OFAC Regulatory Provisions - 31 CFR § 560.543 - Sale of certain real and personal property in Iran and transfer of related funds to the United States.

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TURBOFAC Commentary (187 words)

Notes:

1) Consult the Research System for dozens of guidance letters dealing at least in part with the real property .

2) This GL was amended in November 2018, to add sales of personal property to its scope. Guidance letters issued prior to 2018 should be read with that in mind.

3) The guidance documents show OFAC wrestling with the fact that—given its strict interpretation of the prohibitions on "imports of services" as including things such as paying a person to maintain property already in Iran—there are many technical violations of the committed by persons moving to the U.S. without understanding the scope of the ITSR prohibitions they will be subject to once they become U.S. persons. Iranian-Americans with relatives and property in Iran also find themselves in technical violation of prohibitions related to real and personal property. OFAC paired the harshness of the scope of the ITSR’s prohibitions with a history of never—at least not as of 2006 up through 2019—enforcing the ITSR for unintentional violations involving the personal and/or real property of U.S. persons.

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31 CFR § 560.543 - Sale of certain real and personal property in Iran and transfer of related funds to the United States.

TURBOFAC Commentary (187 words)