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The importation and exportation of most goods and services to and from Iran are not permitted unless OFAC has issued a license allowing that activity. There are two types of licenses issued by OFAC: general and specific licenses.
General Licenses: General licenses permit transactions that the U.S. government believes will not violate U.S. sanctions policy goals. A general license states that all U.S. persons can engage in the specific activity and/or transactions outlined in the general license. Examples of activities that are allowed under general licenses are sending family money, sending noncommercial personal remittances to or from Iran, and selling real or personal property acquired as an inheritance or before one became a U.S. person. If a general license exists for the desired activity, one does not need to apply for a specific license.
Specific Licenses: A specific license is required for something that an individual or entity wants to engage in that is not allowed under sanctions regulations, and there is no general license that allows that activity. In that case, that individual or entity would need to apply for a specific license, asking for personal and specific authorization from the government to engage in that specific activity. Applications for obtaining a specific license are usually sent as a letter to the government via their online portal. A common mistake that is made is when individuals apply for a specific license when OFAC has already issued a general license permitting that activity. If a general license exists, the government will not issue a specific license in the individual’s name. Instead, they will just return the application, taking no action on it. They will send a one-page "return without action" letter that has no legal significance and cannot serve as a license. If you thought you were granted a specific license but are not sure, send us a copy via our mobile app or email (info@yazdanyarlaw.com), and we will be happy to take a look at it for you and let you know if the document is a specific or general license.
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