Tag: Exchange Act Section 13(r)

Russia’s treatment of Navalny could have implications for your disclosure obligations

You might recall that the Iran Threat Reduction and Syria Human Rights Act added Section 13(r) to the Exchange Act, which requires public reporting companies that knowingly engaged (directly or through affiliates) in certain transactions or dealings with Iran to report those transactions or dealings in their periodic reports and through separate filings with the SEC.  But some sections of the statute are not necessarily limited to Iran. In fact, following the imposition on Russia of sanctions by the State Department in March, those disclosure and filing requirements could apply to dealings with certain Russian agencies and persons.