Item 5. Other Information
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Item 5. Other Information
Disclosure Pursuant to Section 219 of the Iran Threat Reduction and Syria Human Rights Act of 2012 and Section 13(r) of the Exchange Act. We have comprehensive export controls and economic sanctions programs designed to ensure compliance with United States and other applicable export control and sanctions laws, rules, and regulations. As discussed in our Annual Report, on April 15, 2021, the Treasury Department’s Office of Foreign Assets Control (“OFAC”) designated Positive Technologies, a Russian company, on the List of Specially Designated Nationals and Blocked Persons (“SDN List”) pursuant to Executive Order 13382. We timely identified this company as a customer of TNT Express Worldwide (CIS) Limited Liability Company, a subsidiary of FedEx Express in Russia, and during the fourth quarter of 2021 completed a wind down of the customer relationship and instituted a policy of not accepting future shipments to or from Positive Technologies. As discussed in our Annual Report, while this wind down was in progress, two shipments of printed documents from Positive Technologies were picked up and delivered to Kazakhstan and one shipment of printed documents from Positive Technologies was picked up and returned to the sender for operational reasons. During the first quarter of fiscal 2022, Positive Technologies arranged for additional shipments of printed documents by TNT Express subsidiaries organized in Europe through a courier service aggregator, and six of these shipments were inadvertently picked up in Russia and delivered to Azerbaijan, Czech Republic, Italy, or Russia, respectively. While these activities did not involve a U.S. nexus and were in compliance with applicable laws, including the sanctions regulations administered by OFAC, they require disclosure pursuant to Section 219 of the Iran Threat Reduction and Syria Human Rights Act of 2012 and Section 13(r) of the Securities Exchange Act of 1934. These shipments resulted in aggregate revenue of approximately $300, and aggregate profit of approximately $10. We have implemented enhanced controls, procedures, and other measures to ensure compliance with our export controls and economic sanction programs.
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