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AUGUST 25, 2010 WSJ

LyondellBasell Will Quit Iran

LyondellBasell Industries NV, one of the world's biggest plastic and chemical producers, will end its business operations in Iran to shield itself against penalties the U.S. could soon impose on companies for violating trade sanctions.

The Dutch-based company's board approved the decision early this month after months of deliberation, according to David Harpole, a LyondellBasell spokesman.

In the past year, a number of companies - including many of Iran's gasoline suppliers - have cut business ties with Iran because of worries about legal consequences in the U.S. and elsewhere, and public-relations concerns. They include Royal Dutch Shell PLC, which halted gasoline sales, and Toyota Motor Corp., which suspended car exports.

ロイヤル・ダッチ・シェルは3月10日、イランに対するガソリン販売を打ち切ったことを明らかにした。
トヨタ自動車は
811日、イランへの自動車輸出を6月から止めていることを明らかにした。

LyondellBasell's decision means it will stop all licensing of its proprietary technology and services to Iranian petrochemical companies, which have depended heavily on technology from European concerns to produce plastics and other high-value products derived from natural gas.

Mr. Harpole said the move would be "immaterial" to LyondellBasell's overall operations.

But the decision is a blow to the Iranian government, which is trying to build the country's petrochemicals industry to diversify the economy.

Iran exported some $6.5 billion of petrochemical products in 2009, according to Facts Global Energy, a Singapore-based consultancy that tracks the Iranian energy sector. That is a small amount compared with the value of Iran's oil exports.

LyondellBasell's Mr. Harpole said that the mounting pressure over sanctions played a decisive role in the board's decision to halt its Iranian operations. The company - which has extensive U.S. operations, particularly in Texas - is also ending its business ties in Syria and Sudan. Those countries are also covered by existing U.S. sanctions.

The decision also reflects LyondellBasell's desire to avoid legal problems after exiting bankruptcy protection in April. The company plans to list 566 million shares on the New York Stock Exchange any day, according to Mr. Harpole, to beef up its capital position and help fund its growth plans.

He said the company recently made a "voluntary disclosure" about the nature of its past business in Iran to the U.S. agency that enforces sanctions, the Office of Foreign Assets Control, which is a unit of the Treasury Department.

He declined to elaborate. OFAC wouldn't comment on LyondellBasell's case or whether other companies had made similar disclosures.

The Obama administration could soon announce plans to sanction or warn companies, primarily from Europe and Asia, that they are in violation of U.S. sanctions against Iran.

"The administration is in the final stages of reviewing cases of potentially sanctionable activity [of companies] under U.S. law and expects to be making decisions on those cases soon," a senior official said.

The official declined to specify which companies are being targeted, but a person familiar with the matter said the State Department is considering action against about 10 companies. The companies could face civil or even criminal penalties depending on the nature of any confirmed violations, but such action could take months.

The U.S. last month adopted new sanctions against Iran, primarily targeting the country's energy sector.

For the first time, the rules require firms to effectively choose between doing business in the U.S. or Iran. Australia, Canada, the European Union and the United Nations have also passed their own versions of sanctions against Iran in recent months.

U.S. companies have long been barred from doing business in Iran. A report earlier this year from the U.S. Government Accountability Office, an oversight agency and arm of Congress, cited 41 companies, nearly all from Europe and Asia, with operations in Iran's oil, natural gas and petrochemical industries from 2005 to 2009.

2010/5/12  http://www.gao.gov/new.items/d10721t.pdf

Firms Reported to Have Commercial Activity in the Iranian Energy Sector and U.S. Government Contracts

U.S. law restricts U.S. firms from investing in Irans energy sector through sanctions to discourage Iran from supporting terrorism and developing nuclear weapons. In addition, the Iran Sanctions Act (ISA) provides for sanctions against persons, including foreign firms, who invest more than $20 million in Irans energy sector in any 12-month period. The act allows the President, who delegated authority under the act to the Secretary of State, to ban such persons from U.S. government procurement, including contracts for goods or services. The Secretary of State is responsible for determining whether a firms activities meet the legal criteria for an investment, and the firm could therefore be subject to actions under the Iran Sanctions Act. The Secretary of State may waive the sanctions if the Secretary determines it is in the national interests of the United States to do so.

Table 1: Foreign Firms Publicly Reported to Have Commercial Activity in the Iranian Oil, Gas, or Petrochemical Sectors

Firm                          Country Sector
ABB Lummus   Refining, petrochemicals
OMV Austria Natural gas
Belneftekhim Belarus Oil exploration and production
Petrobras Brazil Oil exploration and production
China National Offshore Oil Corporation China Natural gas
China National Petroleum Corporation China Oil exploration and production, natural gas
Sinopec China Oil exploration and production, refining
INA Croatia Oil exploration and production, natural gas
Haldor Topsoe Denmark Refining
Total France Natural gas
Uhde Germany Petrochemicals
Indian Oil Corporation India Natural gas
Oil and Natural Gas Corporation India Oil exploration and production, natural gas
Oil India Ltd. India Natural gas
ONGC Videsh Ltd. India Natural gas
Petronet LNG India Natural gas
Edison Italy Oil exploration and production
ENI Italy Oil exploration and production
Snamprogetti Italy Pipeline
Tecnimont Italy Petrochemicals
Inpex Japan Oil exploration and production
JGC Corporation Japan Refining
Amona Malaysia Oil exploration and production
Petrofield Malaysia Natural gas
SKS Ventures Malaysia Natural gas
LyondelBasell Netherlands Petrochemicals
Royal Dutch Shell Netherlands Natural gas
StatoilHydro Norway Oil exploration and production, natural gas
PGNiG Poland Natural gas
Gazprom Russia Oil exploration and production, pipeline
Lukoil Russia Oil exploration and production
Daelim South Korea Natural gas
Daewoo Shipbuilding & Marine Engineering South Korea Oil tankers
GS South Korea Natural gas
Hyundai Heavy Industries South Korea Oil tankers
Repsol Spain Natural gas
PTT Exploration & Production Thailand Natural gas
Turkish Petroleum Company Turkey Natural gas
Costain Oil, Gas & Process Ltd. United Kingdom Natural gas
Hinduja United Kingdom Oil exploration and production, natural gas
Petroleos de Venezuela S.A. Venezuela Natural gas

LyondellBasell, German engineering firm Uhde GmbH and Italy's Maire Tecnimont SpA, an energy and engineering-services firm, were named in the GAO report as firms with business in Iran's petrochemical sector in the past five years. Other foreign companies like them also work in Iran's petrochemical sector, analysts say.

Uhde is a unit of German industrial conglomerate ThyssenKrupp AG. Alexander Wilke, a ThyssenKrupp spokesman, said that "to the best of our knowledge, all group companies are in full compliance with U.S. sanctions against Iran." Maire Tecnimont didn't respond to requests for comment.

Analysts say that actually levying penalties against companies for violations of U.S. sanctions could be a long, drawn-out process posing many hurdles.

OFAC has to establish a variety of legal criteria, including whether a company's apparent violation was part of a "pattern or practice" and whether a company demonstrated "reckless disregard" of U.S. sanctions law, in order to determine what action can be taken, according to agency enforcement guidelines. If OFAC thinks a company's actions could lead to a violation, the company may receive just a cautionary letter.

Illustrating the barriers to the imposition of sanctions, the recent GAO report said that in 1998 the U.S. made its first and only determination that a company's investments violated existing U.S. sanctions against Iran. In that case, the sanctions were eventually waived because they were deemed to conflict with American foreign-policy interests.