As global companies assess the implications of Iran sanctions relief announced on January 16, 2016, they should remain mindful that their Iran-related activities will actually increase the complexity of their compliance obligations in several areas, including socalled ‘‘Section 219’’ Securities and Exchange Commission (SEC) disclosure requirements under the Iran Threat Reduction Act. In fact, requirements to disclose certain categories of Iran-related operations will remain unaffected by Iran sanctions relief, while continuing to cover many of the Iran-related business activities specifically contemplated by sanctions relief.
Originally published in Bloomberg BNA's Securities Regulation & Law Report, 48 SRLR 168 - January 25, 2016.
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