Office of Foreign Assets Control amends its Iranian transactions and sanctions regulations to authorize wind-down transactions and extension of section 218 deadline under Iran Threat Reduction and Syria Human Rights Act *

Iran, Syria, USA - December 28 2012
On December 26, 2012, the Office of Foreign Assets Control (OFAC) issued its long-anticipated "guidance" on Section 218 of the Iran Threat Reduction and…

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Congress passes new legislation tightening sanctions on Iran *

USA - December 21 2012
On December 19, 2012, House and Senate conferees reached agreement on the final language of the Menendez Amendment (SA 3232) (the "Amendment") to the…

Co-authors: Jason M. Waite.

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SEC clarifies reporting requirements for certain activities relating to Iran and specially designated nationals; DOD, GSA and NASA issue interim procurement rule to implement Iranian sanctions *

USA - December 20 2012
On August 10, 2012, President Obama signed the Iran Threat Reduction and Syria Human Rights Act of 2012 (the “Act”), which includes a wide array of amendments to the Iran Sanctions Act of 1996 (ISA), the Comprehensive Iran Sanctions, Accountability and Divestment Act of 2010 (CISADA), and other measures designed to prohibit transactions with Iran and persons or entities listed on the U.S. Department of the Treasury’s Office of Foreign Assets Control’s Specially Designated Nationals and Blocked Persons List (SDNs).

Co-authors: Chad A. Thompson.

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New sanctions legislation mandates public disclosure and investigation of certain activities involving Iran, SDNs *

Iran, USA - November 19 2012
On August 10, 2012, President Obama signed the Iran Threat Reduction and Syria Human Rights Act of 2012 (the “Act”), which includes a wide array of amendments to the Iran Sanctions Act of 1996 (ISA), the Comprehensive Iran Sanctions, Accountability and Divestment Act of 2010 (CISADA) and other measures designed to prohibit transactions with Iran and persons or entities listed on the U.S. Department of the Treasury’s Office of Foreign Assets Control’s Specially Designated Nationals and Blocked Persons List (SDNs).

Co-authors: Chad A. Thompson.

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Urgent: President issues executive order implementing Section 218 of the Iran Threat Reduction and Syria Human Rights Act of 2012 eliminating immediately the “foreign subsidiary loophole” to u.s. iran sanctions *

Iran, Syria, USA - October 10 2012
On October 9, 2012, the President issued an Executive Order implementing a number of provisions under various Iran-related statutes, including Section 218 of the Iran Threat Reduction and Syria Human Rights Act of 2012, which for the first time applies Office of Foreign Assets Control Iran sanctions to U.S.-controlled offshore subsidiaries.

Co-authors: Kenneth G. Weigel.

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