On December 26, 2012, the Office of Foreign Assets Control amended the Iranian Transactions and Sanctions Regulations in order to implement new provisions which extend the reach of U.S. sanctions against Iran to foreign subsidiaries of U.S. companies. Under a new law passed in August 2012, “an entity owned or controlled by a United States person and established or maintained outside the United States” is prohibited from “knowingly engaging in any transaction directly or indirectly with the Government of Iran or any person subject to the jurisdiction of the Government of Iran that would be prohibited by an order or regulation . . . if the transaction were engaged in by a United States person or in the United States.” According to the new regulations, a U.S. person “owns or controls” an entity if (A) it holds more than 50 percent of the equity interest by vote or by value in the entity; (B) it holds a majority of seats on the board of directors of the entity; or (C) it otherwise controls the actions, policies, or personnel decisions of the entity. A U.S. person may be subject to civil penalties if a foreign entity that it owns or controls engages in these prohibited transactions. The new regulations contain a safe harbor provision, giving U.S. owned or controlled foreign entities until March 8, 2013 to complete all transactions incident and necessary to winding down business with Iran, so long as the transactions do not involve a U.S. person or occur in the United States.