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OFAC issued a new FAQ concerning travel and donation transactions related to the Imam Reza Holy Shrine in Mashhad, Iran.
According to the FAQ, transactions ordinarily incident to travel by U.S. persons are generally permitted under the Iranian Transactions and Sanctions Regulations, including transactions related to (i) religious pilgrimages, (ii) the purchase of goods and services for use during travel, and (iii) donations "intended to be used to alleviate human suffering." OFAC clarified that transactions involving blocked entities, including the Astan Quds Razavi and its subsidiary, The Holy Shrine Organization, which oversees the Imam Reza Holy Shrine may be prohibited. Astan Quds Razavi and its subsidiary was "added to OFAC's Specially Designated Nationals and Blocked Persons List on January 13, 2021 pursuant to Executive Order (E.O.) 13876 ("Sanctions With Respect to Iran") for being owned or controlled by the Supreme Leader of Iran."
OFAC encouraged individuals with questions about the permissibility of particular transactions involving the Imam Reza Holy Shrine to contact the agency's Sanctions Compliance and Evaluation Division.
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