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Focus on Regulation

Tag Archives: ITRA

Narrowing of an exemption under Iran sanctions

On 6 February 2013, U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) issued guidance regarding the impact of section 504 of the Iran Threat Reduction and Syria Human Rights Act (ITRA).  As previously reported in our Iran-related client alerts and blog entries, ITRA was enacted on 10 August 2012 and imposed a number of

Expanded Iran Sanctions Now Apply to Foreign Subsidiaries of U.S. Companies

 On 9 October 2012, the President issued Executive Order 13628 implementing certain provisions of the Iran Threat Reduction and Syria Human Rights Act of 2012.  Among other things, the Executive Order effectively prohibits non-U.S. entities that are owned or controlled by U.S. persons (including foreign subsidiaries of U.S. companies) from knowingly taking virtually any action