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

This list describes the changes in the Iranian Transactions and Sanctions Regulations and how Iranians and the Iranian American community will be impacted by these changes. This list covers new general license authorizations and new prohibitions on funds transferring.

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 the U.S. Department of the Treasury’s Office of Foreign Assets Control (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.

2012-11-01 12:44:08

Source: http://www.niacouncil.org/site/News2?page=NewsArticle&id=8669