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Case No. IA-15582
Golden Assisted Living EB-5 Fund, LLC
Chicagoland Foreign Investment Group, LLC
c/o Lotus Law Group
800 Fifth Avenue, Suite 4100
Seattle, Washington 98104
Attn: Anthony B. Ravani, Esq.
Dear Mr. Ravani:
This responds to your letter of February 12. 2011, (the "Application"), to the Office of Foreign Assets Control ("OFAC"), on behalf of the Golden Assisted Living EB-5 Fund, LLC (“GALEF") and Chicagoland Foreign Investment Group, LLC ("CFIG"), seeking authorization under the Iranian Transactions Regulations, 31 C.F.R. Part 560 (the "ITR"), to export services to Mr. Seyed Abdolhossein Sabet and his spouse and child, all of whom are citizens of Iran, in connection with Mr. Sabel's application for permanent residency in the United States under the EB-5 visa investor program. We understand from information provided in the Application that Mr. Sabet and...
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1) See pp. 52-56 of native PDF file. As discussed in the comments to Case No. IA-15877, there are several guidance letters that contain statements similar to the ones found in the last substantive paragraph of this license. This is the only one that specifies that a U.S. person holder of a pre-existing investment in an Iranian company must be a "non-majority" shareholder for there to be any chance of a continued investment not coming within the scope of any of the ITSR’s prohibitions.
Civil Enforcement Information - Clearstream Banking, S.A. and some other enforcement actions construe "custodial services" (i.e. the holding of securities for the indirect benefit of a person in Iran) as a "service" within the scope of the ITSR. Query: does the possibility...