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SEC Iran Disclosure Requirements Proving ‘Difficult’ for Foreign Banks

By Brian Monroe

Foreign financial institutions and other non-U.S. companies newly tasked with disclosing when their affiliates deal with Iranian government officials are finding the requirements onerous, according to compliance officers and consultants. Under the Iran Threat Reduction and Syria Human Rights Act of 2012, passed in August, companies obligated to report to the U.S. Securities and Exchange Commission (SEC) must disclose in public regulatory filings whether any of their affiliates knowingly conducted transactions for, or otherwise dealt with, entities acting on behalf of the Iranian government. The requirements, which took effect last week, have already posed significant challenges for foreign banks, according...

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