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Focus on Regulation

Tag Archives: ITRSHRA

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