Case No. IA-2012-297076-1

Date issued: Apr. 18 2012

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TURBOFAC Commentary (1447 words)

Notes:

1) BACKGROUND

This guidance letter is similar to others in the Research System that involve activities of person ordinarily resident in Iran that has an EB-5 investor visa application pending as of the time of the request. As is the case with this one, those letters (see e.g. Case No. IA-2012-299441-1) make clear that such persons are not subject to the prohibitions of the ITSR until they actually become U.S. persons, and an EB-5 visa applicant does not actually become a U.S. person until s/he actually relocates to the United States. (“[U]pon receipt of a U.S. visa and entry into the United States, the Client would be subject to the prohibitions in the ITSR and would require a specific license from OFAC to continue to engage in active commercial activities within...