World Fuel Services Corporation

"The Bush administration's record enforcing export laws is mixed. The Office of Foreign Assets Control let the statute of limitations expire in at least 25 cases involving trade with Iran from 2002 to 2005, according to one internal department audit. The companies involved, disclosed to the AP under the Freedom of Information Act, include Acterna Corp., American Export Lines, Parvizian Masterpieces, Protrade International Corp., Rex of New York, Shinhan Bank, Phoenix Biomedical Corp., World Cargo Alliance and World Fuel Services...World Fuel Services said an employee fueled a ship out of Singapore that turned out to be Iranian-owned, and the U.S. government spotted it from a wire transfer." (The Daily Herald, "From bull semen to bras, Iran still buys American Products," 7/8/2008)

"From time to time, certain of our subsidiaries have had limited business dealings in countries subject to comprehensive OFAC-administered sanctions, specifically Iran.  We provided to the U.S. Treasury Department's Office of Foreign Assets Control ("OFAC"), in response to an administrative subpoena, information regarding all transactions by the Company involving Iran. Pursuant to licenses issued by OFAC, Company subsidiaries purchase overflight permits from Iran. Payments for overflight permits are made to the Iranian Civil Aviation Authority. The Company's subsidiaries have also provided certain services (e.g., procuring ground handling services and landing permits and providing flight plans) and supplied fuel in connection with passenger flights to and from the country. the Company has recently discovered one instance in which one of its subsidiaries arranged for the sale of marine fuel to a Singapore-owned and operated vessel while it was at port in Bandar Abbas, Iran.  The Company recently supplied fuel in the United States to an Iranian government owned aircraft in connection with the Iranian government's participation at meetings of the United Nations." (10-K for WORLD FUEL SERVICES CORP, 2/25/2010) (https://www.sec.gov/Archives/edgar/data/789460/000119312510040758/d10k.htm','WORLD%20FUEL%20SERVICES%20CORP',''))

A subsidiary of World Fuel Services Corp, Tramp Oil Marine and Aviation, lists in its directory that it is involved in fuel services with nine airports in Iran. "This booklet lists over 2,000 airports where Tramp Oil Aviation Ltd can offer jet fuel supplies on an into-plane basis." (Tramp Oil & Marine Website) (http://www.tramp-oil.com/downloads/pdfs/guides/trampoilaviation.pdf)

In their 2010 10-k form to the SEC, World Fuel Services Corp. disclosed information regarding their ventures in Iran.