Case No. SDGT-2014-308512-1
Hal Eren, Esq.
The Eren Law Firm
2555 Pennsylvania Avenue NW, Suite 1005
Washington, DC 20037
Dear Mr. Eren:
This responds to your request dated February 19, 2014 (the “Application”), to the Office of Foreign Assets Control (“OFAC”), requesting authorization for The Eren Law Firm to receive payment of legal fees and reimbursement of expenses incurred from the provision of legal services authorized by section 594.506 of the Global Terrorism Sanctions Regulations (the “GTSR”), to your client, Hamid Reza Malakotipour, who is designated pursuant to Executive Order 13224 and blocked pursuant to the GTSR. You state in your Application that the services under section 594.506 of the GTSR that you intend to provide are to advise and represent your client in connection with a petition to OFAC for the rescission of your client’s designation...
1) At the time the request for guidance was made, section 594.517 of the GTSR clearly authorize the receipt of payment of legal fees and reimbursement of expenses incurred from the provision of legal services authorized by section 594.506 of the GTSR. It is possible that the U.S. person law firm's bank required something in writing from OFAC confirming the same before it processed a payment from an SDN. It is also possible that the U.S. paerson law firm was unclear as to whether the legal services GL authorized the provision of advice to an SDN "on compliance with the GTSR and the Iranian Transactions and Sanctions Regulations". Here, OFAC confirms that such advice may qualify under the legal services GL. Compare Case No. IA-2012-299845-1, clearly stating that...