You are hereEB-5-related issues for Project Companies, EB-5 clients, Regional Centers and wanna-be Regional Centers / For Everyone Interested in EB-5 Program / [HOT] Office of Foreign Assets Control (OFAC) issues for EB-5 cases involving, Iran, Iranians & other countries

[HOT] Office of Foreign Assets Control (OFAC) issues for EB-5 cases involving, Iran, Iranians & other countries


Office of Foreign Assets Control (OFAC) within Treasury Department which administers a series of laws administering economic sanctions. The reason why it pertains to EB-5 Program is because Regional Center is a "U.S. Person".

At this point, Iran, Cuba, and Sudan are countries that will have OFAC issues because there are U.S. economic sanctions against these countries.

Basically, a license or permit has to be obtained in advance for the subject EB-5 investors to participate in a U.S. EB-5 project, and it can take as long as several months to obtain such license.

Therefore, if an EB-5 case (whether individual or regional center based) involves Iran, Iranian or any portion of your investment fund come from Iran, our office has to work with an attorney specializing in OFAC law and procedure to evaluate and facilitate obtaining a license or permit to handle the EB-5 case. Basically, EB-5 cases involving EB-5 investors with OFAC issues will cost more to handle properly.

However, we believe whether or not OFAC license is obtained, CSC examiners will be reviewing these cases very carefully, so that proper care must be taken to evidence lawful source requirements.

http://www.bis.doc.gov/policiesandre...tions/Iran.pdf

http://www.ustreas.gov/offices/enfor...ran/iran.shtml

Another good resource: 31 C.F.R. Section 560 and Appendix A to part 560