As such, he faces up to 20 years in prison, and millions of dollars in potential fines and restitution. In addition to the criminal charges for violating the International Emergency Economic Powers Act–the underlying legal authority of the Iranian Transactions Regulations (“ITR”)-this individual was also convicted on conspiracy and money laundering charges. In that case, an Iranian immigrant was convicted of federal criminal charges in New York for transferring money between the U.S. A recent court case where an Iranian who had immigrated to America has recently highlighted the consequences of such beliefs. The sad truth is that havaleh is not the answer to circumventing U.S. I hear this comment from individuals in the Iranian American community all the time. “The US cannot interfere with the transfer of money if it is sent using havaleh.” WRONG. If you would like more information about the contents of Erich’s article, call him at 20 or email. If you are impacted by any topic discussed in this article you should consult with an attorney who has expertise in OFAC. Nothing in this article should be construed as legal advice as every case is different. economic sanctions programs he publishes on related issues and blogs at. Erich is an internationally recognized expert in OFAC litigation and U.S. He kindly obliged with Just Say No, an informative and thoughtful article that we are happy to share with you. and a member of the Iranian American Bar Association-Washington, DC Chapter to tell us about the laws and regulations that govern these transactions. Just Say No: Prohibitions Against Havaleh Between the US and IranĪ Note from PAAIA: In response to several inquiries by our members about havaleh, we asked Eric Ferrari, a Partner in the Washington, DC office of McNabb Ferrari, P.C.
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