Pursuant to the Iran Threat Reduction and Syria Human Rights Act of 2012 (ITRA), any company that is required to file annual or quarterly reports under Section 13(a) of the Exchange Act must disclose in those reports whether, during the period covered by the subject report, it or any affiliate has knowingly engaged in certain sanctionable activities generally relating to Iran. Public companies, even companies that concluded that they did not need to include ITRA disclosure in their most recent annual and quarterly reports, need to ensure that they have disclosure controls in place to determine each quarter whether any such disclosure is needed with respect to the period covered by the report.
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