• A Primer for New Iran-Related Disclosures: Correspondence by the SEC's Office of Global Security Risk
  • January 9, 2013 | Authors: Matthew B. Hanson; Dixie L. Johnson
  • Law Firm: Fried, Frank, Harris, Shriver & Jacobson LLP - Washington Office
  • 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 SEC filings, they may want to consider examples from published comment-letter correspondence triggered by the SEC's Office of Global Security Risk (OGSR). OGSR is an office within the Division of Corporation Finance. For nearly a decade, OGSR has been monitoring disclosures related to business activities involving U.S.-sanctioned countries, as well as prompting additional disclosures from issuers about those activities (or the lack thereof).