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Case No. IA-2018-352602-1
[***]
[***]
5335 Wisconsin Avenue, NW, Suite 440
Washington, DC 20015
Dear [***]:
This responds to your request dated April 26, 2018 on behalf of your client, [***] the “Application”) to the Office of Foreign Assets Control (OFAC), for authorization to obtain records from Iran in order to receive [***] due to the death in Iran of [***]. Specifically, the application indicates that [***] needs to obtain an Iranian death certificate and possibly a coroner’s report, police report, or hospital records to establish the cause of [***] death. According to the Application, New York-based lawyers handling [***] estate have sought the assistance of [***] a U.S. lawyer based in Baltimore, Maryland, who is licensed to practice law in both Maryland and Iran, in obtaining these records.
The Iranian Transactions and Sanctions Regulations,...
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1) This guidance letter contains notable guidance concerning the scope of the standard legal services GL, 560.510 of the ITSR, and the informational materials exemption. As indicated in the letter, the facts involve a proceeding in the U.S. before the Social Security Administration, where there was a need to obtain information from Iran concerning a person’s death in Iran order to obtain payments in the U.S. The letter indicates that a U.S. law firm was handling the estate proceedings generally while a lawyer “who is licensed to practice law in both Maryland and Iran” was engaged to obtain the records for the SSA proceeding (i.e. “an Iranian death certificate and possibly a coroner’s report, police report, or hospital records to establish the cause of [decedent’s] death”). As notable background see...