U.S. Sanctions Update: Non-U.S. Entity Activity
with Iran and Other Sanctions Targets Now Required to be
Disclosed to the SEC, Additional U.S. Sanctions Targeting
Non-U.S. Business with Iran Imposed, and OFAC Sanctions
Regulations Amended
Issuers
subject to the jurisdiction of the Securities and Exchange
Commission (“SEC”), as well as, more broadly, many non-U.S.
companies should be aware of the potential impact of the
latest expansion of U.S. economic sanctions laws targeting
Iran and other areas, such as international terrorism.
Beginning on February 6, 2013, issuers required to file
periodic reports under Section 13(a) of the Securities
Exchange Act of 1934 that engage, or have any “affiliates”
that engage, in a broad range of activities covered by a
recent statute are required to disclose those activities to
the SEC, without regard to the materiality of such activities.
Such issuers will need to consider carefully how to identify
when their affiliates (which may include the issuer’s
directors and executive officers) are engaged in such
activities so they can comply with the new disclosure
requirements. A separate new law expands the range of
activities relating to Iran and certain parties targeted as
national security threats that, even if conducted by
businesses outside of the United States, will be sanctionable
by the U.S. government. U.S. companies engaged directly or
indirectly in international business should evaluate whether
their business activities now could be subject to sanctions,
and, in order to avoid becoming subject to sanctions,
undertake measures to prevent those activities from occurring
in the future.
"U.S. Sanctions Update: Non-U.S. Entity Activity with Iran and Other Sanctions Targets Now Required to be Disclosed to the SEC"
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