RESPONSE TO WRITTEN QUESTIONS SUBMITTED BY HON. FRANK R. LAUTENBERG TO
JAMES J. MULVA
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Question 3. Please describe any business relationship or transaction your company or any of its subsidiaries, wherever located and wherever incorporated, whether wholly owned or not, have had with Iranian nationals (except employment of Iranian expatriates), the Iranian government, individuals or corporations located or incorporated in Iran, or any representative of these people or companies.
Answer. ConocoPhillips does not have any operations or investments in Iran, either directly or indirectly through foreign subsidiaries, nor is ConocoPhillips currently negotiating for business opportunities in Iran. In 1995, the National Iranian Oil Company ("NIOC") awarded our foreign subsidiary, Conoco Iran N.V., a service contract to develop the Sirri Fields located offshore Iran adjacent to ConocoPhillips operations in Dubai, but the subsequent imposition of U.S. sanctions precluded our involvement in that project and we...
Notes:
1) Document contains an excerpt of the CEO of ConocoPhillips' answers to questions asked in connection with his testimony before Congress.
Mulva recounts the details concerning two settlement agreement entered into with OFAC prior to 2006, when OFAC began disclosing the details of its enforcement actions (but OFAC did disclose that the penalty amounts were $16,500.00, paid by ConocoPhillips on behalf of Conoco, Inc. and Conoco Middle East Ltd.).[1]
The was penalty issued on the basis of the ITR (now the ITSR) as it existed from 1999-2000, prior to the blocking of all GOI property (EO 13599 and 560.211) and prior to all U.S.-owned or -controlled entities being subject to the general...