Laredo Petroleum

Subsidiary of Warbug Pincus.

"in its February 16, 2017 filing, Laredo Petroleum, Inc. (a U.S. company) stated clearly that neither it nor its affiliates knowingly engaged in any activities associated with Iran. However, “because the SEC defines the term ‘affiliate’ broadly,” Laredo disclosed information provided by Warburg Pincus, Laredo’s founding member and whose affiliates own 36.2% of Laredo’s common stock. According to the disclosure, the affiliates of Warburg Pincus beneficially own more than ten percent of the equity interests of another company, Santander Asset Management Investment Holdings Ltd. (SAMIH). Because SAMIH may be deemed to be under common control with Laredo due to the SEC’s broad interpretation of affiliate, Laredo disclosed that a SAMIH affiliate—Santander U.K. plc—held savings accounts for two SDNs during the year, even as it noted that SAMIH’s activity does not relate to any activity conducted by Laredo or Laredo’s affiliates." (https://www.shearman.com/Perspectives/2018/01/Dynamics-in-the-Era-Iran-Sanctions)