Morgan Lewis (JD Supra Iran)

Relief is very limited and alleviates threat of sanctions regarding transactions by non-U.S. or foreign persons. On January 30, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) published guidance in the Federal Register on how the U.S. government would proceed to implement Iran sanctions relief while diplomatic negotiations unfold with Iran.

Mandatory requirements cover actions of issuers' foreign subsidiaries and affiliates. On August 10, 2012, section 219 of the Iran Threat Reduction and Syria Human Rights Act of 2012 (the Act), 112 P.L. 158, added new subsection (r) to section 13 of the Securities Exchange Act of 1934 (Exchange Act), 15 U.S.C. § 78m. This new subsection imposes mandatory reporting requirements for certain 2012

Grace period through March 8 provided to foreign subsidiaries to wind down Iranian transactions. On December 26, 2012, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) amended the Iranian Transactions and Sanctions Regulations (ITSR), 31 C.F.R. pt. 560, to implement section 218 of the Iran Threat Reduction and Syria Human Rights Act of 2012 (the Act), 112 P.L. 158

Foreign subsidiaries of U.S. parent companies are deemed fully subject to U.S. jurisdiction regarding all Iranian sanctions. On October 9, an Executive Order was issued by President Barack Obama, fully implementing Section 218 of the Iran Threat Reduction and Syria Human Rights Act of 2012 (the Act), P.L. 112-158, which was signed into law on August 10, 2012.