Testimony

• Ms. Sherry Williams

  Vice President and Corporate Secretary

  Halliburton Company
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  Testimony

  Ms. Sherry Williams

   

• Mr. Victor D. Comras

  Attorney and Consultant

  Special Counsel to Eren Law Firm
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  Testimony

  Mr. Victor D. Comras

  Written Statement

  Victor D. Comras, Esquire

  Iran Sanctions and Halliburton

  Interstate Commerce, Trade, and Tourism Subcommittee

  United States Senate

  April 30, 2007

   

   

  Thank you, Mr. Chairman for inviting me to share my views on the application of US sanctions measures against Iran.  I have watched closely as the United States has sought to engage other countries to join with us in applying increased pressure on Iran to comply with international counter-proliferation and counter-terrorism norms.  This has been a very slow and painful process, and it is regrettable that so little has been accomplished. The international community continues to remain reluctant and seriously divided when it comes to taking meaningful steps to convince Iran to change course. 

   

  One can understand a certain amount of reluctance and caution on the part of many countries when it comes to imposing sanctions on Iran, given Iran’s importance as a supplier to the world oil market.  There are legitimate concerns that sanctions might cause dislocation in the world market which could drive the price of oil well above current high levels.  But, one must also weigh the enormous strategic and security risks posed by a nuclear-armed Iran that supports international terrorism.  Every day the international community stands down only serves to strengthen Iran’s resolve to forge ahead making further confrontation increasingly inevitable, and at an ever increasing cost.

   

  This situation has placed a considerable burden on the United States, which many years ago chose to impose unilateral sanctions on Iran to demonstrate our approbation and concern with Iran’s international misconduct. And it has imposed a considerable burden on US companies.  These US measures sought to impair Iran’s potential to develop chemical, biological, and nuclear weapons, and to reduce resources available to the Iranian government to fund terrorism.  These objectives are still far from being realized, for we have, so far, failed to convince others in the international community to follow this lead, and to also adopt measures that will bring home to Iran’s leaders that their conduct will not be tolerated.

   

  I have long advocated using well considered targeted, economic and political sanctions to dissuade Iran from pursuing its irresponsible nuclear programs.  By well considered I mean sanctions tailored to achieve specific objectives by having a significant impact on those individuals or entities, and/or specific segments of the targeted country’s economy, that are likely to influence the course of conduct in question.  I believe that the credible threat or use of such sanctions offers us the best chance of convincing Iran to change course without having to engage in costly and dangerous military action.  I do not believe that the current United Nations sanctions program can achieve these objectives.

   

  The recent sanctions measures adopted by the Security Council fall well short of the measures long advocated by the United States.  They have had little, if any, impact on Iran’s leaders and do little more than freeze the overseas assets of a few dozen Iranian individuals and entities associated with Iran’s uranium enrichment program.   The most important measure adopted by the UN, so far, has been to ban transactions with Iran’s fifth largest bank, Bank Sepah, and to cut that bank off from the international financial network.  Bank Sepah has been closely involved in funding Iran’s missile development program.  This is the kind of action that needs to be adopted and replicated on a much broader scale.  Beyond that, the UN resolutions merely call upon all countries “to exercise vigilance and restraint” when it comes to supplying sensitive nuclear, military and dual use equipment to Iran, or allowing key Iranian military and nuclear industry officials to visit and travel within their countries.  Each country remains pretty much free to decide for itself which sensitive military equipment and technology they should no longer provide.   These are not obligatory measures.

   

  The UN resolutions have purposely stayed away from limiting commercial ties with Iran or restricting investments, loans or financial and developmental assistance.  They leave Russia free to pursue an ambitious multibillion dollar Iran trade promotion program and to support Iran’s Russian built nuclear reactor at Bushehr.   They also leave on the table a substantial number of signed or still to be negotiated oil and gas development deals, including a potential $10 billion investment by Royal Dutch Shell and the Spanish oil company Repsol YFP to develop Iran’s South Pars field; the construction of a multi-billion LPG export plant by Total; and a $20 billion investment by SKS Ventures of Malaysia to produce national gas in Iran’s Golshan and Ferdow fields.  Chinese companies have also been active in lining up lucrative energy contracts with Iran.  China's state-owned oil trading company, Zhuhai Zhenrong Corporation, has signed a 25-year deal to import some 110 million tons of liquefied natural gas (LNG) from Iran.  And China's state-owned oil company, Sinopec,  signed an agreement in October 2004 that allows China to import a further 250 million tons of LNG from Iran's Yadavaran oilfield over a 25-year period.  This huge deal also envisages substantial Chinese investment in Iranian energy exploration, drilling and production as well as in petrochemical and natural gas infrastructure.  Total Chinese investment targeted toward Iran's energy sector could exceed some $100 billion over 25 years.

   

  These are precisely the types of investments and business activity that the Iran Sanctions Act, and the preceding Iran Libya Sanctions Act, sought to discourage so long as Iran continues to violate key international commitments that threaten international peace and security.  These major investment projects undermine US objectives to get Iran to change course, and they eliminate any chance for the current UN sanctions to influence Iran’s leaders.   They demonstrate that key countries continue to lack the political will necessary to face up to Iran’s challenge.  And this signal has been received loud and clear by the current Iran regime.

    Iran will only change course if and when its leadership is convinced that the international community will, in fact, take the steps necessary to seriously impact Iran’s leaders and Iran’s very vulnerable economy. Such an impact on Iran’s economy, Iran’s leaders know, would, in turn, seriously threaten the stability and durability of their regime.

   

  That brings us back to what we can and should do to protect our own national security and foreign policy interests.  I think it is important that the Congress and the Administration are now reviewing our domestic sanctions against Iran to see how they might best be used and leveraged to apply pressure on Iran.

   

  I am pleased that this process has already led to changes in policy and has already produced some results.

   

  Treasury Under Secretary Stuart Levey recently informed the Senate Banking Committee of the Treasury Department’s new high level outreach program directed at the international private sector.  Senior Treasury Department officials, he said,  have met with more than 40 banks worldwide to discuss the threat Iran poses to the international financial system. The message was clear.  By keeping and servicing customers that the United States has identified as terrorists or proliferators, the banks risk facing American public scrutiny and regulatory action that could have a serious impact on their ability to do business with the United States.  An increasing number of international banks, financial institutions, and corporations are taking this message seriously and are now beginning to limit their exposure re Iran.  Several international banks have already indicated their intentions to withdraw from Iran completely.  Others have cut off Iranian business in dollars.  We must follow up on these kinds of measures.

   

  There are  a number of additional steps we can take to maximize the leverage capabilities of the various sanctions measures that we have adopted. 

  Following President Clinton’s imposition of trade sanctions against Iran in 1995, annual both-direction trade with Iran fell to less than $500,000.  But, by 2006, this combined trade had again grown to over $242 million  ($85 million in exports to Iran and  $157 million in imports, principally Iranian nuts, dried fruits carpets and caviar).  This is still quite small compared to the booming $26 billion two-way trade that has developed between Iran and Europe over these intervening years.  Iran’s fledgling commercial class has become very reliant on this growing trade. And it is this very commercial class that provides the greatest number of employment opportunities in Tehran and Iran’s other urban centers.  Sanctions that threaten to constrict this trade could have a considerable impact on this commercial class, placing further distress on Iran’s vulnerable economy and high urban unemployment.  And this in turn will have an impact on Iran’s leaders.

  Ironically, Iran, which is such a major exporter of oil and gas, is, itself a major importer of gasoline and other finished petroleum products. With a daily consumption of more than 18 million gallons of gasoline Iran must now import some 180 to 200 million gallons of gasoline per month.  Rising petroleum prices have already been the cause of civil unrest, and gasoline shortages could have a significant impact on local business activity and put increased pressure on Iranian leaders to alter course. Royal Dutch/Shell is now serving as an advisory partner with Iran in an assessment project to upgrade Iran’s refining capacities. This is the kind of activity that should be halted.

   

  The Iran Sanctions Act targets Iran’s energy, oil and gas sector, and calls for US sanctions to be imposed on foreign companies making investments of more than $20 million in one year in Iran’s energy sector. The President is required to impose at least two out of a menu of six sanctions against overseas companies violating these guidelines.   These secondary sanctions can be waived by the President, however, if the President certifies that waiving the sanctions is  important to the US national interest.  Despite continued, and broad investment in Iran’s energy sector, these sanctions have never been invoked.  

  Many argue that imposing sanctions on companies in third countries would be counter-productive to US business interests, and would harm our ability to convince these countries to cooperate further with us vis a vis Iran.  But, there is also good reason to believe that, in the current atmosphere of growing concern with Iran’s nuclear program, the threat of such action might lead Europe, and European companies doing business in both Iran and the United States, to act more intently in pressing Iran to change.

   

  We have already used third party sanctions against companies in third countries that have violated the Iran Nonproliferation Act.  This has included companies in Austria, Belarus, China, India, Macedonia, North Korea, Russia, Spain, Taiwan, UAE, and Ukraine.  These measures may well have helped convince the international community to move forward on the UN sanctions that do target the sale of sensitive equipment and technology to Iran’s military and uranium enrichment programs.

   

  US sanctions regulations have prohibited US persons from doing business directly or indirectly with Iran since May 1995. This ban also covers brokering transactions on behalf of Iran, or engaging in any transaction with a foreign entity where there is reason to know it is intended for Iran.  But what about the dealings of foreign subsidiaries of US firms with Iran?  Here the guidelines are murky.  The regulatory standards applied to foreign subsidiaries have varied over the years and under different sanctions and export control programs.  The Cuba and North Korean embargos, for example, do extend to foreign subsidiaries of US companies. These sanctions were implemented under the Trading with the Enemy Act (TWEA) which provides broad enough authority to cover foreign subsidiaries.   But, more recently imposed sanctions, including the current Iran sanctions, are based on Presidential Executive Orders issued pursuant to the International Economic Emergency Powers Act (IEEPA).  The authorities under that act are more circumspect. This is because IEEPA sanctions apply only to “United States persons,” and the act defines “United States person” as “any United States citizen, permanent resident alien, entity organized under the laws of the United States (including foreign branches), or any person in the United States.”   In line with this definition, the prohibitions in Executive Order 12959 of May 6, 1995, issued by President Clinton pursuant to IEEPA  reach only to foreign subsidiaries “owned and controlled” by a US person, or otherwise used by a US person to “evade,  avoid, or violate”  any of the prohibitions set forth in the executive order.  The issue here is whether or not there is a real and effective management separation between the US parent and foreign subsidiary, and whether or not the foreign subsidiary is actually being used by the U.S. person to “evade or avoid” the prohibitions against its doing business with or in Iran.  These are difficult factual issues to determine.

   

  On January 11, 2005, Iran announced publicly that it had just concluded a contract with the U.S. Company, Halliburton, and an Iranian company, Oriental Kish, to drill for gas in Phases 9 and 10 of South Pars. Under the deal, a Halliburton subsidiary registered in the Cayman Islands, but doing business out of Dubai, Halliburton Products & Services Limited (HPSL), was awarded a subcontract from the Iranian firm Oriental Kish to provide some $30 million to $35 million worth of engineering services per year through Oriental Kish.   HPSL had also previously been engaged, since 1995 in several other offshore oil and gas drilling and related engineering projects in Iran.  In addition to its Dubai headquarter, the company reportedly also maintained an operational office in Tehran.

   Halliburton’s position is that the transactions involving HPSL do not violate US sanctions since Halliburton does not exercise direction or control of HPSL’s activities. They point out that Halliburton Product and Services has no American employees; that its 5 person board of directors consists of four British citizens and a Canadian citizen, but no Americans; and that the “day to day” management and decision-making responsibility at HPSL resides with the Management Director (who is a British citizen) and other local management, all of whom reside in Dubai.”    Nevertheless, revelation of this Iran project led to a public outcry.

    In response, Halliburton subsequently announced that all Halliburton employees would be withdrawn from Iran and that it would end its pursuit of future business in Iran, apart from the ongoing Oriental Kish deal.

   

  Halliburton is not the only US Corporation with foreign subsidiaries working with and in Iran.  Some of its main competitors in the oil field industry, including Baker Hughes, and Smith International, also have foreign operations there.  General Electric’s Canadian, Italian and French subsidiaries have also long been engaged in business deals with Iran, and there is a Swiss owned Caterpillar dealership in the heart of Tehran.   Some 35 foreign subsidiaries of different US companies reportedly now operating in Iran.   Several, including GE have decided to follow Halliburton’s example. They have announced they also will no longer seek new business deals with Iran.  This is an interesting declaration given the fact that they have long claimed to exercise absolutely no corporate control over these subsidiaries.     

   

  Iran’s banking sector is notorious for its failures to comply with international anti-money laundering, fraudulent and corrupt practices, and counter-terrorism financing norms.  Yet, Iranian banks continue to have broad access to, and to network through, the international financial and banking sectors.  The U.S. Treasury Department recently began to scrutinize ties of foreign banks with branches in the United States with Iran.  These actions are being taken ostensibly to ensure that US branches are not used to facilitate exchanges or transfers for Iranian banks and other entities.  The Treasury Department recently fined the Dutch bank ABN Amro some $80 million for failing to report the processing of financial transactions involving Iran’s Bank Melli.  And since January 2007 bars U.S. banks, including US branches of foreign banks, from facilitating any dollar transactions for banks dealing with Iran’s state-owned Bank Saderat or Bank Sepah.

  I believe additional Iranian banks should be added to the Treasury Department’s designated list and that further actions should be taken to isolate these banks and to assure that all transactions stemming from, or destined to or through Iranian banks be subjected to close regulation and scrutiny.  Such action would also bring home to Iran a significant cost for the irresponsible policies it is pursuing.

   

  As noted above, convincing foreign subsidiaries of US companies to withdraw from Iran may provoke some reactions from their parent countries, especially in Canada and Europe, who remain very sensitive to what they consider US attempts to reach extra-territorially into their bailiwick.   But, our task now must really be to convince these countries to join with us in putting greater pressure on Iran by cutting back their business dealings with Iran.

   

  There are some positive signs that the EU leaders are finally coming to the realization that the EU’s carrot-sweet negotiating approach toward Iran must be strengthened by the addition of sticks.  EU Foreign Ministers agreed last week to move beyond the paltry Security Council measures and to impose a more extensive asset freeze, travel ban, and arms embargo on Iran.  But, these measures still fall short of impacting Iran’s vulnerable economy. 

   

  We must continue to press our European friends and allies, and Japan to take even firmer measures.  This should include getting their companies and financial institutions to refrain from entering into new deals or making further capital investment commitments in Iran until Iran complies with the UN’s non proliferation resolutions. Beyond that, we must use our combined economic clout with Europe and Japan to retain pressure on Russian and China not to undercut these sanctions measures. 

   

  Thank you, Mr. Chairman. 

   

  .

   

• Mr. William C. Thompson Jr.

  New York City Comptroller
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  Testimony

  Mr. William C. Thompson Jr.

  WILLIAM C. THOMPSON, JR.

  NEW YORK CITY COMPTROLLER

   

  SUMMARY OF TESTIMONY

  ON HALLIBURTON AND IRAN

   

                             

  • The Comptroller of the city of New York is the chief investment advisor to the City’s five retirement systems, managing over 100 billion dollars in pension monies for the City.  

                              

  • Our responsibility to protect retiree assets requires a constant effort to pursue the highest standards of corporate responsibility at companies in which we invest.

   

  • Our clout as a large institutional investor has enabled us to help safeguard our nation’s security by supporting the fight against international terrorism.

   

  • As Comptroller, I have pressured corporations we invest in that do business with state sponsors of terrorism to change their policies.

   

  • Most Americans don’t realize that their investments, including their retirement nest eggs, could be financing regimes that condone and encourage violence and bloodshed.

   

  • Example: The Police and Fire Department Pension Funds owned some 400,000 shares in Halliburton Co., valued at roughly ten million dollars.

   

  • Halliburton, as is now well known, was doing substantial business with Iran, a nation that had been identified by the U.S. State Department as a state sponsor of terrorism. 

   

  • Because of a loophole in federal law, other Fortune 500 companies, like General Electric and ConocoPhillips, were doing the same.

   

  • The law that bans American companies from doing business with or in countries identified as terror sponsors does not apply to any foreign or offshore subsidiary, so long as non-Americans are nominally in control. This loophole was exploited by these companies.

   

  • In February 2000, Halliburton opened an office in Tehran under the name of Halliburton Products and Services, Ltd., its Cayman Islands-based subsidiary.

   

  • In November 2002, my office submitted a shareholder resolution calling on Halliburton to review the potential financial and reputational risks of the operations of its subsidiary in Iran. Similar resolutions were filed at the time with General Electric and Conoco-Phillips.

   

  • In January 2004, the television news program 60 Minutes aired a segment on Halliburton that mentioned the efforts of my office and raised the public awareness of this issue dramatically.

   

  • The attention from the 60 Minutes show led Conoco-Phillips to announce within a month that they would cease any new business in Iran through their foreign subsidiaries.

   

  • My office filed resolutions in December 2004 with two additional companies – Cooper Cameron and Aon -- to likewise cease their backdoor dealings with Iran.

   

  • We also applied pressure to another US-based company, Foster Wheeler, that is incorporated in Bermuda and not subject to U.S. sanctions.

   

  • In February 2005, GE announced that they would cease any new business in Iran through their foreign subsidiaries.

   

  • The next month, Cooper Cameron announced that its subsidiary would divest of its interest in an Iranian joint venture.

   

  • Within weeks, Halliburton likewise committed to cease any new initiatives in Iran. It will be completely out of the country by the end of 2007.

   

  • In December of 2005, Foster-Wheeler made a similar commitment. In January of 2006, the last firm in our campaign, Aon, announced that it would cease its backdoor operations in Iran.

   

  • We must close the loophole in Federal law that allows companies to act through foreign subsidiaries. In past sessions of Congress, I have supported language offered by Senator Frank Lautenberg to do just that.

   

  • The Lautenberg language is now contained Oregon Senator Gordon Smith’s “Iran Counter-Proliferation Act of 2007.”  I support that legislation and encourage you all to work for its passage.

   

   

   

             

  
  

   

  Testimony of

   

   

  William C. Thompson, Jr.

   New York City Comptroller

   

   

   

   

   

   

  Before the

  UNITED STATES SENATE

  Subcommittee on Interstate Commerce, Trade and Tourism

   

   

   

   

   

  Halliburton and U.S. Business Ties to Iran

   

   

   

   

  April 30, 2007

   

  
  

  WILLIAM C. THOMPSON, JR.

  NEW YORK CITY COMPTROLLER

   

  TESTIMONY

  BEFORE THE SUBCOMMITTEE ON

  INTERSTATE COMMERCE, TRADE, AND TOURISM

  OF THE

  SENATE COMMITTEE ON

  SCIENCE, COMMERCE & TRANSPORTATION

   

  MONDAY, APRIL 30, 2007

  2:00 PM

   

              Good afternoon, Chairman Dorgan, and honorable members of the Subcommittee on Interstate Commerce, Trade and Tourism.

   

              I appear before you today to express my deep concern over the ability of American firms to circumvent the intent of sanctions law with respect to nations deemed to be sponsors of terror by our State Department.

   

              As Comptroller for the city of New York, I am the chief investment advisor to the City’s five retirement systems, managing over 100 billion dollars in pension monies for the City.

   

              Our responsibility to protect retiree assets requires a constant effort to pursue the highest standards of corporate responsibility at companies in which we invest.

   

              We have argued that when companies fail to consider the possible reputational or financial damage resulting from their operations – whether directly (through their hiring policies, for example) or indirectly (through policies of the government with which they contract) – they put their shareholders’ long-term investments at risk.

   

              As Comptroller, I have pressured corporations we invest in that do business with state sponsors of terrorism to change their policies…..New York City pension funds have taken on a number of U.S. corporate giants who were doing business with rogue nations such as Iran and Syria.  

   

              Americans have been hearing for years that there’s a connection between money and terrorism, but most didn’t realize that their own investments, including their retirement nest eggs, could be financing regimes that condone and even encourage widespread violence and bloodshed.

   

              It certainly came as a shock to New York City’s police and firefighters, who suffered combined losses of 366 men and women on September 11, 2001.

   

              Our Police and Fire Department Pension Funds owned some 400,000  shares in Halliburton Co., valued at roughly ten million dollars. Our other funds had an additional 20 million dollars invested in Halliburton.

   

              And Halliburton, as is now well known, was doing substantial business with Iran, a nation that had been identified by the U.S. State Department as a state sponsor of terrorism. 

   

              Halliburton was not alone. Because of a loophole in federal law, other Fortune 500 companies, like General Electric and ConocoPhillips, were doing the same.

   

              How did this happen? Our government forbids American companies from doing business with or in countries it identifies as terror sponsors.

   

              However, that ban does not apply to any foreign or offshore subsidiary, so long as non-Americans are nominally in control. This loophole was exploited by these companies.

   

              In February 2000, Halliburton opened an office in Tehran under the name of Halliburton Products and Services, Ltd., its Cayman Islands-based subsidiary.

   

              The alleged headquarters for Halliburton Products and Services Ltd. is in Abu Dhabi in the Persian Gulf, where it shares office space, fax and phone numbers with its U.S. parent.

   

              Given this evidence, the notion that Halliburton’s subsidiary is in any way independent of its parent is laughable.

   

              Halliburton owed an explanation to thousands of current and retired New York City police and firefighters, along with the rest of the members of the New York City pension system.

   

              On their behalf, my office submitted a shareholder proposal to Halliburton in November 2002 to review the potential financial and reputational risks of its operations in Iran. Similar resolutions were filed at that time with General Electric and Conoco-Phillips.

   

  When Halliburton agreed to such a review, my office withdrew the proposal. Halliburton subsequently produced a report that, rather than addressing the broader risks inherent to doing business with rogue states, offered a narrow, legalistic explanation of how its operations fall within the bounds of the law.

   

              Halliburton was clearly unwilling to address the broader implications of its activities in Iran for both its shareholders and the country.

   

              In January 2004, the television news program 60 Minutes aired a segment on Halliburton that mentioned the efforts of my office and raised the public awareness of this issue dramatically.

   

              The show uncovered new information about Halliburton’s subsidiary….For instance, the Cayman Islands address is just a mailbox in a local bank – and barely that. When mail arrives there, it is rerouted to Halliburton headquarters in Houston.

   

              The attention from the 60 Minutes show led Conoco-Phillips to announce within a month that they would not renew any current contracts in Iran by their foreign subsidiaries and cease any new business there.

   

              As pressure mounted on Halliburton, my office filed resolutions in December 2004 with two additional companies – Cooper Cameron (now Cameron International) and Aon -- to likewise cease their backdoor dealings with Iran.

   

  At the same time, we applied pressure to another US-based company, Foster Wheeler, that is incorporated in Bermuda and therefore not subject to U.S. sanctions.

   

              I am pleased to say that only three months later, in February 2005, our campaign began to reap greater rewards as GE announced that they would let all current contracts in Iran by their foreign subsidiaries lapse and cease any new business.

   

  The next month Cooper Cameron affirmed to my office that its subsidiary would divest of its interest in an Iranian joint venture. Within weeks, Halliburton likewise committed with us not to pursue new business in Iran after current contracts by their subsidiary ended.

   

              In December of that year, Foster-Wheeler made a similar commitment, and in January of 2006 the last firm in our campaign, Aon, announced that it would cease its backdoor operations in Iran.

   

  Halliburton originally indicated to my office that it would be completely out of Iran by the end of 2007. A few weeks ago they announced that they are now out for good.

   

              Ultimately, we must close the loophole in Federal law that allows U.S. companies to act through foreign subsidiaries….In past sessions of Congress, I have supported language offered by Senator Frank Lautenberg to do just that.

   

              The Lautenberg language is now contained in Oregon Senator Gordon Smith’s “Iran Counter-Proliferation Act of 2007.”  I support that legislation and encourage you all to work for its passage.

   

              While the companies we identified as doing backdoor business with state sponsors of terror have all signed letters of agreement with our office to end that practice, other companies could choose to engage in such dealings tomorrow or the next day.

   

              Only the passage of the Smith bill will ensure that no new firms will take such measures.

   

              In the meantime, my office has begun the process of reviewing how we may be able to influence firms with no ties to the United States and are not subject to the SEC shareholder proposal rule.

   

              I am in the process of initiating a conversation with the Trustees of the five New York City pension funds on this matter.

   

              After the events of the summer, in which Israeli cities and towns were targeted by the Hezbollah militia with missiles that many believe are supplied by Iran and Syria, our efforts to curtail the ability of these nations and others to engage in acts of terror are more important than ever before.

   

              And at a time when Iran has stated its intention to develop a nuclear program, we cannot ignore the risks posed by the Ahmadinejad regime – whether we are talking about the development of nuclear weapons in Iran or the export of weapons, technology and terrorism abroad.

   

              For the safety and security of the United States and other peace-seeking nations around the world, institutional investors must continue to insist that the firms they invest in not attempt to wriggle out of sanctions against state sponsors of terror by acting through subsidiaries not beholden to American law.

   

              I want to thank Chairman Dorgan and all the members of the Subcommittee on Interstate Commerce, Trade and Tourism for convening a panel on this critically important topic and for giving me the opportunity to present testimony here today.

   

              It has been my very great pleasure to share with you the experiences of my office and I look forward to our continued work together on this very important issue.

   

              Thank you very much.