OFAC Overhauls the Iran Sanctions Landscape

Author: Afshin Pishevar, Esq. Date: October 24, 2012

Many individuals residing in the United States who have pending files with the Office of Foreign Assets Control (OFAC) need not follow through with their applications as several General Licenses have been granted that directly affect their legal rights. Yesterday, OFAC overhauled the entire landscape of the Iranian Financial Sanctions regulations. OFAC has changed various aspects of Executive Order 13599 and National Defense Authorizations Act (NDAA). OFAC has posted the new regulations at: http://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pages/20121022_33.aspx. It is recommended that you talk to your lawyer about the implications of this forthwith.

Several new General Licenses have been issued and old ones withdrawn. One of the new General Licenses authorizes Iranians to engage in certain financial activities. Certain licenses authorize medical and humanitarian activities. Other financial transactions are authorized for US persons exporting certain U.S. immigration-related services to Iran. Of particular note is one General License that permits E2 and EB5 visa applicants to transfer of funds. Legal advice on the specifics of strict compliance is highly advisable.

This is for general information purposes only. Not to be relied upon as legal advice. For legal advice on compliance issues, fact-specific detailed consultation is highly recommended.