SEC Disclosure Obligations under the Iran Threat Reduction and Syria Human Rights Act of 2012

Summary

This practice note discusses disclosure obligations set out by the SEC under the Iran Threat Reduction and Syria Human Rights Act of 2012 (ITRSHRA). ITRSHRA's ultimate goal is Iran's cessation of its nuclear weapons program and other terrorist initiatives. ITRSHRA imposes new disclosure requirements on domestic and foreign companies that file annual and quarterly reports with the Securities and Exchange Commission (SEC). It requires a public company to disclose if it, or any of its affiliates, has knowingly engaged in certain activities involving Iran. Attorneys advising issuers with reporting obligations under Section 13(a) should have an understanding of the new disclosure requirements and the best practices to ensure compliance.