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
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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’’)...

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