The answer is more complicated than might be expected.
Is there a “policy gap” regarding U.S. sanctions targeting the IRGC and its designated agents or affiliates? Proposed legislation seems to think so, yet I am skeptical that this is the case.
If a U.S. person is interested in moving to Iran on a permanent basis, can that U.S. person open a bank account there without falling afoul of U.S. sanctions?
Reports indicate that the Trump administration is considering the promulgation of an Executive Order that would direct the Secretary of State to designate the Islamic Revolutionary Guard Corps (IRGC) – a branch of Iran’s armed forces – a Foreign Terrorist Organization...
Some are characterizing OFAC’s latest designations of Iran-related persons as evidence of a new aggressive posture by the Trump administration. But the facts may well tell a different story.