CNH Global

According to its Annual Report filed with the SEC for fiscal year 2017: "CNH Industrial has limited commercial activity in Iran, which is conducted by non-US subsidiaries. In 2017, sales in Iran were significantly less than one percent of CNH Industrial’s revenues.  In 2017, one of our non-US subsidiaries generated net revenues of approximately $11.3 million attributable to the sale of on and off-road trucks and spare parts to an entity that is indirectly owned or controlled by the Government of Iran." (https://www.sec.gov/Archives/edgar/data/1567094/000156459018004221/cnhi-20f_20171231.htm)

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On February 24, 2016, a delegation of CNH officials met with Iran’s Arak HEPCO Company in Iran. (IRNA, “Arak HEPCO capacities introduced to Italian investors,” 2/24/2016) (http://www.irna.ir/en/News/81978081/)

"Fiat and its sister companies, Fiat Industrial and CNH Global N.V. (CNH), said they will cease business activities in Iran in support of diplomatic efforts to convince the leaders of Iran to abandon its nuclear program, which is widely suspected of developing nuclear weapons. Iran has denied that it is making nuclear weapons... Fiat Industrial and CNH issued statements with the same wording. Fiat exports cars to Iran while Fiat Industrial exports buses and trucks under its Iveco brand. CNH Global builds farm and construction machinery that is sold in Iran." (Dow Jones, "Fiat Ban On Sales To Iran Seen As Victory In Sanctions Campaign," 5/25/2012) -- In a correspondance with the SEC in December of 2009, CNH disclosed details of its sales in Iran. (http://www.nasdaq.com/article/fiat-ban-on-sales-to-iran-seen-as-victory-in-sanctions-campaign-20120525-00672)

(CORRESP for CNH GLOBAL N V, 12/7/2009) (https://www.sec.gov/Archives/edgar/data/1024519/000119312509248665/filename1.htm','CNH%20GLOBAL%20N%20V',''))

CNH Industrial, reportedly was part of a 370-member Italian trade delegation to Iran in late November 2015. (Press TV, “Fiat in talks for car manufacturing in Iran,” 11/29/2015). (http://www.presstv.com/Detail/2015/11/29/439612/Iran-automotive-industry-Fiat-Italy-sanctions)

According to its Annual Report filed with the SEC for fiscal year 2018: "In 2018, CNH Industrial suspended business activities in Iran, other than those activities required to fulfill binding orders. Prior to the suspension of business activities in Iran, CNH Industrial had limited commercial activity in Iran conducted by non-US subsidiaries. In 2018, sales in Iran were significantly less than one percent of CNH Industrial’s revenues. In 2018, one of our non-US subsidiaries generated net revenues of approximately $4.6 million attributable to the sale of on and off-road trucks and spare parts to an entity that is indirectly owned or controlled by the Government of Iran. The Iran-related activity was negligible to our overall revenues and profits. Our activities in Iran comply in all material respects with applicable laws and regulations, including U.S. and other international trade sanctions." (https://www.sec.gov/Archives/edgar/data/1567094/000162828019002353/cnhi-20xfdocument2018.htm)

"CNH’s foreign subsidiaries’ total sales into Iran: $27.8 million in 2006, $42.9 million in 2007, $36.8 million in 2008, and $6.2 million in 2009.  In Iran, CNH’s foreign subsidiaries sell equipment to independent distributors or with the assistance of a commission agent."