On Friday, August 10, the President signed the "Iran Threat Reduction and Syria Human Rights Act" (H.R. 1905) into law. As described in Drinker Biddle's client alert last week, the new law will significantly strengthen existing Iran sanctions and will add to disclosure of any dealings with Iran in public company annual and quarterly '34 Act filings. Most notably, the bill prohibits certain transactions by foreign businesses that are owned or controlled by a U.S. parent company.
Under the new law, U.S. companies that own or control foreign entities must ensure that these foreign companies cease all transactions with the Iranian Government or parties subject to the jurisdiction of the Iranian Government by October 9, 2012, or divest themselves of such foreign businesses by February 6, 2013.
Also effective February 6, 2013, the new law requires '34 Act reporting companies to disclose information about their Iran related activities in their annual and quarterly '34 Act reports.
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