LICENSE No. IRAN-EO13902-2025-1370670-1, 2, 3

Date issued: May. 15 2025

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TURBOFAC Commentary (791 words)

Notes:

1) On April 22, 2025, OFAC added Meisam Emamjomeh (“UAE-based British and Iranian national”), Pearl Petrochemical FZE (UAE entity) and the vessel Tinos I to the SDN List (see https://ofac.treasury.gov/recent-actions/20250422) pursuant to EO 13902 (for “for operating in the petroleum sector of the Iranian economy”). Concurrent with the date of the designations, OFAC issued LICENSE No. IRAN-EO13902-2025-1370670-1 to counsel for Pearl Petrochemical FZE (“Pearl”) (p. 1, PDF). According to an email sent by OFAC to the licensee at the time license was issued (p. 94, PDF), the license was required EO 13902 “is not incorporated into” any OFAC regulations (that would contain a standard legal services GL), such that the ongoing provision of legal services to Pearl required a specific license. Compare LICENSE No. IA-2012-298595-1/a>. We...