Law360, New York (September 4, 2012, 4:16 PM EDT) -- President Obama signed into law on Aug. 10, 2012, the Iran Threat Reduction and Syria Human Rights Act of 2012 (the Act). The act, like the Comprehensive Iran Sanctions, Accountability and Divestment Act of 2010 (CISADA), broadens the sanctions programs put forth by the Iran Sanctions Act of 1996 (ISA) and otherwise significantly expands the extraterritorial impact of U.S. sanctions.
Key provisions of the act include:
Liability of U.S. Firms for Activities of Their Non-U.S. Subsidiaries
The act requires the imposition of civil penalties on U.S....