Posted on 11/02/2012 by Mark A. Ivener, A Law Corporation
The Department of the Treasury’s Office of Foreign Assets Control (OFAC) published a final rule (PDF) in the Federal Register on October 22, 2012, amending its Iranian Transaction Regulations, including changing the name to the Iranian Transactions and Sanctions Regulations. The final rule includes new sections on prohibitions, definitions, interpretations, and licensing provisions.
Among other things, OFAC amended the General License so that pending E-2 or EB-5 applications are considered approved, and specific licenses are not required to transfer related funds from Iran. For such applications, OFAC will issue a Return Without Action letter that administratively closes out the application and references the amended General License. Those receiving funds should still check watch lists to ensure that the funds are not from banned entities.
OFAC also established a “favorable licensing regime” for licensing applications submitted by U.S. persons to engage in certain human rights, humanitarian, and democracy-related activities with respect to Iran.