Final Rule On New Iranian Sanctions Published

On December 26, 2012 the Department of the Treasury's Office of Foreign Assets Control ("OFAC") published a final rule amending the Iranian Transactions and Sanctions Regulations, 31 C.F.R. part 560 (the "ITSR"), to implement section 218 of the Iran Threat Reduction and Syria Human Rights Act of 2012 ("TRA") and sections of Executive Order 13622 of July 30, 2012, and Executive Order 13628 of October 9, 2012. It may be found at 77 Fed. Reg. 75845 (December 26, 2012).

The ITSR final amendments prohibit entities owned or controlled by a United States person and established or maintained outside the United States ("foreign subsidiaries") 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 pursuant to this part if engaged in by a United States person or in the United States.