Gazprom

“Our work on entering the projects in Iran has not been completed yet, which is why it is too early to speak [about] where gas from Iran will run,” he said to Russia’s Tass news agency.

But those figures may need revising, upwards - a point well grasped in Moscow. According to Simon Watkins, of Oilprice.com, further studies have revealed that the field has far more reserves than previously thought, with a total 7.1 trillion cubic meters, fully half the reserves of South Pars, Iran’s huge field in the Persian Gulf.

In June, Iran’s Khazar Exploration and Production Company (Kepco), then touted as the field’s main developer, suggested the field held 30 percent of the developable natural gas reserves of all Caspian Sea littoral counties and could potentially meet 20 percent of all European demand for gas.

--

"In July 2008, OAO Gazprom signed an MOU with the NIOC, which expired in July 2010. Additionally, Gazprom Neft, a subsidiary of OAO Gazprom, signed an MOU with the NIOC providing for joint exploration of oilfields in Iran. In 2014, the company reported that Iran had suspended cost recovery payments related to Phase 2 and 3 of the South Pars gas field. In December 2017, the company signed an MOU relating to the development of Iranian gas fields. In 2009, CalSTRS designated OAO Gazprom as “Under Review.” In 2010, CalSTRS designated OAO Gazprom as “Being Monitored” after confirming the company has no current investments in Iran. In 2011, CalSTRS maintained OAO Gazprom as “Being Monitored” as the U.S. Government Accountability Office (GAO) stated it had insufficient information on the company’s activities and the Russian government’s reported interest in developing a deal with Iran. In 2014, due to U.S. sanctions on Gazprom Bank, an OAO Gazprom subsidiary, CalSTRS determined to minimize its exposure to the company by restricting managers from making new purchases in OAO Gazprom securities. In 2016, for risk control purposes, CalSTRS revised the restriction on purchasing shares of OAO Gazprom to allow managers underweighted in OAO Gazprom (versus their benchmark) to purchase up to benchmark weight. In 2018, CalSTRS maintained the “Being Monitored” status and removed the benchmark weighting restriction on OAO Gazprom but required managers holding the security to make quarterly updates on their investment rationale. In 2020, CalSTRS maintained the “Being Monitored” status." (https://www.calstrs.com/sites/main/files/file-attachments/calstrs-investment-reports-2020.pdf?1609284307)

“As of today, we are at the stage of considering our participation in projects in Iran.”

As of January 28, 2020, Gazprom is included on the District of Columbia Retirement Board’s (“DCRB”) Iran Divestment Scrutinized Companies List. (https://dcrb.dc.gov/sites/default/files/dc/sites/dcrb/publication/attachments/Iran Divestment Scrutinized Companies List January 2020_0.pdf)

In 2017 the U.S. states of Alaska, Florida, Minnesota, Pennsylvania, Rhode Island, South Carolina, Tennessee lists Gazprom on its list of companies doing material business with Iran rendering Gazprom ineligible for investment and/or state contracting. (http://treasury.dor.alaska.gov/Portals/3/docs/ARMB%20Iran%20Divestment%20List%2012-31-17.pdf) (https://www.sbafla.com/fsb/Portals/FSB/Content/GlobalGovernanceMandates/QuarterlyReports/2017/Global_Governance_Mandates_and_Florida%20Statutes_2017_12_13.pdf?ver=2017-12-13-145507-737) (https://www.leg.state.mn.us/docs/2017/mandated/170167.pdf) (https://www.patreasury.gov/pdf/divestment/2017-Annual-Divestment-Report.pdf) (https://www.unitedagainstnucleariran.com/ http://data.treasury.ri.gov/dataset/scrutinzed-companies-list-iran/resource/6936d293-53b5-4223-8f6d-36777bf91c6d) (https://www.ipers.org/sites/default/files/media/2017%2009%20Iran%20Prohibited%20Companies%20List%2009-30-17.pdf) (https://www.tn.gov/content/dam/tn/generalservices/documents/cpo/cpo-library/public-information-library/List_of_persons_pursuant_to_Tenn._Code_Ann._12-12-106_Iran_Divestment_Act_updated_7.7.17.pdf)

On May 15, 2020, the IPERS identified Gazprom on its Iran Prohibited Companies List. (https://www.ipers.org/sites/default/files/IPERS%27 Iran Prohibited Companies 2Q20.pdf)

He also said that Gazprom has ruled out participating in the planned scheme to build a gas pipeline from Iran to Oman." (6/4/2019) (https://www.offshore-technology.com/comment/gazprom-and-iran-2019/)

"Russias Gazprom, the worlds top gas producer, said on Tuesday it will take on big new energy projects in Iran, a move likely to anger the United States which wants Tehran isolated over its nuclear work. State-controlled Gazprom, which supplies a quarter of Europes gas needs, said it had agreed to develop more phases of Irans giant South Pars gas field and drill in the countrys oilfields. Gazprom, together with Frances Total and Malaysias Petronas, has already invested in phases 2-3 of massive South Pars gas field, a project worth around $2 billion." (Reuters, "Gazprom, Iran agree new large new large energy projects," 2/19/08) (http://www.reuters.com/article/2008/02/19/gazprom-iran-idUSL1990944220080219)

At its meeting on February 16, 2021, the Board of Trustees of Maryland State Retirement and Pension System determined that Gazprom is not eligible for investment as a result of oil-related activity in Iran. (https://sra.maryland.gov/sites/main/files/file-attachments/legislative_report-_iran_sudan_4-1-21.pdf?1617283662)

In 2019 Gazprom was removed from the Texas Comptroller List of Companies Engaging in Scrutinized Business Operations in Iran.   (https://comptroller.texas.gov/purchasing/publications/divestment.php)

"Russian natural gas company Gazprom announced Thursday that it was exploring ways to cooperate more closely with Iran in the energy sector. Gazprom chief Alexei Miller welcomed Iranian Deputy Vice President for Economic Affairs Ali Agha Mohammadi to Moscow to discuss bilateral energy issues. 'The parties discussed the opportunities for Russia and Iran to develop cooperation in the oil and gas industry,' the Russian company said in a statement. 'Special attention was paid to the global energy market trends and the issues of strategic partnership within the Gas Exporting Countries Forum activities.' ... State-run Gazprom has played a role in the giant South Pars gas field off the coast of Iran since 1997." (UPI, "Russia, Iran explore energy times," 4/8/11) (http://www.upi.com/Science_News/Resource-Wars/2011/04/07/Russia-Iran-explore-energy-ties/UPI-95931302182191/)

"Russian giant Gazprom signed a memorandum of understanding with the National Iranian Oil Company, to cooperate in the field of hydrocarbon prospecting, exploration and production within Iran." (March 29, 2017). (https://www.lngworldnews.com/gazprom-inks-mou-with-iranian-nioc/)

"Alexey Miller and Ali Kardor, Iran’s Deputy Minister of Petroleum, CEO of National Iranian Oil Company, inked a Roadmap. Pursuant to the document, Gazprom will conduct a proof-of-concept study with regard to implementing integrated projects for hydrocarbon production, transmission and processing, including petrochemistry, in Iranian territory." (December 2017) (http://www.gazprom.com/press/news/2017/december/article386279/)

"The enormous New York State Common Retirement Fund plans to divest $86.2 million in investments from nine companies doing business in Sudan and Iran...The decision comes after two years of reviewing these companies, the potential risk of the investments and, in some cases, humanitarian efforts in these countries.'We don't expect our investments to benefit regimes that support genocide and terrorism,' said DiNapoli. The fund plans to divest out of $86 million in Gazprom (OGZPY), Inpex (1605.TO), Lukoil (LUKOY), Oil And Natural Gas Corp (500312.BY), OMV (OMVKY), Petroleo Brasilia (PBR), Statoil (STO), Wartsila OYJ and Sinopec Corp. DiNapoli said the firms were chosen because 'they failed to respond or we were not satisfied with their responses' when asked to provide information to the fund on the investments and their risks. (Dow Jones Newswires, "NY Comptroller To Divest $86.2M In State Pension Fund Investments", 6/30/09) (http://www.advfn.com/nyse/StockNews.asp?stocknews=ABB&article=38444840&headline=ny-comptroller-to-divest-86-2-million-in-state-pension-fund)

"Is negotiating with the National Iranian Oil Company (NIOC) to develop the Kish, Farzad-A, and Farzad-B gas fields, and another field in South Pars."  ("Gazprom says ready to start major gas projects in Iran," Press TV, June 17, 2018.) (https://www.presstv.com/Detail/2018/06/17/565235/Gazprom-says-ready-to-start-major-gas-projects-in-Iran-)

<!--td {border: 1px solid #ccc;}br {mso-data-placement:same-cell;}--> Gazprom is listed on the March 2019 Alaska Retirement Management Board, Companies Doing Material Business with Iran list. (http://treasury.dor.alaska.gov/Portals/3/docs/resolutions/ARMB%20Iran%20Divestment%20List%203-31-19.pdf)

In 2018 Gazprom was listed on the Texas Comptroller List of Companies Engaging in Scrutinized Business Operations in Iran.   (https://web.archive.org/web/20180304055352/https://comptroller.texas.gov/purchasing/docs/anti-bds.pdf)

"The company was reported as potentially having signed MOUs with Iranian petroleum authorities regarding petrochemical development opportunities. In 2018 CalPERS designated the company as under review. In 2019 CalPERS changed the designation to “being monitored” because CalPERS’ initial screening has not identified the company as having involvement in the regions and/or activities targeted by the Act. CalPERS has maintained the company in “monitor” status for 2020. CalPERS continues to monitor the company for possible changes in status relevant to the Act." (https://www.calpers.ca.gov/docs/forms-publications/iran-sudan-divestment-2020.pdf)

Gazprom is listed on the March 1, 2022 Report to the New Jersey Legislature Iran Divestment as a prohibited company. (https://www.nj.gov/treasury/doinvest/pdf/index/Iran_Progress_Report.pdf)

As of May 17, 2021, Iowa's Public Employee's Retirement System lists Gazprom on its Iran Scrutinized Companies List. (https://www.ipers.org/sites/default/files/IPERS%27%20Iran%20Prohibited%20Companies%202Q21.pdf)

In 2018 the U.S. state of Iowa, Ohio listed Gazprom on its Iran prohibited companies list rendering Gazprom ineligible for investment and/or state contracting. (https://www.op-f.org/Files/Scrutinized%20Companies%20Iran%20Sudan.pdf)

"New Jersey is poised to jettison $360 million worth of stock in 11 companies to comply with new state legislation that prohibits state investment in firms doing business with Iran, officers of the pension fund reported yesterday. The companies to be shed under the Iran prohibition are all international engineering or energy firms, including Lukoil and Gazprom, that have financial ties to the government of Iran." (The Star-Ledger, "State to shed $360M worth of stock in firms tied to Iran," 3/21/08) (http://www.nj.com/news/ledger/jersey/index.ssf?/base/news-10/1206077884253190.xml&coll=1)

In 2016 Tennessee used the South Carolina list of "Entities Ineligible to Contract with the State of South Carolina or any Political Subdivision of the State per the Iran Divestment Act of 2014, S.C. Code Ann." as its list of persons it determines engage in investment activities in Iran.Gazprom was included on this list in 2016. "Inclusion on this list would make a person ineligible to contract with the state of Tennessee, if a person ceases its engagement in investment activities in Iran, it may be removed from the list." (https://www.tn.gov/content/dam/tn/generalservices/documents/cpo/cpo-library/public-information-library/List%20of%20persons%20pursuant%20to%20Tenn.%20Code%20Ann.%2012-12-106%20Iran%20Divestment%20Act.pdf)

Gazprom is listed on the June 2019 Alaska Retirement Management Board, Companies Doing Material Business with Iran list. (http://treasury.dor.alaska.gov/Portals/3/docs/resolutions/ARMB%20Iran%20Divestment%20List%206-30-19.pdf)

As of August 15, 2019, the state of Iowa listed Gazprom on its Iran scrutinized companies list. (https://www.ipers.org/sites/default/files/media/2017%2009%20Iran%20Prohibited%20Companies%20List%2009-30-17.pdf)

Russian companies including Gazprom PJSC signed a raft of initial agreements with Iran that could lead to contracts worth billions of dollars, as Energy Minister Alexander Novak outlined Russia’s ambition to become a major investor in the Persian Gulf nation. A Russian delegation to Tehran signed nine agreements on Tuesday in industries ranging from energy to railways. Gazprom reached an unspecified accord with Iran’s state natural gas company, and its subsidiary Gazprom Neft PJSC signed a deal to study the Cheshmeh-Khosh and Changuleh oil fields. State-run Gazprom is the third Russian energy company to sign a memorandum of understanding with Iran, joining Lukoil PJSC and Zarubezhneft OAO. “Our priority is to develop Iran’s big projects,” Novak said at one of several signing ceremonies during the day. “These agreements will have a significant influence on the relationship between our two countries.” (Bloomberg News, "Gazprom Signs Oil deal With Iran as Russians Return in Force," 12/13/2016). (https://www.bloomberg.com/news/articles/2016-12-13/gazprom-neft-signs-oil-deal-as-russia-adds-to-presence-in-iran)

On September 19, 2007, Gazprom 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, Gazprom 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)

As of May 28, 2020, the Florida State Board of Administration (“SBA”) continues to list Gazprom on its list of “Scrutinized companies with Activities in the Iran Petroleum Energy Sector.” (https://www.unitedagainstnucleariran.com/company/china-nonferrous-metal-mining-group)

On January 20, 2020, Minnesota SBI listed Gazprom as a scrutinized investment. The managers are explicitly instructed to refrain from purchasing securities on this list. (https://www.leg.state.mn.us/docs/2020/mandated/200121.pdf)

"Iran's negotiations to finalize an oil-fields deal with Russia's OAO Gazprom Neft (SIBN.RS) are in the final stages...Russia has come into trouble with Iran after agreeing to support U.S. efforts to get new sanctions from the UN Security Council, but speaking to Dow Jones Newswires, Hojatollah Ghanimifard, vice president in charge of investment affairs at the National Iran Oil Co., said 'we hope to have a final decision soon,' on the Gazprom Neft deal. In November of [2009], Gazprom Neft, the oil arm of Russia's OAO Gazprom, signed a preliminary agreement with NIOC to help develop the Azar and Shangule oil fields." (Wall Street Journal, "Iran Talks with Gazprom Over Oil Fields Reach Final Stages," 6/26/2010). (http://online.wsj.com/article/BT-CO-20100626-701075.html)

"Iran will have a new, attractive investment model for oil contracts by September, its president and oil minister told some of the world's top oil executives here on Thursday, part of its drive to win back Western business. Iranian President Hassan Rouhani and Oil Minister Bijan Zanganeh said their new administration was keen to open up to Western investments and technology, executives who attended the meeting said. They also stressed the importance of fossil fuel, with global energy demand rising. ‘The fact that the president of Iran came to the meeting today... is clearly a sign that Iran wants to open up to international oil companies,’ said Paolo Scaroni, chief executive of Italy's Eni, who was at the meeting. ’It was an impressive presentation,’ said one of three further oil executives who were at the meeting and spoke with Reuters on condition of anonymity. ’They said they are working on a new model to work with investors and are happy to see us,’ he added. ‘They not only need money but technologies. They are happy to have consultations about how new contracts shall work. They want to decide on the model by September.’ ’The message was - look at us, our geological risks are minimal, reserves are huge, come and we will create competitive terms and you will be happy. Your return on investments will be acceptable,’ another executive said. Along with ENI, France's Total, Britain's BP , LUKoil and GazpromNeft from Russia, and several other companies were present.” (Reuters, “Iran lures oil majors with new contracts pledge,” 1/23/14) (http://unitedagainstnucleariran.com/company/eni) (http://www.unitedagainstnucleariran.com/company/total-sa) (http://www.unitedagainstnucleariran.com/company/bp) (http://www.unitedagainstnucleariran.com/company/lukoil) (https://www.unitedagainstnucleariran.com/company/idUSL5N0KX1UH20140123)

"The lucrative Chalous gas field in the Caspian Sea looks increasingly to be at the center of discussions underway over an Iran-Russia 20-year cooperation deal.

"Russian giant Gazprom (GAZP.MM) agreed last year to take on more Iranian gas projects and has invested about $4 billion since 2007 in the country." (Reuters, "Q+A: Iran's oil supply and potential for disruption," 6/15/09). (http://www.reuters.com/article/2009/06/15/us-iran-oil-sb-idUSTRE55E1VE20090615)

“Russia's economy chief on Wednesday announced plans to visit Iran amid reports of the two sides nearing a mammoth oil-for-goods deal that has raised consternation in the United States. Economy Minister Alexei Ulyukayev told Russian media his late April trip would focus on a ‘wide range of trade and economic issues’ but provided no further details.Moscow's Kommersant business daily on January 16 said the two close trading partners were negotiating a barter agreement under which Russia could import up to 500,000 barrels of Iranian oil per day. Russian officials have neither confirmed nor denied the discussions…Other reported aspects of the proposed deal would see Russia's state-run energy behemoth Gazprom get access to natural gas deposits controlled by Iran in the Caspian Sea. Russia's private crude producer Lukoil also confirmed on Wednesday that it was in talks with the Iranian oil ministry about resuming work in its energy sector once the Western sanctions are removed.” (AFP, “Russian minister plans Iran trip amid oil deal reports,” 2/12/14) (http://www.unitedagainstnucleariran.com/company/lukoil) (http://www.google.com/hostednews/afp/article/ALeqM5jouUglcbJgSAMOmLVYkcdfGPC-Bg?docId=48ccb203-6e8a-462b-9445-906b05dfaed3)

Gazprom may be planning to begin gasoline shipments to Iran, after many European and American petroleum companies halted gasoline shipments in the wake of new sanctions (Bloomberg).  (http://www.bloomberg.com/news/2010-08-02/iran-s-gasoline-imports-declined-50-last-month-after-sanctions-emc-says.html)

In 2018, the California State Teachers Public Employees Retirement System (“CalPERS”) designated Gazprom as “under review” for reportedly having signed MoUs with Iranian petroleum authorities regarding petrochemical development opportunities.  In 2019, CalPERS changed the designation to “being monitored” because CalPERS’ “initial screening has not identified the company as having involvement in the [activities] targeted by the [2019 California Public Divest from Iran] Act.”  In 2009, the California State Teachers’ Retirement System (“CalSTRS”), designated Gazprom as “Under Review” for signing an MoU with the NIOC, which expired in 2010. In 2010, CalSTRS designated Gazprom as “Being Monitored” after confirming the company has no current investments in Iran. In 2011, CalSTRS maintained Gazprom as “Being Monitored” as the GAO stated it had insufficient information on the company’s activities and the Russian government’s reported interest in developing a deal with Iran. In 2014, due to U.S. sanctions on Gazprom Bank, an OAO Gazprom subsidiary, CalSTRS determined to minimize its exposure to the company by restricting managers from making new purchases in Gazprom securities. For risk control purposes, in 2016, CalSTRS revised the restriction on purchasing shares of Gazprom to allow managers underweighted in Gazprom (versus their benchmark) to purchase up to benchmark weight. CalSTRS maintained the restriction on purchasing Gazprom in 2017. In 2018, CalSTRS maintained the “Being Monitored” designation and removed the benchmark weighting restriction on Gazprom but require managers holding the security to make quarterly updates on their investment rationale. In 2019, CalSTRS maintained Gazprom as “Being Monitored.” CalSTRS and CalPERS are the top two largest public pension funds in the United States with more than $550 billion in total assets under management combined. (https://www.calpers.ca.gov/docs/legislative-regulatory-letters/investments-ca-divest-iran-sudan.pdf)

In 2011, Gazprom was added to 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/2011-Annual-Divestment-Report-print.pdf)

"Russian energy company Gazprom is evaluating possible participation in projects in Iran, according to the company’s deputy chief executive officer Vitaly Markelov.Gazprom is the largest company in Russia in terms of revenue. (https://www.offshore-technology.com/comment/gazprom-and-iran-2019/)

Gazprom is listed on the June 4, 2019 and July 12, 2019 Florida State Board of Administration list of prohibited investments (Scrutinized companies) for Iran related business. (https://www.sbafla.com/fsb/Portals/FSB/Content/Performance/Quarterly/2019_06_04_Web_Update_PFIA_Prohibited_List.pdf?ver=2019-06-04-162911-617) (https://www.sbafla.com/fsb/Portals/FSB/Content/Performance/Quarterly/2019_07_12_Web_Update_PFIA_Prohibited_List.pdf?ver=2019-07-12-114201-343)

Gazprom International is one of the companies listed as a speaker at the HR Trends Summit taking place from October 18-19, 2016 in Tehran, Iran. (Speakers). (http://www.thepworld.com/pevents/event/129/global-hr-trends-summit-iran)

Watkins reported Monday that this has led to a revised understanding, during the Tehran-Moscow cooperation discussions, that would see for 20 years 40 percent share of output go to Russia’s Gazprom and Transneft, 28 percent to China’s CNPC (China National Petroleum Corporation) and CNOOC (China National Offshore Oil Corporation), and only 25 percent to Iran’s Kepco." (Iran International, "Iran's Caspian Gas Field, And Russia’s Share, ‘Far Bigger Than Expected’," 11/16/21) (https://www.iranintl.com/en/20211116106809)

“Iran has dropped Russian giant Gazprom from an oil field project near the Iraqi border, claiming development is taking too long. Hamid Karimi, a senior Oil Ministry official, is quoted by the semiofficial Mehr news agency as saying that a consortium of Iranian companies will replace Gazprom in the Azar oil field project… Years of sanctions have deterred significant investment by international companies with deep pockets and technical expertise.” (AP. "Iran drops Russia’s Gazprom from developing oil field, claiming delays," 8/29/11) (http://www.washingtonpost.com/business/iran-drops-russias-gazprom-from-developing-oil-field-due-to-delay/2011/08/29/gIQAZ7m1mJ_story.html)

As of December 31, 2019, the Alaska Retirement Management Board lists Gazprom as a company doing material business with Iran. (https://treasury.dor.alaska.gov/Portals/3/docs/resolutions/ARMB Iran Divestment List 12-31-19.pdf)

As of September 30, 2019, Gazprom is included as a company doing business in Iran for oil related business activity on Maryland's Iran Scrutinized Business List.  (https://sra.maryland.gov/sites/main/files/file-attachments/legislative_report-_iran_sudan_9-30-19.pdf?1570201241)

Iran has signed a basic agreement with Russia’s energy giant Gazprom over the development of Farzad B gas field – a project which the country has for long been negotiating with an Indian consortium.  The announcement over Farzad B agreement was made by Iran’s Petroleum Minister Bijan Zanganeh. (http://en.nioc.ir/Portal/home/?news/81365/71248/210625/Iran-Signed-Deal-with-Gazprom-over-Farzad-Bhttp://en.nioc.ir/Portal/home/?news/81365/71248/210625/Iran-Signed-Deal-with-Gazprom-over-Farzad-B). (http://en.nioc.ir/Portal/home/?news/81365/71248/210625/Iran-Signed-Deal-with-Gazprom-over-Farzad-B)

On March 13, 2019, the Mississippi Department of Finance & Administration identified Gazprom as a company “engaged in investment activities in Iran, providing funds, goods or services valued at $20,000,000 or more in the energy sector of Iran.”   (https://www.dfa.ms.gov/media/8124/businesses-doing-business-with-iran.pdf)

Gazprom is listed on the 4Q 2020 Minnesota State Board of Investment List of Unauthorized (Scrutinized) Iran Companies. (https://www.lrl.mn.gov/docs/2021/mandated/210295.pdf)

In 2020, the U.S. state of Mississippi listed Gazprom 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)

As of July 2020, Gazprom 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)

On January 13, 2020, the South Dakota Investment Council submitted a report to the Executive Board of the Legislative Research Council regarding compliance with SDCL 4-5-48 to 4-5-60, Iran Divestiture. Included in this report is an Iran Scrutinized Companies list of all prohibited investments for which the internal managers and direct external managers are instructed not to purchase any company on the list. Gazprom is included on this list. (https://sdlegislature.gov/docs/referencematerials/requiredreports/RR901152020.pdf)

On February 11, 2019, Gazprom wrote to the Minnesota State Board of Investments and said, "Gazprom has a representative office in Islamic Republic of Iran in Tehran. The work of the representative office is not of a commercial nature, does not generate revenue and is limited to representative functions. All the memoranda with the Iranian parties which were described in details in our previous letter are non-binding." (https://www.lrl.mn.gov/docs/2020/mandated/200121.pdf)

As of October 2019, Gazprom 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/2019-Annual-Divestment-Report.pdf)

“Iran will offer foreign partners incentives to find and pump more crude and natural gas and will pay some fees in barrels as it seeks to boost income once international sanctions are lifted. New contracts Iran is developing will offer higher fees for riskier exploration and production projects, oil-ministry officials said at a conference in Tehran yesterday. Local and international executives attended a two-day meeting to discuss rules that would govern oil and gas production if Western curbs on Iranian energy exports are removed. The committee revising the Islamic republic’s contract model presented terms called the ‘Iran Petroleum Contract.’ ‘We’ve analyzed all the contracts in the market right now, all available beneficial models, and this is what we’ve come up with,’ Mehdi Hosseini, a government energy adviser who leads the ministry committee, said at the conference. ‘This is a good model, with flexibility.’ Russia’s OAO Gazprom (GAZP), China National Petroleum Corp. and Malaysia’s Petroliam Nasional Bhd., or Petronas, were among a dozen foreign firms the organizers said attended the conference. Western European companies were not present…International companies will act as the sole operator at oil and gas exploration blocks and will be responsible for the risks of those projects. NIOC may be a technical partner in the developments. The ventures will have 15 to 20 years to pump oil after seven to nine years of exploration under the new contracts, Hosseini said. Fees paid to international companies will be linked to the oil price and determined on a sliding scale, with riskier developments paying more, Hosseini said.” (Bloomberg, “Iran Plans Higher Fees for Riskier Oil Fields in New Accords,” 2/24/14) (http://www.unitedagainstnucleariran.com/company/cnpc) (http://www.unitedagainstnucleariran.com/company/petronas) (http://www.bloomberg.com/news/2014-02-23/iran-plans-higher-pay-for-riskier-oil-fields-with-new-contracts.html)

Markelov said that a joint coordination committee made up of Gazprom employees and Iranian partners would evaluate potential projects.