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💨IMPACT LEVEL 1 — MEH

Epstein File EFTA01363583: Construction and Procure (DS10)

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This document contains intelligence alerts dated July 29, 2010 and December 2010 regarding connections between Caterpillar Belgium SA and the National Iranian Oil Engineering and Construction Company (NIOEC), which was listed by the Australian Department of Foreign Affairs and Trade. The document notes that NIOEC took legal advantage of a controversial loophole in US sanctions legislation to procure materials, with a critical priority alert assigned.

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Excerpt 1
Connect IRC - Iran Connect ASC - Associated with, Seen with, 07/29/2010 Caterpillar Belgium SA is an associate of National Iranian Oil Engineering and **Construction**
Excerpt 2
On July 29, 2010, Australian Department of Foreign Affairs and Trade has listed National Iranian Oil Engineering and **Construction** Company (NIOEC) under
Excerpt 3
Priority: Critical Alert ID: 12612432.11620919.86458141 December 2010 that took legal advantage of a controversial loophole in US sanctions legislation to **procure**

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