Iran Threat Reduction and Syria Human Rights Act

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

Governance & Securities Law Focus: Latin America Edition

In this issue: - US DEVELOPMENTS - Securities and Exchange Commission (“SEC”) Developments - SEC Reporting Companies Begin to Comply with New Iran-Related Disclosure Requirements - SEC Says Social Media...more

Governance & Securities Law Focus: Asia Edition, April 2013

In this issue: - US DEVELOPMENTS - Securities and Exchange Commission (“SEC”) Developments - Noteworthy US Securities Law Litigation - Recent SEC/DOJ Enforcement Matters - EU DEVELOPMENTS...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

What’s Going On – Over A Month Of Section 219 Disclosures Under The Iran Threat Reduction And Syria Human Rights Act Of 2012

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...more

10Qs and 10Ks Now Required to Include Transactions Subject to Economic Sanctions

Effective February 6, 2013, companies required to file quarterly and annual reports (10Qs and 10Ks) with the Securities and Exchange Commission (SEC) are required to include information about certain of their own and their...more

Small Business Securities Bulletin - Smaller Reporting Companies Become Subject to Say-on-Pay in 2013; New Iran/Terrorism...

A periodic bulletin keeping small businesses informed about current developments in securities law and related matters. For the first time, smaller reporting companies are subject, in 2013, to the stockholder advisory...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

Planning for the 2013 Annual Meeting and Reporting Season

As companies prepare for the 2013 annual meeting and reporting season, we have compiled an overview of the corporate governance and disclosure matters that companies should consider as they draft this season’s disclosure...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

SEC Reporting for Certain 2012 Iran-Related Transactions

Mandatory requirements cover actions of issuers' foreign subsidiaries and affiliates. On August 10, 2012, section 219 of the Iran Threat Reduction and Syria Human Rights Act of 2012 (the Act), 112 P.L. 158, added new...more

Disclosure tips for 2013

The proxy and annual reporting season has begun, with relatively few changes in reporting requirements from last year. Here are some tips to take you through the season and prepare for changes to come. 1. Consider the...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

Disclosures Under the Iran Threat Reduction and Syria Human Rights Act of 2012

In August 2012, the Iran Threat Reduction and Syria Human Rights Act of 2012 (ITR) was signed into law. ITR is part of a broad sanctions strategy designed to deter the pursuit of nuclear weapons and support for terrorism and...more

New OFAC Regulations Implement Iranian Sanctions

Grace period through March 8 provided to foreign subsidiaries to wind down Iranian transactions. On December 26, 2012, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) amended the Iranian...more

Considerations for the 2013 Form 10-K and Annual Proxy Season

The upcoming 2013 proxy season will likely be impacted by new policies issued by proxy advisers, as well as shareholder activists taking advantage of previously adopted rules, rather than by recent legislative or rulemaking...more

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