In July 2011, Reflect Geophysical obtained a BIS license to re-export subsea survey equipment under national security and anti-terrorism regulation. The equipment was mounted on Orient Explorer, a vessel owned by DMNG, a Russian state-owned company.

In March 2012, Reflect lost control of the equipment on board the vessel in Singapore as a result of a contractual dispute between DMNG and the operated survey equipment. Subsequently, Nordic obtained possession of the equipment by chartering the Orient Explorer from DMNG.

In April 2012, Reflect sent a cessation letter to DMNG, Nordic and Innhaug advising the parties that the use of Reflect equipment in Iranian waters would breach the terms of the BIS re-export permit.

Given a alert from Reflect, Nordic used managed equipment to conduct a 3D offshore seismic survey in the Forouz B natural gas field in Iranian territorial waters. The survey was performed on the basis of a contract signed by Nordic with Mapna International FZE, a subsidiary of the Mapna Group, also known as the Iran Power Plant Management Company.

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