Sanctions are penalties imposed by one nation on another. The U.S. Office of Foreign Assets Control ("OFAC") enforces U.S. sanctions. Since the 1980s, the U.S. government has imposed sanctions on the Islamic Republic of Iran. Under the Obama administration, the depth and breadth of the sanctions have expanded significantly, the latest in February 2012. Civil penalties for violations include fines up to $250,000 or twice the value of the involved transaction. Criminal penalties include up to 20 years in prison.

Anyone physically in the United States must comply with the sanctions, regardless of citizenship status. All U.S. citizens must comply with the sanctions, regardless of their place of residence, including Iran. Individuals may not attempt to evade the sanctions through a third-party. The sanctions do not only affect business transactions, but also directly impact Muslims traveling to Iran to visit family, holy sites or study.

The sanctions prohibit working or providing services in Iran without an OFAC license. To apply for an OFAC license, visit the OFAC website. Any investment in Iran is now illegal. The term investment is interpreted broadly. Illegal investments include buying property in Iran for investment or personal use and opening a bank account. One who currently possesses property or a bank account in Iran should contact an attorney for guidance.

The sanctions prohibit importing goods (i.e. carpets) from Iran or exporting goods to Iran without an OFAC license. The only exceptions are informational materials, travel related costs, personal living expenses and payment for food, clothing and medicine to relieve human suffering. Bringing gifts to or from Iran violates the sanctions if the gifts are valued, in total, at more than $100.

Almost all money transfers between the U.S. and Iran violate the sanctions. One practical exception is that one may send/receive money from family for non-commercial use. These transfers may not be conducted through a prohibited medium, such as an Iranian bank or hawala. One option to consider is transferring money from a U.S. bank to a third-country bank who would then legally transfer the money to family. Consult an attorney prior to making any money transfers.

Sending/receiving phone calls, texts and emails to/from Iran is legal. Transactions ordinarily incident to travel to/from Iran is also legal, as is traveling and booking flights on Iran Air. A Customs Agent may seize any item he/she believes reasonably violates the sanctions. If your property is seized, request a receipt and contact an attorney. Iranian sanctions are complicated and changing rapidly. One should consult an attorney familiar with Iranian sanctions to ensure compliance.

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