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Case No. IA-2013-304698
[ ]
Attorney At law
1503 South Coast Drive. Suite 207
Costa Mesa, CA 92626
Dear [ ]
This is in response to your correspondence dated August 19, 2013 (the "Application"), on behalf of your client, [ ] to the Office of Foreign Assets Control ("OFAC"). Specifically, your client is seeking authorization to retain an attorney in Iran to litigate and recover real property taken by imminent* domain, and to transfer the proceeds of the sale from Iran to the United States.
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...
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1) Notable amalgamation of three distinct general licenses. 560.510 (pertaining to legal disputes) allows for the engagement of Iranian lawyers and other transactions needed to carry out a legal proceeding in Iran (imports of services (560.201)). 560.543 permits services related to the sale of the property once recovered, and 560.516 allows for the transfer of the proceeds from the sale to the U.S. as ordinarily incident to the sale of the property.
2) Note the interpretation of 560.510(c)(1) as interpreting "abroad" to include Iran itself. This is not totally evident from a reading of 560.510(c)(1) in conjunction with (c)(2).
3) The GOI was blocked as of the time this letter was written.
560.510(c), which was in place long before the ITSR...