• URGENT: President Issues Executive Order Implementing Section 218 of the Iran Threat Reduction and Syria Human Rights Act of 2012 Eliminating Immediately the “Foreign Subsidiary Loophole” to U.S. Iran Sanctions
  • October 12, 2012 | Authors: Thomas E. Crocker; Kenneth G. Weigel
  • Law Firm: Alston & Bird LLP - Washington Office
  • On October 9, 2012, the President issued an Executive Order (http://www.whitehouse.gov/the-pressoffice/2012/10/09/executive-order-president-regarding-authorizing-implementation-certain-s) implementing a number of provisions under various Iran-related statutes, including Section 218 of the Iran Threat Reduction and Syria Human Rights Act of 2012 (ITRSHRA), which for the first time applies Office of Foreign Assets Control (OFAC) Iran sanctions to U.S.-controlled offshore subsidiaries. The language of Section 4 of the Executive Order, which gives effect to Section 218 of the ITRSHRA, is essentially identical to that of Section 218 and adds little in the way of clarification.