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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
President Obama has issued two new Executive Orders that impose significant new extraterritorial sanctions on persons who do business with Iran or Syria
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
