Log in or register
Share on LinkedInShare on LinkedIn

ARTICLE · 28 JANUARY 2013

SEC Reporting For Certain 2012 Iran-Related Transactions

Morgan Lewis
Explore more from Morgan Lewis

On August 10, 2012, section 219 of the Iran Threat Reduction and Syria Human Rights Act of 2012 (the Act), 112 P.L. 158, added new subsection (r) to section 13 of the Securities Exchange Act of 1934 (Exchange Act), 15 U.S.C. § 78m.

United StatesInternational Law
Margaret Gatti
Margaret Gatti
Linda Griggs
Linda Griggs
Timothy Rolland
Timothy Rolland
Louis Rothberg
Louis Rothberg

Mandatory requirements cover actions of issuers' foreign subsidiaries and affiliates.

On August 10, 2012, section 219 of the Iran Threat Reduction and Syria Human Rights Act of 2012 (the Act), 112 P.L. 158, added new subsection (r) to section 13 of the Securities Exchange Act of 1934 (Exchange Act), 15 U.S.C. § 78m. This new subsection imposes mandatory reporting requirements for certain 2012 Iran-related transactions—even when such a transaction was not an Office of Foreign Assets Control (OFAC) violation at the time the transaction occurred.

Reporting Requirements

Section 219 of the Act requires that an "issuer" disclose certain information in either its annual or quarterly report filed with the Securities and Exchange Commission (SEC) if the issuer or any "affiliate" of the issuer (as defined for purposes of the Exchange Act and Rule 12b-2) has knowingly conducted or engaged in any activity that includes, but is not strictly limited to, the following:

We operate a free-to-view policy, asking only that you register in order to read all of our content. Please login or register to view the rest of this article.

Register for freeORLog in

Related Articles

Legal Intelligence Newsletters: sign up for the latest legal and regulatory news on your chosen topics

Read more about

See more popular content from

Article

Trump Administration Waives New Russia Sanctions And Tariffs Under Graham Act

President Trump issued an executive order implementing the Graham Act, which establishes substantial new tariffs on Russian goods and countries purchasing Russian energy, but simultaneously waives their application. The order creates a monitoring framework that leaves open the possibility of future enforcement while maintaining existing Russia sanctions regimes.
GlobalInternational Law
Herbert Smith Freehills Kramer LLP
Herbert Smith Freehills Kramer LLP
Article

U.S.-China Trade Truce Extended Two Months: BIS Affiliates Rule Suspension Follows

The U.S.-China trade truce has been extended through January 10, 2027, pushing back the effective date of the Bureau of Industry and Security's Affiliates Rule. While the suspension delays immediate compliance obligations, the rule remains in place and companies should use this additional time to prepare their compliance programs before the suspension potentially expires.
GlobalInternational Law
Crowell & Moring LLP
Crowell & Moring LLP
Article

The Lindsey Graham Sanctions Act: What Businesses Need To Know About The New Tariffs

President Trump signed the Lindsey O. Graham Sanctioning Russia and Iran Act into law on September 18, 2026, establishing mandatory tariffs of up to 500% on Russian goods and up to 100% on goods from countries that continue to buy Russian energy. The Act targets major importers like China, India, and Turkey, with limited relief mechanisms including natural gas exceptions, presidential waivers, and a 270-day winddown period for entities divesting from Russian operations.
GlobalInternational Law
Crowell & Moring LLP
Crowell & Moring LLP
Article

Updates On Export Controls Impacting AI & Advanced Computing

The U.S. Department of Commerce's Bureau of Industry and Security issued guidance on May 31, 2026, clarifying licensing requirements for advanced computing items and AI technologies. The guidance maintains export restrictions for entities in certain countries while providing limited relief for data center operators, though questions remain about future regulatory direction. Companies must now strengthen their compliance programs and supply-chain due diligence as BIS continues to prioritize national security
GlobalInternational Law
Finnegan, Henderson, Farabow, Garrett & Dunner LLP
Finnegan, Henderson, Farabow, Garrett & Dunner LLP