Today the President signed a new Executive Order (E.O.) “Authorizing the Implementation of Certain Sanctions Set Forth in the Iran Threat Reduction and Syria Human Rights Act of 2012 and Additional Sanctions with Respect to Iran.” OFAC is providing a list of frequently asked questions pertaining to section 4 of the new E.O., which prohibits foreign subsidiaries of United States persons from knowingly violating the Iranian Transactions Regulations, E.O. 13599, section 5 of E.O. 13622, or Section 12 of the new E.O., and provides for civil penalties on the U.S. parent company for any such violations.
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