New Iranian Business Disclosures – Are you impacted?

In August of last year, the United States Congress passed H.R. 1905: Iran Threat Reduction and Syria Human Rights Act of 2012.  The stated purpose of the bill is…

To strengthen Iran sanctions laws for the purpose of compelling Iran to abandon its pursuit of nuclear weapons and other threatening activities, and for other purposes. (Full text of bill available here.)

iranOne specific area of note for US businesses is section 219, which requires disclosures to the SEC related to “sanctionable activities”.  Sanctionable activities are those in violation of the Iran Sanctions Act of 1996, the Comprehensive Iran Sanctions, Accountability and Divestment Act of 2010, several Executive Orders, and the Code of Federal Regulations.    The language of the bill requires disclosures if those activities occurred within the corporation or within any affiliate of the corporation.

Take a Closer Look and Reinforce Your Policies

The new disclosure requirements – in effect for all SEC reporting due after February 6, 2013 – are prompting companies to take a closer look at the activities of their affiliates – and many may choose to reinforce their internal policies on Iranian business activities as well as to require attestations or disclosures from their affiliates.

As with all new regulations, your legal and compliance teams should review and determine your obligations, including which organizations you would define as “affiliates” under section 219.  With that guidance in mind, consider taking the following steps:

  • Formalize and document internal policies based on your legal requirements under these regulations
  • Communicate your policies or position to affiliate organizations
  • Require attestations (or disclosures) from affiliate organizations via electronic forms

Need a place to manage those policies, attestations or disclosures?  Contact us.

This entry was posted in Industry News and tagged , by Chris Burd. Bookmark the permalink.

About Chris Burd

Chris is the Managing Director of the policyIQ group at RGP. She gets geeky about compliance and technology, and gets to spend every day working at the crossroads of the two. With policyIQ since 2005, Chris has worked with hundreds of policyIQ clients to implement technology and enhance their internal compliance environment. In the past few years, she's focused on enhancing policyIQ's offering as a Conflict Minerals and Anti-Corruption tool. In past lives, Chris worked as a system implementation consultant, a e-commerce specialist, a customer service call center manager, and - for one short but memorable summer during high school - a machine operator on midnight shift in a plastics factory. In her free time, she spoils her nieces, volunteers at her local food bank, and spends more time than she should taking photos of her cats. She would like to be a rock star when she grows up.

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