For everyone out there contracting with the State of California — here is a quick heads up. Remember way back in 2010 when Congress passed the Comprehensive Iran Sanctions, Accountability, and Divestment Act? Well, it turns out that California has decided to take advantage of the Divestment part. The Iran Contracting Act of 2010 requires the state to create a list of “persons” who “invest” in Iran. If a person makes it onto the list, they are prohibited from contracting or renewing a contract with California state and local governments. Contractors are encouraged to be on the lookout for communication from California indicating that the state plans on listing them. After all, the only evidence needed to list a person is “credible information available to the public.”
For more of the fine print, exceptions, and defenses check out this Reed Smith Client Alert.