Compliance Issues with the New SEC Reporting and Disclosure Requirements Under the Iran Threat Reduction and Syria Human Rights Act of 2012

Sheppard Mullin Richter & Hampton LLP

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 and Syria. ITRSHRA includes a new disclosure requirement for public companies subject to Section 13(a) of the Securities and Exchange Act of 1934, as amended (‘‘Exchange Act’’).1 The new disclosure requirement is in ITRSHRA Section 219, which amends Section 13 of the Exchange Act by adding subsection (r). New subsection 13(r) provides that each issuer required to file an annual or quarterly report pursuant to Section 13(a) of the Exchange Act shall disclose if, during the period covered by the report, the issuer or any affiliate of the issuer knowingly engaged in any of the following:

..(i) providing support for Iran’s ability to develop petroleum resources or produce or export refined petroleum products, as described in Section 5, subsections (a) and (b) of the Iran Sanctions Act of 1996 (‘‘ISA’’)...

Please see full alert below for more information.

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

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© Sheppard Mullin Richter & Hampton LLP | Attorney Advertising

Written by:

Sheppard Mullin Richter & Hampton LLP

Sheppard Mullin Richter & Hampton LLP on:

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:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
Custom Email Digest
- hide
- hide

This website uses cookies to improve user experience, track anonymous site usage, store authorization tokens and permit sharing on social media networks. By continuing to browse this website you accept the use of cookies. Click here to read more about how we use cookies.