Friday, March 18, 2005


Site of Reference:

A press release of Halliburton in 2003; the preface states, “This report is being submitted to the Halliburton Company Board of Directors pursuant to an agreement worked out with Mr. William Thompson Jr.'s Office of the Comptroller, which represents the New York City Police Pension Fund and the New York City Fire Department Pension Fund which are Halliburton stockholders. (approximately 318,540 shares.) The Fund's stated concern was that the Halliburton Board of Directors have actual knowledge of operations conducted in Iran or for Iranian entities by the various worldwide elements of the Company.” So the New York City Fire Department Pension Fund wants to make sure that Halliburton is acting in a legal manner. But in the next paragraph we find that Halliburton has identified a technicality on which to operate. A loophole described as “independent foreign subsidiaries.” In other words don’t mess with us we are Halliburton and we will find a way to get what we want.
“As the Board is aware, Iran is the subject of special sanctions administered by the U.S. Treasury, through the U.S. Office of Foreign Assets Control. In general, all "U.S. Persons", both corporate and individual, are prohibited to enter into transactions with Iran or entities working on behalf of Iran, and are further prohibited to "approve or facilitate" transactions by foreign persons. The sanctions leave open, however, the possibility for "independent foreign subsidiaries" of U.S. corporations, which are not considered to be "U.S. Persons" to conduct such business. Many U.S. corporations have foreign subsidiaries active in Iran, including our major competitors.” I am surprised they didn’t go ahead and name names. If they are saying that they do not have any Americans whatsoever working in Iran who is to get in the country and investigate? I believe the F.B.I. and the C.I.A. has employed non-U.S. persons before. All it takes is a different passport. It is not as if Iran is checking their office paperwork everyday as a requirement for their presence there.
“Halliburton has taken care to isolate its entities that continue to work in Iran from contact with U.S. citizens or managers of U.S. companies, so as to insure that all work in Iran is undertaken independently, without any facilitation, authorization or approval from U.S. citizen managers. The Board should be assured however, that the U.S. Sanctions do not prohibit them as individuals, or as the Halliburton Company Board of Directors, from having knowledge of the activity there.” So they can employ these non-U.S. persons but can’t have any contact with them? Can you imagine Halliburton having no knowledge of the job its workers are doing? “Well, tell us how it went when you get back, can’t wait to find out.”
Recently Halliburton has come under intense scrutiny, or as intense as the Bush government will let it and is to be banned from doing work in Iraq so the headlines read. They can simply hire these non-U.S. persons and ……

- Chris Mansel

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