U.S. Presidential Order Marks Start of U.S. Sanctions Liability for Foreign Subsidiary Business With Iran, OFAC Provides Limited Guidance

On October 9, 2012, the U.S. president signed an Executive Order, “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,” (the “Order”).