OFAC Strategy for Iranian Affiliates

A decedent’s estate desired to transfer assets into the embargoed country of Iran. An in-depth analysis of the Code of Federal Regulations ensued, specifically the prohibition existing in section 560.204. After much diligence, an exception was found and a transaction structured to appropriately allow for transfer of assets within the legal confines of the Office of Foreign Assets Control (OFAC) and the Council on Foreign Relations (CFR).