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LICENSE No. IRAN-EO13902-2025-1370670-1
EXECUTIVE ORDER 13902: IMPOSING SANCTIONS WITH RESPECT TO ADDITIONAL SECTORS OF IRAN
LICENSE
(Issued under the authority of one or more of 22 U.S.C. § 8724, 50 U.S.C. §§ 1601-51, 1701-06, Executive Order 13902, and 31 C.F.R. Part 501.)
To: Ferrari & Associates
655 15th St., NW, Suite 420
Washington, DC 20004
ATTN: Erich C. Ferrari, Esq.
1. Based upon information received on March 10, 2025 and March 14, 2025, to the Office of Foreign Assets Control (the “Application”), the transactions described herein are hereby authorized.
2. This License is subject to the condition, among others, that the Licensee(s) comply with its terms and with all regulations, rulings, orders, and instructions issued under any of the authorities cited above.
3. This License expires on the earlier of...
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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...