Top 5 Ways The New Iranian Transactions and Sanctions Regulations Will Impact Iranian Americans

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1. General License for Medicine and Basic Medical Supplies

One of the most important changes in the new Iranian Transactions and Sanctions Regulations (ITSR), is the addition of a general license for the exportation or reexportation of medicine and basic medical supplies to Iran. Previously, only food was covered by a general license. This means that U.S. companies wishing to sell certain medicines or certain basic medical supplies to Iran will not have to apply for a license from OFAC to do so. This, of course, does not allow any dealings with blocked parties designated pursuant to sanctions programs other than the ITSR.


2. Sale of Real Property in Iran

U.S. persons are now allowed to sell real property in Iran if the property was acquired before an individual becoming a U.S. person or inherited from a person in Iran. This authorization includes the hiring a real estate broker, attorney, or funds agent as part of the sales process. However, U.S. persons are prohibited from dealing directly with a saraafi or money service business to conduct any transfers, thus the transfer must be done by an agent in Iran or the engagement with the saraafi must be specifically licensed.


3. Student Loan Payments

United States depository institutions and private loan companies are authorized to engage in all transactions necessary to collect, accept, and process student loan payments from persons in Iran or ordinarily resident in Iran.


4. Noncommercial personal remittances

While noncommercial personal remittances are still authorized, there have been some changes as to how those transfers can be conducted. Remittances to Iran may no longer be sent by a U.S. person through a saraafi, hawala, or processed by any method other than through a U.S. depository institution or a United States registered broker or dealer in securities. However, covered funds may be physically carried by a U.S. person to or from Iran, as long its not done on behalf of another person.


5. Visa Requirements

U.S. persons are now authorized to conduct any transactions necessary in connection with an Iranian individual's application for a non-immigrant E-2 (treaty investor) visa application or an immigrant EB-5 (immigrant investor), including receipt of investment funds. It is important that any funds transferred to the United States be held in an escrow account until the visa is granted, as the regulations authorize the release of these funds in a lump sum. If funds are not held in an escrow account, there is a chance that the funds will be blocked once the visa is denied.

Additional Resources

The Iranian Transactions and Sanctions Practice Guide

FAQ on Iranian Transactions and Sanctions Regulations

The U.S. Department of the Treasury's Office of Foreign Assets Control

Ferrari & Associates

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