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Chicagoland Foreign Investment Group, LLC
c/o Kameli Law Group
111 East Wacker Drive, Suite 555
Chicago, IL 60601
Attn: [ ]
Dear Mr. Barnett:
This responds to your letters dated July 25, 2012 (collectively, the "Application"), to the Office of Foreign Assets Control ("OFAC"), on behalf of Chicagoland Foreign Investment Group, LLC; Aurora Assisted Living EB-5 Fund, LLC; Elgin Assisted Living EB-5 Fund, LLC; Wood Dale Assisted Living EB-5 Fund, LLC; Golden Assisted Living EB-5 Fund, LLC; Silver Assisted Living EB-5 Fund, LLC; Platinum Assisted Living EB-5 Fund, LLC; Wood Dale Assisted Living Expansion EB-5 Fund, LLC; Diamond Assisted Living EB-5 Fund, LLC; Bronze Assisted Living EB-5 Fund, LLC; and Ruby Assisted Living EB-5 Fund, LLC (collectively, "CFIG"), requesting authorization under the Iranian Transactions and Sanctions Regulations, 31 C.F.R. Part 560 (the "ITSR"), or written confirmation that no such authorization...
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Notes:
1) Guidance deals with a law firm involved in applying for EB-5 investor visas on behalf of Iranian clients, and involvement with the actual investment of the funds in the U.S.
OFAC distinguishes between two different services provided by a U.S. person in connection with an EB-5/E-2 visa application. Advice concerning eligibility requirements, for example, falls within the scope of the general license for the provision of legal services to persons ordinarily resident in Iran.
Activities related to the investment of the funds required to qualify for the visa, however, constitute the export of "financial services," and require specific...