German manufacturer KROHNE responds to UANI letter

German industrial manufacturer KROHNE responds to the letter received from United Against Nuclear Iran (UANI) Ambassador Marc Wallace. UANI called on KROHNE to end its Iran business activities. In a letter sent today to Ambassador Wallace, KROHNE CEOs Michael Dubbick and Stephan Neuburger state that KROHNE has not violated any U.S., EU or German sanctions and that since 8 months the company has neither secured nor executed any orders and refuses to accept any new orders from Iran or with destination Iran.
This is the original letter sent to Ambassador Wallace:
“Dear Ambassador Wallace,
We have received your above mentioned letter and would like to assure you that this matter is of utmost concern to us. As a responsible company as well as responsible citizens we fully understand and support any actions against extremist regimes such as Iran and its Government.
Let us first of all give you a short introduction to the KROHNE group. KROHNE is a family owned company since 1921. Our main business is to produce process instrumentation for all kind of industries, like Water and Waste Water, Chemicals and Petrochemicals, Pharmaceuticals, Food & Beverage, Steel, Energy, Paper, HVAC and Oil & Gas. KROHNE is known for highest quality and its long-lasting and reliable partnerships also in the international marketplace.
We are of course well aware of all relevant sanctions measures and legislation issued by both the EU and the U.S. and we have been observing that they are being followed by all subsidiaries and representatives of the KROHNE Group. As such we introduced automated procedures through an AEB Compliance Software as early as 2005 through which all customers or prospects are checked against the daily updated sanction lists of the following sources:
•    EU – Bank of England
•    US – DPL
•    US – Entity List
•    US – List of Statutorily Debarred Parties
•    US – SDN
•    US – Unverified List
•    US 101 – S Bad Guys
•    GER – Frühwarn List (early Warning List)
In addition all regulations concerning so called “dual Use” Products have been painstakingly applied and we have given written instructions to all our subsidiaries at least at 2 occasions, once in March 2008 and again in April 2011 not to ship any goods without obtaining prior authorizations from the respective national agencies granting export permits.
While we have so far maintained our Iranian office to assure continued service to our customers the actual business has come to a virtual standstill since we have not secured any business for more than 8 months. As a family owned company we have also maintained our very limited presence in order not to lay off innocent and hard-working staff and punish them for an unacceptable regime.
In fact, KROHNE just recently decided not to honor a major order which we already had in hand, for a publicly listed Iranian engineering company and this company is not even on the embargo list.
The order you mentioned for the delivery of tank monitoring systems to the China Shipbuilding Industry Corporation (CSIC) was received already in 2010 and the last shipment left our Norwegian subsidiary in September of last year, well before any sanction measures came into effect. KROHNE is well aware of the EU Council Decision 2012/635/CFSB you mentioned in your letter. The effective date of that decision, specifically concerning NITC, was October 16, 2012, well after the last shipment for tank monitoring equipment to the Chinese shipyards left KROHNE Skarpenord, Norway.
As you see KROHNE has already ceased to do any business with Iran and there are no further orders which need to be filled. Let us all hope that the sanctions will have the desired effect to stop the dangerous threat emanating from the current regime in Iran.”
Source: KROHNE