Section 219 of the iran threat reduction and syria human rights act of 2012 mandates additional disclosure requirements for usregistered issuers concerning certain iran related activities and, under a plain reading of the statute, certain activities with non iran related persons or entities listed on the us department of. Authorizing the implementation of certain sanctions set forth in the iran threat reduction and syria human rights act of 2012 and. The iran threat reduction act readers beware lexology. President trump maintains iran sanctions waivers, but. Section 219 of the iran threat reduction and syria human rights act of 2012 the threat reduction act requires secregistered issuers to disclose in periodic reports filed with the sec, among other things, if they or their affiliates knowingly conducted any transaction or dealing with a person or entity. Department of justice office of legislative affairs. New disclosure requirements under the iran threat reduction and syria human rights act of 2012. Full text copy of the iran threat reduction and syria human rights act of 2012, signed into law by president obama on august 10, 2012. Be it enacted by the senate and house of representatives of the united states of america in congress assembled, section 1. Iran threat reduction act sec disclosure requirements. The iran threat reduction and syria human rights act of 2012 itra itra is the third significant sanctions law passed by the us congress over the past two years, building upon the comprehensive iran sanctions, accountability, and divestment act in september 2010 cisada and the national defense authorization act in december 2011 ndaa. Section 219 of the iran threat reduction and syria human. United states enacts further sanctions on iran and syria. This act may be cited as the iran threat reduction and syria human rights act of 2012.
Iran threat reduction and syria human rights act of. Companies sanctioned under the iran sanctions act and the. By the authority vested in me as president by the constitution and the laws of the united states of america, including section 301 of title 3, united states code, i hereby order as follows. Following months of negotiations between and among the house, the senate, and the administration, both chambers of congress reached agreement on a reconciled bill2, which the house passed by a vote of 4216 on august 1, and the senate.
This letter presents the views ofthe department of justice on h. Section 219 of the iran threat reduction and syria human rights act of 2012 itra added a new subsection r to section of the securities exchange act of 1934, as amended the exchange act, requiring an issuer to disclose in its annual and quarterly reports whether it or. And given iran s history of threats, its dedicated progress in enriching uranium, its evident determination to hide its nuclear program from the world and its abysmal human rights record, the world should do everything possible to hinder it from obtaining. What are the new sec reporting requirements under section. New reporting requirements under the iran threat reduction. Section 219 of the iran threat reduction and syria human rights. Rights act of 2012 additional reporting requirements for. Authorizing the implementation of certain sanctions set forth in the iran threat reduction and syria human rights act of 2012 and additional sanctions with respect to iran open pdf 204 kb. On august 10, 2012, the president signed into law the iran threat reduction and syria human rights act of 2012, public law 112158 tra. Authorizing the implementation of certain sanctions set forth in the iran threat reduction and syria human rights act of 2012 and additional sanctions with respect to iran a presidential document by the executive office of the president on 10122012. Securities and exchange commission released compliance and disclosure interpretations the sec guidance relating to the new disclosure requirements set forth in the iran threat reduction and syria human rights act of 2012 itra. On august 10, 2012, the president signed into law the iran threat reduction and syria human rights act of 2012.
Expansion of multilateral sanctions regime with respect to iran sec. Iran threat reduction and syria human rights act of 2012 itra 180 days. Iran threat reduction and syria human rights act of 2012 title i. President obama signed into law on august 10, 2012 the iran threat reduction and syria human rights act of 2012 the act. Under the iran threat reduction and syria human rights act of 2012. On october 9, 2012, president obama signed an executive order 1 implementing key provisions of the recently enacted iran threat reduction and syria human rights act of 2012 the act. In august 2012, president obama signed into law the iran threat reduction and syria human rights act of 2012 the irt act. Iran threat reduction and syria human rights act of 2012 united states. One hundred twelfth congress of the united states of america. The iran and libya sanctions act of 1996 ilsa was a 1996 act of the united states congress that imposed economic sanctions on firms doing business with iran and libya.
Sec requirements under the iran threat reduction and syria. On august 10, 2012, president obama signed into law h. Title iexpansion of multilateral sanctions regime with respect to iran sec. Iran threat reduction and syria human rights act congress. The iran threat reduction and syria human rights act the act, the latest in an ever expanding arsenal of usbased longarm jurisdiction statutory instruments, was. Iran sanctions act disclosure is required if the issuer or any of its affiliates knowingly 2 engaged in any activity described in section 5a or b of the isa.
On august 10, 2012, the united states delivered its latest economic blow to iran by enacting the iran threat reduction and syria human rights act of 2012. At its top level, it divides the world of legislation into fifty topicallyorganized titles, and each title is further subdivided into any number of logical subtopics. Iran threat reduction and syria human rights act of 2012 imposes a new iranrelated sec disclosure requirement. We have several constitutional comments on this bill. Delegation of certain functions and authorities under the iran threat reduction and syria human rights act of 2012.
Public companies, however, may have new disclosure obligations as a consequence of the act. Trade law and supply chain news, insights, and commentary. Title iexpansion of multilateral sanctions regime with respect to iran. Iran threat reduction act actually enhances threat of war. President enacted the iran threat reduction and syria human rights act of 2012 p. Sanctions with respect to iran signed into law on august 10, 2012. The department of state is acting under the iran sanctions act, as amended by the iran threat reduction and syria human rights act of 2012 tra, and the tra. Under section r, any issuer of securities that is required to file quarterly or annual reports. What public companies need to know about broadened sanctions and new sec reporting requirements under the iran threat reduction and syria human rights act december 19, 2012 the iran threat reduction and syria human rights act the threat reduction act, enacted on august 10, 2012, imposes new liabilities on u. Hr 1905 the iran threat reduction act of 2011 department of. On august 10, 2012, president obama signed into law the iran threat reduction and syria human rights act of 2012 the act. The united states code is meant to be an organized, logical compilation of the laws passed by congress. Disclosure pursuant to section 219 of the iran threat reduction and syria human rights act. Iran threat reduction and syria human rights act treasury.
Iran threat reduction act actually enhances threat of war 11142011 01. Notice required by the iran threat reduction and syria. The iran threat reduction and syria human rights act of. An act to strengthen iran sanctions laws for the purpose of compelling iran to abandon its pursuit of nuclear weapons and other threatening activities, and for.
The iran threat reduction act is designed to clamp new and tougher sanctions on iran s energy sector, threatening the regimes existence if it refuses to halt its nuclear weapons program. The iran threat reduction act of 2011 itra, introduced by house foreign affairs committee chairwoman ileana roslehtinen rfl and ranking member howard berman dca, adds significant new sanctions to our diplomatic arsenal while there is. Federal register authorizing the implementation of. Home president trump maintains iran sanctions waivers, but issues ultimatum president trump maintains iran sanctions waivers, but issues ultimatum.
Congress approved new legislation, the iran threat reduction and syria. The iran threat reduction and syria human rights act of 2012 act, like its 2010 predecessor, the comprehensive iran sanctions, accountability, and divestment act of 2010 cisada, broadens the iran sanctions act of 1996 isa by requiring the president to take action against nonus firms involved directly or indirectly in specified transactions with iran. Be it enacted by the senate and house of representatives. Expansion of definitions under the iran sanctions act of 1996. Exchange act requires issuers to disclose iranrelated. The iranrelated provisions in the law provide for sanctions on activities related to iran s energy and financial sectors, proliferation of weapons of mass destruction, support for terrorism, and human rights abuses. Section 504 of the tra amends section 1245d4d of the national defense authorization act for fiscal year 2012, public law 11281 ndaa, which the president signed into law on december 31, 2011. Presidential memorandum delegation of certain functions. On september 20, 2004, the president signed an executive order to terminate the national emergency with respect to libya and to end ieepa based economic sanctions on libya. Statement in support of hr 1905, the iran threat reduction act.
Iran threat reduction and syria human rights act of 2012 imposes a new iran related sec disclosure requirement. Iran threat reduction and syria human rights act of 2012. Iran sanctions contained in the iran threat reduction and. August 15, 2012 introduction on august 1, 2012, the u. The term knowingly has the meaning given that term in section 14 of the iran sanctions act of 1996 public law 104172. 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. The recently iran threat reduction and syria human rights act of 2012enacted 1 the act strengthens existing sanctions on iran, especially those aimed at thirdcountry nationals engaging in business with iran, and includes measures relating to human rights abuses in iran and syria. Section 219 of the act amends section of the exchange act to add new subsection r, which requires an issuer that files exchange act periodic reports to provide disclosure in its periodic report if during the reporting period it or any of its affiliates. On august 10, president obama signed into law another expansion of us sanctions against iran and syria that, most significantly, makes us. The iran threat reduction act of 2011 itra, passed in the house on dec. Disclosure pursuant to section 219 of the iran threat.
This subtitle may be cited as the iran freedom and counterproliferation act of. As part of the tightening of sanctions against iran, in august 2012, president obama signed into law the iran threat reduction and syria human rights act of 2012 the act. The bill closes loopholes in energy and financial sanctions and. The iran threat reduction and syria human rights act of 2012. On august 10, 2012, president obama signed into law the iran threat reduction and syria human rights act of 2012 itrshra. Pdf as part of the tightening of sanctions against iran, in august 2012, president obama signed into law the iran threat reduction and syria human rights act of 2012 the act. Section 219 of the iran threat reduction and syria human rights act of 2012 itra1 added section r to the securities exchange act of 1934, as amended the exchange act. Section 219 disclosures under the iran threat reduction and syria human rights act of 2012 as of noon today, eight secregistered issuers have made disclosures of iran related activities pursuant to the new reporting requirements under section 219 of the iran threat reduction and syria human rights act of 2012 section 219. Public law 112 158 iran threat reduction and syria human. Subsection 32, section 103, and section 202 declaring the policy of the united states in foreign affairs. Iran remains the 23 foremost state sponsor of terrorism and is increasing 24 its ability to influence regional crises and conduct 25 terrorism.
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