According to the BBC, Greek pianist Yanni (yes that Yanni) is scheduled to perform shows in Tehran and vacation destination Kish Island. This information comes courtesy of an official from Iran’s Ministry of Culture and Islamic guidance.

While it’s definitely a positive sign that Iranian authorities seem to be slightly lengthening their leash when it comes to the Western decadence that Yanni represents, there is a big piece missing from the BBC report. The author clearly forgot to consult with the other governmental body tasked with approving musical performances in Iran: The United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”).

While it’s true that OFAC does not quite have universal jurisdiction when it comes to the Tehran music scene, they certainly have the power to regulate the activities of U.S. persons in Iran. According to the BBC, as well as his Encyclopedia Britannica entry, Yanni is a naturalized U.S. citizen. §560.314 of the Iranian Transactions and Sanctions Regulations (“ITSR”) defines U.S. persons as “any United States citizen, permanent resident alien, entity organized under the laws of the United States or any jurisdiction within the United States (including foreign branches), or any person in the United States.” Simply put, Yanni better consider sanctions before he plays a single note in Iran.

Based on the information available, Iranian New Age fans might be disappointed. Performing a concert in Iran appears to be a very clear violation of 31 C.F.R. §560.204, which prohibits U.S. persons from exporting services to Iran. Anyone who has ever heard the sweet sweet tones of Yanni’s keyboard would have to consider this a service.

While I assume Yanni does what he does purely for the love of the music, it is possible that he’s being compensated for these concerts, in which case there’s a good chance that he will be forced to engage in a prohibited transaction involving parties blocked pursuant to §560.211.

Following the issuance of Executive Order 13599, the property of all Iranian financial institutions was blocked, meaning that unless Yanni’s payment comes in a suitcase full of Rial, he would probably need to be paid through an Iranian financial institution. It is true that U.S. persons are allowed to receive funds transfers from Iranian financial institutions in certain circumstances. However, the underlying transaction must also be authorized and in this case I don’t believe it is permitted under any existing exemption or general license.

It may well be the case that Yanni is seeking or has already received a specific license from OFAC to perform for his adoring crowds in Iran. If, not he might want to be reminded of what has become something of a motto for those involved in the world of U.S. sanctions compliance: “In God We Trust, Everyone Else Better Check with OFAC.”

If Yanni (or any other aspiring American musician) is determined to take his talents to South Tehran, he would be advised to consult with an experience OFAC attorney beforehand. I do believe OFAC would at least provide substantial consideration to providing an OFAC license to Yanni, as it does not seem to be contrary to U.S. national security and foreign policy interests to make sure ordinary Iranian people have an opportunity to hear this: