On October 9, 2012, President Obama issued an Executive Order authorizing the implementation of certain sanctions set forth in the Iran Threat Reduction and Syria Human Rights Act of 2012, including the requirements of Sections 204, 402 and 403. The Executive Order also authorizes additional sanctions with respect to Iran. Specifically, it prohibits foreign subsidiaries of United States persons from knowingly violating the Iranian Transactions Regulations, Executive Order 13599, section 5 of Executive Order 13622, or Section 12 of the Order and provides for civil penalties on the U.S. parent company if such violations occur. Penalties for such violations do not apply if the United States person that owns or controls the entity divests or terminates its business with the entity not later than February 6, 2013.
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