In our continuing series on Section 219, we now move beyond interpreting the requirements of Section 219 to the mundane yet important task of complying with these new requirements. Section 219 of the Iran Threat Reduction and Syria Human Rights Act of 2012 (the “Threat Reduction Act”) requires SEC-registered issuers to disclose in periodic reports filed with the SEC, among other things, if they or their affiliates knowingly conducted any transaction or dealing with a person or entity affiliated with the Government of Iran or that has been listed on the US Department of the Treasury’s Office of Foreign Assets Control’s Specially Designated Nationals and Blocked Persons List (the “SDN List”) for support of global terrorism or weapons of mass destruction proliferation activities. This publication focuses on practical and realistic measures that SEC-registered issuers should consider when implementing their Section 219 compliance program.
View full memo, "The Iran Threat Reduction and Syria Human Rights Act of 2012 – How Are You Planning to Comply with Section 219’s New Reporting Requirements?"
