Ameron International Corporation

In addition, certain foreign subsidiaries included within the Current Consolidated Group had limited sales from current operations into Iran during 2008 – Two foreign subsidiaries included within the Current Consolidated Group (Ameron (Pte) Ltd. (“PTE”), a wholly-owned subsidiary of the Company located in Singapore and Ameron Malaysia Sdn. BHn. (“AM”), a wholly-owned subsidiary of PTE located in Malaysia, reported combined direct sales from current operations of $342,826.76, and no indirect sales, into Iran during the 2009 Comment Letter Period.

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In their 2010 10-K form for the SEC, Ameron announced that they would continue to conduct inquiries into their subsidiaries' businesses in Iran.

In a 2008 Correspondance with the SEC, the company disclosed what materials were being sold in Iran.

In a correspondance with the SEC in 2009, the company disclosed details regarding their subsidiaries' activities in Iran.

Ameron International was fined $434,700 by the U.S. government in 2013 for violating Iran sanctions. (OFAC, Enforcement Information for October 24, 2013) (https://ofac.treasury.gov/media/13701/download?inline)

"Ameron (Pte.) Ltd. (“APL”), a wholly-owned subsidiary of the Company located in Singapore, Ameron (Malaysia) Sdn. Bhn. (“AM”), a wholly-owned subsidiary of APL located in Malaysia and Bondstrand Gulf FZE (“BFZE”), located in Dubai, a wholly-owned subsidiary of Ameron B.V. (“ABV”), a wholly-owned subsidiary of the Company located in the Netherlands, have reported to us, in response to our inquiry about their current operations in 2008, that APL, AM and BFZE do have limited contacts in Iran.  APL, AM and BFZE reported limited sales of non-United States origin products into Iran.  These sales were reported to be confined to sales of pipes and pipe-related products."

>"The products sold were fiberglass pipe, which is used for fluid conveyance.">(>CORRESP for AMERON INTERNATIONAL CORP, >6/28/2008) (https://www.sec.gov/Archives/edgar/data/790730/000079073008000013/filename1.htm','AMERON%20INTERNATIONAL%20CORP',''))

“Although we have not discovered any evidence that the Company or any of its subsidiaries directly distributed any of the Dualoy CD-Roms in Iran, we have discovered evidence that a copy of the CD-ROM may have been provided to an unaffiliated Iranian sales agent by an UAE subsidiary of the Company.

"In 2008, the Company received from the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) a Requirement to Furnish Information regarding transactions involving Iran.   Based upon the information available to it at this time, the Company is not able to predict the outcome of this matter." (10-K for AMERON INTERNATIONAL CORP, 1/29/2010) (https://www.sec.gov/Archives/edgar/data/790730/000079073010000003/ameron_10k09.htm','AMERON%20INTERNATIONAL%20CORP',''))

>>(CORRESP for AMERON INTERNATIONAL CORP, 5/22/2008) (https://www.sec.gov/Archives/edgar/data/790730/000079073008000010/filename1.htm','AMERON%20INTERNATIONAL%20CORP',''))

>In a previous correspondence with the SEC in 2008, the company disclosed the names of their foreign subsidiaries conducting business in Iran.

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The Company has also recently received information that Bondstrand Ltd. (a foreign company of which the Company indirectly – through a wholly-owned foreign subsidiary – owns 40%) had sales of approximately $13,936.98 of adhesive to an Iranian company."   (CORRESP for AMERON INTERNATIONAL CORP, <>9.14.2009) (https://www.sec.gov/Archives/edgar/data/790730/000079073009000020/filename1.htm','AMERON%20INTERNATIONAL%20CORP',''))