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Nov 07, 2012

Section 219 of the Iran Threat Reduction and Syria Human Rights Act of 2012 – Additional Reporting Requirements for US Domestic and Foreign Issuers Registered with the SEC

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Section 219 of the Iran Threat Reduction and Syria Human Rights Act of 2012 mandates additional disclosure requirements for US-registered issuers concerning certain Iran-related activities and, under a plain reading of the statute, certain activities with non-Iran-related persons or entities listed on the US Department of the Treasury’s Office of Foreign Assets Control’s Specially Designated Nationals and Blocked Persons List (SDNs). In light of these new requirements, US-registered issuers should carefully review their business activities to determine whether such activities are reportable under Section 219 and consider implementing screening procedures to ensure that they are not engaged in reportable activities with SDNs.

View full memo, "Section 219 of the Iran Threat Reduction and Syria Human Rights Act of 2012 – Additional Reporting Requirements for US Domestic and Foreign Issuers Registered with the SEC"

Authors and Contributors

Stephen Fishbein

Partner

Litigation

+1 212 848 4424

+1 212 848 4424

New York

Philip Urofsky

Partner

Litigation

+1 202 508 8060

+1 202 508 8060

Washington DC

Danforth Newcomb

Of Counsel

Litigation

+1 212 848 4184

+1 212 848 4184

New York