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O’Melveny’s Lichtenbaum Quoted in Wall Street Journal on Iran Sanctions

February 20, 2013

O’Melveny & Myers LLP’s Greta Lichtenbaum was quoted in the Wall Street Journal’s February 20, 2013, blog “Iran Sanctions Law Reporting Causing Confusion.” The article discusses recently enacted provisions that require companies to disclose their contracts, deals, and contacts within Iran. Lichtenbaum called the provisions open to interpretation in the article and she predicted they will affect non-US companies--more than US corporations--since they have more interaction with Iranian companies. “We are working together with many clients to make sure they are comfortable that not only are they reporting accurately if they have something to report, but also that they are doing the right kind of diligence on their affiliates to make sure they can properly reach a conclusion that they don’t have anything to report,” Lichtenbaum said in the article.

Lichtenbaum also said the SEC is very thoughtfully reviewing the reporting law for guidance going forward. “After this first round of disclosures are made, perhaps they will be in a better position about what people should be doing in the future,” she said in the article. “It’s hard for an agency when new statutory requirements come into play. They have to exercise care and look at the legislative intent, but they also don’t want to create unnecessary burdens for public companies.”