News & Analysis as of

Office of Foreign Assets Control (OFAC) Iran Threat Reduction and Syria Human Rights Act

Baker Donelson

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

Baker Donelson on

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

Sheppard Mullin Richter & Hampton LLP

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

Stinson - Corporate & Securities Law Blog

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

Miller Canfield

Wire Stripping: What is Old is New Again

Miller Canfield on

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

King & Spalding

The New Year Brings New Sanctions Against Iran

King & Spalding on

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

Morgan Lewis

SEC Reporting for Certain 2012 Iran-Related Transactions

Morgan Lewis on

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

Holland & Knight LLP

Iran Sanctions Update

Holland & Knight LLP on

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

Smith Anderson

New Reporting Requirements Under the Iran Threat Reduction and Syria Human Rights Act of 2012

Smith Anderson on

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

Morgan Lewis

New OFAC Regulations Implement Iranian Sanctions

Morgan Lewis on

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

Proskauer Rose LLP

Final Rule on New Iranian Sanctions Published

Proskauer Rose LLP on

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

Holland & Knight LLP

Iran Sanctions: U.S. Bans Foreign Subsidiaries of U.S. Companies from Doing Business with Iran

Holland & Knight LLP on

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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