All "U.S. Persons", both corporate and individual, are prohibited to enter into transactions with Iran or entities working on behalf of Iran, and are further prohibited to "approve or facilitate" transactions by foreign persons. The sanctions leave open, however, the possibility for "independent foreign subsidiaries" of U.S. corporations, which are not considered to be "U.S. Persons" to conduct such business.
Halliburton has taken care to isolate its entities that continue to work in Iran from contact with U.S. citizens or managers of U.S. companies, so as to insure that all work in Iran is undertaken independently, without any facilitation, authorization or approval from U.S. citizen managers.
2004 Press Release
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