Fresenius Medical Care AG & CO. KGaA

Medical
FWB: FME
Germany
Fresenius

Fresenius Medical Care AG & Co. KGaA (a German company) noted in its disclosure that certain exceptions apply when transactions involve the sale of medical devices. Fresenius referenced “OFAC’s public guidance provides that sales of medical devices to Iran by non-U.S. companies are generally subject to humanitarian exceptions.” Fresenius’ disclosure was notable because it was a departure from most filings, which as a general rule did not reference OFAC guidance but rather simply asserted that certain actions are permissible under all applicable laws.