The recently signed Iran Threat Reduction and Syria Human Rights Act of 2012 extends to foreign subsidiaries of US companies the preexisting OFAC sanctions against Iran. It also imposes new reporting requirements on firms with securities traded on US stock exchanges and expands the scope of the Iran Sanctions Act, as amended by CISADA. As a result, the US sanctions program against Iran now consists of a complicated patchwork of legislation, Executive Orders, and regulations, making it difficult for both US and non-US companies to understand their obligations under US law.
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