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

Correspondence issued by the Government Accountability Office with an abstract that begins "The United States has imposed multiple sanctions against Iran to deter it from developing its nuclear program, supporting terrorism, and abusing human rights. On July 1, 2010, the President signed into law the Comprehensive Iran Sanctions, Accountability, and Divestment Act (CISADA) of 2010. CISADA amends the Iran Sanctions Act of 1996 (ISA) to require the President to impose three or more of a possible nine sanctions against persons who knowingly sell or provide Iran with refined petroleum products that, during a 12-month period, (1) have a fair market value of $1 million or more or (2) have an aggregate fair market value of $5 million or more. These new provisions regarding the sale or provision of refined petroleum products to Iran apply only to the sale or provision of refined petroleum products made on or after July 1, 2010. Under ISA, one of the sanctions that the President can apply is to bar foreign firms State administers ISA sanctions. According to the Department of Energy (DOE), Iran currently does not have sufficient refining capacity to meet its domestic demand for gasoline. Iran imported approximately 130,000 barrels of gasoline per day in 2009 as well as other refined products, such as diesel fuel. Iran's nine refineries are operated by the National Iranian Oil Refining and Distribution Company, according to DOE. With the potential participation of foreign companies, Iran plans to add capacity at eight of its nine refineries in an attempt to fully meet domestic demand for gasoline by 2013 or 2014 at currently projected demand levels, according to DOE officials. This report highlights open source information that, following further investigation by the State Department, could contribute to the identification of persons or firms whose activities may be sanctionable under ISA, as amended by CISADA. As Congress requested, in this report, we identify (1) firms that were reported to have sold refined petroleum products to Iran at any time during the period between January 1, 2009, and June 30, 2010, and (2) firms that also had U.S. government contracts in fiscal year 2009 or 2010 (up to June 2010). We define the sale of refined petroleum products as receiving payment for the provision of any such products through direct sale, shipment, or brokering (i.e., trading) of these products to Iran. GAO did not review the contracts or documents underlying these transactions reported in open sources and did not independently verify these transactions. Further, we did not attempt to determine whether the firms listed in this report meet the legal criteria specified in ISA, as amended by CISADA, and we did not attempt to determine whether reported transactions were conducted on or after July 1, 2010--the date of enactment of CISADA. The Secretary of State is responsible for making such determinations.