How to Avoid
Common Pitfalls
and Navigate through
a Successful
Iranian EB-5 Petition
by Marjan Kasra and Babak Hojjat
In 2014, Iranian EB-5 cases represented just
0.7 percent of the entire EB-5 pool, sitting at
8th place behind India1. While that may not
seem significant, Chinese retrogression issues
and talk of easement of existing sanctions mean
that this segment of the EB-5 market may be
of particular interest as an emerging pool of
investors. That being said, navigating through a
successful petition can be challenging for an EB-5
practitioner new to this portion of the market.
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Prior to October 22, 2012, a U.S. entity was obligated to acquire a specific Office of Foreign Asset Control license to legally
accept funds from an Iranian National. On that date, OFAC
issued an amended general license that allowed U.S. projects
to accept EB-5 and E-2 investment funds without having to
procure a specific license. This cut processing times for Iranian
cases by about 8 months (the average time to obtain specific
license in 2012). This general license, however, is by no means a
carte blanche for U.S. projects.
EB5 INVESTORS MAGAZINE