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
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
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
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
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
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
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
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
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
On December 26, 2012 the Department of the Treasury's Office of Foreign Assets Control ("OFAC") published a final rule amending the Iranian Transactions and Sanctions Regulations, 31 C.F.R. part 560 (the "ITSR"), to implement...more
President Obama issued an Executive Order on Oct. 9, 2012, implementing recent legislation barring foreign subsidiaries of U.S. companies from engaging in most transactions with Iran and making the U.S. parent companies...more
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