What You Need to Know About Iran OFAC License

Disclaimer: The following information regarding Iran-related OFAC matters is provided for general informational purposes only and does not constitute legal or tax advice. Reading this page or communicating with our office does not create an attorney-client relationship.
Iran OFAC Regulations & Legal Services-Understanding Iran OFAC Regulations
The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) administers and enforces economic and trade sanctions against targeted foreign countries and regimes, including Iran.
Under the Iranian Transactions and Sanctions Regulations (ITSR), 31 C.F.R. Part 560, U.S. persons are generally prohibited from directly or indirectly exporting, re-exporting, selling, or supplying goods, services, or technology to Iran without appropriate authorization.
“U.S. Persons” Generally Include:
- U.S. citizens
- U.S. lawful permanent residents (green card holders)
- Entities organized under U.S. law, including their foreign branches
Certain activities involving Iran may require either a specific OFAC license, reliance upon a general license, or qualification for a valid exemption under applicable regulations. Examples may include:
- Maintaining or closing Iranian bank accounts
- Receiving inheritances from Iran
- Receiving gifts from Iran
- International money transfers involving Iran
- Certain real estate or family-related financial transactions
Certain inherited or gifted property interests in Iran, including family residences, undeveloped land, or other non-commercial property retained for passive personal or family purposes, may not necessarily require liquidation or transfer. Nevertheless, U.S. persons should carefully evaluate potential OFAC, tax, FBAR, FATCA, and related reporting obligations.
Even where a transaction may qualify under a general OFAC authorization, separate U.S. tax and international reporting obligations may still apply, including potential FBAR, FATCA, Form 3520, or other international information reporting requirements.
For example, although receipt of a foreign inheritance may qualify under a general OFAC authorization, the transaction may nevertheless remain subject to U.S. tax reporting obligations.
Due to the complexity of OFAC regulations, as well as overlapping issues involving the Bank Secrecy Act (BSA), Anti-Money Laundering (AML) compliance, and international tax law, individuals are strongly encouraged to seek guidance from qualified legal and tax counsel before initiating related transactions.
Informational Resources
For additional background regarding OFAC regulations and related international tax matters, please refer to the following resources:
- OFAC Frequently Asked Questions and Answers (FAQ)
- What is OFAC Voluntary Self-Disclosure?
- Tax Implication of Money Transfer from Iran
- Taxation of Persian Americans Living in Iran
- OFAC Cryptocurrency Guidance Brochure
- OFAC Frequently Asked Questions on Cryptocurrency
Legal & Tax Services Related to Iran OFAC Matters
Zaher Fallahi, OFAC & International Tax Counsel
Zaher Fallahi provides legal and regulatory counsel involving Iran-related OFAC compliance matters and international tax reporting issues.
Services include:
- Assisting clients with Iran-related Specific OFAC License applications
- Advising regarding General Licenses and interpretive guidance
- Counseling regarding money transfers involving Iran in compliance with OFAC regulations
- Advising on Anti-Money Laundering (AML) and banking compliance considerations
- Advising on U.S. tax implications involving foreign gifts, inheritances, and transfers of foreign assets
- Developing strategic defense approaches relating to potential or alleged OFAC violations
- Consulting regarding cryptocurrency-related OFAC compliance and enforcement risks
Cryptocurrency & OFAC Compliance
OFAC has increasingly focused on digital assets and cryptocurrency transactions involving sanctioned jurisdictions and blocked persons.
Relevant guidance includes Crypto Related OFAC Matters
2021-10-15 Cryptocurrency and OFAC Sanctions Programs, what do the terms “digital currency,” “digital currency wallet,” “digital currency address,” and “virtual currency” mean? For more details click here:
OFAC Frequently Asked Questions of Cryptocurrency
OFAC Cryptocurrency Guidance Brochure
Professional Background
Zaher Fallahi, Attorney At Law, Certified Public Accountant, and Tax Lawyer serving clients in Los Angeles, Orange County, and internationally.
Practice areas include:
- International tax law
- IRS audits and tax controversy
- Cryptocurrency taxation
- FBAR & FATCA compliance
- Iran OFAC compliance and licensing matters
Contact Information
📞 Toll-Free: 1-877-687-7558
📞 Los Angeles: (310) 719-1040
📞 Orange County: (714) 546-4272
📧 Email: taxattorney@zfcpa.com
Professional Recognitions & Education:
Rated 10 of 10 by Avvo
TOP Tax Attorney Ranked by Coast Magazine
Harvard Law School–Executive Programs in Negotiation & Leadership
Massachusetts Institute of Technology (MIT)–Executive Certificate in Blockchain Technologies: Basis of Cryptocurrency
A relatively small percentage of U.S. attorneys are also Certified Public Accountants (CPAs), allowing for an integrated legal and tax approach to complex international matters.