Under Section 219 of the Iran Threat Reduction and Syria Human Rights Act of 2012, companies are required to disclose any transactions with people or entities sanctioned under programs relating to terrorism or the proliferation of weapons of mass destruction. That’s why Sony Corp. reported in an SEC filing on Thursday that $12.8M of goods it sold to dealers in Dubai were resold in Iran, including to groups that are under U.S. sanctions. Tech equipment including security cameras, medical instruments and broadcasting gear was resold, or planned to be resold, to Iran’s state broadcasting unit and to the information technology department of the Iranian Police, among others, Sony said in the filing. The company noted that it “maintains policies and procedures designed to ensure that its transactions with Iran and elsewhere have been conducted in accordance with applicable economic sanctions, laws and regulations and do not involve transactions likely to result in the imposition of sanctions or other penalties on Sony.” However, if any government engaged in the sanctions were to disagree, the impact of penalties or sanctions “could be material,” Sony said. Third-party transactions may be made in the future, but Sony said it intends to conduct any such sales in accordance with applicable law.

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