Just ahead of this week’s meeting in Baghdad between Tehran and other nations concerning Iran’s controversial nuclear program, the U.S. Senate passed an Iran sanctions bill by a unanimous voice vote. This bill is the Senate counterpart to the “Iran Threat Reduction Act of 2011” (H.R. 1905), which passed the House in December. The two bills will have to be reconciled before reaching President Obama’s desk for final passage. Among its many provisions, the Senate bill would impose high civil penalties on U.S. parent companies for any activities of their foreign subsidiaries that, if they had been undertaken by a U.S. person or in the United States, would violate U.S. sanctions law. The bill adopts a broad definition of “subsidiary” so that those foreign entities that are either owned or controlled by U.S. interests will be subject to the legislation. Click here to read our Client Alert, written by Leigh T. Hansson, Matthew J. Thomas, Jeffrey Orenstein & Michael A. Grant.