![]() person or was inherited from persons in Iran-the same transactions might nevertheless require one or more specific licenses if they involve, for example, sanctioned parties or other circumstances that would render a generally authorized transaction unlawful if engaged in without specific authorization. ![]() persons seeking to engage in generally authorized sales and related transactions pursuant to § 560.543 must nevertheless understand that while a real or personal property transaction might meet the criteria of the ISTR provision as amended- i.e., the property is “real” or “personal” and was acquired before becoming a U.S. Notwithstanding the expansion of the general authorization, U.S. Because OFAC previously received and approved “specific license applications related to the sale of personal property in Iran,” OFAC amended the general license conferred by § 560.543 to apply also to certain personal property. Prior to November 5, 2018, § 560.543’s general authorization pertained only to sales and “necessary and ordinarily incident” transactions in real property inherited from persons in Iran or acquired prior to the individual becoming a U.S. person” or (2) was “inherited from persons in Iran.” citizens and permanent residents “are authorized to engage in transactions necessary and ordinarily incident to the sale of real and personal property in Iran and to transfer the proceeds to the United States,” but only if the real and personal property was (1) “acquired before the individual became a U.S. Under amended Section 560.543 of the ISTR, individuals who are U.S. persons-as a practical matter, primarily Iranian-Americans-to sell certain “personal property” in Iran. Pursuant to a final rule issued by OFAC on Octoand effective as of November 5, 2018, an important Iranian Transactions and Sanctions Regulations ( ITSR) provision was expanded to allow U.S. ![]() persons needing to transact in certain real and personal property in Iran. sanctions were substantially ratcheted-up after the United States’ unilateral withdrawal from the Iran Nuclear Deal last year, OFAC took a more practical and permissive approach to U.S. Persons Are Generally Authorized to Sell Certain Personal Property in Iran and Transfer Sale Proceeds to the United States, But Due Diligence is Still Required
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