Alert January 15, 2013

Goodwin Procter Alert Discusses OFAC Issuance of General License Authorizing Foreign Subsidiaries of U.S. Companies to Wind Down Transactions with Iran

Goodwin Procter Alert issued by the firm’s National Security and Foreign Trade Regulation Practice discusses the general license issued by the Office of Foreign Assets Control of the U.S. Department of the Treasury (“OFAC”) that gives foreign subsidiaries of U.S. companies through March 8, 2013, to wind down any open transactions or dealings involving Iran that would otherwise be unlawful.  This authorization will be of interest to foreign companies attempting to comply with the Iran Threat Reduction and Syria Human Rights Act of 2012 (the “Threat Reduction Act”) and Executive Order 13628 (October 9, 2012), which expanded the reach of U.S. sanctions against Iran by closing the long-standing “foreign-subsidiary loophole.”  The Threat Reduction Act was discussed in an August 16, 2012 Goodwin Procter Alert.