OFAC FAQ (Current) # 932 - Iran Sanctions

Date issued: Sep. 30 2021

You've hit a wall. Sign in if you have an account, or learn more about TURBOFAC and subscription options.
TURBOFAC is a module of the compliance platform OverRuled. To learn more about OverRuled, visit www.overruled.com.

TURBOFAC Commentary (3938 words)

Notes:

1) BACKGROUND

While ostensibly about the Imam Reza Holy Shrine and the entity that “oversees” it, this FAQ appears to contain some highly significant statements concerning the scope and operation of the travel exemption and the basic blocking prohibition.

According to OFAC (in the designation notice blocking Astan Quds Razavi (or "AQR")), Astan Quds Razavi is an Iranian “bonyad,” which OFAC characterizes as “opaque, quasi-official organizations generally controlled by current and former government officials and clerics that report directly to the Supreme Leader.” (https://home.treasury.gov/news/press-releases/sm1234). OFAC says that Astan Quds Razavi specifically “is ostensibly a charitable organization tasked with overseeing the operations of the Imam Reza shrine in Mashhad, Iran[, but] In reality, under the direct supervision of the Supreme Leader, Astan Quds Razavi has acquired vast economic holdings in construction, agriculture, energy, telecommunications, and financial services.”

See also "Inside Iran's...