On April 20, 2016, the Supreme Court decided Bank Markazi v. Peterson, No. 14-770, holding that Congress did not unconstitutionally infringe on the role of the judiciary when it passed the Iran Threat Reduction and Syria...more
As we roll into a new year and a new public company reporting season, public companies should be aware of a number of rule changes and rulemakings, Securities and Exchange Commission (SEC) staff guidance, disclosure trends...more
This has been a historic month for the United States and several other leading nations as they reached an apparent settlement with Iran over the development of its nuclear program. On July 14, the five permanent members of...more
After a twelve-year standoff that saw the United States and Europe ratchet up sanctions pressure on Iran, a diplomatic breakthrough has been reached. But robust trade between Iran and the West will not arise immediately,...more
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
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
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
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
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
On August 10, 2012, President Obama signed into law the Iran Threat Reduction and Syria Human Rights Act of 2012, or the TRA....more
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
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 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
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
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
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
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
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
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
In This Issue: - 2013 Annual Meeting Season - Dealing with ISS and Other Proxy Advisory Firms this Proxy Season - SEC Update - Other NYSE/NASDAQ Developments - Delaware Law Update — Delaware Court Applies...more
The Iran Threat Reduction and Syria Human Rights Act (ITRA), signed into law on August 10, 2012, added new Section 13(r) to the Exchange Act, requiring issuers that file reports under Section 13(a) of the Exchange Act to...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