Case No. IA-2012-293570-1

Date issued: Dec. 19 2012

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TURBOFAC Commentary (291 words)

Notes:

1) The Iranian national at issue here appears to have set up a U.S. company as an investment vehicle for use in connection with an investor visa application. This activity is not evidently not within the scope of the immigration-related GL at 560.505 of the ITSR (560.505(3)(i) authorizes exportation of financial services in connection with E-2 visa applications “other than in connection with funds used in pursuit of an E-2 or EB-5 visa.” (See also Case No. IA-16692a).

In this case, the “ordinarily resident” determination mooted the “retroactive license” request, an exportation of services “to Iran” must involve a person in or ordinarily resident in Iran. General Note on the Immigration-related GLs in the ITSR and...