
which are used to calibrate landing systems. This required equipment is of American origin and
cannot be obtained because of the sanctions. These landing systems are being used by twenty­
three foreign airlines as well as Iranian airlines (ibid., p. 11).
In its report, ICAO [the independent experts] stated, "[a]ny continuation of severe sanctions must
be construed to be very detrimental to aviation safety, and immediate action must be taken to
avoid a regrettable occurrence. Whatever the justification of economic sanctions is there must be
safeguards to protect the minimum level of safety" (ibid., p. 7).
In its report, ICAO [the independent experts] stated, [a]ny continuation of severe sanctions must
be construed to be very detrimental to aviation safety, and immediate action must be taken to
avoid a regrettable occurrence. Whatever the justification of economic sanctions is there must be
safeguards to protect the minimum level of safety" (ibid., p.7)
3.3
3.3
ICAO is engaged to take the lead to remove any sanctions as they are applied to aircraft
ICAO is engaged to take the lead to remove any sanctions as they are applied to aircraft
equipment, spare parts, CNS equipment and technical reports. Aviation safety, as it affects human life and
human rights, stands above political differences. The civil aviation safety is and should be the bedrock
principle of the Chicago Convention carved into Articles 4 and 44.
equipment, spare parts, CNS equipment and technical reports. Aviation safety, as it affects human life and
human rights, stands above political differences. The civil aviation safety is and should be the bedrock
principle of the Chicago Convention carved into Articles 4 and 44.
4.
4.
CONCLUSION
CONCLUSION
4 .1
4 .1
The Iran Sanctions, to the extent they bar the acquisition of parts and support essential for
The Iran Sanctions, to the extent they bar the acquisition of parts and support essential for
civil aviation safety, does not conform with both the letter and spirit of the Chicago Convention to which
the U.S. is not only a member, but also one of it principal architects.
civil aviation safety, does not conform with both the letter and spirit of the Chicago Convention to which
the U.S. is not only a member, but also one of it principal architects.
4.2
4.2
The civil aviation worldwide and ICAO have been and will be commendably obsessive
The civil aviation worldwide and ICAO have been and will be commendably obsessive
about civil aviation safety. Nevertheless, the Chicago Convention does exist to prescribe a policy of
safety... in civil aviation. However, the U.S. sanctions have a destructive effect on the civil aviation
safety, Chicago Convention and ICAO; thus, must be lifted. Furthermore, civil aviation by definition is
international and must not be subject to embargo and/or sanctions.
about civil aviation safety. Nevertheless, the Chicago Convention does exist to prescribe a policy of
safety.. in civil aviation. However, the U.S. sanctions have a destructive effect on the civil aviation
safety, Chicago Convention and ICAO; thus, must be lifted. Furthermore, civil aviation by definition is
international and must not be subject to embargo and/or sanctions.
4.3
4.3
The Political differences between the parties to the Chicago Convention must not be used
The Political differences between the parties to the Chicago Convention must not be used
as an instrument for foreign policy. This is the commitment, which the United States was able to
successfully exact from Member States. The LR. of Iran requests the Untied States to honor this
commitment.
as an instrument for foreign policy. This is the commitment, which the United States was able to
successfully exact from Member States. The I.R. of Iran requests the Untied States to honor this
commitment.
4.4
4.4
The Conference is invited to:
The Conference is invited to:
a) note that the imposed trade embargo by the United States of America on the LR. of
Iran, which, as per the findings of ICAO mission, is detrimental to the safety of civil
aviation and does originate safety deficiencies.
a) note that the imposed trade embargo by the United States of America on the I.R. of
Iran, which, as per the findings ofICAO mission, is detrimental to the safety of civil
aviation and does originate safety deficiencies.
b) note that further follow-up measures subsequent to the fact-finding mission to the
I.R. of Iran, and report of the findings to the United States Administration for the
lifting of embargo by the good offices of the President of the Council have not yet
been replied; although, the findings, for the sake of safety, justify an immediate
reply.
b) note that further follow-up measures subsequent to the fact-finding mission to the
I.R. of Iran, and report of the findings to the United States Administration for the
lifting of embargo by the good offices of the President of the Council have not yet
been replied; although, the findings, for the sake of safety, justify an immediate
reply.
- 273 -

DGCA/06-WP/3 l
DGCA/06-WP/3 l
- 6­
- 6­
c) note that the issue in hand is within the ambit of the Chicago Convention; thus, it
must be dealt in the ICAO as a technical UN agency.
c) note that the issue in hand is within the ambit of the Chicago Convention; thus, it
must be dealt in the ICAO as a technical UN agency.
d) note that the U.S. Iranian Sanctions is an obvious non-conformity to the letter and
spirit of the Chicago Convention and disrespect to human life, which is endangered
by this policy. These sanctions undoubtedly undermine the mandate that the
Member States have delegated to ICAO to ensure the safety of civil aviation
worldwide.
d) note that the U.S. Iranian Sanctions is an obvious non-conformity to the letter and
spirit of the Chicago Convention and disrespect to human life, which is endangered
by this policy. These sanctions undoubtedly undermine the mandate that the
Member States have delegated to ICAO to ensure the safety of civil aviation
worldwide.
-END-
-END-

- 274 -

Annex 257
“Zagros Airlines places a commitment for 28 new Airbus aircraft”, Airbus,
22 June 2017

- 275 -

- 276 -

AIRBUS
AIRBUS
22 An 2947+Corn cit Airer
22 An 2017+Corn cit Airer
Zagros Airlines places a commitment for 28 new Airbus
aircraft
Zagros Airlines places a commitment for 28 new Airbus
aircraft
Zagros Airlines. one of the leading domestic airlines in an, has signed a memorandum of understanding with Airbus for the acquisition of 28 new aircraft covering 2 A320ne0 and 8 A33ne0
Zagros Airlines. one of the leading domestic airlines in lran, has signed a memorandum of understanding with Airbus for the acquisition of 28 new aircraft.covering 20 A320neo and 8 A33One0
aircraft
aircraft
The commitment was signed at the 52 Le Bourget Paris airshow by Seyed Abdolreza Mousai. Zagros Nines CEO and Fabnice Bregier, Airbus COO and President Commercial Aircraft
The commitment was signed at the 52·Le Bourget Paris airshow by Seyed Abdolreza Mousa. Zagros irtines CEO and Fabrice Br@gier, Nbus COO and President Commercial Aircraft
lo date Zagros Airlines is the largest domestic single-aisle Airbus operator in lran wit 11 A320ce0 Family aircraft
lo date Zagros Airlines is the largest domestic single-aisle Airbus operator in ran with 11 A320ce0 Family aircraft
we ere delighted to have been able toreach an agreement with Airbus for these new aircraft We have been a loyal operator of the A320 Family and the performance, operational and cost
we ere delighted to have been able toreach an agreement with Airbus for these new aircraft We have been a loyal operator of the A32 Family and the performance, operational and cost
efficiencies of Airbus aircraft was the selling point for us to order these aircraft,said Seyed Abdoireza Mousa This represents a practical step for Zagros Airlines fleet renewal as well as
efficiencies of Airbus aircraft was the selfing point for us to order these aircraft,said Seyed Abdoirze Mousa Thi represents practical step for Zagros Airlines fleet renewal s well as
expanding our operations both domestically and internationally
expanding our operations both domestically and internationally
We thank Zagrog Airlines for their trust in our most efficient single and twin-aisle product families They will all ow Zagros to modernise and expand ts feet with minimum change benefiting rom
We thank Zagros Airlines for their trust in our most efficient single and twin-aisle product families They will ell ow Zegros to modernise and expand #ts feet with minimum change benefiting rom
our feet commonality which is unique to Airbus.aid Fabrice Bregier
our feet commonality which is unique to rbus.aid Fabnice Bregier
The Mou is contingent upon all necessary approvals, including those from the Office of Foreign Assets Control (OFAC) Airbus will continue to act in full compliance with the Joint Comprehensive
The Mou is contingent upon all necessary approvals. including those from the Orce of Foreign Assets Control (OF AC) Airbus will continue to act in full compliance with the Joint Comprehensive
Plan OM Action (CPOA) and associated rules
Plan OM Action (CPOA) and associated rules
As the worlds leading aircraft manufacturer, Airbus offers the most comprehensive range of passenger airliners from 100 to more than 600 seats. Airbus has design and manufacturing facilities in
As the worlds leading aircraft manufacturer, Airbus offers the most comprehensive range of passenger airliners from 100 to more than 600 seats. Airbus has design and manufacturing facilities in
France. Germany,the UK and Spain, and subsidiaries in the US, China Inda.Japan and in the Mde East in addition Airbus provides the highest standard of customer support and training
France. Germany,the UK and Spain, and subsidiaries in the US, China Inda.Japan and in the Mdie East in add«ion Airbus provides the highest standard of customer support and training
through an expanding international network
through an expanding international network
Your Contact
Your Contact
Justin Dubon
Justin Dubon
Mustafa Al.Aus.aje
Mustafa Al.Aus.aje
lead of Global News
lea of Global News
lead of Communications Airbus AMrioa & Me East
lead of Communications Nibus AMroa & Mile East
+33$61$31as
+33$61$31ad
+0156 603 7704
+0156 603 7704

- 277 -

- 278 -

Annex 258
“Iran Airtour commits to 45 A320neo aircraft”, Airbus, 22 June 2017

- 279 -

- 280 -

AIRBUS
AIRBUS
22 June 2017 + Commercial Aircraft
22 June 2017 +
Commercial Aircraft
Iran Airtour commits to 45 A320neo
aircraft
Iran Airtour commits to 45 A320neo
aircraft
Tehran based ran Airtour Airlines, has become Airbus' newest customer for the A320neo Family after signing a memorandum of
Tehran based ran Airtour Airlines, has become Airbus' newest customer for the A320neo Family after signing a memorandum of
understanding (Mot) for 45 aircraft at the Paris Air Show
understanding (Mot) for 45 aircraft at the Paris Air Show
Celebrating 45 years since establishment, the carrier now has been added to Airbus' list of new customers. Operating scheduled
Celebrating 45 years since establishment, the carrier now has been added to Airbus' list of new customers. Operating scheduled
services lo domestic and international markets, Iran Airtour will benefit from the new aircraft lo modernise its fleet and expand its
services to domestic and international markets, Iran Airtour will benefit from the new aircraft to modernise its fleet and expand its
operations to domestic and international markets.
operations to domestic and international markets.
The A320neo Family with its unique features enabling operational efficiency and reliability will contribute to our growth and
The A320neo Family with its unique features enabling operational efficiency and reliability will contribute to our growth and
expansion strategy," said Majid Shekari, Chairman of Iran Airtour Airlines. Our success as a domestic and regional airline will be
expansion strategy," said Majid Shekari, Chairman of Iran Airtour Airlines. "Our success as a domestic and regional airline will be
reinforced by this investment in the world's leading single-aisle aircraft"
reinforced by this investment in the world's leading single-aisle aircraft"
This commitment for 45 A320ne0 Family aircraft demonstrates the confidence airlines have in our successful market leading
This commitment for 45 A320ne Family aircraft demonstrates the confidence airlines have in our successful market leading
single-aisle for its operational efficiency and unrivaled passenger comfort," said Fabrice Br~gier, Airbus COO and President
single-aisle for its operational efficiency and unrivaled passenger comfort," said Fabrice Br~gier, Airbus COO and President
Commercial Aircraft. "We are delighted to add Iran Airtour as a new Airbus customer and we look forward to our long-term
Commercial Aircraft. "We are delighted to add lran Airtour as a new Airbus customer and we look forward to our long-term
partnership.
partnership.
The MoU is contingent upon all necessary approvals, including those from the Office of Foreign Assets Control (OFAC). Airbus
The MoU is contingent upon all necessary approvals, including those from the Office of Foreign Assets Control (OFAC). Airbus
will continue to act in full compliance with the Joint Comprehensive Plan Of Action (CPOA) and associated rules
will continue to act in full compliance with the Joint Comprehensive Plan Of Action (JCPOA) and associated rules.
The A320 Family is the world's best-selling single aisle product line. To date, the Family has won over 13,000 orders and more
The A320 Family is the world's best-selling single aisle product line. To date, the Family has won over 13,000 orders and more
than 7,600 aircraft have been delivered to some 400 customers and operators worldwide. Mth one aircraft in four sizes (A318,
than 7,600 aircraft have been delivered to some 400 customers and operators worldwide. With one aircraft in four sizes (A318,
A319, A320 and A321), the A320 Family seats from 100 t 240 passengers. The Family features the widest cabin in the single
A319, A320 and A321), the A320 Family seats from 100 to 240 passengers. The Family features the widest cabin in the single
aisle market with 18" wide seats in Economy as standard.
aisle market with 18" wide seats in Economy as standard.
- 281 -

Your Contact
Your Contact
Mustafa Al-Ausaje
Mustafa Al-Ausaje
Justin Dubon
Justin Dubon
Head of Corrunicat ions Airbus Africa &
Head of Corrunicat ions Airbus Atr«ca &
Head of Global News
Head of Global News
Middle East
Middle East
+33561 93 31 90
+33 581 93 31 90
1971 55 8083 7704
+971 55 8083 7704

- 282 -

Annex 259
Letter from Civil Aviation Organization of Iran to ICAO, 11 November 2018
(enclosing official statement dated 27 October 2018)

- 283 -

- 284 -

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Date:
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Number: 48065
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Date:
2018/11/11
Number: 48065
co?'
Islamic Republic of Iran
Islamic Republic of Iran
Civil Aviation Organization
Civil Aviation Organization
Dr. Olumuyiwa Benard Aliu
President
ICAO Council
Dr. Olumuyiwa Benard Aliu
President
ICAO Council
Email: [email protected]
Email: [email protected]
Subject: Official Statement of the Civil Aviation Organization of the l.R of Iran
Subject: Official Statement of the Civil Aviation Organization of the l.R of Iran
Dear Dr. Aliu,
Dear Dr. Aliu,
The Civil Aviation Organization of the Islamic Republic of Iran presents
The Civil Aviation Organization of the Islamic Republic of Iran presents
its best
its best
compliments to the International Civil Aviation Organization Council.
compliments to the International Civil Aviation Organization Council.
This letter entails the Official Statement of the Civil Aviation Organization of the Islamic
Republic of Iran for your consideration. The Statement deals with the sanctions
currently imposed against Iranian nation by the US unilaterally. These unjustified
sanctions are in blatant and complete contradiction to the principles and spirit of the
Chicago Convention, leading to highly adverse consequences for the international civil
aviation and air transport.
This letter entails the Official Statement of the Civil Aviation Organization of the Islamic
Republic of Iran for your consideration. The Statement deals with the sanctions
currently imposed against
Iranian nation by the US unilaterally. These unjustified
sanctions are in blatant and complete contradiction to the principles and spirit of the
Chicago Convention, leading to highly adverse consequences for the international civil
aviation and air transport.
While I would I ike to remind you of the main goals and objectives of the Civil Aviation
Organization, being development of safe, regular and affordable air transport for all
peoples in the world, preparing the ground for cooperation between various air carriers in
terms of air transport, as well as cooperating with 1CAO and other international
organizations; I would like to request that you kindly pay special heed to all the articles of
the Convention cited in the Statement and lend your kind support to full implementation
of the Convention.
While I would I ike to remind you of the main goals and objectives of the Civil Aviation
Organization, being development of safe, regular and affordable air transport for all
peoples in the world, preparing the ground for cooperation between various air carriers in
terms of air transport, as well as cooperating with 1CAO and other international
organizations; I would like to request that you kindly pay special heed to all the articles of
the Convention cited in the Statement and lend your kind support to full implementation
of the Convention.
Considering the current circumstances, I would like to kindly request that the matter be
raised in the upcoming meeting of the Council and the Statement be deposited with ICAO.
Considering the current circumstances, I would like to kindly request that the matter be
raised in the upcoming meeting of the Council and the Statement be deposited with ICAO.
Sincerely yours,
Sincerely yours,
Vice Minister of Roads and Urban
Vice Minister of Roads and Urban
Development and President of
Civil Aviation Organization
Development and President of
Civil Aviation Organization
Mehrabad Airport, Tehran, The Islamic Republic Of lren
Mehrabad Airport, Tehran, The Islamic Republic Of Iran
Fax. 0098-21-66025405 Tel. 0098-21-66078700-9
Fax. 0098-21-66025405 Tel. 0098-21-66078700-9
http://www.cao.ir email: [email protected]
http://www.cao.ir email: [email protected]
- 285 -

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OFFICIAL STATEMENT
OFFICIAL STATEMENT
OF THE CIVIL AVIATION ORGANISATION OF THE ISLAMIC REPUBLIC OF IRAN
ON
UNILATERAL SANCTIONS IMPOSED BY THE UNITED STATES OF AMERICA
AGAINST THE CIVIL AVIATION
OF THE CIVIL AVIATION ORGANISATION OF THE ISLAMIC REPUBLIC OF IRAN
ON
UNILATERAL SANCTIONS IMPOSED BY THE UNITED STATES OF AMERICA
AGAINST THE CIVIL AVIATION
October 27, 2018
October 27, 2018
Air transport has performed a substantial role in bringing the world's peoples
closer together, in distributing resources and opportunities fairly around the
world, and in developing a spirit of peace and friendship instead of dispute and
hostility among nations.
Air transport has performed a substantial role in bringing the world's peoples
closer together, in distributing resources and opportunities fairly around the
world, and in developing a spirit of peace and friendship instead of dispute and
hostility among nations.
International cooperation is essential for the continued regular international
transport, and so much so that the minimum amount of competition and political
confrontation is observed in this area. However, the United States in recent
decades has unfortunately abused the enhancements achieved in aviation
technology and industry to cause limitation and conflict instead of expanding
global interactions.
International cooperation is essential for the continued regular international
transport, and so much so that the minimum amount of competition and political
confrontation is observed in this area. However, the United States in recent
decades has unfortunately abused the enhancements achieved
in aviation
technology and industry to cause limitation and conflict instead of expanding
global interactions.
Having a deep understanding of the fact that any kind of restriction imposed on
nations concerning regular, safe and efficient communications would contradict
the aims and purposes of international air transport, and appreciating the negative
effects that would sooner or later become obtrusive in all countries of the world,
including the countries in default; in an atmosphere of international hardships and
disagreement leading to World War II, the representatives of nations established
Having a deep understanding of the fact that any kind of restriction imposed on
nations concerning regular, safe and efficient communications would contradict
the aims and purposes of international air transport, and appreciating the negative
effects that would sooner or later become obtrusive in all countries of the world,
including the countries in default; in an atmosphere of international hardships and
disagreement leading to World War II, the representatives of nations established
a solid foundation for international cooperation in the field of civil aviation in the
a solid foundation for international cooperation in the field of civil aviation in the
form of the International Civil Aviation Convention, in various Articles of which,
the importance of cooperation between the nations and avoiding misuse of
aviation industry has been underlined.
form of the International Civil Aviation Convention, in various Articles of which,
the importance of cooperation between the nations and avoiding misuse of
aviation industry has been underlined.
The Preamble to the convention states:
The Preamble to the convention states:
WHEREAS the future development of international civil aviation can greatly help
to create and preserve friendship and understanding among the nations and
WHEREAS the future development of international civil aviation can greatly help
to create and preserve friendship and understanding among the nations and
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peoples of the world, yet its abuse can become a threat to the general security;
and
peoples of the world, yet its abuse can become a threat to the general security;
and
WHEREAS it is desirable to avoid friction and to promote that cooperation
between nations and peoples upon which the peace of the world depends;
WHEREAS it is desirable to avoid friction and to promote that cooperation
between nations and peoples upon which the peace of the world depends;
THEREFORE, the undersigned governments having agreed on certain principles
and arrangements in order that international civil aviation may be developed in
a safe and orderly manner and that international air transport services may be
established on the basis of equality of opportunity and operated soundly and
economically;
THEREFORE, the undersigned governments having agreed on certain principles
and arrangements in order that international civil aviation may be developed in
a safe and orderly manner and that international air transport services may be
established on the basis of equality of opportunity and operated soundly and
economically;
Article 4 of the Convention, dealing with misuse of civil aviation, states:
Each contracting State agrees not to use civil aviation for any purpose
inconsistent with the aims of this Convention.
And Article 44 of the Convention, is as follows:
The aims and objectives of the Organization are to develop the principles and
techniques of international air navigation and to foster the planning and
development of international air transport so as to:
(a) Insure the safe and orderly growth of international civil aviation throughout
the world;
(b) Encourage the arts of aircraft design and operation for peaceful purposes;
(c) Encourage the development of airways, airports, and air navigation facilities
for international civil aviation;
(d) Meet the needs of the peoples of the world for safe, regular, efficient and
economical air transport;
(e) Prevent economic waste caused by unreasonable competition;
(f) Insure that the rights of contracting States are fully respected and that every
contracting State has a fair opportunity to operate international airlines;
(g) Avoid discrimination between contracting States;
(h) Promote safety of flight in international air navigation;
(i) Promote generally the development of all aspects of international civil
aeronautics.
Article 4 of the Convention, dealing with misuse of civil aviation, states:
Each contracting State agrees not to use civil aviation for any purpose
inconsistent with the aims of this Convention.
And Article 44 of the Convention, is as follows:
The aims and objectives of the Organization are to develop the principles and
techniques of international air navigation and to foster the planning and
development of international air transport so as to:
(a) Insure the safe and orderly growth of international civil aviation throughout
the world;
(b) Encourage the arts of aircraft design and operation for peaceful purposes;
(c) Encourage the development of airways, airports, and air navigation facilities
for international civil aviation;
(d) Meet the needs of the peoples of the world for safe, regular, efficient and
economical air transport;
(e) Prevent economic waste caused by unreasonable competition;
(f) Insure that the rights of contracting States are fully respected and that every
contracting State has afair opportunity to operate international airlines;
(g) Avoid discrimination between contracting States;
(h) Promote safety of flight in international air navigation;
(i) Promote generally the development of all aspects of international civil
aeronautics.
Page 2 of 4
Page 2 of 4
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Regarding the text and spirit of the Articles of the Convention which were just
mentioned, and with respect to the fact that any limitation of the Signatories to
the Convention in terms of their equitable access to aviation-related hardware,
support, services and markets is contrary to the rudimentary objectives of the
Chicago Convention, which include provision of safe, efficient, regular and
economical opportunities, creation and development of friendship and mutual
understanding between nations and peoples of the world is severely undermined,
and the misuse of the aviation industry for purposes other than those stipulated in
the Convention can tum into a serious threat to global security,
Regarding the text and spirit of the Articles of the Convention which were just
mentioned, and with respect to the fact that any limitation of the Signatories to
the Convention in terms of their equitable access to aviation-related hardware,
support, services and markets is contrary to the rudimentary objectives of the
Chicago Convention, which include provision of safe, efficient, regular and
economical opportunities, creation and development of friendship and mutual
understanding between nations and peoples of the world is severely undermined,
and the misuse of the aviation industry for purposes other than those stipulated in
the Convention can turn into a serious threat to global security,
Accordingly, with the aim of correcting a detrimental approach adopted by
certain Contracting States and especially pursued in recent years with the purpose
of misusing the aviation industry, aircraft design and manufacturing technologies
and capabilities, and the aviation equipment needed for international air transport,
as a device for exerting influence in areas other than civil aviation, being a huge
challenge to the equitable and efficient development of global air transport,
Accordingly, with the aim of correcting a detrimental approach adopted by
certain Contracting States and especially pursued in recent years with the purpose
of misusing the aviation industry, aircraft design and manufacturing technologies
and capabilities, and the aviation equipment needed for international air transport,
as a device for exerting influence in areas other than civil aviation, being a huge
challenge to the equitable and efficient development of global air transport,
The Civil Aviation Organisation of the Islamic Republic of Iran, while officially
declares that the restrictions imposed by the United States on the civil aviation
industry of the [slamic Republic of Iran, is in a flagrant contradiction to the
provisions of the Convention and the spirit thereof, would like to underscore the
fact that such restrictions will jeopardize the ultimate goals of the Convention,
will block the access of peoples and nations of the world to safe, economical,
efficient and regular air transport, and will have serious and immediate effects on
the rights of the Contracting States of the Chicago Convention;
The Civil Aviation Organisation of the Islamic Republic of Iran, while officially
declares that the restrictions imposed by the United States on the civil aviation
industry of the Islamic Republic of Iran, is in a flagrant contradiction to the
provisions of the Convention and the spirit thereof, would like to underscore the
fact that such restrictions will jeopardize the ultimate goals of the Convention,
will block the access of peoples and nations of the world to safe, economical,
efficient and regular air transport, and will have serious and immediate effects on
the rights of the Contracting States of the Chicago Convention;
Therefore, the Islamic republic of Iran would like to call on all the Contracting
States to recognize the US sanctions against civil aviation of the Islamic Republic
of Iran as illegitimate and:
Therefore, the Islamic republic of Iran would like to call on all the Contracting
States to recognize the US sanctions against civil aviation of the Islamic Republic
oflran as illegitimate and:
I- spare no effort to develop international civil aviation cooperation with other
countries, and in particular with the Islamic Republic of Iran, as a committed
Contracting State, stand in the way of any kind of restrictions that may be
imposed on Iranian carriers, and express their appropriate and effective
opposition to unilateral measures that are contradictory to the objectives of the
Convention, in the hope that this will prevent the diversion of the goals that we
have been striving for through formation of the global civil aviation industry.
I- spare no effort to develop international civil aviation cooperation with other
countries, and in particular with the Islamic Republic of Iran, as a committed
Contracting State, stand in the way of any kind of restrictions that may be
imposed on Iranian carriers, and express their appropriate and effective
opposition to unilateral measures that are contradictory to the objectives of the
Convention, in the hope that this will prevent the diversion of the goals that we
have been striving for through formation of the global civil aviation industry.
Page 3 of 4
Page 3 of 4
- 288 -

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2- through more effective participation in decision-making processes in the
global forums, in particular the global civil aviation ones, develop and employ
new approaches to dealing with unilateral restrictive measures that conflict with
the objectives of the ICAO, and also put an end to appointments from restricting
Contracting States to decision-making posts.
2- through more effective participation in decision-making processes in the
global forums, in particular the global civil aviation ones, develop and employ
new approaches to dealing with unilateral restrictive measures that conflict with
the objectives of the ICAO, and also put an end to appointments from restricting
Contracting States to decision-making posts.
The Iranian Civil Aviation Organization requests the TCAO Council to:
Remind all the Contracting states of the objectives and values behind the
formation of International Civil Aviation Organisation, in particular the
provisions of the Preamble of its Convention, Article 4 and Article 44,
And highlight the right of all peoples and nations of the world to have access to
safe, regular, efficient and economical air transport,
And recognize the immediate and irreversible consequences of any kind of
restriction imposed on the access of peoples and nations of the world to air
transport,
And call on the Contracting States to remain committed to the provisions of the
Convention and its aim of expanding international air transport with a view to
promoting friendship and mutual understanding between the peoples and nations
of the world.
The Iranian Civil Aviation Organization requests the ICAO Council to:
Remind all the Contracting states of the objectives and values behind the
formation of International Civil Aviation Organisation, in particular the
provisions of the Preamble of its Convention, Article 4 and Article 44,
And high! ight the right of al I peoples and nations of the world to have access to
safe, regular, efficient and economical air transport,
And recognize the immediate and irreversible consequences of any kind of
restriction imposed on the access of peoples and nations of the world to air
transport,
And call on the Contracting States to remain committed to the provisions of the
Convention and its aim of expanding international air transport with a view to
promoting friendship and mutual understanding between the peoples and nations
of the world.
Vice Minister of Roads and Urban Development and
President of Civil Aviation Organization oflslamic Republic of IRAN
Vice Minister of Roads and Urban Development and
President of Civil Aviation Organization of Islamic Republic of IRAN
Page 4 of 4
Page 4 of 4

- 289 -

- 290 -

Annex 260
Letter from Dunlop to Kish Air, 22 May 2018

- 291 -

- 292 -

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ASSOCIATION of IRANIAN AIRLINES
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- 293 -
e
ASSOCIATION of IRANIAN AIRLINES
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THE LETTEREHEAD OF ASSOCIATION OF IRANIAN AIRLINES
THE LETTEREHEAD OF ASSOCIATION OF IRANIAN AIRLINES
NO. 98/4407
NO. 98/4407
DATE: 25-01-1398 [14 April 2019]
DATE: 25-01-1398 [14 April 2019]
Attachment: 1 page
Attachment: 1 page
Centre for International Legal Affairs, Presidential Office
Centre for International Legal Affairs, Presidential Office
Greeting,
Greeting,
Referring to the letter No. 6969 dated 21/12/1397 [12 March 2019], enclosed please
kindly find, for making any use thereof, a copy of a report from Kish Air's concerning the
refusal of DUNLOP Company (UK) from cooperation due to the issues arising from the [US]
sanctions.
Referring to the letter No. 6969 dated 21/12/1397 [12 March 2019], enclosed please
kindly find, for making any use thereof, a copy of a report from Kish Air's concerning the
refusal of DUNLOP Company (UK) from cooperation due to the issues arising from the [US]
sanctions.
Samani
Samani
Secretary of Association of Iranian Airlines
Secretary of Association of Iranian Airlines
[SEAL AND SIGNATURE]
[SEAL AND SIGNATURE]
- 294 -

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Vy.7 Jaus ta'iil- '·!ye9kl la- lgsls¢? -lt :ash
1rob/r:,gs.no]
1rfo/rA:,ig Ai]
?rt; asl3 rrr2rot:usu ryPrrk--&·:l
rPrt; as/3 rrFr2rot:us ryPrk--&·:Mi
- 295 -

THE LETTEREHEAD OF KISH AIR
THE LETTEREHEAD OF KISH AIR
DATE: 5/12/1397 [24 February 2019]
DATE: 5/12/1397 [24 February 2019]
NO. 206/8931
NO. 206/8931
Secretary of Association of Iranian Airlines
Secretary of Association of Iranian Airlines
Greeting,
Greeting,
Reference is made to the letter No. 97 /4215 dated 6/11/97 [26 January 2019], it is hereby
declared that hitherto DUNLOP Company (UK) has cancelled the purchase order issued by
Kish Air for the supply of 100 MAIN [aircraft] tyres and 100 NOSE [aircraft] tyres due to the
United States sanctions.
Reference is made to the letter No. 97 /4215 dated 6/11/97 [26 January 2019], it is hereby
declared that hitherto DUNLOP Company (UK) has cancelled the purchase order issued by
Kish Air for the supply of 100 MAIN [aircraft] tyres and 100 NOSE [aircraft] tyres due to the
United States sanctions.
Saiedreza Nasr Fard Jahromi
Saiedreza Nasr Fard Jahromi
Deputy-Chair of the Board and Managing Director
Deputy-Chair of the Board and Managing Director
[SEAL AND SIGNATURE]
[SEAL AND SIGNATURE]
- 296 -

22" May 2018.
22" May 2018'
Mr M- A Khazaie
Mr M- A Khazaie
Technical Procurement Manager
Technical Procurement Manager
Kish Airlines
Kish Airlines
.
.
.
.
Mr A Soltanzali
Purchasing Supervisor
Mr A Soltanzali
Purchasing Supervisor
Kish Airlines
Kish Airlines
BY E-MAIL ONLY
BY E-MAIL ONLY
·. Dear Sirs,
Dear Sirs,
·Iranian Sanctions
·Iranian Sanctions
'My name is. Adrian Thompson, I am a board director of Dunlop Aircraft Tyres Limited
'My name
is. Adrian Thompson, I am a board director of Dunlop Aircraft Tyres Limited
·(Dunlop) and Managing Director of Dunlop's Afternarket Services organisation :'.
·(Dunlop) and Managing Director of Dunlop's Aftermarket Services organisation. l:''..
.
..
·.
.
.··.,.
.
.
:\
... ··.
r.
... ·.
.
. .
.
'\
. .
.
-
.I'wanted to follow up on your recent communications with our Regional Sales Manger
.I'wanted to follow up on your recent communications with our Regional Sales Man~ger
David Jones·to outline Dunlop's position regarding the sanctions that are being implemented
David Jones·to outline Dunlop's position regarding the sanctions that are being implemented
·on lran by the United States of America (USA).
:·
·on lran by the United States of America (USA).
'
?
•••
,'
·
"
·.-
,·
Dunlop is own~d by an investor from the USA and has, at this time, been advised that
Dunlop is owned by an investor from the USA and has, at this time, been advised that
shipments cannot be made to Iran at present.
shipments cannot be made to lran at present.
+
+
Dunlop is however
working
with our USA owner and legal counsel to determine whether
shipments ~f existing and (uture orders with your company are possible.
Dunlop is however, working with our USA owner and legal counsel to determine whether
shipments bf existing and (uture orders with your company are possible.
.,
.
+·
,
'
,.
• Dunlop wishes to broaden and strengthen its relationship with your company and will
'continue to work towards this desired outcome but ~t all times in compliance with laws end
• Dunlop wishes to broaden and strengthen its relationship with your company and will
'continue to work towards this desired outcome but ~t all times in compliance with laws end
r
gulations relating to export controls.

- 297 -
e
:
regulations relating to export controls.
:·.
.·
:
··:.
t
l will work with David Jones to ensure that you are updated with any change in status and I
l will work with David Jones to ensure that you are updated with any change in status and L
hope that w~ are able to commence supply in the future.
hope that w~ are able to commence supply in the future.
Adrian Thompson.
Adrian Thompson.
Managing Director Global Aftermarket Services
Managing Director Global Aftermarket Services
,·_.,
+..+.
; ;;
c,
1!g
.1re
«~
cg'stereri (re: 4p Fort Park:w. Erisgton, irminghsm, &z ?Kt z'glen«
e@'stereri Ce: 40 5art Psrww. Eriigton. Sirminghsm, U2+ 9! £nglsn«
. Te!phone: «5 Ui21334 8:0}s: +44 {0)121 277 2150
. Is!phone: «44 (0#1213$4 8&:0f: +44 {)121277 7.150
«nirjs@dar±ups:.ce k, ww.Jalapgircrz:tyres.co.uk
«n@iris@darugs:Ace uk, www.{elapygiccrz:tyres.co.uk
Reg'±tered m £ gla! , 322{323
Reg'±tered m £ gla! , 322{333

- 298 -

Annex 261
Letter from a non-U.S. company to Iran Air, 22 May 2018
Redacted

- 299 -

- 300 -

·--�-----------------
' From;
sent:
·· 2010,LM ½:.o 1 ...
·--'"'"
• To:.
'Gtguna102.5)'
L'Ce: •
[email protected], [email protected]
Subject:
AW C/3394-ZS
,
Atta&hmant;
,' tape001.git; imapa002.png: impo003.png: image006.pdg. imago0o pr.
image008.png; Image008.png: impe011.png
:
[egr Shahnematoilahl,
Many thanks tor your new inquiry.
SI&8.8" May 2018 .we,aro no longur able lo offer or toll you any Itom due to the American ext from the
uc6er'&silt lrin:
·
.
j
At,thig,moment we hove a time frame of 2 month to oond you al ems which have been ordered belore 8"
M~ 201:-·
.
'+,"
> S
·'
''That~ans all orders'which have nat baon delivered till 31 July 2018 have to be canceled due to the
{-pois
mentioned roanon.
e; W
-
really regret this-circumstances arid the Inconvenlencos this will cause you but we are forced to act this
+
•

- 301 -
e
way, d
t
herwise we will.be listed or'.the black list.,
­
•I[es-
':"
',
' Betretc/3y
1.7$_
~
i
i:vs­
·
--------------
' From;
sent:
PP
, To:.
'Gtgur@1@2s)
'ce
.
[email protected], tupply-trappirsnalr.com
AW: C/3394-ZS
Subject:
,
Atta&hmant;
,' tape001.git; imapa002.png: impo003 png: image006.pdg, imago0o pug.
[email protected]; Image008.png: impe011.png
:,
[egr Shahnematoilahl,
Many thank tor your pew inquiry.
SIn¢@.8" May 2018 .we,aro no longur able lo offer or toll you any Itam due to the American ext from the
u6er66srl lr~n:
·
.
j
At,thig,moment we hove a time frame of 2 month to oond you all Items which have been ordered before 8"
AM~j 2018-·
•
'
.''Th~ik~ant all orders'which have nat baon dellvred till 31 July 201 have to be canceled due to the
7jg«vrwon
e; Wereally;regret this circumstances ani the Inconveniences this will cause you but we are forced to act this
way, otherwise we will.be listed ord.the blacklist.,
•
·1Seo
':
•
',
;Betret; c/3g
.·
1.7$
:
.. ,
.. , �---· -·-· -------
·--■-
---- ------

- 302 -

Annex 262
Email from a non-U.S. aircraft engine parts supplier to Iran Air, 31 May 2018
Redacted

- 303 -

- 304 -

I
I
I
I
Amir Houshang Abdi
Amir Houshan
From:
Sent
To:
Subject:
Faramarz Rohani <[email protected]>
Saturday, November 24, 3.02 2018 PM
tagh •
[email protected]; 'Amir Houshang Abdi'"

- 305 -
.
Fw]
support suspended until further notice
From
Sent
To:
Subject:
Faramanz Rohani <[email protected]>
Saturday, November 24, 3.02 2018 PM
our@irnn.:iir.com; iAm1r Houshang Abdi'
tagh •
Dear Mr. Taghipour/ Mr. Abdi,
I
Please find the below email for your kind attention
Best Regards,
Faramarz Rolani
Director, Power plant Engineering
-
From:
Sent:
nut
lay, May 31, 2018 7:02 PM
To; Kamran Bayati; a-shokouhi; Mr.Behnam; 'ta
Cc:
Dear Iran Air team,
�has been supporting you as a supplier undC?r the scope of an export license provided by the US OFAC to
!]
The OFAC revoked this license with immediate effect, and a temporary license has been granted but unfortunately cannot be used to export anything to lran Air [the win.
down period until August 6" ): it only allows discussion / payment.
j
p
l
t
moni1ori:ng al
limited to technical clarifications, engine health
l
Because of this situation out of our control@ust suspend all exportations, including but no
parts.
d spare
The payment process of some spare parts that were available since the end of 2017 should now e s1opped because-cannot deliver those p<1rts anymbre.
''
I
Our legal and export control teams are working together with all our partners to seek solutions fdr what happens next. We will revert back to you soon to
inform you on
this.
I
.
'
}
.
Fw]
support suspended until further notice
Dear Mr. Tagbipour/ Mr. Abdi,
I
Please find the below email for your kind attention.
Best Regards,
Faramarz Roani
Director, Powerplant Engineering
-
From:
Sent: Thursday, May 31, 2018 7:02 PM
To: Kamran Bayati; a-shokouhi; Mr.Behnam; 'ta
Cc:
Dear lran Air team,
�has been supporting you as a supplier under the scope of an export License provided by the US OFAC to -
�
j
The OFAC revoked this license with immediate effect, and a temporary license has been granted but unfortunately cannot be used to export anything to ran Air (the wind­
down period until August 6 ): it only allows discussion / payment,
j
t
I
i
limited to technical clarifications, engine health
monitor{ng a!d
spare
Because of this situation out of our control@ust suspend all exportations, including but no
parts.
The payment process of some spare parts that were available since the end of 2017 should now
I'
e stopped because-cannot deliver those parts anymore.
I
Our legal and export control teams are working together with all our partners to seek solutions fdr what happens next. We will revert back to you soon to inform you on
this.
I
t

- 306 -

Annex 263
Email from a non-U.S. aircraft tyres supplier to Iran Air, 6 June 2018
Redacted

- 307 -

- 308 -

BAYATI Kamran
BAYATI Kamran
I
From:
From:
' r·---
----·
·-·- ----
.
Dute: Wednesday, June 06, 2018 223 AM
Dute: Wednesday, June 06, 2018 223 AM
To:
·
"Kamr@n Bayati" <kb~yati@[email protected]> .
· ·
To:
·
"Kamyr@nBayat" <kb~yati@irn~it.com>: ._
........,_,_.__ .....
,_�-�-,C�
-- -·
.........,_,,,_...,. __
�,�-'C� ---- -·-- --· --
- --· -- -
Subject:
Subject:
Dear Mr Bayati.
Dear Mr Bayati.
I very sorry to advise that we have been notified by our U.S. Owners, and Lawyers, that we currently cannot
supply further Tyres to Iran Air.
I very sorry to advise that we have been notified by our U.S. Owners, and Lawyers, that we currently cannot
supply further Tyres to Iran Air.
However, the situation is being monitored closely, and as soon as further details are released from the U.S
However, the situation is being monitored closely, and as soon as further details are released from the U.S
Government, we hope we may be in a position to re-instate the supply of both New & Retreaded Aircraft
Tyres to Iran Air.
oe±tote above, we are crremtr orate to svow me 2of re[sans».o
Government, we hope we may be in a position to re-instate the supply of both New & Retreaded Aircraft
Tyres to Iran Air.
oe±tote ±hove, we are crremtw arable to sow me 2of we[saran.o
oleos»
less»
I am very sorry to have to give the above news, as we have enjoyed many years of working with Iran Air, and
building good Business Relationships, and Friendships. Lets hope it is not too long before we are once again
·
allowed to work with Iran Air?
Thanks & Best Regards
I am very sorry to have to give the above news, as we have enjoyed many years of working with Iran Air, and
building good Business Relationships, and Friendships. Lets hope it is not too long before we are once again-·.
allowed to work with Iran Air?
Thanks & Best Regards
-------------------·------- ------------
From: Kamran Bayati [mailto:[email protected]]
Sent: 15 May 2018 07:04
To
From: Kamran Bayati [mailto:[email protected]]
Sent: 15 May 2018 07:04
To
Cc:
Cc:
subject: ORDER 22
subject: ORDER 22
Dear Sir,
Dear Sir,
Y'our/ref: 8195
Y'our/ref: 8195
we woe o rt«c oater no. mo-
orb coo
we woe o rt«c oater no. mo- orator coco
J)0: 20EA PN)
J)0: 20EA PN)
Desc: TIRE STzl l
Desc: TIRE STzl l
FN LT: STOCK
FN LT: STOCK
Cond:
Cond:
Delivery dates and certificates should be as per your quotation.
Delivery dates and certificates should be as per your quotation.
Kindly confirm P.O. by return message and advise us delivery date.
Kindly confirm P.O. by return message and advise us delivery date.
Best regards
Best regards
Majid Behnam
Majid Behnam
Senior Purchasing Manager
Senior Purchasing Manager
11/21/2018
11/21/2018

- 309 -

- 310 -

Annex 264
Letter from a non-U.S. aircraft part supplier to Iran Air, 25 June 2018
Redacted

- 311 -

- 312 -

(v
BAYATI Kamran
BAYATI Kamran
From:
From:
Date Monday, Jane 25, 2018 12.01 PM
Date. Monday, June 25, 20i8 12.0i PM
-..To;
Cc:
,
a
-..To;
Cc:
"Mr.Bayati" <[email protected]>
Subject: AW: Po-I
"Mr.Bayati" <[email protected]>
subject: AW: Po-
Sam(Qry.2lea Pn:2AW623-01) 1013367163 IRA
sam(Qry:2lea Pn:2AW623-01) 1013367163 IRA
Dear Mosayeblou,
Dear Mosayeblou,
unfortunately. we had to cancel this particular order, because meeadquarter is located in the U.s
Due to our OFAC license revocation we are not allowed to export any items anymore, where US entities are
involved.
unfortunately. we had to cancel this particular order, because me[eadauarter is locate in te U.s
Due lo our OFAC license revocation we are not allowed to export any items anymore, where US entities are
involved.
#5 J.8 ] c pp/ecxM nps~row [ Best Regards ] Mit freundlichen Gr~~en {+!!
#5 J.8 ]c pp/ecxM nps~row [ Best Regards ] Mit freundlichen Gr~~en {+!!
] Cordialement [
] Cordialement [
Saludos[
L < tgvL t #]<tl+kl ;
Saludos[
L < tgvLt #]tile.kl
Von: AOGDesk-SAM [mailto:[email protected]]
Gesendet: Samstag, 23. Juni 2018 10:.14
Von: AOGDesk-SAM [mailto:[email protected]]
Gesendet: Samstag, 23. Juni 2018 10:.14
Sam(Qty:2/ea Pn:2AW623-01)
Sam(Qty:2/ea Pn:2AW623-01)
AOG
AOG
Dear Mirko,
Dear Mirko,
Because of AOG situation it is highly appreciated if you check and advise latest status of this Po with
thanks.
Because of AOG situation it is highly appreciated if you check and advise latest status of this Po with
thanks.
We Remain
We Remain
Best Regards
Mosayeblou
Best Regards
Mosayeblou
11/20/2018
11/20/2018

- 313 -

- 314 -

Annex 265
Letter from a U.S. company to Iran Air, 10 July 2018
Redacted

- 315 -

- 316 -

,.
,.
«e
---·-·-··------
IRAN AIR PJSC
IRAN AIR PJSC
IRAN AIR BUILDING, MEHRABAD AIRPORT
TEHRAN, IRAN
IRAN AIR BUILDING, MEHRABAD AIRPORT
TEHRAN, IRAN
10 July 2018
10 July 2018
Dear Sirs,
Dear Sirs,
No.-
No.-
General Terms Agreement
!l.5 amended from time to timr (the "Agreement")- Noticr or
General Terms Agnement
!l.5 amended from lime lo timr (the "Agreement")-- Notice of
termination
termination
I. We write in connection with the Agreement. Terms used but not otherwise defined in this lener shall have
the meaning given thereto in the Agreement.
I. We write in connection with the Agreement. Terms used but not otherwise defined in this lener shall have
the meaning given thereto in the Agreement.
2.
2.
Article 9 (Conditionality of Agreement) provides that the obligations of the Parties under the Agreement are
conditional upon the Seller being able to obtain and maintain, throughout the term of the Agrecmcut, any and
all licenses, pernits authorizations and consents (of any nature whatsoever) which it may deem necessary in
order to transact or continue to transact with Airline in the manner envisaged in the Agreement. Article 9
Article 9 (Conditionality of Agreement) provides that the obligations of the Parties under the Agreement are
conditional upon the Scller being able to obtain and maintain, throughout the term of the Agrecmcut, any and
all licenses, permits authorizations and consents (of any nature whatsoever) which it may deem necessary in
order to transact or continue to transact with Airline in the manner envisaged in the Agreement. Article 9
-trther provides that fthe Seller-considers; et ny time, thet the preceding condition has not been satifet
-trther provides that fthe Seller-considers; et ny time, thet the preceding condition has not been satifet
it may (without incurring any liability towards the Airline) terminate the Agreement with immediate effect
it may (without incurring any liability towards the Airline) terminate the Agreement with immediate effect
by giving notice in writing to the Airline
by giving notice in writing to the Airline
J.
J.
On May 8, 2018, President Trmnp announced that the United States will cease participation in the Joint
Comprehensive Plon of Action and begin re-imposing the US nuclear-related sanctions against lran that were
lifted on Implementation Day in January 2016. Consistent with the President's guidance, the Office of
Foreign Assets Control (OFAC) announced that all specific licenses issued under the Statement of Licensing
Policy for Activities Related to the Export or Re-export to lran of Commercial Passenger Aircraft and Related
Pants and Services (SLP) would be revoked. Persons engaging in activities pursuant to these specific licenses
were instructcd by OFAC to tkc the steps necessary to wind down those activities by August 6, 2018.
On May 8, 2018, President Trmnp announced that the United States will cease participation in the Joint
Comprehensive Plon of Action and begin re-imposing the US nuclear-related sanctions against lran that were
lifted on Implementation Day in January 2016. Consistent with the President's guidance, the Office of
Foreign Assets Control (OFAC) announced that all specific licenses issued under the Statement of Licensing
Policy for Activities Related to the Export or Re-export to lran of Commercial Passenger Aircraft and Related
Pants and Services (SLP) would be revoked. Persons engaging in activities pursuant to these specific licenses
were instructed by OFAC to tkc the steps necessary to wind down those activities by August 6, 2018.
4
4
On May 23, 2018,received correspondence from OFAC revoking License No
which
On May 23, 2018,received correspondence from OFAC revoking License No
which
was issued to.Ender the SLP and allowed:nd other licensees to engage in all transactions necessary
to export or reexport to certain Iranian airlines specified engines ond hardware (spare and rcnJacement pans
was issued toder the SLP end allowed~ind other licensees to engage in ill transactions necessary
to export or reexport to certain lrnnian airlines specified engines nnd h.irdwarc (Sp?rC ond rcp10cement pans
and components), tooling, technology, software, and services for the airlines' and
lCtint
and components), tooling, technology, software, and services for the airlines'[ and
IC~int
powered fleet of aircran cx�lusivc)y fc.r con1mcrdai
powered fleet of :iirr.rafl cx.:lusive)y fc.r cornmcrCiai
passenger
:wiation end use. License No. --
pasi;er.gcr
was rep.aced by License NI
:ivi:llion end use. License No. --
oats author±es sod other licenses to io
was r«paced by License
NI
oiasauoresp ad other licenses to id
doz@ties ii we previous!y aio~iv pursva to Licenss
Noi
However, License
No
l
doz@ties ii we previous!y aio~iv pursari
Licenss
Noi
However, License
No
est ai»ota«es r'dogs pa o·ii .ea recur an e»as
l
est ai»ota«es r'dogs pa o·ii .a recur an seas
technology,or software to Iranian airlines as previously authorized by License No
technology,or software to Iranian airlines as previously authorized by License No
5
on May 25, 2018.[tonne a orAc al» revoked License Nos,
5
LS
on May 25, 2018.[tonne a orAc al revoked License Nos,
LS
which allowed far the transfer of aircraft and associated technical data and services to [ran
which allowed far the transfer of aircraft and associated technical data and services to [ran
Air. Pers
Air. Per8communication, although the licenses have been replaced with wind down licenses, the new
communication, although the licenses have been replaced with wind down licenses, the new
authorizations do not allow the exportation or re-exportation to lran of any_goods, technolg; or ofware
previously authorized for expan pursuant to License Nos[.e
authorizations do not allow the exportation or re-exportation to lran of any_goods, technolog'orfware
la:;g---Musty es INTENT • Air ender License Nos
Tis
previously authorized for export pursuant to License Nos.,
nd
This
l
l;;e%oust!y could MTTT.FF Te?TT ha Air under License Nos
l ts shiers
L ts shiers
6.
6.
Considerinf the restrictions outlined in License No.-�nd the ins1ructiom pro¥ided by
Considcrinf lhe restrictions outlined in License No.-:md !he inslructiom provided by
o longer has an OFAC authorization that would allow it to deliver goods, software, or
o longer has an OFAC authorization that would allow it to deliver goods, software, or
1
1
- 317 -

j
j
I
I
technology to the Airline Although wind down licenses will remain in place until August 6, 2018, these
suthorizations are not sufficient to allow tans±ct or continue to transact with the Airline in the manner
envisaged in the Agreement
technology to the Airline Although wind _down licenses will remain in place until August 6, 2018, these
suthorizations are not sufficient to allow tans±et or continue to transact with the Airline in the manner
envisaged in the Agreement
7.
7.
Accordingly, by tbis letter, we are exercising our night to terninate the Agreement (and all associated Letter
Agrcements) with immediate effect as specifically contemplated in Article 9 of the Agreement
Accordingly, by tbis letter, we are exercising our night to terninate the Agreement (and all associated Letter
Agrcements) with immediate effect as specifically contemplated in Article 9 of the Agreement
We look forward to receiving an acknowledgement of receipt of this notice
We look forward to receiving an acknowledgement of receipt of this notice
Yours faithfully,
Yours faithfully,
Date:
Date:
17
I
I
We acknowledge receipt of tlis letter.
We acknowledge receipt of tliis letter.
Signed by:
Signed by:
Name:
Name:
For and on behalf of:
For and on behalf of:
Date
Date
2
2

- 318 -

Annex 266
Letter from a non-U.S. service provider to Iran Air, 17 July 2018
Redacted

- 319 -

- 320 -

-
, I
, I
!
-�-----
l
IRAN AIR
•
!
For the ten~in6f H~midre ,or%.
----.--­
·1 ·----
j
.e
IRAN AIR
------------ "-pate~itEntionof Haider.,%r;:;---.­
t
ran Air HQ Mehrabad Airport
ran Air HQ Mehrabad Airport
Teheran
Teheran
Iran
Iran
17 July 2018
17 July 2018
;
;
-­
t
%
-­
i
%
ii enat @[email protected]) and courter
Seii at ([email protected]) and courter
l
'
l
l
Subject:
nhjgt:1TA SGH termination notice
IA'TA SGHA termination notice
Dear Sir,
Dear Sir,
According to the contractual provisions of the IATA Standard Ground Handling Agreement
entered into by our respective companies on 1of March 2011("SGHA"), we hereby give you a
l i
According to the contractual provisions of the IATA Standard Ground Handling Agreement
entered into by our respective companies on 1#of March 2011("SGHA"), we hereby give you a
-- · At:e our tent5i to terminate it
-- ·tte6tour iTetii to terminate if
t
We wish to assure you that this is not a decision that we have taken lightly. Our companies have
We wish to assure you that this is not a decision that we have taken lightly. Our companies have
always had a good commercial relationship and we have greatly valued your business. However,
always had a good commercial relationship and we have greatly valued your business. However,
syo know, we are a US owned company and following the US administration's decision to
syo know, we are a US owned company and following the US administration's decision to
withdraw from the [oint Comprehensive Plan of Action, we have no alternative but to comply
withdraw from the [oint Comprehensive Plan of Action, we have no alternative but to comply
with the National Security Presidential Memorandum issued on 8 May 2018 and wind down our
activities with Iran Air as a failure to do so will expose us to potential penalties.
with the National Security Presidential Memorandum issued on 8 May 2018 and wind down our
activities with Iran Air as a failure to do so will expose us to potential penalties.
We take this opportunity to thank you for the trust that you have placed in us over the years and
we wish you all the best for the future.
We take this opportunity to thank you for the trust that you have placed in us over the years and
we wish you all the best for the future.
ease jpe! free to contact us with any question you may have regarding this letter.
ease jee! free to contact us with any question you may have regarding this letter.
Copy: Aran Air
Copy: Aran Air
[tr neon'to
[tr(on'to

- 321 -

- 322 -

Annex 267
Letter from a non-U.S. oil company to Iran Air, 18 July 2018
Redacted

- 323 -

- 324 -

•
18" July, 2018
18" July, 2018
Dear Mr Nazeri,
Dear Mr Nazemi,
­
As you are eware, on May 8, 2018, President Trump announced the withdrawal of the U.S from the Iran
As you are aware, on May 8, 2018, President Trump announced the withdrawal of the U.S from the Iran
nuclear deal (the Joint Comprehensive Plan of -Action or ±CPO±); starting a countdown
there
nuclear deal (the Joint
Comprehensive Plan of
-Action or ±CPO); startimg a countdown
there
imposition of certain Iranian sanction waived by the U.S in January 2016.
imposition of certain Iranian sanction waived by the U.S in January 2016.
In conjunction with this announcement, the President issued a National Security Presidential
In conjunction with this announcement, the President issued a National Security Presidential
Memorandum (NSPM) directing the Secretary of Treasury to prepare immediately for the re-imposition
Memorandum (NSPM) directing the Secretary of Treasury to prepare immediately for the re-imposition
of all the U.S sanctions
of all the U.S sanctions
lifted or waived in connection with the JCPOA to be accomplished as
lifted or waived in connection with the JCPOA to be accomplished as
expeditiously as possible and in no case later than 180 days from the NSPM. Departments of State and
expeditiously as possible and in no case later than 180 days from the NSPM. Departments of State and
Treasury have established 90-day and 180-day wind-down periods for certain transaction involving Iran.
Treasury have established 90-day and 180-day wind-down periods for certain transaction involving Iran.
Additionally, no later than November 5, 2018, all persons or entities that have been removed from the
Additionally, no later than November 5, 2018, all persons or entities that have been removed from the
Specially Designated Nationals and Blocked Persons Lists (SDN Listed) and listed as "non-SDNs" due to
the meeting of the definition of Government of Iran or Iranian financial institution will be re-designated
Specially Designated Nationals and Blocked Persons Lists (SDN Listed) and listed as "non-SDNs" due to
the meeting of the definition of Government of Iran or Iranian financial institution will be re-designated
as SDNs.
as SDNs.
one otEoroy business principles is to respect all aorhicable local and iteroatonal aws and
one ot[orey business principles is to respect all aorhicable local and interaatoral aws ad
norms. This principle covers the compliance with all applicable export control and
international
norms. This principle covers the compliance with all applicable export control and
international
economic sanctions laws and regulations.
economic sanctions laws and regulations.
Consequently, the aviation fuel supply agreement was concluded with you ("Agreement") in strict
compliance with those regulations and in particular pursuant to the U.S sanctions relief provided for in
the JCPOA
Consequently, the aviation fuel supply agreement was concluded with you ("Agreement") in strict
compliance with those regulations and in particular pursuant to the U.S sanctions relief provided for in
the JCPOA
Therefore, to avoid exposure to penalties, sanctions or enforcements actions under US law, we must
Therefore, to avoid exposure to penalties, sanctions or enforcements actions under US law, we must
wind-down operations and settle all payments arising out of the aviation fuel supply agreement by
wind-down operations and settle all payments arising out of the aviation fuel supply agreement by
October 30, 2018 midnight or an earlier date if decided otherwise by the U.S government.
October 30, 2018 midnight or an earlier date if decided otherwise by the U.S government.
- 325 -

.--.._hC0ring!y, p!ease be _kindly
informed that_we_.must apply.pre-payment- conditions -as -from-
-­
Accordingly, please , be kindly_informed that_we_must .apply-pre-payment -conditions -as from- .--..­
-..
September 1, 2018 and terminate the Agreement and deliveries of aviation fuel by October 30, 2018
September 1, 2018 and terminate the Agreement and deliveries of aviation fuel by October 30, 2018
midnight. In order to continue deliveries and supplies, we kindly request you to acknowledge the receipt
and acceptance of terms and conditions contained herein by signing this letter and return it by mail to
midnight. In order to continue deliveries and supplies, we kindly request you to acknowledge the receipt
and acceptance of terms and conditions contained herein by signing this letter and return it by mail to
(advanced by
(advanced by
Yours faithfully,
Yours faithfully,
r .
Accepted and acknowledged by:
Accepted and acknowledged by:
Iran Air
Iran Air
Name:
Name:
Title:
Title:
Date:
Date:

- 326 -

Annex 268
Email from a non-U.S. aviation service provider to Iran Air, 24 July 2018
Redacted

- 327 -

- 328 -

Amir Houshang Abdi
Amir Houshan Abdi
i
From:
From
Sent:
Tuesday, July 24, 118 2018 PM
To:
Hesam Seyedin; [email protected] '
Sent:
To:
Tuesday, July 24, 118 2018 PM
Hesam Seyedin; [email protected]
Cc:
Cc:
Subject:
Attachments
RE. AGS UPGRADE
image013.jpg; image014.png; image015jp9. image016jpg. imag
17jpg: image018j0g
Subject:
Attachments
RE. AGS UPGRADE
image013.jpg; image014.png; image015jp9. image016jpg, imag
+017 jpg: image018j0pg
Importance
Importance
High
High
Dear Hesam, Dear Mostafa
Dear Hesam, Dear Mostafa
I hope this mail finds you well
I hope this mail finds you well
We are waiting an official position from
-
as we are not able to work any
re with IRAN because of US sanctions.
we are wag an ofteiat position tom[a=we are not able to wor aoyr re wum IRAN because of us sanctions
Unfortunately, The AGS upgrade was link to our selection and contract for the WE A products on the new-fleet and your
Unfortunately, The AGS upgrade was link to our selection and contract for the WE A products on !he new-fleet and your
or�e_r
a:f th� new
or�e.r
o_f
th; new
aircraft was cancelled.
aircraft was cancelled.
We will come back to you as soon as possible
With my very best regards
-
We will come back to you as soon as possible
With my very best regards
-
- 329 -

- 330 -

Annex 269
Letter from a non-U.S. equipment supplier to Iran Air, 30 August 2018
Redacted

- 331 -

- 332 -

'
.
°
.
-
.
.
.
____ _;_ -�..,_
-
_.:_.,.,........_,,..._�-�--
- 333 -
-
·
.,,.,_
Mr. Shahnematollahi
General Supply Manager of lranair
Germany
Mr. Shahnematollahi
General Supply Manager of Iranair
Germany
el.
1el.
Iranair
Iranair
.' fa.
Mehrabad airport
Tehran/Iran
Mehrabad airport
Tehran/Iran
t.·
Opbenau, August 30", 2018
Oppenau, August 30", 2018
Subject:
t
.
·
Subject:
- your email dated on.April 7", 2018 regarding the towing tractor
+
- your email dated on August 1,2018 regarding spare parts
- your email dated on.April 7", 2018 regarding the towing
tractor
- your email dated on August 1,2018 regarding spare parts
+ u
·Dear Mr. Shahnematollahi,
·Dear Mr. Shahnematollahi,
t would like to thank you for your trust in comparan tor the long business partnership.
t would mike to thank you for your trust in comparan tor the long business partnership.
We as]
We as]
lwere very pleased in 2016 that.the sanction were finally released and we hoped to
re-setup our
lwere very pleased in 2016 that.the sanction were finally released and we hoped to
re-setup our
business relation with your esteemed company in order to support you with our equipment, as well as spare pats.
business relation with your esteemed company in order to support you with our equipment, as well as spare parts.
we started wt the trst baggage tractors[an pushtacctactors[
we started wt the trst baggage tractors[an pushtacctactors[
erect ahter tie sancttois
erect aher ire sanctois
and those products are now in operation since 2017 in addition to the existing baggage tractors which have been
and those products are now in operation since 2017 in addition to the existing baggage tractors which have been
delivered in 20o7 together wt our transporters[suppled by company [om Germany.
delivered in 2007 together wnth our transporters[suppled by company Som Germany.
.
.
•·
I
,.
I
Due to the new US sanction against the Islamic Republic of Iran from August 1, 2018 we are threatened by the
so-called secondary sanctions in case we do further business with any Iranian company!
Due to the new US sanction against the Islamic Republic of Iran from August 1, 2018 we are threatened by the
so-called secondary sanctions in case we do further business with any Iranian company!
That means we face the:risk to be listed at the US sanction list, which affects us in the way that we cannot do
business any more with,any American company, supplier or customer. This mainly affects us especially in regard
That means we face the:risk to be listed at the US sanction list, which affects us in the way that we cannot do
American
business any more with,any
company, supplier or customer. This mainly affects us
especially in regard
to e.g. drivetrain comp~nerits like automatic gearboxes, engine components and electronic part¢.
to e.g. drivetrain comp~nerits like automatic gearboxes, engine components and electronic parts.
Regarding your payment for the pushback
Regarding your payment for the pushback
tractor[we
have had many meetings wit our hanks to 6a%
tractor[we
have had many meetings wit or hanks to 6a%
sure if there is any possibility to transfer your payment back. Unfortunately, none of our banks is willing to
transfer
the payment back because of the risk of further US sanctions.
;
:
sure if there is any possibility to transfer your payment back. Unfortunately, none of our banks is willing to
transfer
the payment back because of the risk of further US sanctions.
.
:
Therefore, we see no other possibility as to store your payment until the sanctions are released. We furthermore
ensure you that we will manufacture a new tractor,based on the current specification for the soc
Therefore, we see no other possibility as to store your payment until the sanctions are released. We furthermore
ensure you that we will manufacture a new tractor,based on the current specification for the soc
amount even in case the product price has increase.on.
amount even in case the product price has increa.on.

t
I
I
'
I
/
/
Seite 2
Seite 2
,
,
I hope you can understand our difficult situation and would be grateful to keep you as a highly appreciated
I hope you can understand our difficult situation and would be grateful to keep you as a highly appreciated
+
.
,
custoner.
custoner.
Sincerely yours,
Sincerely yours,
t
t
if
+
;
t

- 334 -

Annex 270
Letter from IATA to Iran Air, 14 September 2018

- 335 -

- 336 -

..
14 Sepirober 2018
14 Sepierober 2018
Dr. Farzanah Sharafbafi
Chief Executive Officer
Iran Air
Dr. Farzanah Sharafbafi
Chief Executive Officer
Iran Air
ran jiu Headquarters
Mehrabad Airport
ran #it Headquarters
Mehrabad Airport
.0. 30x 13185-775
5.0. 30x 13185-775
Tehren
Tenren
static Republic of Iran
static Republic of Iran
Dear Dr. Sharafbafi,
Dear Dr. Sharafbafi,
Than you for your letter of 15 July.
Than you for your letter of 15July.
smcerely regret tnat, despite IATA's earlier intention to re-establish a BSP in lran, we have
sincerely regret tnat, cespile IATA's earlier intention to
re-establish
a BSP in lran, we have
now determined that recent developments will make it impossible for us to do so -- at least
until the geopolitical situation improves.
now determined that recent developments will make it impossible for us to do so -- at least
'
until the geopolitical situation improves.
'
As you know, on 7 August of this year, having withdrawn
hs you know, on 7 August of this year, having withdrawn unilaterally from the Joint
Comprehensive Plan of Action ("JCPOA"), the United States re-imposed "secondary
sanctions" targeting non-U.S. persons engaged in commercial activities with Iran. As a
result, even though IATA is a Canadian corporation, certain of our activities -- in particular,
unilaterally from the Joint
Comprehensive Plan of Action ("JCPOA"), the United States re-imposed "secondary
sanctions" targeting non-U.S. persons engaged in commercial activities with Iran. As a
resalt, even though IATA is a Canadian corporation, certain of our activities -- in particular,
any financial services IATA had intended to offer Member airlines headquartered in Iran ­
any financial services IATA had intended to offer Member airlines headquartered in Iran ­
are effectively prohibited because of the many global restrictions that U.S, has imposed on
frzncial transactions with Iranian persons.
are effectively prohibited because of the many global restrictions that U.S. has imposed on
fzzncial transactions with Iranian persons.
.
'
·
:,·t,
.' i
.
Moreover, as of 4 November the U.S. will
Moreover, as of 4 November the U.S. will re-impose full sanctions on financial transactions
with tran. Given [ATA's presence and activilies in the U.S. and With U,S. financial institutions
re-impose
full sanctions on financial transactions
with tran. Given [ATA's presence and activilies in the U.S. and With U,S. financial institutions
around thc globe, re have determined that U.S. restrictions will have a direct impact on
around thc globe, we have determined that U.S. restrictions will have a direct impact on
IATA's financial operations. This means that IATA will be effectively foreclosed from
IATA's financial operations. This means that IATA will be effectively foreclosed from
engaging in settlement or other financial activities in ran until the sanctions are lifted,
engaging in settlement or other financial activities in Iran until the sanctions are lifted,
ln short, the re-imposed U,S: sanctions will make it
In short, the re-impose U,S: sanctions will make it
impossible
for IATA to offer any financial
impossible
for IATA to offer any financial
element services to iranian entities, either in or outside of Iran, for travel agent, interline,
zetlement serices to iranian entities, either in or outside of Iran, for travel agent, interline,
: other transactions.
:'her transactions.
/2
/2
BC Fiacc Veto/BP 1!
Roi pent3:.70.-o 1.
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I;'5 Gene gad
BFiacc Veto/BP 1!
#el, Cube
Roi ti¢pen3:.70.=o 1.
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gad
Cane H? 14;1
5:ct:rd
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Scurti
e +15a700
Fr+1514674; &57
t
s«v.ta
te +15it3700
+«tu
Fr.+514674 2&57
Fa -ti;>T'&
arc$tat.ug
4tr$tat«g
car8gt«
zez7

- 337 -

- 338 -

Annex 271
Letter from a French bank to Iran Air, 17 September 2018
Redacted

- 339 -

- 340 -

le 17 septembre 2018
le 17 septembre 2018
IRAN AIR
IRAN AIR
63 avenue des Champs Elys~es
63 avenue des Champs Elys~es
75008 Parls
75008 Parl5
Al'attention de Mr Nazemi
Al'attention de Mr Nazemi
a« 1A 070287 737} %
ma 1A 07022 73 7} 6
Monsieur,
Monsieur,
Je vous informe que, dans le cadre de notre politlque de gestion des risques,
»decide de proceder ~ ta dbture de votre compte ouvert dans nos fires sous le
Je vous informe que, dans le cadre de notre politlque de gestion des risques,
»dcide de proceder ~ ta dbture de votre compte ouvert dans nos livres sous le
numroll
et e. s copter o 19 ·v«more 2o1s
numFeet ee. s comoter do 19 ·vemre 2o1s
Cette cloture est effeetu~e elonles-modaites -prevues-~-+'article
L21ltV)du code [
Cette cloture est effeetu~e elon les-modates prevues-~l'article
L21ltV du code l
mon~taire et financier,
mon~taire et financier,
Je vous remercie de bien vouloir nous indiquer dans les meilleurs d~lais les coordonn~es de la
banquve vers laquelle vous souhaiter faire transf~rer vos ~ventuels avoirs detenus dans nos
Je vous remercie de bien vouloir nous indiquer dans les meilleurs d~lais les coordonn~es de la
oanque vers laquelle vous souhaiter faire transf~rer vos ~ventuels avoirs detenus dans nos
Vres.
.
vres.
...
Je vous prie, Monsieur, d'avoir l'assurance de ma consideration la meilleure.
Je vous prie, Monsieur, d'avoir l'assurance de ma consideration la meilleure.
-- -"
...
-- -"

- 341 -

- 342 -

Annex 272
Email from a fuel supplier to Iran Air, 5 November 2018
Redacted

- 343 -

- 344 -

lrwdr
from. Mohre heydat «<heydnt. rohrrlr.goers»
From. ghrned heydat «hedn. mohrrireir.goer»
bjet Fuel Stop AM
bet· fuel Stop AM
Tuesday, Decerrber 04, 2018 0448 PM
Fuel
Fuel
I.lrges Moeinil «roeirink-weir.corp»
I.irges Moeinil «oeirink.re.ir.coer»
Stop
Stop
btrrat ires re not diiyd, Dply gs blow
bterrt es re not digitryd, Di.ply eges below
ieherpetete Nchict •
HAM
HAM
ieherpetete Nchict •
betreff fuel Stop AM
betreffr fuet Stop AM
Datum:
Datum: Me
Von;
Von:
A:
A fate
opie(
lopie (CC)
Good dry,
Good dry,
further!
further f
iirport
+irport Pee
€
€
Guten 2g,
Guten 2g,
fat nach nicht belannt:
Afgund der ateriegten Sanltinen gegen~be des Lr, wird unr Supp
Afgund der ateriegten Sanltionen gegen~be des Lr, ird unr Supp
Ueferngen mn 4nrburg Alpert durcht@en. Ste plwen Se es ranttg mt er
Ueferngen mn 4nrburg Alpert durcht@en. Ste plwen Se es
rantg mt
ts tut mir leid, urns sind eider de de geburden, heft trotter uf belie wider Auf'nature der Zurrrrenrbeet
ts tut mir leid, urns sind eider die Hide geburden, heoffe toter uf belie wider Auf'nature de Zuas.rrrencrbeet
€
-
€
-
y
y

- 345 -

- 346 -

Annex 273
Letter from Airbus to Zagros Airlines, 11 November 2018

- 347 -

- 348 -

Dossier Reference:
Dossier Reference:
AIRBUS
TD Operations Support
AIRBUS
TD Operations Support
80539045
80539045
__ .__
Airnav-Maintenance for IZG
Creation date dossier
Airnav-Maintenance for IZG
Creation date dossier
Customer Services
Customer Services
11-NOV-2018
11-NOV-2018
Company:
Requestor:
ZAGROS AIRLINES
ANDRII SHALAI
AIC Type:
A320
Category:
TD Distribution
Company:
Requestor:
Visible by:
ZAGROS AIRLINES
ANDRII SHALAI
AIC Type:
A320
Category:
TD Distribution
Visible by:
Sub Category: Technical Data Package
Sub Category: Technical Data Package
Messages:
Messages:
Airbus Reference ;
Airbus Reference :
AIRNAV-MAINTENANCE
FOR IZG
Title : IZG - Aimav Maintenance
Submitted date : 12-NOV-2018 15.39 UTC+1 DST
Final Answer :N
Urgency:
Requested Answer:
AIRNAV-MAINTENANCE
FOR IZG
Title : IZG - Airnav Maintenance
Submitted date : 12-NOV-2018 15.39 UTC+1 DST
Final Answer : N
Urgency:
Requested Answer :
80539045/003
80539045/003
Requestor Reference ;
Requestor Reference :
Planned Answer :
Planned Answer :
Message:
Dear Customer;
Message:
Dear Customer;
Please be informed that due lo Export Control Restrictions we are currently unable to provide IZG with
access to IZG AirN@v Maintenance.
Please be informed that due to Export Control Restrictions we are currently unable to provide IZG with
access to IZG AirN@v Maintenance.
With Best regards,
Mathilde BOILEVIN
Customers Orders and Fleet Management - SEDOR2
Technical Data - Customer Services
AIRBUS
Phone : +33/(0)5 61 93 46 31
With Best regards,
Mathilde BOILEVIN
Customers Orders and Fleet Management - SEDOR2
Technical Data - Customer Services
AIRBUS
Phone : +33/(0)5 61 93 46 31
Message reference:
Message reference:
AN2U A20a A th f.cf th!d p4pity
{e$ 00et4e4$2p+ratio contained neat
80539045/003
a4NU A20# A Ahr f.cf th.et d pengity et e$ 0et4e$be«pee0ion enaii0 neat
80539045/003
atesoi pry a!USS43Mite#deer party aght grad 4coy o this eouetertedious ot
atesoi gory a!AU$SA434Nit6deer party gt grad t hoy ot this ouetertdiour t
cot his douwet a eat be reproduced or costs tturd party ttot A ts ere 000$14 0/ AUS SAS 70i
cot This doouwet a meat be reproved or scot$turd party ttot A test ere 000$1t A9US $AS 70i
Page 1/1
Page 1/1
curt@nits cool4dotted#a spos ole th .et tee trigs.phis
Export date:
Export date:
curt@nits coo4dotted#a spos ol thn .et ee trigs.phis
12-NOV-2018
12-NOV-2018

- 349 -

- 350 -

Annex 274
Email from Boeing to Zagros Airlines, 20 November 2018

- 351 -

- 352 -

Behzad Seifan
Behzad Seifan
From:
From:
Sent:
To:
Cc:
Washke (US), David A <[email protected]>
Tuesday, November 20, 2018 208 AM
Behzad Seifan
Wilks (US), Matthew W; Richesin (US), Craig S; Hickman (US), Jeffrey J; Daley (US),
Michael W; Daghestani, Fakher A; Salloum (US), Dana I; 'Gholamreza Yadollahi'; 'Jafar
Babaei'; Riverman (US), Tracey L
RE: Maintenance Data
Sent:
Washke (US), David A <[email protected]>
Tuesday, November 20, 2018 208 AM
To:
Cc
Behzad Seifan
Wilks (US), Matthew W; Richesin {US), Craig S; Hickman (US), Jeffrey J; Daley (US),
Michael W; Daghestani, Fakher A; Salloum (US), Dana I; 'Gholamreza Yadollahi'; 'Jafar
Babaei'; Riverman (US), Tracey L
RE: Maintenance Data
Subject:
Subject:
Hello, Mr. Seifan.
Hello, Mr. Seifan.
As referenced below, the export license that Boeing had been using to provide conditional support to Iranian airlines
expired in June 2017 and has not been renewed by the United States Government. This means that, unfortunately,
Boeing cannot respond to your request because at the present time we are not authorized to provide any technical
support or technology exports to Iran.
As referenced below, the export license that Boeing had been using to provide conditional support to Iranian airlines
expired in June 2017 and has not been renewed by the United States Government. This means that, unfortunately,
Boeing cannot respond to your request because at the present time we are not authorized to provide any technical
support or technology exports to Iran.
Regards,
Regards,
David Washke
David Washke
Airline Support Engineering
Customer Support
Airline Support Engineering
Customer Support
Boeing Commercial Airplanes
Boeing Commercial Airplanes
Phone: 562.797.1787
Phone: 562.797.1787
[ Fax: 562.797.1287
] Fax: 562,797.1287
Mobile: 562.243.3052
Mobile: 562.243.3052
[ [email protected]
] [email protected]
From: Behzad Seifan [mailto:[email protected]]
From: Behzad Seifan [mailto:[email protected]]
Sent: Saturday, November 17, 2018 11:22 PM
Sent: Saturday, November 17, 2018 11:22 PM
To: Washke (US), David A <[email protected]>; Wilks (US), Matthew W <[email protected]>;
Richesin (US), Craig S <[email protected]>; Hickman (US), Jeffrey J <[email protected]>; Daley
(US), Michael W <[email protected]>; Daghestani, Fakher A <[email protected]>; Salloum
(US), Dana I <[email protected]>
Cc: 'Gholamreza Yadollahi' <[email protected]>; 'Jafar Babaei'
<[email protected]>
Subject: RE: Maintenance Data
To: Washke (US), David A <[email protected]>; Wilks (US), Matthew W <[email protected]>;
Richesin (US), Craig S <[email protected]>; Hickman (US), Jeffrey J <[email protected]>; Daley
(US), Michael W <[email protected]>; Daghestani, Fakher A <[email protected]>; Salloum
(US), Dana ! <[email protected]>
Cc: 'Gholamreza Yadollahi' <[email protected]>; 'Jafar Babaei'
<[email protected]>
Subject: RE: Maintenance Data
Dear Sir
As you see in attached according to the recent "International Court of Justice" also spare parts, equipment and
associated services (including warranty, maintenance, repair services and inspections) necessary for the safety of civil
aviation are excluded from U.S sanctions. I should emphasis that AD's ,mandatory S8's, Maintenance data's and
Dear Sir
As you see in attached according to the recent "International Court of Justice" also spare parts, equipment and
associated services (including warranty, maintenance, repair services and inspections) necessary for the safety of civil
aviation are excluded from U.S sanctions. I should emphasis that AD's ,mandatory SB's, Maintenance data's and
Operation publications are directly related to safety of civil aviation.
Operation publications are directly related to safety of civil aviation.
Please help us and do whatever you can because this is an Humanitarian action absolutely and I'm sure that you believe
it too.
Thanks
Best Regards
Please help us and do whatever you can because this is an Humanitarian action absolutely and I'm sure that you believe
it too.
Thanks
Best Regards

- 353 -

- 354 -

Annex 275
Letter from Airbus to Zagros Airlines, 13 December 2018

- 355 -

- 356 -

Dossier Reference:
Dossier Reference:
AIRBUS
Engineering
AIRBUS
Engineering
80554288
80554288
FMGC
Creation date dossier
FMGC
Creation date dossier.
Customer Services
Customer Services
13-DEC-2018
13-DEC-2018
A/C Type:
A320
22-83
ATA:
Requestor: ZAGROS AIRLINES
MSN:
00999
Requestor: ZAGROS AIRLINES
MSN:
00999
P/N:
P/N:
Topic:
Sub-topic:
Reference:
SIN:
Visible by:
SIN:
Visible by:
A/C Type:
ATA:
Topic:
Sub-topic:
Reference:
Aircraft FC:
Aircraft FH:
A320
22-83
Aircraft FC:
Aircraft FH:
··················-·-···-·-···-·-----'--'----'--------
Messages
Messages
Airbus Reference: 80554288/003
Requestor Reference :
Airbus Reference: 80554288/003
Requestor Reference :
Title: FMGC
Submitted date : 13 DEC-2018 14:02 UTC+1 DST
Final Answer : N
Urgency :
Requested Answer:
Planned Answer:
Title: FMGC
Submitted date : 13 DEC-2018 14:02 UTC+t DST
Final Answer : N
Urgency:
Requested Answer:
Planned Answer:
Message :
Message :
Dear customer,
Dear customer,
We regret to inform you that due to export control sanctions and embargoes regulations, we are not in
position lo provide you with the requested information. For any clarification on this restrictions, please
contact your Airbus focal point.
We regret to inform you that due to export control sanctions and embargoes regulations, we are not in
position to provide you with the requested information. For any clarification on this restrictions, please
contact your Airbus focal point.
Best regards,
Marc DELHAYE
SB Design Manager
Airbus Upgrade Services
Best regards,
Marc DELHAYE
SB Design Manager
Airbus Upgrade Services
Message reference
Message reference
80554288/003 ARE$ 8AS01% A0gt nerved Cerf.sial sew pro.er ctoc«et Ta cm&et aw at i.term.ion coctet herein
80554288/003
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is ta to property bl4AU$SAS NitrfetaN pooprygit a graet they of this octet or th c.aw oled
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Export date:
Export date:
d0cunt
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its oat«et4ha' et b .et # Ary uoC tat tee wt.c ea.pl.f
its oat«et4ha' net .et le Ary pu o ta tee wt.cu.pl.f
13-DEC-2018
13-DEC-2018

- 357 -

- 358 -

Annex 276
Set of letters from a non-U.S. airline company to Iran Air, 31 January 2019
Redacted

- 359 -

- 360 -

-
--
-
--
I
31/01/2019
IE
31/01/2019
Ms. Farzaneh Sharafbafi
Ms. Farzaneh Sharafbafi
CEO
CEO
Iran Air
Iran Air
Dear Ms. Sharafbafi,
Dear Ms. Sharafbafi,
On behalf of
to greet you with regards.
On behalf of
to greet you with regards.
I would like to take this opportunity
I would like to take this opportunity
As you are aware, with its two-stage withdrawal from the Joint Comprehensive Plan of Action
("JCPOA"), as of August 07, 2018 and November 05, 2018 the U.S. had re-imposed all the
limitations it had previously suspended upon implementation of the JCPOA In January 2016.
As you are aware, with its two-stage withdrawal from the Joint Comprehensive Plan of Action
("JCPOA"), as of August 07, 2018 and November 05, 2018 the U.S. had re-imposed all the
limitations it had previously suspended upon implementation of the JCPOA In January 2016.
Following the withdrawal from the JCPOA, those limitations were fully re-imposed -in the form
of secondary sanctions- in two stages, one completed on August_07, 2018, and the second
completed on November 05, 2018, which also affected our partnership on Special Prorate
Agreement ("SPA").
Following the withdrawal from the JCPOA, those limitations were fully re-imposed -in the form
of secondary sanctions- in two stages, one completed on August_07, 2018, and the second
completed on November 05, 2018, which also affected our partnership on Special Prorate
Agreement ""SPA")
In ight of the above and considering the recent developments,[
provides
hereby
In ight of the above and considering the recent developments,[
provides
hereby
you with written notice of termination of the Special Prorate Agreement, which as set forth in
article 3 herein. After 30 days upon the sending te of this notce, the SPA between[
you with written notice of termination of the Special Prorate Agreement, which as set forth in
article 3 herein. After 30 days upon the sending te of this notce, the SPA between[
and Iran ir will be term ated in line with abovementioner duse 'wt fc ernlnatoi
and Iran it wf be term ated in line with abovementioner clause 'wt fc ernnatoi
,sf eude a termination of any, and al rights, uthorties, obligations and liabilities of the
parties arising out of or under the SPA).
eude a termination of any, and al rights, uthorties, obligations and llabilities of the
parties arising out of or under the SPA).
We thank you for your understanding.
We thank you for your understanding.
Yours sincerely,
Yours sincerely,
- 361 -

--■
--■
31/01/2019
31/01/2019
Ms. Farzaneh Sharafbafi
Ms. Farzaneh Sharafbafi
CEO
CEO
Iran Air
Iran Air
Dear Ms. Sharafbaf,
Dear Ms. Sharafbafi,
On behalf of
to greet you with regards.
On behalf of
to greet you with regards.
J would like to take this opportunity
I would like to take this opportunity
As you are aware, with its two-stage withdrawal from the Joint Comprehensive Plan of Action
("CPOA"), as of August 07, 2018 and November 05, 2018 the U.S. had re-imposed all the
limitations it had previously suspended upon implementation of the JCPOA in January 2016.
As you are aware, with its two-stage withdrawal from the Joint Comprehensive Plan of Action
("CPOA"), as of August 07, 2018 and November 05, 2018 the U.S. had re-imposed al the
limitations it had previously suspended upon implementation of the JCPOA in January 2016.
Following the withdrawal from the JCPOA, those limitations were fully re-imposed -in the form
of secondary sanctions- in two stages, one completed on August 07, 2018, and the second
completed on November 05, 2018, which also affected our partnership on Codeshare
Agreement.
Following the withdrawal from the JCPOA, those limitations were fully re-imposed -in the form
of secondary sanctions- in two stages, one completed on August 07, 2018, and the second
completed on November 05, 2018, which also affected our partnership on Codeshare
Agreement.
'
'
In light of the above and considering the recent developments,[
hereby provides
In light of the above and considering the recent developments,[
hereby provides
you with written notice of termination of the Codeshare Agreement, which as set forth in article
24 therein. After 60 days upon the receipt of this notice, the Codeshare Agreement between
[ind Iran Air will be terminated in fine with abovementioned clause (which
you with written notice of termination of the Codeshare Agreement, which as set forth in article
24 therein. After 60 days upon the receipt of this notice, the Codeshare Agreement between
[ind Iran Air will be terminated in tine with abovementioned cdeuse (which
TT.SM} clude a termination of any, and all rights, authorities, obligations and
liabilities of the parties arising out of or under the Codeshare Agreement).
TT.SM} clude a termination of any, and all rights, authorities, obligations and
liabilities of the parties arising out of or under the Codeshare Agreement).
We thank you for your understanding.
We thank you for your understanding.
-- ·- -- ------
-- ·- -· ·-----
- 362 -

AA
""
--
�
31/01/2019
IE
31/01/2019
Ms. Farzaneh Sharafbafi
Ms. Farzaneh Sharafbafi
CEO
CEO
Iran Air
Iran Air
Dear Ms. Sharafbafi,
Dear Ms. Sharafbafi,
on behalf of
I would like to take this opportunity
on behalf of
I would like to take this opportunity
to greet you with regards.
to greet you with regards.
As you are aware, with its two-stage withdrawal from the Joint Comprehensive Plan of Action
("JCPOA"), as of August 07, 2018 and November 05, 2018 the U.S. had re-imposed all the
limitations it had previously suspended upon implementation of the JCPOA in January 2016.
As you are aware, with its two-stage withdrawal from the Joint Comprehensive Plan of Action
("JCPOA"), as of August 07, 2018 and November 05, 2018 the U.S. had re-imposed all the
limitations it had previously suspended upon implementation of the JCPOA in January 2016.
Following the withdrawal from the JCPOA, those limitations were fully re-imposed -in the form
of secondary sanctions- in two stages, one completed on August 07, 2018, and the second
completed on November 05, 2018, which also affected our partnership on ZED-Interline Staff
Travel Agreement.
Following the withdrawal from the JCPOA, those limitations were fully re-imposed -in the form
of secondary sanctions- in two stages, one completed on August 07, 2018, and the second
completed on November 05, 2018, which also affected our partnership on ZED-Interline Staff
Travel Agreement.
In tight of the above and considering the recent developments,
I
hereby provides
In tight of the above and considering the recent developments,
I
hereby provides
you with written notice of termination of the ZED-Interline Staff Travel Agreement, which as
set forth in article B.4.a. "Terms and Termination" therein. AES3.2/5.g29n the receipt of
you with written notice of termination of the ZED-Interline Staff Travel Agreement, which as
set forth in article B.4.a. "Terms and Termination" therein. AES3.2/5.g2go the receipt of
this notice, the ZED-Interline staff Travel Agreement between[i_end 1ran Air wi
this notice, the ZED-Interline staff Travel Agreement between Si_lend 1ran Air wit
be terminated in line with abovementioned dause (which termination shall include a
be terminated in line with abovementioned dause (which termination shall include a
termination of any and all rights, authorities, obligations and liabilities of the parties arising
termination of any and all rights, authorities, obligations and liabilities of the parties arising
out of or under the ZED-Interline Staff Travel Agreement).
out of or under the ZED-Interline Staff Travel Agreement).
We thank you for your understanding.
We thank you for your understanding.
Yours sincerely,
Yours sincerely,
---------. ---
­
- 363 -

A1
la
la
IE
31/01/2019
IE
31/01/2019
Ms. Farzaneh Sharafbafi
CEO
Ms. Farzaneh Sharafbafi
CEO
Iran Air
Iran Air
Dear Ms. Sharafbafi,
Dear Ms. Sharafbafi,
On behalf of
to greet you with regards.
On behalf of
to greet you with regards.
I would like to take this opportunity
I would like to take this opportunity
As you are aware, with its two·stage' withdrawal from the Joint Comprehensive Plan of Action
("JCPOA"), as of August 07, 2018 and November 05, 2018 the U.S. had re-imposed all the
limitations it had previously suspended upon implementation of the )CPOA in January 2016.
As you are aware, with its two·stage withdrawal from the Joint Comprehensive Plan of Action
("JCPOA"), as of August 07, 2018 and November 05, 2018 the U.S. had re-imposed all the
limitations it had previously suspended upon implementation of the )CPOA in January 2016.
Following the withdrawal from the JCPOA, those limitations were fully re-imposed -in the form
of secondary sanctions- in two stages, one completed on August 07, 2018, and the second
completed on November 05, 2018, which also affected our partnership on FIM[Involuntary
Reroute Agreement (FIM).
Following the withdrawal from the JCPOA, those limitations were fully re-imposed -in the form
of secondary sanctions- in two stages, one completed on August 07, 2018, and the second
completed on November 05, 2018, which also affected our partnership on FIM[Involuntary
Reroute Agreement (FIM).
non er te above no considers me recent
evetoriet.Lees»
rowes
non er te above no considers te recent
develop#rents.Lees»
rowes
you with written notice of termination of the FIM/Involuntary_Reroute Agreement (FIM), which
as set forth in Article 6 therein. After 30 days upon the sending date of this notice, the FIM
between[and 1ran Air will be terminated in line with ebovementioned clause
you with written notice of termination of the FIM/Involuntary Reroute Agreement (FIM), which
as set forth in Article 6 therein. After 30 days upon the sending date of this notice, the FIM
between[and 1ran Air will be terminated in line with abovementioned clause
(which termination shall indude a termination of any and, all rights, authorities, obligations
(which termination shall indude a termination of any and, all rights, authorities, obligations
and liabilities of the parties arising out of or under the FIM),
and liabilities of the parties arising out of or under the FIM),
We thank you for your understanding.
We thank you for your understanding.
--------· ---- - . ·-------
--------· ---- - - ·-------
- 364 -

---
---
J
31/01/2019
A
31/01/2019
Ms. Farzaneh Sharafbafl
Ms. Farzaneh Sharafbafl
CEO
CEO
Iran Air
Iran Air
Dear Ms. Sharafbafi,
Dear Ms. Sharafbafi,
On behalf of
, I would like to take this opportunity
to greet you with regards.
On behalf of
to greet you with regards.
, I would like to take this opportunity
As you are aware, with its two-stage withdrawal from the Joint Comprehensive Plan of Action
("JCPOA"), as of August 07, 2018 and November 05, 2018 the U.S. had re-imposed all the
limitations it had previously suspended upon implementation of the JCPOA in January 2016.
As you are aware, with its two-stage withdrawal from the Joint Comprehensive Plan of Action
("JCPOA"), as of August 07, 2018 and November 05, 2018 the U.S. had re-imposed all the
limitations it had previously suspended upon implementation of the JCPOA in January 2016.
Following the withdrawal from the JCPOA, those limitations were fully re-imposed -in the form
of secondary sanctions- in two stages, one completed on August 07, 2018, and the second
completed on November 05, 2018, which also affected our partnership on Direct Billing
Agreement.
Following the withdrawal from the )CPOA, those limitations were fully re-imposed -in the form
of secondary sanctions- in two stages, one completed on August 07, 2018, and the second
completed on November 05, 2018, which also affected our partnership on Direct Billing
Agreement.
In light of the above and considering the recent developments,,
In light of the above and considering the recent developments,,
hereby provides
hereby provides
you with written notice of termination of the Direct Billing Agreement, which as set forth in
article 5 therein. After 30 days upon the receipt of this notice, the Direct Billing Agreement
you with written notice of termination of the Direct Billing Agreement, which as set forth in
article 5 therein. After 30 days upon the receipt of this notice, the Direct Billing Agreement
between[ad 1ran Ai w be terminated in he wt abovementioned clause
between[ad 1ran Ai w be terminated in he wt abovementioned clause
(which termination shall include a termination of any, and all rights, authorities, obligations
and liabllities of the parties arising out of or under the Direct Billing Agreement).
(which termination shall include a termination of any, and all rights, authorities, obligations
and liabllities of the parties arising out of or under the Direct Billing Agreement).
We thank you for your understanding
We thank you for your understanding
-
-
Yours sincerely,
Yours sincerely,

- 365 -

- 366 -

Annex 277
Email from Honeywell to Kish Air, 9 April 2019

- 367 -

- 368 -

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ASSOCIATION of IRANIAN AIRLINES
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- 369 -
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ASSOCIATION of IRANIAN AIRLINES
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c5,st
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€5,dt»MD (Safety Issue);t55US8 Over Wing Heater Blanket
d-ls3h9-Re?sj)a~ldt
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Ab ? pl «db$· l' Jl; ,litl «·4ask'·!Sul
www.aira.ir:clay [email protected]:JI FF·Fr· :S FF·YYF - FF.FYFW: ;il

THE LETTEREHEAD OF ASSOCIATION OF IRANIAN AIRLINES
THE LETTEREHEAD OF ASSOCIATION OF IRANIAN AIRLINES
NO. 98/4420
NO. 98/4420
DATE: 02/02/1398 [22 April 2019]
DATE: 02/02/1398 [22 April 2019]
Attachment: 2 pages
Attachment: 2 pages
Centre for International Legal Affairs, Presidential Office
Centre for International Legal Affairs, Presidential Office
Greeting,
Greeting,
Following the letter No. 97 /4075 dated 04/10/1397 [25 December 2018], enclosed please
kindly find, for making any use thereof, a copy of an email [sic] to Kish Air concerning
Honeywell's refusal from cooperation with regard to SB Over Wing Heater Blanket for MD
fleet (Safety Issue) due to the issues arising from the [US] sanctions.
Following the letter No. 97 /4075 dated 04/10/1397 [25 December 2018], enclosed please
kindly find, for making any use thereof, a copy of an email [sic] to Kish Air concerning
Honeywell's refusal from cooperation with regard to SB Over Wing Heater Blanket for MD
fleet (Safety Issue) due to the issues arising from the [US] sanctions.
Samani
Samani
Secretary of Association of Iranian Airlines
Secretary of Association of Iranian Airlines
[SEAL AND SIGNATURE]
[SEAL AND SIGNATURE]
- 370 -

·
I
4/16/2019 12:11 AM FRGM: Fax TO: 44014440 PAGE: 0O Or'po?
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Begin forwarded message:
Begin forwarded message:
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Fi@r: hamed'sh <[ish@[email protected]>
Fr~r: hamed 'sh <<dish@[email protected]>
?'p~j&:. Abril 9, 2019 at 2di35:11 GMT,4.30
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is~bj@ct: Fwd: Response to Honeywell Reference Case # : 00813597
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participate in business or financial activities, directly or indirectly in any way, with 2ny lran legal e«ti or
With aniy business located in Iran, due to commercial and other business reasons:·.',·
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- 371 -
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Et'~jjk you for.the prompt reply I should intormi you recently /MRO found some fa~lt, in
the overiing hester
zbjahket system but because they o not have related SBs consequently fault cannot be rectified'h%n%
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ty issue subject.
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$416/2019 12:11 AM FRO: Fax 70; 44014440
4426/2019 12:11 AM FR: Fa: 70; 44014440 PAGE: 002
= o3
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i. Hamed shokuhi
@Aio Manager:
i
Hamed shokouhi
e·
@io Manager
Kish Airlines
"
Kish Airlines
"
Phone: +98 764 4444071-2
Phone: +98 764 4444071-2
Cell: +98 912 2156542
cell: +98 912 2156542
E-tail: [email protected]
E-rail: [email protected]
.. ·.:; •,
-i· -
"~med shokouhi
.CMO Manager.
Kish Airlines
·Phone: +98 764 4444071-2 '
-C~l; +98 912 2156542
'Er'~il: [email protected]
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Annex 278
“Iranian airline finalizes deal to purchase 60 Boeing planes”, AP, 10 June 2017

- 373 -

- 374 -

Iranian airline finalizes deal to purchase 60 Boeing planes
Iranian airline finalizes deal to purchase 60 Boeing planes
E]nypost.com/2017/06/10/iranian-airline-finalizes-deal-to-purchase-60-boeing-planes/
E]
nypost.com
/2017/06/10/iranian-airline-finalizes-deal-to-purchase-60-boeing-planes/
By Associated Press
Modal Trigger
By Associated Press
Modal Trigger
TEHRAN, Iran -
TEHRAN, Iran -
Iran's official IRNA news agency is reporting that the country's Aseman Airlines has finalized a
Iran's official IRNA news agency is reporting that the country's Aseman Airlines has finalized a
deal to purchase 60 planes from the American company Boeing.
deal to purchase 60 planes from the American company Boeing.
The Saturday report said that the planes will be
delivered in two batches and the first batch will
consist of 30 737 passenger planes to be
delivered in 2019.
The Saturday report said that the planes will be
delivered in two batches and the first batch will
consist of 30 737 passenger planes to be
delivered in 2019.
This is the second deal between the Chicago-based Boeing and an Iranian airliner since a landmark nuclear
agreement between Iran and world powers went into practice in 2016.
This is the second deal between the Chicago-based Boeing and an Iranian airliner since a landmark nuclear
agreement between Iran and world powers went into practice in 2016.
In December Iran Air, the country's flag carrier, finalized a $16.6 billion deal with Boeing to purchase 80 passenger
planes.
In December Iran Air, the country's flag carrier, finalized a $16.6 billion deal with Boeing to purchase 80 passenger
planes.
In September, Washington granted permission to Boeing and its European competitor Airbus to sell billions of dollars
worth of aircraft to Iran.
In September, Washington granted permission to Boeing and its European competitor Airbus to sell billions of dollars
worth of aircraft to Iran.
1/1
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- 376 -

Annex 279
“Iran Aseman Airlines crash: Years of sanctions have left passengers with one of
oldest air fleets in the world”, The Independent, 18 February 2018

- 377 -

- 378 -

Independent News Email
Independent News Email
independent.co.uk/news/world/middle-east/iran-aviation-crash-aseman-airlines-oldest-fleet-boeing-727-a8216221.html
independent.co.uk/news/world/middle-east/iran-aviation-crash-aseman-airlines-oldest-fleet-boeing-727-a8216221.html
February 18, 2018
February 18, 2018
News» World » Middle East
News » World » Middle East
Iran Aseman Airlines crash: Years of sanctions have left
passengers with one of oldest air fleets in the world
Iran Aseman Airlines crash: Years of sanctions have left
passengers with one of oldest air fleets in the world
Until the new planes arrive - possibly never, if President
Trump decides to ban their export - engineers are having to
make do with cannibalising grounded aircraft for parts
Until the new planes arrive -possibly never, if President
Trump decides to ban their export -- engineers are having to
make do with cannibalising grounded aircraft for parts
Click to follow
The Independent Online
Click to follow
The Independent Online
+ i
. .
.
.
.
,-
i
±
5
Boeing 727: the only carrier still flying these three-engined jets is Aseman Airlines ( Mehrad
Watson)
Boeing 727: the only carrier still flying these three-engined jets is Aseman Airlines ( Mehrad
Watson)
Sixty-six people have died in a second aviation tragedy in a week. After the loss of a
Russian airline near Moscow, fatalities from plane crashes so far this year far exceed those
in 2017, which was the safest year in aviation history.
Sixty-six people have died in a second aviation tragedy in a week. After the loss of a
Russian airline near Moscow, fatalities from plane crashes so far this year far exceed those
in 2017, which was the safest year in aviation history.
1/2
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- 379 -

Aseman Airlines' flight EP3704, the daily departure from Tehran, took off as normal shortly
after Barn to fly to Yasouj, 344 miles south. The aircraft involved, an ATR72, was 24 years
old -- which made it a relatively young part of the airline's fleet. The average age is more
than a quarter of a century, making it one of the oldest fleets in the world.
Aseman Airlines' flight EP3704, the daily departure from Tehran, took off as normal shortly
after Barn to fly to Yasouj, 344 miles south. The aircraft involved, an ATR72, was 24 years
old -- which made it a relatively young part of the airline's fleet. The average age is more
than a quarter of a century, making it one of the oldest fleets in the world.
There is nothing inherently unsafe about old aircraft. Right now British Airways and Virgin
Atlantic are flying Boeing 747s which are over 20 years old; a BA Jumbo jet is en route
today to Delhi at the venerable age of 27. But these aircraft are meticulously maintained by
well-resourced airlines.
There is nothing inherently unsafe about old aircraft. Right now British Airways and Virgin
Atlantic are flying Boeing 747s which are over 20 years old; a BA Jumbo jet is en route
today to Delhi at the venerable age of 27. But these aircraft are meticulously maintained by
well-resourced airlines.
It is far too early to know what caused the loss of EP3704, but the calamity draws attention
to aviation in a country starved of the equipment and expertise which makes flying in the
West so safe.
It is far too early to know what caused the loss of EP3704, but the calamity draws attention
to aviation in a country starved of the equipment and expertise which makes flying in the
West so safe.
Two years ago, when sanctions against Tehran were eased, Iran's airlines ordered
hundreds of new planes. Aseman Airlines, whose aircraft was lost today, has 30 Boeing
737MAX jets on order. But until the planes arrive -- possibly never, if President
Trump decides to ban their export -- the airlines' engineers are having to make do with
cannibalising grounded aircraft for parts.
Two years ago, when sanctions against Tehran were eased, Iran's airlines ordered
hundreds of new planes. Aseman Airlines, whose aircraft was lost today, has 30 Boeing
737MAX jets on order. But until the planes arrive - possibly never, if President
Trump decides to ban their export -- the airlines' engineers are having to make do with
cannibalising grounded aircraft for parts.
Production of the Boeing 727 ended in 1984, over a third of a century ago. The three­
engined jet is still flying scheduled passengers services in only one country: Iran. And the
carrier: Aseman Airlines.
Production of the Boeing 727 ended in 1984, over a third of a century ago. The three­
engined jet is still flying scheduled passengers services in only one country: Iran. And the
carrier: Aseman Airlines.
New, safer aircraft cannot arrive soon enough.
New, safer aircraft cannot arrive soon enough.
More about: / Iran aviation I Boeing I plane crashes
More about: [ ran aviation [ Boeing I plane crashes
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212
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- 380 -

Annex 280
“Iran Airport Traffic Expands 8 Percent”, Financial Tribune, 7 April 2018

- 381 -

- 382 -

Iran Airport Traffic Expands 8 Percent
Iran Airport Traffic Expands 8 Percent
financialtribune.com/articles/economy-business-and-markets/84225/iran-air port-traffic-expands-8-percent
financialtribune.com/articles/economy-business-and-markets/84225/iran-air port-traffic-expands-8-percent
April 7, 2018
April 7, 2018
Economy, Business And Markets
April 07, 2018 19:48
Economy, Business And Markets
April 07, 2018 19:48
On the domestic front, 371,000 takeoffs and landings were registered as more than 44.28
million passengers and 325,000 tons of goods were transported domestically.
On the domestic front, 371,000 takeoffs and landings were registered as more than 44.28
million passengers and 325,000 tons of goods were transported domestically.
ran Airports Company registered 455,613 takeoffs and landings in the last Iranian year (ended
March 20, 2018), which registers an 8% rise compared with the year before, the Ministry of
Roads and Urban Development's news service reported citing IAC data.
ran Airports Company registered 455,613 takeoffs and landings in the last Iranian year (ended
March 20, 2018), which registers an 8% rise compared with the year before, the Ministry of
Roads and Urban Development's news service reported citing IAC data.
Close to 57 million passengers and 552,341 tons of cargo were transported during the year,
indicating a 7% and 9% year-on-year growth respectively.
Close to 57 million passengers and 552,341 tons of cargo were transported during the year,
indicating a 7% and 9% year-on-year growth respectively.
As for passenger transportation, Tehran's Mehrabad International Airport was the busiest
Iranian airport during the year with 143,440 takeoffs and landings and the transportation of
17.45 million passengers.
As for passenger transportation, Tehran's Mehrabad International Airport was the busiest
Iranian airport during the year with 143,440 takeoffs and landings and the transportation of
17.45 million passengers.
Coming next is Mashhad International Airport that handled about 74,000 takeoffs and landings,
and moved more than 10.50 million passengers.
Coming next is Mashhad International Airport that handled about 74,000 takeoffs and landings,
and moved more than 1 0.50 million passengers.
O Financial Tribune Daily and Contributors 2014-2018
O Financial Tribune Daily and Contributors 2014-2018
111
111

- 383 -

- 384 -

Annex 281
T. Hepher, “Factbox – Iran’s $38 billion airplane purchases under nuclear deal”,
Reuters, 8 May 2018

- 385 -

- 386 -

FACTBOX-lran's $38 billion airplane purchases under
nuclear deal
FACTBOX-lran's $38 billion airplane purchases under
nuclear deal
uk.reuters.com/article/iran-nuclear-aircraft-deals/factbox-irans-38-billion-airplane-purchases-under-nuclear-deal­
uk.reuters.com/article/iran-nuclear-aircraft-deals/factbox-irans-38-billion-airplane-purchases-under-nuclear-deal­
idUKLB8N1SE75Z
May 8 (Reuters) - Aircraft deals with Iran worth some $38
idUKLB8N1SE75Z
May 8 (Reuters) - Aircraft deals with Iran worth some $38
billion at catalogue prices are among western business
transactions in the balance as President Donald Trump prepares
to announce a decision on whether to keep the united States
inside the Iran nuclear deal.
Here is a breakdown of principal deals negotiated since most
international sanctions were lifted under the 2015 deal between
Tehran and major powers, which reopened trade in exchange for
restrictions on Iran's nuclear activities.
All orders depend on U.S. export licences because both U.S.
and European aircraft contain more than 10 percent U.S. parts.
Prices shown are at catalogue prices. Airlines typically win
discounts of 50 percent or more for bulk orders.
billion at catalogue prices are among Western business
transactions in the balance as President Donald Trump prepares
to announce a decision on whether to keep the United States
inside the Iran nuclear deal.
Here is a breakdown of principal deals negotiated since most
international sanctions were lifted under the 2015 deal between
Tehran and major powers, which reopened trade in exchange for
restrictions on Iran's nuclear activities.
All orders depend on U.S. export licences because both U.S.
and European aircraft contain more than 10 percent U.S. parts.
Prices shown are at catalogue prices. Airlines typically win
discounts of 50 percent or more for bulk orders.
PURCHASE CONTRACTS
PURCHASE CONTRACTS
Supplier
Buyer
units
Model
Supplier
Seats
( mln $)
Buyer
units
Model
Seats
(mln $)
Airbus
IranAir
6
A320
150
Airbus
IranAir
6
A320
150
606
606
IranAir
32
A320ne0
150
IranAir
32
A320ne0
150
3,232
3,232
IranAir
8
A321
185
IranAir
8
A321
185
946
946
IranAir
8
A330-200
246
IranAir
8
A330-200
246
1, 908
1, 908
IranAir
28
A330-900
310
IranAir
28
A330-900
310
8,299
8, 299
IranAir
16
A350-1000 369
IranAir
16
5, 864
Total
A350-1000 369
5, 864
Total
98
98
Airbus
20, 856
Airbus
20, 856
Boeing
IranAir
50
737 MAX 8 162
Boeing
IranAir
50
737 MAX 8 162
5, 620
5, 620
IranAir
15
777-300ER 396
IranAir
15
777-300ER 396
5, 297
5, 297
IranAir
15
777-9
406
IranAir
15
777-9
406
6,132
6, 132
Total
Total
80
80
Boeing
Boeing
16, 959
16, 959
ATR
IranAir
20
70
ATR
IranAir
20
70
Turboprop
Turboprop
1/3
1/3
- 387 -

520
520
Total ATR
20
Total ATR
20
72-600
72-600
520
520
Total firm
198
Total firm
198
orders
38, 334
orders
38, 334
Airbus order excludes 1 new A321 and 1 new A330 originally
Airbus order excludes 1 new A321 and 1 new A330 originally
sold to another airline. These became available for Iran after
sold to another airline. These became available for Iran after
the original buyer did not take delivery, according to industry
sources. While Airbus booked 98 new orders, IranAir has
the original buyer did not take delivery, according to industry
sources. While Airbus booked 98 new orders, IranAir has
therefore ordered a total of 100 Airbus jets.
therefore ordered a total of 100 Airbus jets.
·Boeing announced the signature of a contract in Dec 2016, but
Boeing announced the signature of a contract in Dec 2016, but
has not yet placed the deal in its official order book
has not yet placed the deal in its official order book
PROVISIONAL
DEALS
PROVISIONAL
DEALS
Supplier
Buyer
units
Model
Seats
(mln $)
Supplier
Buyer
units
Model
Seats
(mln $)
Airbus
Airbus
Iran Airtour
45
A320ne0
150
Iran Airtour
45
A320ne0
150
4,545
4,545
Zagros
20
A320ne0
150
Zagros
20
A320ne0
150
2, 020
2,020
Zagros
8
A330neo
310
2,371
Total
Zagros
8
A330neo
310
2,371
73
Total
73
Airbus
Airbus
8,936
8,936
Boeing
Iran Aseman
30
737 MAX
162
Boeing
Iran Aseman
30
737 MAX
162
3, 372
3,372
Total
Total
30
30
Boeing
3,372
Boeing
3,372
Total provisional orders
Total provisional orders
12, 308
12, 308
103
103
DELIVERIES
DELIVERIES
Airbus
1
A320
Airbus
1
A320
1
A321
1
A321
1
A330
1
A330
Total
3
Total
3
Airbus
Airbus
AT
AT
72-600
72-600
8
8
Boeing
0
Boeing
0
(ATR is 50/50-owned by Airbus and Leonardo)
(ATR is 50/50-owned by Airbus and Leonardo)
2/3
2/3
- 388 -

(Reporting by Tim Hepher, Editing by William Maclean)
(Reporting by Tim Hepher, Editing by William Maclean)
3/3
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- 389 -

- 390 -

Annex 282
D. Lawder, “U.S. Treasury's Mnuchin: Revoking Boeing, Airbus licenses to sell jets to
Iran”, Reuters, 8 May 2018

- 391 -

- 392 -

U.S. Treasury's Mnuchin: Revoking Boeing, Airbus licenses
to sell jets to Iran
U.S. Treasury's Mnuchin: Revoking Boeing, Airbus licenses
to sell jets to Iran
reuters.com/ a rti cl e/us-i ran-nu cl ea r-boei ng/u-s-treasu rys-m nu chi n-revoki ng-boei ng-a i rbu s-I i censes-to-sel I­
jets-to-i ran-id US KB N 1I92Q6
reuters.com/ a rti cl e/us-i ran-nu cl ea r-boeing/u-s-treasurys-m nu chi n-revoki ng-boei ng-a i rbu s-I i censes-to-sell­
jets-to-i ran-id US KB N 1I92Q6
WASHINGTON (Reuters) - Licenses for Boeing Co and Airbus to sell passenger jets to Iran
will be revoked, U.S. Treasury Secretary Steven Mnuchin said on Tuesday after President
Donald Trump pulled the United States out of the 2015 Iran nuclear agreement.
WASHINGTON (Reuters) - Licenses for Boeing Co and Airbus to sell passenger jets to Iran
will be revoked, U.S. Treasury Secretary Steven Mnuchin said on Tuesday after President
Donald Trump pulled the United States out of the 2015 Iran nuclear agreement.
Trump said he would reimpose U.S. economic sanctions on Iran, which were lifted under
the agreement he had harshly criticized.
Trump said he would reimpose U.S. economic sanctions on Iran, which were lifted under
the agreement he had harshly criticized.
The pact, worked out by the United States, five other world powers and Iran, lifted
sanctions in exchange for Tehran limiting its nuclear program. It was designed to prevent
Iran from obtaining a nuclear bomb.
The pact, worked out by the United States, five other world powers and Iran, lifted
sanctions in exchange for Tehran limiting its nuclear program. It was designed to prevent
Iran from obtaining a nuclear bomb.
lranAir had ordered 200 passenger aircraft - 100 from Airbus SE, 80 from Boeing and 20
from Franco-Italian turboprop maker ATR. All the deals are dependent on U.S. licenses
because of the heavy use of American parts in commercial planes.
lranAir had ordered 200 passenger aircraft- 100 from Airbus SE, 80 from Boeing and 20
from Franco-Italian turboprop maker ATR. All the deals are dependent on U.S. licenses
because of the heavy use of American parts in commercial planes.
Boeing agreed in December 2016 to sell 80 aircraft, worth $17 billion at list prices, to
lranAir under an agreement between Tehran and major world powers to reopen trade in
exchange for curbs on Iran's nuclear activities.
Boeing agreed in December 2016 to sell 80 aircraft, worth $17 billion at list prices, to
lranAir under an agreement between Tehran and major world powers to reopen trade in
exchange for curbs on Iran's nuclear activities.
The U.S. Treasury Department, which controls licensing of exports, said the United
States would no longer allow the export of commercial passenger aircraft, parts and
services to Iran after a 90-day period.
The U.S. Treasury Department, which controls licensing of exports, said the United
States would no longer allow the export of commercial passenger aircraft, parts and
services to Iran after a 90-day period.
"The Boeing and (Airbus) licenses will be revoked," Mnuchin told reporters at the
Treasury. "Under the original deal, there were waivers for commercial aircraft, parts and
services and the existing licenses will be revoked."
"The Boeing and (Airbus) licenses will be revoked," Mnuchin told reporters at the
Treasury. "Under the original deal, there were waivers for commercial aircraft, parts and
services and the existing licenses will be revoked."
European planemaker Airbus said on Tuesday before the Mnuchin news conference that
it would study Trump's decision, adding that it would take some time.
European planemaker Airbus said on Tuesday before the Mnuchin news conference that
it would study Trump's decision, adding that it would take some time.
Following the 90-day period ending Aug. 6, the Treasury also said it would revoke a
license that allowed U.S. companies to negotiate business deals with Iran. The Boeing
license had been valid until September 2020, a person involved in the deal said.
Following the 90-day period ending Aug. 6, the Treasury also said it would revoke a
license that allowed U.S. companies to negotiate business deals with Iran. The Boeing
license had been valid until September 2020, a person involved in the deal said.
"As we have throughout this process, we'll continue to follow the U.S. government's lead,"
Boeing spokesman Gordon Johndroe said before Mnuchin's comments.
"As we have throughout this process, we'll continue to follow the U.S. government's lead,"
Boeing spokesman Gordon Johndroe said before Mnuchin's comments.
Mnuchin said it may be possible for some companies over the next three months to seek
waivers from the sanctions or new licenses to do business with Iran, but he did not
identify which companies.
Mnuchin said it may be possible for some companies over the next three months to seek
waivers from the sanctions or new licenses to do business with Iran, but he did not
identify which companies.
1/2
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- 393 -

'That's something we'll consider on a case-by-case basis, but as an overview, I would say
that the purpose is to broadly enforce the sanctions," he said, adding the
administration's objective was to deny Iran access to the U.S. financial system.
"That's something we'll consider on a case-by-case basis, but as an overview, I would say
that the purpose is to broadly enforce the sanctions," he said, adding the
administration's objective was to deny Iran access to the U.S. financial system.
Boeing Chief Executive Dennis Muilenburg said last month the airplane manufacturer
had no Iranian deliveries scheduled this year. He said Boeing's 777 production plan "is
not dependent on the Iranian orders." Muilenburg is set to address the Economic Club of
Washington on Wednesday.
Boeing Chief Executive Dennis Muilenburg said last month the airplane manufacturer
had no Iranian deliveries scheduled this year. He said Boeing's 777 production plan "is
not dependent on the Iranian orders." Muilenburg is set to address the Economic Club of
Washington on Wednesday.
The lranAir order included 15 Boeing 777-300ER long-range jets. Industry sources said
Boeing had been tentatively due to send Iran three 777s this year but had reshuffled
deliveries with other buyers.
The lranAir order included 15 Boeing 777-300ER long-range jets. Industry sources said
Boeing had been tentatively due to send Iran three 777s this year but had reshuffled
deliveries with other buyers.
Shares of Boeing closed down $2.06, or 0.6 percent, at $338.37 on the New York Stock
Exchange after Trump's announcement.
Shares of Boeing closed down $2.06, or 0.6 percent, at $338.37 on the New York Stock
Exchange after Trump's announcement.
Reporting by David Lawder, David Shepardson and Mike Stone in Washington and Tim
Hepher in Paris; Writing by Chris Sanders and David Lawder; Editing by Jonathan Oatis
and Peter Cooney
Reporting by David Lawder, David Shepardson and Mike Stone in Washington and Tim
Hepher in Paris; Writing by Chris Sanders and David Lawder; Editing by Jonathan Oatis
and Peter Cooney
Our Standards:The Thomson Reuters Trust Principles,
Our Standards:The Thomson Reuters Trust Principles.
2/2
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- 394 -

Annex 283
C. Charpentreau, “Boeing confirms passing $20B Iran deal”, AeroTime News,
7 June 2018

- 395 -

- 396 -

Boeing confirms passing $20B Iran deal
Boeing confirms passing $20B Iran deal
aerotime.aero/clement.charpentreau/21390-boeing-confirms-passing-2Ob-iran-deal
aerotime.aero/clement.charpentreau/2 1390-boeing-confirms-passing-20b-iran-deal
June 7, 2018
June 7, 2018
Aerotime.aero
Aerotime.aero
AER TIME
AER TIME
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4#$
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CLEMENT
CLEMENT
CHARPENTREAU
CHARPENTREAU
on 7" June 2018
on 7" June 2018
Image:
Boeing confirmed the manufacturer would comply with US
sanctions and will not fulfill the orders placed by Iran Air and
Aseman Airlines. The two Iranian carriers hold an order of more
than 11 O aircraft for an estimated total of about $20 billion.
Image:
Boeing confirmed the manufacturer would comply with US
sanctions and will not fulfill the orders placed by Iran Air and
Aseman Airlines. The two Iranian carriers hold an order of more
than 110 aircraft for an estimated total of about $20 billion.
Arpinqstone
Arpingstone
As it was previously declared soon after Trump's decision to withdraw
As it was previously declared soon after Trump's decision to withdraw
from the Iran deal. a spokesperson from Boeing confirmed the news to AFP. "We have not
delivered any aircraft to Iran, and given we no longer have a license to sell to Iran at this
time, we will not be delivering any aircraft," the spokesman said. Despite contracts being
among the biggest signed by a foreign airline, Boeing never recorded these orders in its
backlog unlike rival Airbus, the spokesperson insisted.
from the Iran deal, a spokesperson from Boeing confirmed the news to AFP. "We have not
delivered any aircraft to Iran, and given we no longer have a license to sell to Iran at this
time, we will not be delivering any aircraft," the spokesman said. Despite contracts being
among the biggest signed by a foreign airline, Boeing never recorded these orders in its
backlog unlike rival Airbus, the spokesperson insisted.
After a preliminary agreement with Iran in 2015, the U.S. Treasure Department delivered
After a preliminary agreement with Iran in 2015, the U.S. Treasure Department delivered
Specific licenses to both Boeing and Airbus in September 2016, allowing to sell
commercial planes to Iran. Soon after, Iran airlines started ordering planes to renew their
aging fleets. Indeed, several aircraft of Iran Air fleet are on the EU blacklist due to safety
concerns, and those still allowed are regularly inspected when they land at European
airports.
Specific licenses to both Boeing and Airbus in September 2016, allowing to sell
commercial planes to Iran. Soon after, Iran airlines started ordering planes to renew their
aging fleets. Indeed, several aircraft of Iran Air fleet are on the EU blacklist due to safety
concerns, and those still allowed are regularly inspected when they land at European
airports.
On December 11, 2016, Boeing agreed to sell 80 aircraft to Iran. This included 50 B737
and 30 B777. The delivery was to be made in the next 10 years, with the first planes
landing in Iran in 2018.
On December 11, 2016, Boeing agreed to sell 80 aircraft to Iran. This included 50 B737
and 30 B777. The delivery was to be made in the next 10 years, with the first planes
landing in Iran in 2018.
The total contract of about $16.6 billion was expected to secure up to 100,000 jobs in the
United States according to the New York Times. The U.S. based manufacturer also
The total contract of about $16.6 billion was expected to secure up to 100,000 jobs in the
United States according to the New York Times. The U.S. based manufacturer also
1/2
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- 397 -

secured a $3 billion contract with Iranian company Aseman Airlines for thirty Boeing 737
MAXs that were to be delivered between 2022 and 2024.
secured a $3 billion contract with Iranian company Aseman Airlines for thirty Boeing 737
MAXs that were to be delivered between 2022 and 2024.
Airbus will now have to give an answer as to whether or not it will follow Boeing and
comply. The European manufacturer uses U.S.-made parts for its planes and even owns an
assembly line for the American market in Mobile, Alabama. Thus, it could face sanctions
from Washington.
Airbus will now have to give an answer as to whether or not it will follow Boeing and
comply. The European manufacturer uses U.S.-made parts for its planes and even owns an
assembly line for the American market in Mobile, Alabama. Thus, it could face sanctions
from Washington.
On December 22, 2016, Airbus received a firm order from Iran Air for 100 aircraft: 46 A320,
38 A330 and 16 A350XWB. Two A330-200s and an A321 were already delivered in 2017.
The total catalogue price was estimated at $10 billion maximum. Another_order was placed
on June 22, 2017, by Zagros Airlines for 28 aircraft including 20 A320neos and 8
A330neos. As for helicopters, Iran was in the process of_acquiring 45 civilian models from
Airbus for emergency medical use.
On December 22, 2016, Airbus received a firm order from Iran Air for 100 aircraft: 46 A320,
38 A330 and 16 A350XWB. Two A330-200s and an A321 were already delivered in 2017.
The total catalogue price was estimated at $10 billion maximum. Another order was placed
on June 22, 2017, by Zagros Airlines for 28 aircraft including 20 A320neos and 8
A330neos. As for helicopters, Iran was in the process of_acquiring 45 civilian models from
Airbus for emergency medical use.
Iran will be forced to find other plane suppliers as the Transport Minister of the Islamic
Republic, Abbas Akhoundi, estimated that 400 new planes will be needed in the next ten
years, a huge market now closed to Western manufacturers. Russian Sukhoi could benefit
from this opportunity: the manufacturer announced being in the process of
modifying its Superjet-100, dropping the number of U.S.-made parts down to 10%. That
way, it would not need approval from the U.S. Treasure in order to sell its planes to Iran.
Iran will be forced to find other plane suppliers as the Transport Minister of the Islamic
Republic, Abbas Akhoundi, estimated that 400 new planes will be needed in the next ten
years, a huge market now closed to Western manufacturers. Russian Sukhoi could benefit
from this opportunity: the manufacturer announced being in the process of
modifying its Superjet-100, dropping the number of U.S.-made parts down to 10%. That
way, it would not need approval from the U.S. Treasure in order to sell its planes to Iran.
212
2/2
- 398 -

Annex 284
A. Feitz, “ATR passe entre les gouttes de l’embargo iranien”, Les Echos,
6 August 2018

- 399 -

- 400 -

ATR passe entre les gouttes de l'embargo iranien
ATR passe entre les gouttes de l'embargo iranien
I e sechos.fr/06/08/2018/LesE chos/22 7 5 3-046-ECH_atr-passe-e ntre-1 es-go uttes-de-l-embargo-iran i en.h tm
lesechos.fr/06/08/2018/LesEch0s/22753-046-ECH_atr-passe-entre-les-gouttes-de-l-embargo-iranien.htm
ENTREPRISE & MARCHES
ENTREPRISE & MARCHES
La livraison de 5 avions ~ h~lices intervient ~ la veille de la mise en
oeuvre des sanctions am~ricaines dans la R~publique islamique.
La livraison de 5 avions ~ h~lices intervient ~ la veille de la mise en
oeuvre des sanctions am~ricaines dans la R~publique islamique.
ls sont arriv~s. Apr~s avoir annonc~ samedi qu'elle s'appr~tait ~ recevoir 5 avions ATR, la
compagnie a~rienne Iran Air a publi~ dimanche matin des photos des appareils sur le tarmac de
l'a~roport Mehrabad de T~h~ran, et de la c~r~monie d'accueil des 5 avions ~ h~lices ATR72.
Ils sont arriv~s. Apr~s avoir annonc~ samedi qu'elle s'appr~tait ~ recevoir 5 avions ATR, la
compagnie a~rienne Iran Air a publi~ dimanche matin des photos des appareils sur le tarmac de
l'a~roport Mehrabad de T~h~ran, et de la c~r~monie d'accueil des 5 avions ~ h~lices ATR72.
Selon l'agence officielle de presse iranienne, Irna, la directrice g~n~rale d'lran Air, Farzaneh
Sharafbafi, avait m~me fait le d~placement pour assister ~ leur d~collage du sol franais, samedi
soir.
Selon l'agence officielle de presse iranienne, Irna, la directrice g~n~rale d'Iran Air, Farzaneh
Sharafbafi, avait m~me fait le d~placement pour assister ~ leur d~collage du sol fran~ais, samedi
soir.
Pour l'avionneur bas~ ~ Toulouse, d~tenu ~ parit~ par Airbus et l'italien Leonardo, c'est une ­
Pour l'avionneur bas~ ~ Toulouse, d~tenu ~ parit~ par Airbus et l'italien Leonardo, c'est une ­
relativement - bonne nouvelle. Car cette livraison intervient in extremis, a la veille de la mise en
oeuvre des premi~res sanctions am~ricaines en Iran : les entreprises de plusieurs secteurs, dont
l'a~ronautique, doivent cesser toute activit~ avec la R~publique islamique ~ compter du lundi 6
ao~t (lire nos infomations page 4).
relativement - bonne nouvelle. Car cette livraison intervient in extremis, a la veille de la mise en
oeuvre des premi~res sanctions am~ricaines en Iran : les entreprises de plusieurs secteurs, dont
l'a~ronautique, doivent cesser toute activit~ avec la R~publique islamique ~ compter du lundi 6
ao~t (lire nos infomations page 4).
Or, la livraison de ces appareils, inclus dans une commande ancienne, eta it suspendue a une
autorisation de l'administration am~ricaine, qui doit approuver l'exportation des avions
contenant plus de 10 % de composants fabriqu~s aux Etats-Unis. Finalis~e d~but 2017, cette
commande portait sur 20 appareils, mais ATR n'en avait livr~ que 8 orsque l'accord sur le
nucl~aire iranien a ~t~ d~nonc~ par Donald Trump, d~but mai.
Or, la livraison de ces appareils, inclus dans une commande ancienne, eta it suspendue a une
autorisation de l'administration am~ricaine, qui doit approuver l'exportation des avions
contenant plus de 10 % de composants fabriqu~s aux Etats-Unis. Finalis~e d~but 2017, cette
commande portait sur 20 appareils, mais ATR n'en avait livr~ que 8 lorsque l'accord sur le
nucl~aire iranien a ~t~ d~nonc~ par Donald Trump, d~but mai.
112
112
- 401 -

Commandes record
Commandes record
Mi-juillet, le pr~sident ex~cutif d'ATR, Christian Scherer, d~clarait ~tre optimiste sur la livraison
des derniers appareils. « Sinon, nous sommes confiants sur les possibilit~s de /es replacer ailleurs ",
Mi-juillet, le pr~sident ex~cutif d'ATR, Christian Scherer, d~clarait ~tre optimiste sur la livraison
des derniers appareils. « Sinon, nous sommes confiants sur les possibilit~s de les replacer ailleurs",
avait-il indiqu~. Le 31 juillet, le ministre de l'Economie et des Finances, Bruno Le Maire, avait, lui
aussi, indiqu~ avoir « bon espoir » de voir le dossier se d~bloquer avant le 6 a0~t, ~voquant
toutefois la livraison de huit avions - et non pas cinq. Un peu plus tot dans le mois, il avait ~t~
question de «6 ~ 8 » avions susceptibles d'~tre pr~ts d'ici ~ l'~ch~ance. Personne n'~tait
disponible dimanche chez ATR pour commenter l'information du jour.
avait-il indiqu~. Le 31 juillet, le ministre de l'Economie et des Finances, Bruno Le Maire, avait, lui
aussi, indiqu~ avoir « bon espoir » de voir le dossier se d~bloquer avant le 6 ao~t, ~voquant
toutefois la livraison de huit avions - et non pas cinq. Un peu plus t~t dans le mois, il avait ~t~
question de «6 ~ 8 » avions susceptibles d'~tre pr~ts d'ici ~ l'~ch~ance. Personne n'~tait
disponible dimanche chez ATR pour commenter !'information du jour.
Le constructeur d'avion ~ h~lices, qui a r~alis~ un chiffre d'affaires de 1,8 milliard de dollars en
2017 (1,6 milliard d'euros), avait alert~ d~but juillet sur le « grave pr~judice" que les sanctions
risquaient de lui faire subir. Au prix catalogue, la commande de 20 appareils repr~sentait 1, 1
milliard de dollars.
Le constructeur d'avion ~ h~lices, qui a r~alis~ un chiffre d'affaires de 1,8 milliard de dollars en
2017 (1,6 milliard d'euros), avait alert~ d~but juillet sur le « grave pr~judice " que les sanctions
risquaient de lui faire subir. Au prix catalogue, la commande de 20 appareils repr~sentait 1, 1
milliard de dollars.
L 'avionneur avait engrang~ l'an dernier un record de commandes, ayant sign~ globalement pour
la vente de 113 de ses avions ~ 70 si~ges (ATR72) 0u ~ 50 si~ges (ATR42), II mise cette ann~e sur
80 nouvelles commandes et fonde de grands espoirs sur l'ouverture du march~ chinois ~
L 'avionneur avait engrang~ l'an dernier un record de commandes, ayant sign~ globalement pour
la vente de 113 de ses avions ~ 70 si~ges (ATR72) 0u ~ 50 si~ges (ATR42), II mise cette ann~e sur
80 nouvelles commandes et fonde de grands espoirs sur l'ouverture du march~ chinois ~
compter de 2019. II devra en tout cas, pour l'heure, faire une croix sur l'option sign~e par Iran
Air d~but 2017, qui portait sur 20 ATR72 suppl~mentaires.
compter de 2019. II devra en tout cas, pour l'heure, faire une croix sur l'option sign~e par Iran
Air d~but 2017, qui portait sur 20 ATR72 suppl~mentaires.
212
2/2

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Annex 285

“Tehran Slams Ankara for Refusing to Refuel Iranian Aircraft”, Iran Front Page
News, 3 November 2018

- 403 -

- 404 -

Tehran Slams Ankara for
Refusing to Refuel Iranian Aircraft
Tehran Slams Ankara for
Refusing to Refuel Iranian Aircraft
By IFP Editorial Staff - November 3, 2018-14:.29
By IFP Editorial Staff - November 3, 2018-14:29
.J
ij)
---
Iran's Civil Aviation Organisation has expressed its
protest at a Turkish company's unilateral decision to
refrain from providing fuel for
Iranian passenger
Iran's Civil Aviation Organisation has expressed its
protest at a Turkish company's unilateral decision to
refrain from providing fuel for
Iranian passenger
planes at Istanbul's Ataturk International Airport
planes at Istanbul's Ataturk International Airport.
Maqsoud Asadi Samani, an official with the organisation, says
there is a good relationship between the governments of Iran
and Turkey, and Ankara has stated that it does not abide by
US sanctions against Iran.
Maqsoud Asadi Samani, an official with the organisation, says
there is a good relationship between the governments of Iran
and Turkey, and Ankara has stated that it does not abide by
US sanctions against Iran.
However, he said, a Turkish company which supplies Iranian
planes with fuel has unfortunately stated in an e-mail, without
providing any explanation, that it will not be able to deliver fuel
to Iranian airline companies as of November.
However, he said, a Turkish company which supplies Iranian
planes with fuel has unfortunately stated in an e-mail, without
providing any explanation, that it will not be able to deliver fuel
to Iranian airline companies as of November.
Asadi Samani stressed that for sure this will create problems
for Iranian airlines, and in the meantime it is not in the interest
Asadi Samani stressed that for sure this will create problems
for Iranian airlines, and in the meantime it is not in the interest
https://ifpnews.com/exclusive/tehran-slams-ankara-for-refusing-to-refue…
https://ifpnews.com/exclusive/tehran-slams-ankara-for-refusing-to-refue…
- 405 -

of the two countries' ties.
of the two countries' ties.
"We expect the problem be resolved th rough the ongoing
efforts. We certainly expect that, given the added value of the
establishment of flights between the two countries, the
problem that the Turkish fueling company has created will be
resolved as soon as possible."
"We expect the problem be resolved through the ongoing
efforts. We certainly expect that, given the added value of the
establishment of flights between the two countries, the
problem that the Turkish fueling company has created will be
resolved as soon as possible."
Certainly, the decision of the Turkish company is against the
agreements between Tehran and Ankara. The Islamic Republic
hopes the Turkish government would solve this problem, he
added.
Certainly, the decision of the Turkish company is against the
agreements between Tehran and Ankara. The Islamic Republic
hopes the Turkish government would solve this problem, he
added.
According to the bilateral agreement between Iran and Turkey,
there are 200 flights per day between the two countries of
which 100 are carried out by Iranian companies and 100 by
Turkish ones.
According to the bilateral agreement between Iran and Turkey,
there are 200 flights per day between the two countries of
which 100 are carried out by Iranian companies and 100 by
Turkish ones.
Fars News Agency quoted Samani as saying that the number
slightly increases or decreases in some weeks with respect to
the travel season, but 2.5 million Iranians travel to Turkey
annually.
Fars News Agency quoted Samani as saying that the number
slightly increases or decreases in some weeks with respect to
the travel season, but 2.5 million Iranians travel to Turkey
annually.
Earlier, some foreign media had reported that the refraining of
the Turkish company is a result of US sanctions against Iran.
Earlier, some foreign media had reported that the refraining of
the Turkish company is a result of US sanctions against Iran.
This comes as the US Secretary of State Mike Pompeo said on
Friday that Washington has agreed to temporarily allow eight
countries to continue buying Iranian oil after it reimposes
crippling sanctions on Tehran on November 5. Turkey is one of
these eight countries.
This comes as the US Secretary of State Mike Pompeo said on
Friday that Washington has agreed to temporarily allow eight
countries to continue buying Iranian oil after it reimposes
crippling sanctions on Tehran on November 5. Turkey is one of
these eight countries.
Reuters reported on Friday that some Iranian airliners were
refused fuel in Turkey's Istanbul airports and had to cancel at
least one flight, while other carriers had to cut the number of
passengers on board in order to fly on less fuel.
Reuters reported on Friday that some Iranian airliners were
refused fuel in Turkey's Istanbul airports and had to cancel at
least one flight, while other carriers had to cut the number of
passengers on board in order to fly on less fuel.
https://ifpnews.com/exclusive/tehran-slams-ankara-for-refusing-to-refue…
https://ifpnews.com/exclusive/tehran-slams-ankara-for-refusing-to-refue…
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However, some informed sources in the airline industry believe
that with the official launch of the new Istanbul airport in
Turkey, most companies are preparing to move to this new and
major airport within the next three months and leave the
Ataturk airport.
However, some informed sources in the airline industry believe
that with the official launch of the new Istanbul airport in
Turkey, most companies are preparing to move to this new and
major airport within the next three months and leave the
Ataturk airport.
Turkey's Petrol Ofisi, a subsidiary of Vitol Investment
Partnership Ltd., is also one of the companies that will prepare
itself for this relocation. Sources say the company is providing
services and fuel to an Iranian airline that has a high debt to it
and has also received warnings in this regard. Therefore, this is
not apparently related to US anti-Iran sanctions.
Turkey's Petrol Ofisi, a subsidiary of Vitol Investment
Partnership Ltd., is also one of the companies that will prepare
itself for this relocation. Sources say the company is providing
services and fuel to an Iranian airline that has a high debt to it
and has also received warnings in this regard. Therefore, this is
not apparently related to US anti-Iran sanctions.
Iran's Mahan Air, ATA, Qeshm, Iran Air, Taban, Zagros, Meraj,
Caspian, Iran Air Tour, and Aseman Airlines all operate flights
between Tehran and Istanbul.
Iran's Mahan Air, ATA, Qeshm, Iran Air, Taban, Zagros, Meraj,
Caspian, Iran Air Tour, and Aseman Airlines all operate flights
between Tehran and Istanbul.
IFP Editorial Staff
IFP Editorial Staff
https://ifpnews.com/ifp-editorial-staff/
https://ifpnews.com/ifp-editorial-staff/
The IFP Editorial Staff is composed of dozens of skilled journalists,
news-writers, and analysts whose works are edited and published by
experienced editors. The editor of each IFP Service is responsible for
The IFP Editorial Staff is composed of dozens of skilled journalists,
news-writers, and analysts whose works are edited and published by
experienced editors. The editor of each IFP Service is responsible for
the report published by the Iran Front Page (IFP) news website, and can
be contacted through the ways mentioned in the "IFP Editorial Staff'
section.
the report published by the Iran Front Page (IFP) news website, and can
be contacted through the ways mentioned in the "IFP Editorial Staff'
section.
https://ifpnews.com/exclusive/tehran-slams-ankara-for-refusing-to-refue…
https://ifpnews.com/exclusive/tehran-slams-ankara-for-refusing-to-refue…

- 407 -

- 408 -

Annex 286
E. Batmanghelidj, “For Iranian Passengers, Old Planes and Few Parts Make Air
Travel 5.5 More Times Deadly”, Bourse & Bazaar, 5 December 2018

- 409 -

- 410 -

For Iranian Passengers, Old Planes and Few Parts Make Air Travel 5.5 More Times Deadly
For Iranian Passengers, Old Planes and Few Pants Make Air Travel 5.5 More Times Deadly
For Iranian Passengers, Old Planes and Few
Parts Make Air Travel 5.5 More Times Deadly
For Iranian Passengers, Old Planes and Few
Parts Make Air Travel 5.5 More Times Deadly
Esfandyar Batmanghelidj
Esfandyar Batmanghelidj
In November, Kim Hjelmgaard of USA Today reported on the misery and danger
faced by Iran's air travelers as US sanctions return. Hjelmgaard's interviewed with
former airline pilot Houshang Shahbazi who heroically "saved the lives of more than
100 passengers and crew in 2o12 when he successfully landed a 747 commercial
airplane with a disabled wheel carriage." His report also included data on aviation
safety in Iran complied by Bourse & Bazaar. A closer look at that data is presented
here.
In November, Kim Hjelmgaard of USA Today reported on the misery and danger
faced by Iran's air travelers as US sanctions return. Hjelmgaard's interviewed with
former airline pilot Houshang Shahbazi who heroically "saved the lives of more than
100 passengers and crew in 2o12 when he successfully landed a 747 commercial
airplane with a disabled wheel carriage." His report also included data on aviation
safety in Iran complied by Bourse & Bazaar. A closer look at that data is presented
here.
To measure the risks posed to air travelers in Iran, it is possible to look to deaths per
passenger journey. This is considered the "most accurate measure" for the mortality
risks posed by flying as it accounts for the difference between long and short haul
flights, which operate different types of aircraft.
To measure the risks posed to air travelers in Iran, it is possible to look to deaths per
passenger journey. This is considered the "most accurate measure" for the mortality
risks posed by flying as it accounts for the difference between long and short haul
flights, which operate different types of aircraft.
Passenger journeys are tabulated by the International Civil Aviation Organization,
and accessible via the World Bank's data portal. Air accidents and fatalities in Iran
are recorded by the Air Safety Network, an industry database. For the purposes of this
analysis, we will compare global fatalities with passengers fatalities from accidents
involving Iranian-registered commercial aircraft within Iran.
Passenger journeys are tabulated by the International Civil Aviation Organization,
and accessible via the World Bank's data portal. Air accidents and fatalities in Iran
are recorded by the Air Safety Network, an industry database. For the purposes of this
analysis, we will compare global fatalities with passengers fatalities from accidents
involving Iranian-registered commercial aircraft within Iran.
The period examined is 1997 to 2017, a 20 year period which includes the most recent
available data. This is also the period which covers the intensification of international
sanctions on Iran, beginning with the Iran Libya Sanctions Act signed into law by the
Clinton administration in 1997. The International Civil Aviation Organization (1CAO),
a United Nations body, has long gathered evidence which suggests that US sanctions
contribute to the poor safety record of Iran's aviation industry. A 2010 ICAO
Universal Safety Audit found that "Iranian carriers are unable at present to fulfill
most requisite ICAO aviation safety and maintenance standards and recommended
practices (SARPs)... because they were denied access to updated aircraft and aircraft
spare parts and post-sale services around the world."
The period examined is 1997 to 2017, a 20 year period which includes the most recent
available data. This is also the period which covers the intensification of international
sanctions on Iran, beginning with the Iran Libya Sanctions Act signed into law by the
Clinton administration in 1997. The International Civil Aviation Organization (1CAO),
a United Nations body, has long gathered evidence which suggests that US sanctions
contribute to the poor safety record of Iran's aviation industry. A 2010 ICAO
Universal Safety Audit found that "Iranian carriers are unable at present to fulfill
most requisite ICAO aviation safety and maintenance standards and recommended
practices (SARPs)... because they were denied access to updated aircraft and aircraft
spare parts and post-sale services around the world."
Looking to the data on risk of death, Iran's 2o year average is 1.89 deaths per 1
million passenger journeys. The same figure for the rest of the world is o.34 deaths.
By this measure, flying in Iran is on average 5.5 times more deadly than flying in the
rest of the world, in aggregate. Notably, this does not include 2018 figures, a year
where Iran has had 66 fatalities.
Looking to the data on risk of death, Iran's 2o year average is 1.89 deaths per 1
million passenger journeys. The same figure for the rest of the world is o.34 deaths.
By this measure, flying in Iran is on average 5.5 times more deadly than flying in the
rest of the world, in aggregate. Notably, this does not include 2018 figures, a year
where Iran has had 66 fatalities.
When depicted in a chart, the ratios help illustrate the frequency with which Iran
experiences serious air accidents. There have been accidents in 18 of the last 2o years,
with an average of 2 accidents per year.
When depicted in a chart, the ratios help illustrate the frequency with which Iran
experiences serious air accidents. There have been accidents in 18 of the last 20 years,
with an average of 2 accidents per year.
- 411 -

For Iranian Passengers, Old Planes and Few Parts Make Air Travel 5.5 More Times Deadly
For Iranian Passengers, Old Planes and Few Pants Make Air Travel 5.5 More Times Deadly
Ratio of Fatalities to Passenger Journeys
Ratio of Fatalities to Passenger Journeys
(Civil aviation, per 1 million journeys)
(Civil aviation, per 1 million journeys)
an ROW
an ow
1998
1998
2000
2000
2002
2002
2004
2004
2006
2006
2008
2008
2010
2010
2012
2012
2014
2014
2016
2016
Chart Burse4 B.· Source Air Safety Network, I/CAO· Get the dat· Created wth Datwrapper
Chart Burse4 B.• Source Air Safety Network, /CAO· Get the data· Created wth Dat
wrapper
Accidents do not always lead to fatalities. Fatalities are recorded in 9 of the last 20
years. But deaths can quickly mount when accidents occur at higher than normal
levels. In 2009, Iran tragically experienced 7 aviation accidents, resulting in 189
deaths.
Accidents do not always lead to fatalities. Fatalities are recorded in 9 of the last 20
years. But deaths can quickly mount when accidents occur at higher than normal
levels. In 2009, Iran tragically experienced 7 aviation accidents, resulting in 189
deaths.
Statistically speaking, air travel in Iran is still safe. This is in large part due to the
efforts of Iranian pilots and maintenance crews to keep aircraft operable despite
limited resources. But even if the overall risk of an accident remains statistically low,
the risk still far exceeds expected levels. Over the last 20 years, Iran has witnessed 41
Statistically speaking, air travel in Iran is still safe. This is in large part due to the
efforts of Iranian pilots and maintenance crews to keep aircraft operable despite
limited resources. But even if the overall risk of an accident remains statistically low,
the risk still far exceeds expected levels. Over the last 2o years, Iran has witnessed 41
accidents, accounting for 6 percent of the global total. But the country accounts for
just o.6 percent of passenger journeys made worldwide in the same period. By this
measure, the frequency of accidents in Iran is 10 times higher than the global norm.
accidents, accounting for 6 percent of the global total. But the country accounts for
just o.6 percent of passenger journeys made worldwide in the same period. By this
measure, the frequency of accidents in Iran is 10 times higher than the global norm.
To help put the risk of death in context, one French study found that the rate of
fatalities for motorcyclists in France is 1.26 deaths per million journeys. By this
jarring measure, a journey on a commercial flight in Iran is more dangerous than a
journey on a motorcycle. Iranian passengers put up with these risks because they
must-it is the only way to visit family, conduct business, or travel for pleasure. But
the situation remains unacceptable.
To help put the risk of death in context, one French study found that the rate of
fatalities for motorcyclists in France is 1.26 deaths per million journeys. By this
jarring measure, a journey on a commercial flight in Iran is more dangerous than a
journey on a motorcycle. Iranian passengers put up with these risks because they
must-it is the only way to visit family, conduct business, or travel for pleasure. But
the situation remains unacceptable.
As Shabazi poignantly told Hjelmgaard, "Everybody knows the risks Iranians face in
the air... and everybody's scared."
As Shabazi poignantly told Hjelmgaard, "Everybody knows the risks Iranians face in
the air... and everybody's scared."
Photo Credit: IRNA
Photo Credit: IRNA

2
2
- 412 -

Annex 287
P. Hafezi, “Iran urges EU to press Washington on Airbus deliveries: ISNA”, Reuters,
17 December 2018

- 413 -

- 414 -

Iran urges EU to press Washington on Airbus deliveries: ISNA
Iran urges EU to press Washington on Airbus deliveries: ISNA
reuters.com/article/us-iran-airbus/iran-urges-eu-to-press-washington-on-airbus-deliveries-isna-idUSKBN 1 0G19X
reuters.com/article/us-iran-airbus/iran-urges-eu-to-press-washington-on-airbus-deliveries-isna-idUSKBN10G19¥
The logo of Airbus is seen at the Airbus A330 final assembly line at Airbus headquarters in
Colomiers, near Toulouse, France, November 26, 2018. REUTERS/Regis Duvignau
The logo of Airbus is seen at the Airbus A330 final assembly line at Airbus headquarters in
Colomiers, near Toulouse, France, November 26, 2018. REUTERS/Regis Duvignau
DUBAI (Reuters) - Iran called on the European Union on Monday to press U.S. authorities to
allow delivery of Airbus passenger aircraft purchased by Tehran, Iran's student news agency
ISNA reported.To upgrade its aging fleet, Iran Air ordered 200 passenger aircraft- 100 from
Airbus, 80 from Boeing and 20 from Franco-Italian turboprop maker ATR - after a 2015 nuclear
deal was reached between Iran and six major powers. But the U.S. Treasury revoked licenses for
Boeing Co and France's Airbus to sell commercial planes to Iran Air after President Donald
Trump pulled the United States out of the agreement in May and reimposed sanctions.
DUBAI (Reuters) - Iran called on the European Union on Monday to press U.S. authorities to
allow delivery of Airbus passenger aircraft purchased by Tehran, Iran's student news agency
ISNA reported.To upgrade its aging fleet, Iran Air ordered 200 passenger aircraft - 100 from
Airbus, 80 from Boeing and 20 from Franco-Italian turboprop maker ATR - after a 2015 nuclear
deal was reached between Iran and six major powers. But the U.S. Treasury revoked licenses for
Boeing Co and France's Airbus to sell commercial planes to Iran Air after President Donald
Trump pulled the United States out of the agreement in May and reimposed sanctions.
"Our main concern is being able to serve our passengers better ... We hope that the EU can get
the OFAC (Office of Foreign Assets Control) licenses for delivery of purchased Airbus planes,"
lranAir Chief Executive Farzaneh Sharafbafi was quoted by ISNA as saying.
"Our main concern is being able to serve our passengers better ... We hope that the EU can get
the OFAC (Office of Foreign Assets Control) licenses for delivery of purchased Airbus planes,"
lranAir Chief Executive Farzaneh Sharafbafi was quoted by ISNA as saying.
Although Airbus is based in France, it must have the approval of the U.S. Treasury's Office of
Foreign Assets Control to sell planes to Iran because at least 10 percent of the components of
the aircraft are U.S.-made.
Although Airbus is based in France, it must have the approval of the U.S. Treasury's Office of
Foreign Assets Control to sell planes to Iran because at least 10 percent of the components of
the aircraft are U.S.-made.
"As OFAC licenses were issued for ATR planes ...the licenses for Airbus planes can be pursued by
(the EU)," she said. "lranAir can never be stopped."
"As OFAC licenses were issued for ATR planes ...the licenses for Airbus planes can be pursued by
(the EU)," she said. "lranAir can never be stopped."
Under a special agreement after U.S. licenses were revoked but before new sanctions came in
force on Nov. 5, ATR delivered 13 of the 20 turboprop aircraft sought by lranAir while the
remainder remain on order.
Under a special agreement after U.S. licenses were revoked but before new sanctions came in
force on Nov. 5, ATR delivered 13 of the 20 turboprop aircraft sought by lranAir while the
remainder remain on order.
Other signatories of the nuclear deal and the EU have remained committed to the pact and have
been trying to salvage it.
Other signatories of the nuclear deal and the EU have remained committed to the pact and have
been trying to salvage it.
Airbus, which delivered three aircraft before the licenses were withdrawn, continues to show the
order as active on its books.
Airbus, which delivered three aircraft before the licenses were withdrawn, continues to show the
order as active on its books.
Boeing never officially added Iran's order to its list of sold jets and has said it will not pursue the
deal.
Boeing never officially added Iran's order to its list of sold jets and has said it will not pursue the
deal.
Writing by Parisa Hafezi; editing by Jason Neely
Writing by Parisa Hafezi; editing by Jason Neely
Our Standards:The Thomson Reuters Trust Principles.
Our Standards:The Thomson Reuters Trust Principles.
111
111

- 415 -

- 416 -

Annex 288
“Europeans refusing fuel to Iranian aircraft”, presstv.com, 18 December 2018

- 417 -

- 418 -

Europeans refusing fuel to Iranian aircraft: Official
Europeans refusing fuel to Iranian aircraft: Official
presstv.com/Detail/2018/12/18/583295/1ran-aviation-airlines-EU-Airbus-Boeing-fuel
presstv.com/Detail/2018/12/18/583295/1ran-aviation-airlines-EU-Airbus-Boeing-fuel
An Iran Air Airbus is refueling at Imam Khomeini International Airport in March 2016.
An Iran Air Airbus is refueling at Imam Khomeini International Airport in March 2016.
Iran's airspace remains open to all international flights, including US airliners, but most
European countries refuse fuel to Iranian planes, an official says.
Iran's airspace remains open to all international flights, including US airliners, but most
European countries refuse fuel to Iranian planes, an official says.
"Iran's sky is open to all countries, except Israel," head of the Iranian Civil Aviation Organization
(CAO) Ali Abedzadeh said.
"Iran's sky is open to all countries, except Israel," head of the Iranian Civil Aviation Organization
(CAO) Ali Abedzadeh said.
Currently, American airplanes are also passing through the Iranian sky and Iran has not
imposed restrictions on any country, the official said. Likewise, no country has put any
restrictions on the passage of Iranian planes.
Currently, American airplanes are also passing through the Iranian sky and Iran has not
imposed restrictions on any country, the official said. Likewise, no country has put any
restrictions on the passage of Iranian planes.
However, "unfortunately, most European countries are refusing to supply fuel to Iranian aircraft
and this creates problems for us, for which we have plans to overcome," Abedzadeh said.
However, "unfortunately, most European countries are refusing to supply fuel to Iranian aircraft
and this creates problems for us, for which we have plans to overcome," Abedzadeh said.
Fuel service providers in Europe and some other countries are citing new US sanctions in
refusing to refuel Iranian aircraft.
Fuel service providers in Europe and some other countries are citing new US sanctions in
refusing to refuel Iranian aircraft.
"US goal is to cut off foreign flights of Iranian airlines," Abedzadeh said.
"US goal is to cut off foreign flights of Iranian airlines," Abedzadeh said.
Iran is already angry with the EU over its failure to stop European companies from leaving the
Islamic Republic.
Iran is already angry with the EU over its failure to stop European companies from leaving the
Islamic Republic.
For months, the Europeans have been working on a virtual clearing house to process Iran-
For months, the Europeans have been working on a virtual clearing house to process Iran-
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related transactions independent of the US.
related transactions independent of the US.
The three main countries behind the initiative - Germany, France and the UK - say they have set
up a special purpose vehicle (SPVJ to facilitate non-dollar trade with Iran.
The three main countries behind the initiative - Germany, France and the UK - say they have set
up a special purpose vehicle (SPV) to facilitate non-dollar trade with Iran.
However, they appear to be passing the buck on who should take the responsibility for the
system and house it.
However, they appear to be passing the buck on who should take the responsibility for the
system and house it.
Last month, Iran's nuclear chief Ali Akbar Salehi said he had warned the Europeans that Iranian
patience was wearing thin.
Last month, Iran's nuclear chief Ali Akbar Salehi said he had warned the Europeans that Iranian
patience was wearing thin.
Salehi said while the European Union's efforts were encouraging, "we have not yet seen any
tangible results."
Salehi said while the European Union's efforts were encouraging, "we have not yet seen any
tangible results."
Iran is disappointed with a mass exodus of major European companies which began even
before the sanctions kicked in after President Donald Trump announced pulling the US out of
the nuclear deal in May.
Iran is disappointed with a mass exodus of major European companies which began even
before the sanctions kicked in after President Donald Trump announced pulling the US out of
the nuclear deal in May.
On Monday, national flag carrier Iran Air Chief Executive Farzaneh Sharafbafi called on the
European Union to press US authorities to allow delivery of Airbus passenger aircraft purchased
by Tehran.
On Monday, national flag carrier Iran Air Chief Executive Farzaneh Sharafbafi called on the
European Union to press US authorities to allow delivery of Airbus passenger aircraft purchased
by Tehran.
European commercial aircraft manufacturer Airbus signed a contract to sell 100 passenger
aircraft to Iran Air after a 2015 nuclear deal was reached with the Islamic Republic.
European commercial aircraft manufacturer Airbus signed a contract to sell 100 passenger
aircraft to Iran Air after a 2015 nuclear deal was reached with the Islamic Republic.
The US revoked licenses for Airbus as well as Boeing which had signed the delivery of 80 planes
to Iran Air after Trump withdrew from the nuclear deal.
The US revoked licenses for Airbus as well as Boeing which had signed the delivery of 80 planes
to Iran Air after Trump withdrew from the nuclear deal.
"We hope that the EU can get the OFAC (Office of Foreign Assets Control) licenses for delivery of
purchased Airbus planes," Sharafbafi said.
"We hope that the EU can get the OFAC (Office of Foreign Assets Control) licenses for delivery of
purchased Airbus planes," Sharafbafi said.
The official urged the EU to press US authorities, "as OFAC licenses were issued for ATR planes"
built by the Franco-Italian turboprop maker which had signed to deliver 20 planes to Iran Air.
The official urged the EU to press US authorities, "as OFAC licenses were issued for ATR planes"
built by the Franco-Italian turboprop maker which had signed to deliver 20 planes to Iran Air.
ATR delivered 13 aircraft, some of which came after OFAC had withdrawn the licenses, with the
rest remaining on order.
ATR delivered 13 aircraft, some of which came after OFAC had withdrawn the licenses, with the
rest remaining on order.
Airbus delivered only three aircraft before the licenses were withdrawn. The Europeans say they
have to get American permits for their deliveries because 10 percent of the components of the
aircraft are US-made.
Airbus delivered only three aircraft before the licenses were withdrawn. The Europeans say they
have to get American permits for their deliveries because 10 percent of the components of the
aircraft are US-made.
On Wednesday, a top official said Iran needs some 500 planes and would likely back buying the
Sukhoi Superjet 100 if Russia was willing to sell them to its airlines.
On Wednesday, a top official said Iran needs some 500 planes and would likely back buying the
Sukhoi Superjet 100 if Russia was willing to sell them to its airlines.
Russian officials have been reported as saying Sukhoi is working on reducing the number of US
parts in the hopes of winning an Iranian order for up to 100 aircraft.
Russian officials have been reported as saying Sukhoi is working on reducing the number of US
parts in the hopes of winning an Iranian order for up to 100 aircraft.
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"If the Iranian airlines want to use this aircraft (Superjet 100 ) and the seller is willing to sell it to
Iran, the Civil Aviation Organization is ready to issue its final comment on this aircraft,"
Abedzadeh said.
"If the Iranian airlines want to use this aircraft (Superjet 100) and the seller is willing to sell it to
Iran, the Civil Aviation Organization is ready to issue its final comment on this aircraft,"
Abedzadeh said.
313
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- 422 -

Annex 289
S. Shahrabi, “Plane Crash in Iran: Failed Navigation System Was to Blame”, Aircraft
Rescue & Fire Fighting Working Group, 14 January 2019

- 423 -

- 424 -

Plane Crash in Iran: Failed Navigation System
was to Blame -ARFFWG I ARFF Working
Group
Plane Crash in Iran: Failed Navigation System
was to Blame - ARFFWG [ ARFF Working
Group
ADACEL
ADACEL
By SHIMA SHAHRABI
By SHIMA SHAHRABI
At about 8:30 on the morning of Monday, January 14, people near the Fath Airport in
Karaj near Tehran heard a terrifying sound that shook the windows of their homes and
businesses. An Iranian Army Air Force Boeing 7o7 cargo plane had overrun the runway
and burst into flames after crashing into a residential villa. "It was lucky that the villa
was empty, otherwise the casualties would have been hiy,her," one eyewitness told
At about 8:30 on the morning of Monday, January 14, people near the Fath Airport in
Karaj near Tehran heard a terrifying sound that shook the windows of their homes and
businesses. An Iranian Army Air Force Boeing 707 cargo plane had overrun the runway
and burst into flames after crashing into a residential villa. "It was lucky that the villa
was empty, otherwise the casualties would have been hiy,her," one eyewitness told
Iran Wire.
According to Iranian media, of the 16 on board, only one person miraculously survived.
The others, 14 men and one woman, lost their lives in the incident. According to an
army spokesperson, the plane was carrying frozen lamb from Bishkek, the capital of the
Central Asian republic of Kyrgyzstan, to be distributed among the needy. "The lamb
carcasses were thrown out of the plane's wreckage, creating a weird scene," the
eyewitness said. "The burned lamb carcasses were mixed with human bodies and pieces
of the plane." According to him, the crowd around the airport grew so big that the
rescue workers had to push back onlookers in order to do their jobs.
According to Fars News Agency, the plane was scheduled to land at the nearby Payam
International Airport, but landed at Fath Airport by mistake. However, the Army's
Public Relations office claimed that the plane had been forced to make an emergency
landing at Fath Airport.
Payam Airport is located 35 kilometers from Tehran and is used for cargo transport,
serving Iran's information and communications technology industry. The airport is
operated by Payam Aviation Services Co. and belongs to Iran's Ministry of Information
and Communications Technology. It is also used as a training site for pilots.
"Landing by mistake is not out of the question," one airline pilottold Iran Wire. "Fath
and Payam airports are on the same path and are very close to each other. It is highly
likely that the pilot landed at Fath Airport by mistake. The runway at Fath is short for a
Boeing 707 and that is why the plane overran the runway and hit a residential area."
Iran Wire.
According to Iranian media, of the 16 on board, only one person miraculously survived.
The others, 14 men and one woman, lost their lives in the incident. According to an
army spokesperson, the plane was carrying frozen lamb from Bishkek, the capital of the
Central Asian republic of Kyrgyzstan, to be distributed among the needy. "The lamb
carcasses were thrown out of the plane's wreckage, creating a weird scene," the
eyewitness said. "The burned lamb carcasses were mixed with human bodies and pieces
of the plane." According to him, the crowd around the airport grew so big that the
rescue workers had to push back onlookers in order to do their jobs.
According to Fars News Agency, the plane was scheduled to land at the nearby Payam
International Airport, but landed at Fath Airport by mistake. However, the Army's
Public Relations office claimed that the plane had been forced to make an emergency
landing at Fath Airport.
Payam Airport is located 35 kilometers from Tehran and is used for cargo transport,
serving Iran's information and communications technology industry. The airport is
operated by Payam Aviation Services Co. and belongs to Iran's Ministry of Information
and Communications Technology. It is also used as a training site for pilots.
"Landing by mistake is not out of the question," one airline pilottold Iran Wire. "Fath
and Payam airports are on the same path and are very close to each other. It is highly
likely that the pilot landed at Fath Airport by mistake. The runway at Fath is short for a
Boeing 707 and that is why the plane overran the runway and hit a residential area."
Failure of Navigation System
Failure of Navigation System
According to the pilot, a failure in the navigation system of the plane is the likely reason
for the ensuing disaster. "All over the world, when two airports are close to each other,
there is a system that warns the pilot to prevent an error, but we do not have this
According to the pilot, a failure in the navigation system of the plane is the likely reason
for the ensuing disaster. "All over the world, when two airports are close to each other,
there is a system that warns the pilot to prevent an error, but we do not have this
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system and this makes it possible to land mistakenly," he told Iran Wire.
system and this makes it possible to land mistakenly," he told Iran Wire.
An aviation expert told the Iranian Students' News Agency (ISNA) that this was not the
first time that the proximity of the two airports has led to a pilot making an error. In
November, he said, a veteran pilot flying a passenger airliner from Mashhad to Payam
Airport mistook Fath Airport for Payam Airport and descended toward the runway. At
the last moment, he realized his error and ascended again. This error could have cost
the 150 passengers and crew their lives.
An aviation expert told the Iranian Students' News Agency (ISNA) that this was not the
first time that the proximity of the two airports has led to a pilot making an error. In
November, he said, a veteran pilot flying a passenger airliner from Mashhad to Pa yam
Airport mistook Fath Airport for Payam Airport and descended toward the runway. At
the last moment, he realized his error and ascended again. This error could have cost
the 150 passengers and crew their lives.
The airline pilot we spoke to agreed with the aviation expert's view of events. "Even
though something like this had happened before, the pilot was not warned that there
was another runway close to Pa yam Airport," he said.
The airline pilot we spoke to agreed with the aviation expert's view of events. "Even
though something like this had happened before, the pilot was not warned that there
was another runway close to Payam Airport," he said.
The BBC reported that the plane was a 14 Boeing 707 refueling tanker that had been
built to order from the Iranian Air Force prior the 1979 Islamic Revolution [Persian
link]. Its first flight took place on February 19, 1976, in Seattle in the United States. Two
months later it was delivered to the Iranian Air Force with the registration number
5-8312. During the eight-year Iran-Iraq war in the 1980s, the plane served as a
refueling tanker for Iranian Phantom F-4 and F-14 fighter jets.
The BBC reported that the plane was a 14 Boeing 707 refueling tanker that had been
built to order from the Iranian Air Force prior the 1979 Islamic Revolution [Persian
link]. Its first flight took place on February 19, 1976, in Seattle in the United States. Two
months later it was delivered to the Iranian Air Force with the registration number
5-8312. During the eight-year Iran-Iraq war in the 1980s, the plane served as a
refueling tanker for Iranian Phantom F-4 and F-14 fighter jets.
In 2003, the plane was converted from a refueling tanker to a passenger airliner and
supplied to Saha Airlines, a domestic carrier. In 2009 it was taken out of service after
an accident at Ahvaz airport. After temporary repairs, it was transferred to Tehran.
Between 2014 and 2016 it underwent fundamental repairs and was transferred to the
army. According to reports, the plane had been used to transfer technical personnel for
the air force and deliver food to Syria.
In 2003, the plane was converted from a refueling tanker to a passenger airliner and
supplied to Saha Airlines, a domestic carrier. In 2009 it was taken out of service after
an accident at Ahvaz airport. After temporary repairs, it was transferred to Tehran.
Between 2o14 and 2o16 it underwent fundamental repairs and was transferred to the
army. According to reports, the plane had been used to transfer technical personnel for
the air force and deliver food to Syria.
"Iran is one of the last countries to fly the 707, which was produced between 1957 and
1979, reported the New York Times. "Many airplanes in the country are old: United
States sanctions prevent the military and civilian carriers in Iran from buying new
airplanes, and make it very difficult to obtain parts for those they already have."
"Iran is one of the last countries to fly the 707, which was produced between 1957 and
1979, reported the New York Times. "Many airplanes in the country are old: United
States sanctions prevent the military and civilian carriers in Iran from buying new
airplanes, and make it very difficult to obtain parts for those they already have."
https://iranwire.com/en/features/5775
https://iranwire.com/en/features/5775
https://arffwg.org/news/plane-crash-in-iran-failed-navigation..
https://arffwg.org/news/plane-crash-in-iran-failed-navigation..
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Annex 290
M. Kraft, “Boeing 737 MAX 8 stuck in Iran since December 14, a real headache for
Norwegian”, Airlive, 29 January 2019

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- 428 -

Boeing 737 MAX 8 stuck in Iran since December 14, a real headache
for Norwegian
Boeing 737 MAX 8 stuck in Iran since December 14, a real headache
for Norwegian
gr'
airlive.net/boeing-737-max-8-stuck-in-iran-since-december-14-a-real-headache-for-norwegian
't'
airlive.net/boeing-737-max-8-stuck-in-iran-since-december-14-a-real-headache-for-norwegian
Melanie Kraft with AIRLIVE contributors
Melanie Kraft with AIRLIVE contributors
January 29, 2019
January 29, 2019
On December 14, a Norwegian 737 MAX 8 flying from Dubai to Oslo suffered an
engine problem and was forced to perform an emergency descent from 32,000
feet to land in Iran.
On December 14, a Norwegian 737 MAX 8 flying from Dubai to Oslo suffered an
engine problem and was forced to perform an emergency descent from 32,000
feet to land in Iran.
The aircraft (reg. LN-BKE) had to circle to burn fuel and shut down one of the engines prior
lading at Shiraz International Airport, Iran.
The aircraft (reg. LN-BKE) had to circle to burn fuel and shut down one of the engines prior
lading at Shiraz International Airport, Iran.
UPDATE Thursday 22 February 2019: After a new engine was flown to Iran, the Boeing 737
MAX 8 is flying to Scandinavia.
UPDATE Thursday 22 February 2019: After a new engine was flown to Iran, the Boeing 737
MAX 8 is flying to Scandinavia.
This was the first time that a Norwegian aircraft has ever landed in the country as the airline
doesn't have any regular services or contacts in the country.
This was the first time that a Norwegian aircraft has ever landed in the country as the airline
doesn't have any regular services or contacts in the country.
Norwegian got the stranded passengers to Oslo after sending a replacement aircraft.
Norwegian got the stranded passengers to Oslo after sending a replacement aircraft.
AirNav.ma
AirNav.m
Aircraft LN-DYG - B738 - Norwegian Air Shuttle
Aircraft LN-DYG - B738 - Norwegian Air Shuttle
Headache for passengers
Headache for passengers
The passengers have now officially entered Iran, and no longer are allowed to enter the US
under the visa waiver program. This means if any of them are flying onwards from Oslo to New
York (which many are) they have to go to a US embassy and ask for permission. They might have
to do it for the rest of their lives.
The passengers have now officially entered Iran, and no longer are allowed to enter the US
under the visa waiver program. This means if any of them are flying onwards from Oslo to New
York (which many are) they have to go to a US embassy and ask for permission. They might have
to do it for the rest of their lives.
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Headache for Norwegian
Headache for Norwegian
Norwegian sent a crew of engineers and maintenance personnel to Iran but it looks like the
plane was not able to be fixed and is going to need a new engine.
Norwegian sent a crew of engineers and maintenance personnel to Iran but it looks like the
plane was not able to be fixed and is going to need a new engine.
But due to various sanctions on Iran, importing spare parts for existing Airbus and Boeing
aircraft in Iran is forbidden.
But due to various sanctions on Iran, importing spare parts for existing Airbus and Boeing
aircraft in Iran is forbidden.
Special arrangements will have to be made between Iranian and US authorities.
Special arrangements will have to be made between Iranian and US authorities.
A spokesperson for Norwegian said: "Unfortunately, the paperwork necessary to service the
plane has taken longer than usual, partly due to fact that we have had to familiarize ourselves
with Iranian regulations."
A spokesperson for Norwegian said: "Unfortunately, the paperwork necessary to service the
plane has taken longer than usual, partly due to fact that we have had to familiarize ourselves
with Iranian regulations."
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Annex 291
Nima Alipour, “Obstruction Against Iranian Aircraft; From Europe to Persian Gulf”,
Iranian Students’ News Agency (ISNA), 23 April 2019

- 431 -

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Iranian Students' News Agency (ISNA)
Iranian Students' News Agency (ISNA)
Tuesday/ 3 Ordibehesht 1398 [23 April 2019]/ 10:56 Category: Civil & Employment/ News Code: 98020301215 / Journalist: 71469
Tuesday/ 3 Ordibehesht 1398 [23 April 2019) / 10:56 Category: Civil & Employment/ News Code: 98020301215 / Journalist: 71469
Obstruction Against Iranian Aircraft; From Europe to Persian Gulf
Obstruction Against Iranian Aircraft; From Europe to Persian Gulf
the Secretary of Association of Iranian Airlines explained the latest situation of fuelling Iranian Aircraft
and declared that fuel companies refuse to provide Iranian aircraft with fuel in most of European
countries as well as Persian Gulf countries.
the Secretary of Association of Iranian Airlines explained the latest situation of fuelling Iranian Aircraft
and declared that fuel companies refuse to provide Iranian aircraft with fuel in most of European
countries as well as Persian Gulf countries.
Maghsoud Asasdi Samani, in an interview with ISNA, explaining the latest situation of fuelling Iranian
aircraft in the world, mentioned: "Unfortunately, after the US withdrawal from JCPOA, most of the
fuel companies, due to the fact that they are multinational and have American shareholders or
business ties with Americans, declared that they will not provide fuel for
Iranian airlines.
Nevertheless, none of the flights of Iranian aircraft have been cancelled because of failure in fuel
supply.
Maghsoud Asasdi Samani, in an interview with ISNA, explaining the latest situation of fuelling Iranian
aircraft in the world, mentioned: "Unfortunately, after the US withdrawal from JCPOA, most of the
fuel companies, due to the fact that they are multinational and have American shareholders or
business ties with Americans, declared that they will not provide fuel for Iranian airlines.
Nevertheless, none of the flights of Iranian aircraft have been cancelled because of failure in fuel
supply.
He continued: "The issue with which certain Iranian aircraft are confronted is that they must have an
extra landing and take-off in order to supply the fuel from another country. For instance, a flight from
Iran to Frankfurt, in its way back from Germany and after boarding the passengers, has to have a stop
in another country for fuelling.
He continued: "The issue with which certain Iranian aircraft are confronted is that they must have an
extra landing and take-off in order to supply the fuel from another country. For instance, a flight from
Iran to Frankfurt, in its way back from Germany and after boarding the passengers, has to have a stop
in another country for fuelling.
The Secretary of Association of [Iranian] Airlines, mentioning that the concerns of aviation fuel
companies due to the US pressure have led them to refuse to cooperate with Iranian companies,
stated: "Small European companies may provide fuel if the Iran-Europe transactions channel (I NSTEX)
is launched."
The Secretary of Association of [Iranian] Airlines, mentioning that the concerns of aviation fuel
companies due to the US pressure have led them to refuse to cooperate with Iranian companies,
stated: "Small European companies may provide fuel if the Iran-Europe transactions channel (INSTEX)
is launched."
Samani, pointing out that providing fuel for Iranian aircraft is impossible in many of the European
countries such as Germany, France, UK, Turkey, etc., emphasised that: "Furthermore, fuelling is not
possible in countries such as Lebanon, Kuwait, UAE, and some other Persian Gulf countries either."
Samani, pointing out that providing fuel for Iranian aircraft is impossible in many of the European
countries such as Germany, France, UK, Turkey, etc., emphasised that: "Furthermore, fuelling is not
possible in countries such as Lebanon, Kuwait, UAE, and some other Persian Gulf countries either."
According to ISNA, as a result of reinforcing the United States sanctions [against Iran], alongside with
several aviation companies' refusals to sell aircraft to Iran, most of the fuelling companies also refuse
to supply fuel to Iranian aircraft. Those matters give rise to certain difficulties for Iranian airlines.
Although no flight has been cancelled so far because of non-supply of fuel, some airlines are forced
to have an extra landing and take-off in order to supply their fuel for returning to the country.
According to ISNA, as a result of reinforcing the United States sanctions [against Iran], alongside with
several aviation companies' refusals to sell aircraft to Iran, most of the fuelling companies also refuse
to supply fuel to Iranian aircraft. Those matters give rise to certain difficulties for Iranian airlines.
Although no flight has been cancelled so far because of non-supply of fuel, some airlines are forced
to have an extra landing and take-off in order to supply their fuel for returning to the country.
End of message/
End of message/
Journalist: Nima Alipour / Editor: Matin Kakoui
Journalist: Nima Alipour / Editor: Matin Kakoui
Short Link:
Short Link:
https;//www.isna.ir/news/98020301215/
https;//www.isna.ir/news/98020301215/

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