On July 1, 2010, President Obama signed into law the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 (Pub. L. No. 111-195) (the “Iran Act”), which seeks to increase the economic pressures placed on the Iranian government. As discussed in more detail below, the Iran Act is similar, but not identical to, the earlier Sudan Accountability and Divestment Act of 2007 (the “Sudan Act”), and includes several important amendments to the Sudan Act.
Among other provisions, Title II of the Iran Act encourages the divestment of state and local monies from Iran in a number of ways, some of which have important implications for public plan trustees and public officials. The attached memorandum provides an overview of these implications. A copy of the Iran Act is enclosed for your reference.