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Focus on Regulation

Tag Archives: Section 218

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

Expanded Iran sanctions will reach non-US subsidiaries

Section 218 of the “Iran Threat Reduction and Syria Human Rights Act of 2012,” which was signed by President Obama into law on August 10, 2012, significantly expands the scope of U.S. sanctions against Iran by extending the full range of restrictions to the activiteis of non-U.S. entities owned or controlled by U.S. persons (including U.S. companies).  This provision specifies that the President shall, “[n]ot