A Primer For New Iran-Related Disclosures

Law360, New York (January 15, 2013, 12:40 PM EST) -- As companies, including foreign private issuers, evaluate the scope and level of detail that the recently enacted Iran Threat Reduction and Syria Human Rights Act of 2012 (ITRSHRA) requires in U.S. Securities and Exchange Commission filings,[1] they may want to consider examples from published comment-letter correspondence triggered by the SEC’s Office of Global Security Risk (OGSR). The OGSR is an office within the Division of Corporation Finance. For nearly a decade, the OGSR has been monitoring disclosures related to business activities involving U.S.-sanctioned countries, as well...
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