Case No. IA-16692a

Date issued: Apr. 02 2013

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TURBOFAC Commentary (377 words)

Notes:

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,...