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.

Please see full Article below for more information.

LOADING PDF: If there are any problems, click here to download the file.

Written by:


Shearman & Sterling LLP on:

Readers' Choice 2017
Reporters on Deadline

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:

Sign up to create your digest using LinkedIn*

*By using the service, you signify your acceptance of JD Supra's Privacy Policy.

Already signed up? Log in here

*With LinkedIn, you don't need to create a separate login to manage your free JD Supra account, and we can make suggestions based on your needs and interests. We will not post anything on LinkedIn in your name. Or, sign up using your email address.