Baker Hughes

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According to its Annual Report filed with the SEC for fiscal year 2016: "In January 2016, the U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) issued General License H authorizing U.S.-owned or controlled foreign entities to engage in transactions with Iran if these entities meet the requirements of the general license. Pursuant to this authorization, a non-U.S. BHGE affiliate received seven purchase orders during the fourth quarter of 2017 for the sale of goods pursuant to General License H that could potentially enhance Iran’s ability to develop petroleum resources. The purchase orders cover the sale of valves and parts for industrial machinery and equipment used in gas plants, petrochemical plants and gas production projects in Iran. These purchase orders are valued at less than €0.1 million ($0.1 million), less than €0.1 million ($0.1 million), less than €0.1 million ($0.1 million), €0.3 million ($0.3 million), €0.7 million ($0.8 million), €0.1 million ($0.1 million) and €0.8 million ($1 .0 million). This non-US affiliate also received a cancellation of a previously reported contract for the sale of spare parts for gas turbines. This purchase order cancellation reduces previously reported contract values by €12.3 million ($12.9 million). This non-U.S. affiliate attributed €6.8 million ($8.2 million) in gross revenue and €1.4 million ($1.7 million) in net profits against previously reported transactions during the quarter ending December 31, 2017. A second non-U.S. BHGE affiliate received three purchase orders during the fourth quarter of 2017 for the sale of spares parts to support the development of offshore petroleum resources. The three purchase orders are individually valued at less than €0.1 million ($0.1 million), less than €0.1 million ($0.1 million), and less than €0.1 million ($0.1 million) each. This non-U.S. affiliate did not recognize any revenue or profit during the quarter ending December 31, 2017. A third non-U.S. BHGE affiliate received a purchase order pursuant to General License H valued at €0.2 million ($0.2 million) during the fourth quarter of 2017. The non-U.S. affiliate also received a purchase order at the very end of the third quarter valued at €0.3 million ($0.3 million). Both purchase orders cover the sale of films to be used in inspection of pipelines in Iran. This non-U.S. affiliate did not recognize any revenue or profit during the quarter ending December 31, 2017. All of these non-U.S. affiliates intend to continue the activities described above, as permitted by all applicable laws and regulations." (https://www.sec.gov/Archives/edgar/data/1701605/000170160518000029/fiscalyear2017form10-k.htm)

GE and Baker Hughes will cease operations in Iran in accordance with U.S. law. The trade licenses that the company had been operating under are expected to be revoked in November. (Forbes, 6/8/2018). (https://www.washingtonexaminer.com/business/ge-exits-iran-as-trump-rattles-foreign-trade) (https://www.forbes.com/sites/ellenrwald/2018/06/06/10-companies-leaving-iran-as-trumps-sanctions-close-in/)

These non-U.S. affiliates do not intend to continue the activities described above. The Company has ended all of these activities in full compliance with U.S. sanctions and at this time does not intend to seek specific U.S. Government authorization to collect revenues associated with previously reported projects.

"Baker Hughes, through its foreign subsidiaries, had done work in Iran's oil and gas sectors, but decided several years ago to get out of both Iran and Sudan. A spokesperson said that the company finished all major warranty work it was contractually obligated to do in 2007."  The company has received $7.6 million in revenue and benefits from the US government for their business in Iran during 2000-2009.  They have since withdrawn their investments in Iran. (The New York Times, "Profiting from Iran, and the US," 3/6/2010) (http://www.nytimes.com/interactive/2010/03/06/world/iran-sanctions.html)

According to its Annual report filed with the SEC for fiscal year 2018: "In January 2016, the U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) issued General License H authorizing U.S.-owned or controlled foreign entities to engage in transactions with Iran if these entities meet the requirements of the general license. On May 8, 2018, President Trump announced that the United States will cease participation in the Joint Comprehensive Plan of Action (JCPOA) and begin re-imposing the U.S. nuclear-related sanctions. On June 27, 2018, OFAC revoked General License H and added Section 560.537 to the Iranian Transactions and Sanctions Regulations (ITSR), which authorized all transactions and activities that are ordinarily incident and necessary to the winding down of activities previously approved under General License H through November 4, 2018. Prior to May 8, 2018, certain non-U.S. BHGE affiliates conducted limited activities, as described below, in accordance with General License H. As of November 5, 2018, non-U.S. BHGE affiliates have concluded all activity previously conducted under General License H in Iran. These activities were conducted in accordance with all applicable laws and regulations. During the year ending December 31, 2018, but prior to the expiration of the wind down period for General License H, non-U.S. BHGE affiliates conducted the following reportable activities: • A non-U.S. affiliate of BHGE received five purchase orders and attributed €31.4 million ($36.0 million) in gross revenues and €8.6 million ($9.9 million) in net profits related to the sale of valves and parts for industrial machinery and equipment used in gas plants, petrochemical plants and gas production projects in Iran. (https://www.sec.gov/Archives/edgar/data/1701605/000170160519000021/fiscalyear2018form10-k.htm)

"'Baker Hughes left Sudan in December and since then has been only doing warranty work stemming from contracts in Iran,' spokesman Gary Flaharty said. 'Baker Hughes is not starting new work in Iran,' he said." (The Houston Chronicle, "Weatherford to leave sanctioned countries," 9/11/07) (http://www.chron.com/disp/story.mpl/business/5124336.html)

"At first, even companies incorporated in the United States - including such Schlumberger rivals as Halliburton, Weatherford, and Baker-Hughes - got around US sanctions by utilizing their overseas subsidiaries to perform work in Iran. Then the Sept. 11, 2001, terrorist attacks sparked federal investigations into whether US personnel were involved in the subsidiaries operating in Iran. Facing tighter scrutiny, negative publicity, and investor anger, all three of Schlumberger's main American competitors pulled out of Iran." (The Boston Globe, "Oil firm sidesteps sanctions on Iran," 12/7/08) -- "More importantly, even the threat of unilateral sanctions has been effective as recently as last year. As state after state has ramped up efforts to divest pension funds from companies invested in Iran, and as S 970, the Smith-Durbin Iran Counter-Proliferation Act, has garnered support in Congress, American companies like General Electric, Halliburton, and Baker Hughes with subsidiaries operating in Iran have rethought the wisdom of doing business with one of our nations most dangerous enemies. And as the United States has contemplated additional unilateral banking sanctions on Iran, banks across Europe have ratcheted back their exposure to the Islamic Republic, with some pulling out entirely." (AEI, The Iran Counter-Proliferation Act of 2007, April 21, 2008) (http://www.boston.com/news/world/middleeast/articles/2008/12/07/oil_firm_sidesteps_sanctions_on_iran/) (http://www.aei.org/speech/27773)