Goodwin Procter issued a Client Alert concerning the Iran Threat Reduction and Syria Human Rights Act of 2012 (the “Act”). The Act broadens the scope of U.S. economic sanctions in ways that will impact many U.S. companies, including financial institutions, and their foreign affiliates. The Act’s two most significant provisions relating to Iran (i) expand the reach of U.S. sanctions against Iran and its government to foreign entities owned or controlled by “U.S. persons,” and (ii) require domestic and foreign companies that issue securities traded on a U.S. exchange to disclose to the SEC certain sanctions-related business dealings of the issuer and its affiliates.
Alert August 21, 2012