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Case No. IA-15055
John R. Floss, Esq.
Kameli Law Group
111 East Wacker Drive, Suite 555
Chicago, IL 60601
Dear Mr. Floss:
This responds to your letter of November 24. 2010. from the Kameli Law Group, to the Office of Foreign Assets Control ("OFAC"), on behalf of the Elgin Assisted Living EB-5 Fund, LLC (the "Elgin Fund"), for authorization under the Iranian Transactions Regulations, 31 C.F.R. Part 560 (the "ITR"), to export financial services to thirteen citizens of Iran (the "Clients"), who have applied for permanent residency in the United States through the EB-5 visa investor program. Enclosed please find License IA-15055, which authorizes the exportation of financial services to twelve Clients ordinarily resident in Iran. From information provided in your letter, we understand that one Client is not ordinarily resident in Iran: Siamak Riahi. In addition,...
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1) See pp. 48-51 of native PDF file. The context of the disclosure of the license and cover letter was a suit against JP Morgan, where JP Morgan held funds in escrow pending an EB-5 visa investor’s arrival in the U.S., but the license for the exportation of financial services in connection with the visa application was set to expire, so JP Morgan wanted to return the funds prior to the expiry of the license. The U.S. person investment fund and related persons handling the EB-5 visa investment and application sued to enjoin JP Morgan from returning the funds held in escrow, since that would have interfered with the visa application process. A 2012 amendment to the ITSR implemented an authorization for the exportation of financial services in connection with EB-5 investor visas, so the...