On September 30, 2021, the US Department of the Treasury’s Office of Foreign Assets Control published Frequently Asked Question 932 regarding donations and travel to Iran and, in particular, the Imam Reza Holy Shrine in Mashhad, Iran. FAQ 932 was released following a level four travel advisory issued by the US Department of State, urging US persons not to travel to Iran.
According to FAQ 932, travel-related transactions for US persons travelling to or from Iran, including religious pilgrimages to locations such as the Imam Reza Holy Shrine, are usually allowed as part of an exemption under the Iranian Transactions and Sanctions Regulations (ITSR), and usually include donations of food, clothing and medicine to the Imam Reza Holy Shrine. However, OFAC now advises US persons to use caution when planning activities related to the Imam Reza Holy Shrine.
On January 13, 2021 pursuant to Executive Order 13876, OFAC designated Astan Quds Razavi (AQR) and its subsidiary, the Holy Shrine Organization, for being owned or controlled by the Supreme Leader of Iran. According to OFAC, the Holy Shrine Organization, that oversees the Imam Reza Holy Shrine, is blocked pursuant to EO 13876 and OFAC’s 50 Percent Rule because the organization is owned 50 percent or more by the AQR. For this reason, OFAC advises US persons to use caution concerning activities with AQR or the Holy Shrine Organization, and encourages anyone interested in transactions or activities involving the Imam Reza Holy Shrine to contact OFAC’s Sanctions Compliance and Evaluation Division for additional guidance, or OFAC’s Licensing Division to request a specific license.