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
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.
