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You need to consult with an attorney specializing in cross-boarder business transactions with Ira. I suggest contacting large law firms. Regards.
The situation is particularly complex. There are strict regulations that have to be observed. This is something that needs to be solved with the hiring of a transnational attorney. Best
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OFAC penalties are very harsh. This would require a careful look at both your situation and the rules as to Iran. Using a bank complicates matters as well.
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Look for attorney in your area specializing in Export Compliance issues. The name is a misnomer because you are not exporting anything to Iran however the firms that specializing in export compliance are familiar with OFAC and other government regulations controlling transfer of funds from certain countries. My firm handles such transactions however it is best to find local help in these cases.
Generally, OFAC has general licenses (that cover a class of activities) and specific licenses (that require specific approval). By looking at the non-commercial family remittance, you are trying to fit under one of the two applicable general licenses OFAC issued last year after the Iran sanctions were amended. General licenses have very specific requirements. I would need a lot more information to make a conclusion, but it does not appear that this transaction would qualify.
I do agree with my colleagues that it is best to get an attorney who handles US sanctions law. Penalties for violating US sanctions are very high, which makes "do it yourself" risky in this body of law. Your attorney would gather all of the facts to see whether this fits under an OFAC general license or could help you apply for a specific license. My firm handles this type of work. Please feel free to call or email me, if you would like.
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