EB5 Investors Magazine | Page 54

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. 52 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