As of noon today, eight US-registered issuers have made disclosures of Iran-related activities pursuant to the new reporting requirements under Section 219 of the Iran Threat Reduction and Syria Human Rights Act of 2012 (“Section 219”). As the SEC has provided little guidance on the scope of disclosure required under Section 219, the initial batch of disclosures provide a useful guide for US-registered issuers intending to make disclosures in their next periodic report filed with the SEC.View full memo, "Flash Report: Section 219 Disclosures Under the Iran Threat Reduction and Syria Human Rights Act of 2012"
