The staff stated in one of its comment letters that it noted the transaction from a news article.
The staff’s comment letter suggests that the SEC is taking an active approach to the reporting requirements of Section 13(r). This is consistent with the aggressive approach to enforcement of U.S. sanctions against Iran taken by the U.S. agencies (including the Treasury Department’s Office of Foreign Asset Control and the Department of State) that are tasked with the review and investigation of such information.