Section 219 (codified as Section 13(r) of the Securities Exchange Act) has been in effect for six weeks. During this time, more than 100 SEC-registered reporting issuers have made required disclosures regarding their Iran or SDN-related activity. Collectively, these disclosures highlight several issues confronting this new reporting requirement. More importantly, these disclosures make it clear that further guidance regarding the Section 219’s disclosure procedure would be most beneficial.

Noteworthy Trends -

1. Activities of foreign subsidiaries of US companies have dominated the disclosures.

2. Reporting issuers have taken a broad view of affiliates in their disclosures.

3. Most of the activities disclosed under Section 219 to date were not sanctionable at the time the activity was conducted.

4. Issuers recognize that there is no de minimus value threshold for reporting under Section 219.

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