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Case No. MUL-381
Brian W. Ducharme
President/Chief Executive Officer
MIT Federal Credit Union
700 Technology Square
Building NE48
Cambridge, MA 02139-3586
Dear Mr. Ducharme:
This is in response to the July 22, 2011, April 10, 2012, May 18, 2012, June 5, 2012, and August 1, 2012 letters (collectively, the “Application”), on behalf of the Massachusetts Institute of Technology Federal Credit Union (“MIT FCU”) to the Office of Foreign Assets Control (“OFAC”), requesting guidance on what authorization is needed to provide services to four individuals applying for private student loans, three of whom reside in Iran and Belarus, with the remaining citizen of a sanctioned country currently residing in the United States. Since you have identified Iran and Belarus, our response will focus on these programs.
OFAC administers a number...
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1) Compare Case No. IA-18450 (companion case concerning “transactions necessary to process student loan payments from an individual who now resides in Iran”. Here, the U.S. person applicant university asks about “what authorization is needed to provide services to four individuals applying for private student loans, three of whom reside in Iran and Belarus, with the remaining citizen of a sanctioned country currently residing in the United States.” For Belarus “transactions…would not be prohibited and no license would be required” where such individuals are not on the SDN List. For Iran, OFAC concludes that “[w]hile an Iranian person is located in the United States, his or her procurement of a student loan may be considered authorized under section 560.505 of the ITSR. This general license states that certain...