CNOOC Ltd.

According to its Annual Report filed with the SEC for fiscal year 2015: "To our knowledge, in 2015, China Oilfield Services Limited (COSL), one of our non-controlled affiliates, continued to provide certain drilling and other related services in Iran under renewed subcontracting agreements entered into in 2009, as it did in 2014. We cannot predict at this time whether U.S. sanctions will be imposed on any of our affiliates." (https://www.sec.gov/Archives/edgar/data/1095595/000095010316012730/dp64914_20f.htm)

On June 16, 2011, CNOOC Ltd was added to the Florida State Board of Administration List of Prohibited Investments (Scrutinized Companies) due to its involvement in Iran. As of March 9, 2021, CNOOC Ltd remains on the SBA list of prohibited investments.  (https://www.sbafla.com/fsb/Portals/FSB/Content/Performance/Quarterly/2021_03_09_Web_Update_PFIA_Prohibited_List.pdf?ver=2021-03-09-134849-587)

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According to CNOOC 20-F Filings, the company cites in its risk section the potential for U.S. sanctions related to its affiliates’ operations in Iran and Sudan. In particular, one of the company’s noncontrolled affiliates continued to provide certain drilling and other related services in Iran. In 2011, CalSTRS staff met with executives of the company in its offices in Beijing. The company confirmed its parent may have ties to Iran, but it does not, and will not, seek business in Iran as the company has and is looking to purchase more assets in the United States. CNOOC is listed on the December 31, 2018 CalSTRs Portfolio of companies identified as possibly having ties to Iran and from which CalSTRs has divested from and restricted in 2018. While CNOOC does not appear to have direct ties to Iran, CalSTRS is uncomfortable with its parent company’s relations to the country. In 2012, CalSTRS divested holdings of CNOOC and designated the company as “Divested and Restricted.” CalSTRS has maintained the “Divested and Restricted” designation in 2018. (https://www.calstrs.com/sites/main/files/file-attachments/calstrs_investment_reports_2018.pdf)

According to its Annual Report filed with the SEC for fiscal year 2018, 2017 : "To our knowledge, in 2018, China Oilfield Services Limited (COSL), one of our non-controlled affiliates, provided certain drilling services in Iran. We cannot predict at this time whether U.S. sanctions will be imposed on any of our affiliates." (https://www.sec.gov/Archives/edgar/data/1095595/000095010319005015/dp105023_20f.htm) (https://www.sec.gov/Archives/edgar/data/1095595/000095010318004942/dp89178_20f.htm)

According to its Annual Report filed with the SEC for fiscal year 2013: "To our knowledge, in 2013, China Oilfield Services Limited (COSL), one of our non-controlled affiliates, continued to provide certain drilling and other related services in Iran in relation to subcontracting agreements entered into in 2009, as it did in 2012. We cannot predict at this time whether U.S. sanctions will be imposed on any of our affiliates." (https://www.sec.gov/Archives/edgar/data/1095595/000095010314002737/dp45516_20f.htm)

In 2020, the U.S. state of Mississippi listed CNOOC on its state lists of Companies Doing Business with the Iranian Petroleum/Natural Gas, Nuclear and Military Sectors, rendering it ineligible for investment and/or state contracting. (https://www.dfa.ms.gov/media/sd1ccddh/businesses-doing-business-with-iran-12-4.docx)

According to its Annual Report filed with the SEC for fiscal year 2016: "To our knowledge, in 2016, China Oilfield Services Limited (COSL), one of our non-controlled affiliates, provided certain drilling and other related services in Iran and another non-controlled affiliate of ours was engaged in submarine cable installation and trenching services in Iran. We cannot predict at this time whether U.S. sanctions will be imposed on any of our affiliates." (https://www.sec.gov/Archives/edgar/data/1095595/000095010317003701/dp75013_20f.htm)

As of July 2020, China Oilfield remains on the Pennsylvania Treasury's List of Scrutinized Companies Determined as Having Involvement In Iran because of oil-related investment of US $20 million since 1996.  (https://www.patreasury.gov/pdf/divestment/2020-Annual-Divestment-Report.pdf)

"Chinese oil companies such as Sinopec [SASADZ.UL], CNOOC Ltd and others have managed to reduce their shipments of Iranian oil but it is unclear which Chinese government parties might still be buying Iranian oil, a senior U.S. energy official said on Tuesday." (Reuters, 9/10/2019). (https://www.reuters.com/article/us-energy-wec-usa/u-s-to-monitor-iranian-oil-shipments-will-eye-chinese-purchases-official-idUSKCN1VV2AZ?utm_source=Pompeo+Hints+That+Trump+Could+Meet+With+Iranian+President+At+UN+Meeting+&utm_campaign=eye-on-iran&utm_medium=email)