Iranian sanction regulations - U.S. companies may be responsible for actions of their foreign subsidiaries 

December 27: The Treasury Department’s Office of Foreign Assets Control published a final rule in the Federal Register amending the Iranian Transactions and Sanctions Regulations to implement section 218 of the Iran Threat Reduction and Syria Human Rights Act of 2012 and provisions of Executive Order 13622 of July 30, 2012, and Executive Order 13628 of October 9, 2012.

The amendments to the regulations [PDF 218 KB]—


  • Prohibit certain transactions by entities owned or controlled by a U.S. person and established or maintained outside the United States (i.e., foreign subsidiaries)
  • Provide for civil penalties to be imposed on a U.S. person if its foreign subsidiary violates this new prohibition, unless the U.S. person divests or terminates its business with the subsidiary by February 6, 2013, so that the U.S. person no longer owns or controls the subsidiary
  • Add two general licenses to the regulations
  • Amend several existing licenses to address activities by foreign subsidiaries
  • Expand the categories of persons whose property and interests in property are blocked


For more information, contact a professional with KPMG’s Trade & Customs practice:


Douglas Zuvich

(312) 665-1022


Andrew Siciliano

(631) 425-6057


John L. McLoughlin

(267) 256-2614


Todd R. Smith

(949) 885-5617


Luis A. Abad

(212) 954-3094


Amie Ahanchian

(202) 533-3247


Or your local KPMG Trade & Customs professional.




©2012 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative ("KPMG International"), a Swiss entity. All rights reserved.


The KPMG logo and name are trademarks of KPMG International.


KPMG International is a Swiss cooperative that serves as a coordinating entity for a network of independent member firms. KPMG International provides no audit or other client services. Such services are provided solely by member firms in their respective geographic areas. KPMG International and its member firms are legally distinct and separate entities. They are not and nothing contained herein shall be construed to place these entities in the relationship of parents, subsidiaries, agents, partners, or joint venturers. No member firm has any authority (actual, apparent, implied or otherwise) to obligate or bind KPMG International or any member firm in any manner whatsoever.


The information contained in herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation.


Direct comments, including requests for subscriptions, to us-kpmgwnt@kpmg.com.
For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at:

+ 1 202 533 4366

1801 K Street NW
Washington, DC 20006.

Subscribe

Current and future KPMG clients may subscribe to TaxNewsFlash email alerts.


Email your contact information.

Other TaxNewsFlash publications

TaxNewsFlash-Trade & Customs by year