Alert October 23, 2012

Goodwin Procter Alert: New Iran Sanctions Law Closes Foreign Subsidiary Loophole

Goodwin Procter’s National Security & Foreign Trade Regulation Practice issued a Client Alert discussing the new Iran Threat Reduction and Syria Human Rights Act of 2012 (the “Act”).  The Act, among other things, (i) closes a loophole under which a foreign subsidiary of a U.S. company could engage in transactions with Iran provided it acted independently of, and was not facilitated by, a “U.S. person;” and (ii) requires 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.