PRINT
Case No. IA-2012-293570-1
[ ]
Law Offices of Bita Hamidi
750 B Street, Suite
3300 San Diego, CA 92101
Dear [ ]:
This responds to your letter dated April 6, 2012 (the “Application”), to the Office of Foreign Assets Control (“OFAC”), on behalf of [ ] (the “Client”), a citizen of Canada, requesting a letter stating that no specific license was required, or in the alternative, the granting of a retroactive specific license under the Iranian Transactions Sanctions Regulations, 31 C.F.R. Part 560 (the “ITSR”), to Serenity AF, Inc. (“Serenity”), a corporation formed in California in September 2009, in connection with the Client’s October 2009 application for the E-2 visa investor program.
We understand from information provided in the Application that in 2009 the Client was ordinarily resident in Canada and that the...
Click the appropriate link below for access to this file.
Click the appropriate link below for access to this file.
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...