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Case No. IA-16692a
Farhad R. Alavi, Esq.
BHFA Law Group, PLLC
5335 Wisconsin Ave., NW
Suite 440
Washington, DC 20015
Dear Mr. Alavi:
This is in response to your July 3, 2012 correspondence requesting an amendment to License No. IA-16692 to the Office of Foreign Assets Control ("OFAC") which indicates that the Azadeh LLC was [
].
The Iranian Transactions and Sanctions Regulations, 31 C.F.R. Part 560 (the "ITSR"), generally prohibit the importation into the United States of any goods or services of Iranian origin or owned or controlled by the Government of Iran. ITSR, § 560.201. The ITSR also generally prohibit the exportation, reexportation, sale, or supply of any goods, technology, or services, directly or indirectly, from the United States or...
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1) With regard to the statement "the use of a U.S.-based limited liability company for Iranians to transfer funds from Iran into the United States is prohibited," the statement appears to be a standalone interpretation of 560.550 that would have applied even if there were no ITSR issues involved in the actual establishment of the LLC.
OFAC does not provide the rationale for limiting 560.550 in this manner. It is possible that the agency would consider the involvement of a corporate entity as recipient of the transfer to necessarily take the transaction of the scope of "noncommercial," even if the company exists for the sole purpose of transferring the owner's personal funds from Iran to the U.S. Query whether the remittance GLs always require funds to come from personal, rather than corporate accounts,...