EB5 Investors Magazine Volume 4 Issue 1 | Page 99

DEVELOPERS • Document All Decisions and Reasoning - Ensure you know all the parties involved, their nationalities, and the legal limits of the transaction. Additionally, perform anti-corruption due diligence and document your diligence in writing for further protection. Looking Forward OFAC will continue to revise the Iran sanctions and remove certain entities from restricted parties lists as the political situation evolves. Continue to check in with your legal counsel for updates as the U.S.-Iranian relationship progresses. In the meantime, all parties should continue to fulfill OFAC requirements for Iranian investment and continue completing restricted party due diligence to maintain compliance in this changing environment. ★ Doreen Edelman is a shareholder and cochair of Baker Donelson’s Global Business Team. With 25 years of experience counseling companies on export compliance matters and global expansion, Edelman advises clients on their export and import compliance obligations, conducts internal audits and training, prepares voluntary disclosures, and assists companies with product classification and licensing applications. She works daily with the Office of Foreign Assets Control (OFAC) to help clients navigate the requirements for Iran, Cuba, and Russian trade as well as monitoring restricted transactions. 1.5% - 7.0%* EB-5 LOANS Immigration Agent ImmCapital.com (702) 889-2828 rbiegel@immcapital.com *depending on equity participation Andrew Bisbas is an associate in Baker Donelson’s Washington, D.C. office.  He works on matters regarding import and export compliance including import and export controls, economic sanctions, anti-bribery compliance, EB-5 immigration matters, CFIUS foreign investment issues, and Customs and Border Protection (CBP) regulations. He works with businesses to classify items for import and export and acquire licenses from the Department of Commerce’s Bureau of Industry and Security (BIS), the Department of State’s Directorate of Defense Trade Controls (DDTC), and the Department of the Treasury’s Office of Foreign Assets Controls (OFAC). Abbey Baker is an associate in Baker Donelson’s Washington, D.C. office and a member of the Firm’s Global Business Team where she focuses her practice on trade, assisting companies expanding their businesses and engaging in the global marketplace while also meeting U.S. and foreign regulatory requirements. Baker counsels clients on foreign business climates, regional industry opportunities and obstacles, foreign and domestic governmental obligations, OFAC sanctions, and transaction risks. WWW.EB5INVESTORS.COM 97