Sanctions Update: Numerous New Measures Target
Non-U.S. Business with Iran
U.S.
companies can no longer distance themselves from
business conducted by their foreign subsidiaries with
Iran. On August 10, 2012, President Obama signed into
law the Iran Threat Reduction and Syria Human Rights Act
of 2012 (“the Act”). The Act expands existing sanctions,
for example those under the Iran Sanctions Act of 1996
(“ISA”), as amended by the Comprehensive Iran Sanctions,
Accountability, and Divestment Act of 2010 (“CISADA”),
and creates additional sanctions measures against Iran.
The Act’s broadest impact arguably is the expanded
liability imposed on U.S. companies for activities
related to Iran of any foreign affiliate owned or
controlled by the U.S. company. In addition, the law
creates new reporting requirements for securities
issuers related to Iran business.
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