Law360, New York (October 12, 2012, 1:35 PM EDT) -- In a development that should be heeded by any U.S. company with overseas operations, on Oct. 9, 2012, the Obama administration implemented key provisions of the Iran Threat Reduction and Syria Human Rights Act of 2012 ("ITRA"), Pub. L. No.  112-158 (Aug. 10, 2012). Of particular note is Section 218, which for the first time imposes sanctions liability on a U.S. company for any act by its foreign subsidiary that contravenes prohibitions against "U.S. person" dealings with Iran, regardless of whether any U.S. person actually participated in the conduct or even whether the U.S. parent had knowledge of it. The law thus greatly expands the extraterritorial reach of the Iran sanctions, while imposing what appears to be strict liability on the U.S. parent for the conduct of its subsidiary....