BHP Billiton

The Bruce platform provides transportation and processing services to the nearby Rhum gas field pursuant to a contract between the Bruce owners and Rhum owners (the Bruce-Rhum Agreement). According to BP, the Rhum field is operated by BP and owned under a 50:50 unincorporated joint arrangement between BP and Iranian Oil Company (U.K.) Limited (IOC). IOC is an indirect subsidiary of the National Iranian Oil Company (NIOC), which is a corporation owned by the Government of Iran. As a Bruce owner, BHP Billiton GB is party to the Bruce-Rhum Agreement, and BHP Billiton believes the activities thereunder are authorised by the U.S. Department of the Treasury under OFAC licence No. IA-2013-302799-4."

According to its Annual Report filed with the SEC for fiscal year 2016: "BHP Billiton Petroleum Great Britain Ltd (BHP Billiton GB), a wholly-owned affiliate of BHP Billiton, holds a non-operating 16 per cent interest in the Bruce oil and gas field located offshore United Kingdom, together with co-venturers BP Exploration Operating Company Limited (BP) (operator and 37 per cent interest holder), Marubeni Oil & Gas (North Sea) Limited (3.75 per cent interest holder) and Total E&P UK Limited (43.25 per cent interest holder). (https://www.sec.gov/Archives/edgar/data/811809/000119312516715037/d178736d20f.htm)

In 2017 - In a complex disclosure related to a joint venture, BHP Billiton (an Australian company) disclosed the activity of its wholly owned affiliate BHP Great Britain Ltd. (BHP GB). BHP GB, together with British Petroleum (BP) and two other oil and gas companies, holds a percentage interest in the Bruce oil and gas platform that provides transportation and processing services to the Rhum gas field. BHP Billiton noted that the Rhum field is owned under an unincorporated joint arrangement between BP and the Iranian Oil Company Ltd., whose indirect owner—the National Iranian Oil Company—is owned by the Government of Iran. BHP also noted that the Bruce-Rhum agreement to which its affiliate is a party is an activity authorized pursuant to an OFAC-issued license.

The Bruce platform provides transportation and processing services to the nearby Rhum gas field pursuant to a contract between the Bruce owners and Rhum owners (the Bruce-Rhum Agreement). According to BP, the Rhum field is operated by BP and owned under a 50:50 unincorporated joint arrangement between BP and Iranian Oil Company (U.K.) Limited (IOC). IOC is an indirect subsidiary of the National Iranian Oil Company (NIOC), which is a corporation owned by the Government of Iran. As a Bruce owner, BHP GB is party to the Bruce-Rhum Agreement with BP as the operator. The U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC) issued licence No. IA-2013-302799-5 to BP and its affiliates for Rhum Field activities for the period to 30 September 2017 and thereafter authorised activities under OFAC licence No. IA-2013-302799-6, until the end of September 2018.

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“The U.S. Securities and Exchange Commission looked into BHP Billiton Ltd.'s (BHP.AU) activities in Iran and Cuba due to Washington's labelling of the countries as state sponsors of terrorism, according to documents filed with the regulator. In a document filed June 15, the world's largest miner said that it had earned US$361 million in revenues from Iran in the four years to the end of June 2009 and expected to make a further US$74 million from the country in the most recent financial year.” (FOX Business, "BHP Billiton's Iran, Cuba Activities Subject of SEC Inquiry," Aug. 8, 2010)  (http://www.foxbusiness.com/markets/2010/08/08/bhp-billitons-iran-cuba-activities-subject-sec-inquiry/) (http://www.foxbusiness.com/markets/2010/08/08/bhp-billitons-iran-cuba-activities-subject-sec-inquiry/)

According to its Annual Report filed with the SEC for fiscal year 2018: "BHP Billiton Petroleum Great Britain Ltd (BHP GB), a wholly owned affiliate of BHP, holds a non-operating 16 per cent interest in the Bruce oil and gas field located offshore United Kingdom, together with co-venturers BP Exploration Operating Company Limited (BP) (operator and 37 per cent interest holder), Marubeni Oil & Gas (North Sea) Limited (3.75 per cent interest holder) and Total E&P UK Limited (43.25 per cent interest holder). (https://www.sec.gov/Archives/edgar/data/811809/000119312518275568/d603229d20f.htm)

BHP ceased to rely on US persons for Bruce-Rhum Agreement related activities from 30 September 2017 and continues to monitor developments concerning the US Iranian sanctions program to maintain compliance with applicable sanctions laws and requirements."