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Case No. IA-2012-299450-1
Law Offices of Mike S. Manesh, PC
2049 Century Park East, Ste. 2680
Los Angeles, CA 90067
Attn: [ ]
Dear [ ]
This responds to your letter dated November 23, 2012 (the "Application"), submitted on behalf of [ ] to the Office of Foreign Assets Control ("OFAC"), requesting authorization to receive a transfer of funds involving funds originating from the sale of real property located in Iran and currently owned by her parents, and who are both Iranian citizens.
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...
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1) See "General Note on Remittances; Guidance Letters Concerning Personal Remittances (System Ed. Note)" for a summary of notable points common to the majority of the guidance letters dealing with the subject.
2) Read in conjunction with Case No. SY-2019-360387-1, discussing the relationship between the standard noncommercial remittance GL language and proceeds "derived" from the sale of real property. A U.S. person selling real property in Iran, or being directly involved in such sale, would ordinarily constitute the importation of Iranian origin services and therefore require a license (as of 2022 there is a general license for this, but there was no such license in 2013). Here, however, the fact that the property was "owned by [the U.S. person's] parents [] who [were] both Iranian citizens" apparently made it so the transfer of funds...