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[HOT] [Q] If an Iranian national's investment money comes from an Iranian bank, then any additional requirement?


According to another EB-5 practitioner, Boyd Campbell, "although Iranian Transaction Regulations do not require a U.S. business to get an OFAC license in order to accept Iranian citizens' investments from Iranian banks, but USCIS requires the license anyway, and OFAC has obligingly issued them, citing no authority to do so."

However, we heard that at least in one instance USCIS recently rejected an I-526 application whose money been deposited into a project's escrow account BEFORE OFAC license had been issued to the investor. This may or may not be a shift in USCIS policy towards Iranian applicants. This raises a question of whether under the current OFAC license application procedure and mechanism, an OFAC license can even be obtained BEFORE the funds gets deposited into an escrow account. Perhaps someone can enlighten us.