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GAO Letter on Companies Who Have Sold Iran Refined Petroleum Products

The Government Accountability Office has sent a letter to Congressional requestors1 on firms reported in open sources to have sold Iran refined petroleum products between January 1, 2009 and June 30, 2010.

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Reported Sales Took Place Before CISADA’s July 1 Enactment

On July 1, 2010, the President signed into law the Comprehensive Iran Sanctions, Accountability, and Divestment Act (CISADA2) of 2010. CISADA amends the Iran Sanctions Act of 1996 (ISA) to require the President to impose three or more of a possible nine sanctions against persons who knowingly sell or provide Iran with refined petroleum products beyond a certain value. GAO explains that these new provisions apply only to the sale or provision of refined petroleum products to Iran made on or after July 1, 2010. The sales identified in GAO’s report took place before this time.

16 Firms Allegedly Sold Iran Refined Petroleum from Jan 2009-Jun 2010

The GAO lists 16 firms identified in open sources as having sold refined petroleum products to Iran at any time during this period. GAO states that it did not attempt to determine whether the firms meet the legal criteria specified in ISA as amended by CISADA., or whether sales were conducted on or after July 1, 2010.

Firms Further Sorted Into Those that Have Stopped, Appear to Have Stopped, Etc.

GAO further divides the firms into the following categories:

  • 5 with no indication that they have stopped such sales to Iran (including firms in the United Arab Emirates, Singapore, and China);
  • 3 with some indication that they have stopped such sales (including firms in Kuwait, Russia, and Malaysia);
  • 7 that notified GAO they have stopped sales; and
  • 1 that notified GAO it did not sell petroleum products to Iran during that period.

1The Senate Homeland Security and Governmental Affairs Committee and the Judiciary Committee's Subcommittee on Terrorism and Homeland Security.

2See ITT’s Online Archives or 06/30/10 news, 10063049, for BP summary of the trade-related aspects of the CISADA.