Case No. IA-2016-330121-1
Saeid B. Amini, Esq.
The Law Offices of Saeid B. Amini
730 24th Street, NW
Suite One
Washington, DC 20037
Dear Mr. Amini:
This responds to your request dated May 17, 2016 (the "Application") to the Office of Foreign Assets Control (OFAC) for a license authorizing you to represent Saeed (Allan) Talebi and Satco Incorporated in the United States, by providing legal services regarding the return of funds from a transaction with Gas Turbine Controls Corporation, and the transfer of the returned funds less legal fees to Saeed Talebi and Satco in Iran.
The Iranian Transactions and Sanctions Regulations, 31 C.F.R. Part 560 (ITSR), generally prohibit the exportation, reexportation, sale, or supply, directly or indirectly, from the United States or by a United States person, wherever located, of any goods, technology,...
1) Background
The litigation to which this guidance letter relates (see PDF file) involves an Iranian entity plaintiff suing a U.S. person in a U.S. court over the U.S. person’s alleged failure to return money to the Iranian plaintiff that was connected to the underlying transaction that was in violation of the ITSR. Indeed, the suit was filed only after the natural person Iranian owner of the plaintiff Iranian entity was imprisoned for a violation of the ITSR connected to the transaction at issue in the civil case (see Government's sentencing memorandum at p. 22 et seq. of the native PDF file). Specifically, the suit seeks restitution of a $390,000 "advance payment" made by plaintiffs to the U.S. person defendant company, which defendants evidently did not deny receiving and refusing to return.
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