News & Analysis as of

Capital Thinking: International

Executive and Legislative Branch Activity - Iran - As of last Friday, January 10, the bipartisan Senate bill (S. 1881) to increase sanctions on Iran had reportedly garnered a filibuster-proof majority – at least 60...more

Sanctions Round-Up: First Quarter 2013

In this issue: - OFAC Releases New SDN Search Tool - Additional Provisions Targeting Iran Go Into Effect - OFAC Continues to Target Foreign Sanctions Evaders - Section 219 Disclosures Begin - Burma...more

Alert: Clarifications of the Iranian Sanctions Regulations

On February 6, 2013, the Office of Foreign Assets Control (OFAC) published two guidance documents related to the Iranian sanctions regulations and licenses. The first is Guidance on Humanitarian Assistance and Related...more

IRANNOTICEs Begin To Roll Into The SEC

A number of companies have filed IRANNOTICEs on EDGAR with the SEC (thanks to Broc Romanek for pointing this out). The notices reference disclosures made in annual reports pursuant to Section 219 of the Iran Threat Reduction...more

Public Companies Must Begin Reporting Transactions with Iran

Beginning February 6, 2013, public companies must disclose in annual or quarterly reports to the Securities and Exchange Commission whether the companies or any of their affiliates engaged in proscribed transactions with...more

New Iran Sanctions: Breaking Down the Breaking Points

Energy, shipping, and shipbuilding. Generally, these are the sectors of the Iranian economy that have recently come within the ambit of the existing U.S. sanctions regime against Iran. We write "generally" because in addition...more

Wire Stripping: What is Old is New Again

Recently, Standard Chartered Bank (SCB) was in the news again for stripping original wire details so that payments would go undetected by the U.S. Department of Treasury's Office of Foreign Assets Control (OFAC)....more

New Reporting Company Disclosure Requirements for Activities Relating to Iran

On August 10, 2012, President Obama signed into law the Iran Threat Reduction and Syria Human Rights Act of 2012, or the TRA....more

REGULATORY: International Trade: U.S. Continues to Expand Sanctions Against Iran by Christine Savage, Jane Cohen and Shannon Doyle...

Preventing Iran from obtaining nuclear weapons capability remains one of the United States’ preeminent national security objectives,. Thus, the United States and its allies have increasingly turned to economic sanctions as a...more

The New Year Brings New Sanctions Against Iran

As 2013 begins, the United States has reiterated its commitment to countering the threat posed by Iran by passing new legislation, issuing new regulations and guidance, and bringing into effect new requirements to increase...more

Iran Sanctions Update

The United States continues to impose additional layers of sanctions on Iran. The rate of change and complexity of U.S. sanctions laws present challenges, particularly where these sanctions have extraterritorial effect on the...more

New Iran Sanctions Enacted

Satellite Export Controls Now Eligible to be Returned to Commerce Department Jurisdiction - On January 3, 2013, President Obama signed into law Public Law No. 112-239, the Iran Freedom and Counter-Proliferation Act of...more

New Reporting Requirements Under the Iran Threat Reduction and Syria Human Rights Act of 2012

On August 10, 2012, the United States delivered its latest economic blow to Iran by enacting the Iran Threat Reduction and Syria Human Rights Act of 2012. U.S. companies have long been forbidden from engaging in most...more

Compliance Issues with the New SEC Reporting and Disclosure Requirements Under the Iran Threat Reduction and Syria Human Rights...

Originally published in Securities Regulation & Law Report on December 12, 2012. In August 2012, the Iran Threat Reduction and Syria Human Rights Act of 2012 (‘‘ITRSHRA’’) was passed to expand U.S. sanctions against Iran...more

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