Continued from page 53
As noted at a stakeholder’s meeting conducted at the
California Service Center, OFAC has expressed the view that
involvement of SDN bank terminates at the juncture where the
funds “rest” in a non-SDN bank, noting that at said juncture,
the SDN bank no longer has an interest in the funds. However,
USCIS utilizes a more stringent standard and has denied EB-5
cases where funds traveled through an SDN bank. Therefore,
USCIS appears to take a more broad approach in determining
the legality of funds from Iran.
For example, when the pool of funds involves sale of a real
estate, which at some point was secured by a bank on the
SDN list (which is not at all uncommon), is USCIS going to
challenge “legality