Last week we reported on increased jawboning by the State Department, which has been threatening to impose sanctions under the Iran Sanctions Act on foreign oil companies that do business in Iraq. One target singled out by State is the Austrian oil company OMV. In a daily press briefing, State Department spokesman Sean McCormack had this to say:

Well, we have talked to I think — the company is OMV. We’ve talked to the Austrian Government about these negotiations. I understand that OMV has recently signed a preliminary deal . . . [W]e would question why at this point given Iran’s behavior in the international community . . . [it] would want to encourage these sorts of business dealings with Iran at this . . . particular time.

It’s going to be a choice that each individual state, each individual business is going to have to make. We have also talked to them about the fact that there are potentially applicable U.S. laws that could be triggered under the Iran Sanctions Act for basically over a certain dollar amount for investment in the Iranian oil and gas sector there’s a possibility of looking at applying sanctions to the relevant companies. I’m not saying we’re at that point, by any means, but it is something about which countries around the world, businesses around the world need to be aware of.

Thomas Huemer, a spokesman for OMV, was quick to respond:

OMV spokesman Thomas Huemer said that the company would respect all Austrian, EU and relevant international laws in its dealings with Iran’s National Iranian Oil Company (NIOC).

Hmm, I don’t see U.S. law or the Iranian Sanctions Act included in that list.

Of course, to be fair to OMV, it is in a difficult position. E.U. Council Regulation No 2271/96 explicitly forbids E.U. companies like OMV from complying with the Iran Sanctions Act. And McCormack’s threats were, after all, only of the “we’re only just saying” variety.

In other news, the Bureau of Industry and Security (“BIS”) wins the double plus good Newspeak award for headlining it’s announcement of new, and widely criticized, export controls on China with this headline: “Enhancing U.S. China Technology Trade.”

The Bureau of Industry and Security (“BIS”) published today in the Federal Register an order denying export privileges to Super Net Computers, a Dubai-based computer retailer. You don’t have to be a rocket scientist, or a computer scientist, to guess why — Super Net was transshipping U.S.-origin computer parts to Iran. Surprise, surprise, surprise.

Dubai is just a short hop across the Straits of Hormuz to Iran and, not surprisingly, is the transhipment point of choice for goods being shipped into Iran in violation of the U.S. sanctions on Iran. Any exporter should exercise increased diligence when shipping goods to Dubai, and to the UAE, to insure that the goods don’t wind up in Tehran, which could lead to some pointed questions from BIS.

While searching the Internet to get information on Super Net Computers, we found a valuable asset to assist exporters in exercising that extra measure of care. There is a site called the “Iranian Business Directory Dubai” which bills itself as the “ultimate guide to Iranian businesses in Dubai.” And right there in that directory we found Super Net Computers, more or less advertising that any thing shipped to it would cross the Straits of Hormuz before you could say Ahmadinejad.

More than seven thousand other Dubai businesses — 7,222 to be precise — are listed on that directory, which makes the directory an extremely valuable resource. The “ultimate guide” indeed. Although not in the way we imagine it was intended.