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From: The Licensing Division
Office of Foreign Assets Control
U.S. Department of the Treasury
1500 Pennsylvania Avenue, N.W.
Washington, D.C. 20220
To: [ ]
1605 Hidden Spring Dr.
Las Vegas, NV 89117
Subject: Fundraising and donating funds to support people in Iran
[Case No. IA-2023-1014660-1]
Date: June 6, 2023
COMMENT:
This is in response to your request dated January 2, 2023, and additional correspondence dated March 6, 2023, March 16, 2023, and March 17, 2023, for authorization to: establish a non-profit organization; fundraise in the United States funds in the amount of up to $5,000,000; donate the funds to groups in Iran for the benefit of the Iranian people, including women and orphaned children; donate shoes, canned food, sleeping bags, and warm blankets to...
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1) As of 7-4-23, this is the only guidance letter in the Research System in which OFAC confirms that (i) a U.S. person can, without authorization, establish an NGO for the specific purposes of engaging in sanctions-implicating activities, and (ii) that that the NGO GL applies to entities whose sole mission is to raise funds for ultimate transfer to Iran (albeit “for the benefit of the Iranian people”). Other letters in the Research System appear to confirm that the NGO GL applies to very small / new entities, but this one, dealing with a person writing about an entity that is not yet in existence, really drives the point home.
2) Letter confirms that Iran GL E reporting requirement does not kick in until the $500,000 funds transfer threshold would be reached, but it is still not...