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"If these companies are going through the back door to invest in terrorist nations, Congress must take action to immediately close, lock and seal those doors," Senator Max Baucus (D-MT) the ranking Democrat on the Senate Finance Committee said in February 2004.1

As investigators from 60 Minutes discovered, Halliburton has used an offshore subsidiary incorporated in the Cayman Islands (where the company has no oil and gas construction or engineering operations) to trade with Iran, a country that the Bush administration has described as part of an "axis of evil, arming to threaten the peace of the world."2

Federal law disallows American companies from transacting business with nations that sponsor terrorism, but foreign subsidiaries of such companies are not banned from such transactions. In May 2004, the U.S. Senate voted against legislation that would have stopped companies like Halliburton from using offshore subsidiaries to invest in Iran. The legislation was defeated in a 50-49 vote, mostly along party lines.

As CEO of Halliburton, Mr. Cheney lobbied the Clinton administration to ease sanctions on Libya and Iran, according to various news reports. "I think we'd be better off if we, in fact, backed off those sanctions [on Iran], didn't try to impose secondary boycotts on companies .. trying to do business there," Cheney told an Australian television interviewer in April 1998.3

According to the Financial Times, before he was elected (but after he resigned from Halliburton) Cheney "has said the company is allowed to operate legally in Iran through its foreign subsidiaries."4 "What we do with respect to Iran and Libya is done through foreign subsidiaries, totally in compliance with US law," Cheney told ABC Television's Sam Donaldson. When Donaldson suggested, "it's a way around US law," Cheney replied: "No, no, it's provided for us specifically with respect to Iran and Libya."5 If you're a big multinational that's able to incorporate around the world, you don't have to worry.

As Vice President, Cheney led the National Energy Review which concluded in 2001 that the US should "level the playing field for US companies overseas" and recommended a comprehensive review of sanctions with consideration given to US "energy security."6

The Financial Times reported just before the Iraq War in March 2003 that "the Pentagon is drawing up a blacklist of non-US companies investing in Iran's energy sector, with a possible view to barring them from US-awarded contracts in the reconstruction of neighboring Iraq."7 In 1995, President Clinton passed an executive order barring U.S. investment in Iran's energy sector.8 In 1996, Congress passed the Iran-Libya Sanctions Act, which seeks to punish non-US oil companies that invest $20 million or more in either country, and which has been a source of friction with key US allies, including France, Germany, Russia and the UK.9

Halliburton says their firm is in compliance with U.S. laws.

But in a letter to Treasury Secretary John Snow, Baucus and Finance Committee Chairman Charles Grassley (R-IA), pointed to Halliburton subsidiary Halliburton Products and Services Ltd. "This subsidiary is nominally located in the Cayman Islands, but according to media reports does not conduct any actual business in the Cayman Islands or even maintain a functioning office. ... We are concerned about this specific example, and about the possibility that this may be indicative of a more widespread problem."10

In a letter to New York City's fire and policy pension fund managers, who have also been raising the issue on behalf of Halliburton's shareholders, the company said that Halliburton Products and Services, a Cayman islands firm headquartered in Dubai, the United Arab Emirates, made over $39 million in 2003 (a $10 million increase from 2002) by selling oil-field services to customers in Iran.11

When CBS Television's 60 Minutes program visited the address where Halliburton Products and Services is incorporated in the Cayman Islands, they discovered a "brass plate" operation with no employees whose agent - the Calidonian Bank -- forwards all of the company's mail to Halliburton's offices in Houston (instead of the company's operations in Dubai), "indicating that decision-making authority may be in Houston, not the Cayman Islands or Dubai," according to the Senators. In addition, it was reported that Halliburton's operations in Dubai share the same address, telephone and fax numbers as Halliburton Products and Services - an indication that the companies do not function separately.12

"It is extremely disturbing to hear media reports of possible violations of our anti-terrorism laws by prominent American companies through straw corporations established to evade U.S. law. What makes these charges extraordinary is the involvement of the Vice President, since Halliburton Products and Services began operations in Iran during the time that Vice President Cheney was CEO of Halliburton," Rep. Tammy Baldwin (D-WI) wrote in a letter to her colleagues.

The U.S. Treasury Department's Office of Foreign Assets Control recently asked the company for new information about the subsidiary, according to a filing with the SEC.

In early March 2003, the SEC's new Office of Global Security Risk announced that it would be hiring five full-time staff to look at companies with ties to rogue nations.13

ConocoPhillips agreed to cut its business connections with Iran and Syria in February 2002.14 But Halliburton uses its ability to incorporate subsidiaries all over the world to evade any U.S. restrictions on foreign regimes that are considered too odious for the legislators in Washington.

During the 1990s, under Cheney's leadership Halliburton did business with the former Nigerian regime of dictator Sani Abacha, a brutal military dictator. The Abacha regime threw thousands of political opponents into prison, and executed nine environmental activists, including the playwright Ken Saro-Wiwa.

More Information

Halliburton's detailed report on its business in Iran
CBS 60 Minutes article on tax havens used to skirt U.S. export bans
New York City Comptroller's Office
Conflict Securities Advisory Group
Senate Finance Committee
Congressman Henry Waxman's Letter to Donald Rumsfeld


1. David Ivanovich, "Deals in Iran, Syria appall senators," Houston Chronicle, February 19, 2004.

2. State of the Union Address, January 29, 2002.

3. David Ignatius, "Dick Cheney and the 'Great Game,' " Washington Post, August 27, 2000.

4. U.S. Companies Move Quietly into Iranian Markets, Financial Times, October 5, 2000.

5. This Week (ABC News), July 30, 2000.

6. Guy Dinmore, "Traders with "rogue" states may fact sanctions, Washington Post, July 26, 2003.

7. Guy Dinmore, "Pentagon to blacklist companies with Iran ties," Financial Times (London), March 29, 2003.

8. Executive Orders 12613, 12957, 12959, and 10359.

9. Maureen Lorenzetti, "Oil firms hope US lifts sanctions against Iran, Libya," Oil and Gas Journal, June 9, 2003.

10. Charles E. Grassley, Chairman and Max Baucus, Ranking Member, letter to Hon. John Snow, Secretary of the Treasury, February 19, 2004. http://www.senate.gov/%7Egrassley/releases/2004/p04r02-19.htm

11. "Halliburton Business in Iran - Global Overview," (memo to NYC comptroller), October 21, 2003. http://www.comptroller.nyc.gov/press/pdfs/halliburton-pr03-12-102/Oct21-03_Halliburton-report.pdf

12. CBS 60 Minutes, "Doing Business With the Enemy," January 25, 2004. http://www.cbsnews.com/stories/2004/01/22/60minutes/main595214.shtml

13. "SEC to Scrutinize Companies Doing Business in Rogue Nations," AccoutningWEB.com, March 8, 2004.

14. "ConocoPhillips: Ties to Iran, Syria Will Be Cut on Urging From Pension Funds," Wall Street Journal, February 11, 2004.