Profiting From Iran, and the U.S.

Understanding the Terms

• Withdrew: Company no longer has operations in Iran.
• Active, but no new investment: Company finishing up existing work in Iran but has committed to not making additional investments.
• On hold: Company considering whether to make additional investments.
• Active: Company continues to do business in Iran and has announced no plans to leave.
• Possible violator of the Iran Sanctions Act: Companies in Iran's energy sector whose investments have been deemed by Congress and the State Department as possible violations of the Iran Sanctions Act, which requires the President to sanction companies that make an “investment” of more than $20 million in one year in developing Iran’s vast oil and natural gas reserves. The law defines “investment” as a deal in which the company enters into a contract that includes responsibility for the development of petroleum resources located in Iran or one that provides for general supervision of another person’s performance of such a contract buys shares or an equity interest in a development project, or purchases a share of ownership in that development, or enters into a contract that allows the company to participate royalties, earnings or profits in that development. The term investment does not include the entry into contracts to sell or purchase goods like drilling rigs, technology or certain types of services.
• Revenue & benefits from U.S. government: Includes contracts, grants, Export-Import Bank loans and guarantees, as well as leases that companies have received to drill onshore and offshore for oil and gas on federal lands. Leases are measured in acres.

About The Times’s Analysis

The New York Times identified 74 corporations that have done business in Iran over the last decade, using corporate records filed with the Securities Exchange Commission, company websites, news accounts confirmed by interviews with company officials, and Congressional reports. The Times also used divestiture records compiled by Florida, New York and other states that have forbidden their pensions funds from investing in companies that do certain types of business in Iran, and a list of corporations that the State Department is investigating for possible violations of the Iran Sanctions Act.

The companies, along with their subsidiaries, were then matched against federal contracting and grants databases, Export Import Bank annual reports, Department of Interior oil and gas leasing records and other government documents.

The Times analysis, which covered the years 2000 through the end of 2009, used the following methodology:

• Only dollars that a company or its subsidiaries received while the company or its subsidiaries were doing business in Iran were counted. The Times did not include any dollars received before companies entered into business with Iran or after the company had ceased operations in the country. For example, if the company was in Iran from 2003 to 2005, only payments in those years were counted.
• Because of the way that federal contracting databases are organized, it was not possible to do a month-by-month analysis; if a company left Iran midway through the year, the payments it received for that entire year were counted.
• Because of the way that federal contracting databases are organized, the Times counted the dollars received as a result of government contracts grants etc. during the years a company was in Iran—not the total value of contracts awarded while the company was in Iran.
• Contracts to companies and their subsidiaries were counted. If the subsidiary worked in Iran, the dollars paid by the federal government to the parent were counted for as long as the parent company had owned that subsidiary. If the parent did business in Iran, the subsidiary’s contract payments were counted.
• In most cases, the federal contracting databases automatically included contract dollars given to the subsidiaries of parent companies. In instances where that was not the case, the Times used company websites, published news sources and other information to link parent to subsidiaries.
• If a company said that it planned no new investment in Iran, but continued to perform work there to fulfill existing contracts, the Times counted the dollars it received for as long as that work continued.
• Some companies may not be doing business in Iran themselves but have a significant stake in those that are. When the Times identified cases like this, the contracts, grants etc. of both companies were counted.
• For contracts and grants, the Times was careful to count only those received while a company was in Iran. But for oil and gas leases, the acreage totals provided by the Department of Interior were historic totals. Because the agency and the database it maintains did not break those totals out by year, it was not possible to back out acreage received before a company got into Iran or after it left.
• Contract figures are current as of March 2, 2010. Contract figures may change slightly from day to day because the database is updated constantly.
• The Times contacted all companies listed, and included comments from those companies that responded. Some did not return phone calls and emails, while others declined to comment.