SEC Filings Under The New Iran Disclosure Obligations Have Reached A Steady Drumbeat
In the last several weeks, over sixty issuers have disclosed activities involving Iran or certain so-called bad actors, as mandated by Section 219 of the Iran Threat Reduction and Syria Human Rights Act of 2012 (“ITRA”), in a quarterly or annual report filed with the Securities and Exchange Commission. Enacted last August as part of the U.S. government’s increasingly expansive Iran sanctions program, the new disclosure requirement, included as a new Section 13(r) to the Exchange Act, applies to all SEC filings on Forms 10-K or 10-Q, as well as on Form 20-F, required to be made after February 6, 2013. It appears from these recent disclosures that multinational issuers with worldwide operations across multiple affiliates have undertaken significant time and expense in collecting data about potentially reportable activities that issuers have never before been required to publicly disclose — including transactions with customers, vendors, and other business partners.