Skip to content

Compliance Building

Doug Cornelius on compliance for private equity real estate

Menu
  • Home
  • About
    • About
    • About Doug
    • About This Website
    • Why I Blog
    • Speaking Engagements
    • Contact
    • Publications
  • Archives
    • Topic Archive
    • Book Reviews
    • Most Popular
  • Subscribe
  • Disclaimers
    • Disclaimers
    • Policies and Procedures
    • Use of Site Content
    • Comments
    • FTC Disclosure
Menu

Real Estate and OFAC Compliance

Posted on November 23, 2009 by Doug Cornelius
Print Friendly, PDF & Email

650 fifth avene

The tale of 650 Fifth Avenue is one that should be closely watched by compliance professionals dealing with real estate. Last year, the Department of Justice filed a forfeiture proceeding against a 40% interest in the property held by the Assa Corporation. They recently filed a forfeiture proceeding against the other 60% held by the Alavi Foundation.

The Amended Complaint alleges that the Alavi Foundation has been providing numerous services to the Iranian Government and transferring funds from 650 Fifth Avenue Company to Bank Melli, a bank wholly owned and controlled by the Government of Iran. The Amended Complaint alleges that the properties are forfeitable as the proceeds of violations of the International Emergency Economic Powers Act, 50 U.S.C. §§ 1701 et seq., together with Executive Orders and United States Department of Treasury regulations, and as property involved in and the proceeds of money laundering offenses.

Now the tenants are in the position of having been making rent payments to the Iranian government. This may not result in any criminal or civil sanctions, but the names of those tenants are being dragged through the muck. The same is true for the property management company.

References:

  • Amended Complaint filed by the US DOJ – hosted on JD Supra
  • Press Release from the US Attorney for the Southern District of New York: Manhattan U.S. Attorney Files Civil Action Seeking Forfeiture of Alavi Foundation’s Interest in Fifth Avenue Office Tower Controlled by Iran. (.pdf)
  • Piaget Building Could Go to Auction By Cody Lyon for GlobeSt.com
  • US Seeks Alavi’s Stake In Piaget Building By Chad Bray for the Wall Street Journal
  • Alavi Foundation Is Iran Front, U.S. Says in Seizure Lawsuit By David Glovin for Bloomberg
  • Inside Iran’s Fifth Avenue Skyscraper By Dana Rubinstein for the New York Observer
  • What’s known about Iran-linked Alavi Foundation? by Michael B. Farrell for the Christian Science Monitor
  • Government Seizes 650 Park Avenue -prior post

Share this:

  • Print (Opens in new window) Print
  • Share on Facebook (Opens in new window) Facebook
  • Share on LinkedIn (Opens in new window) LinkedIn
  • Share on X (Opens in new window) X
  • Email a link to a friend (Opens in new window) Email

1 thought on “Real Estate and OFAC Compliance”

  1. Miami Beach Condos says:
    November 24, 2009 at 9:34 am

    I found your blog on MSN Search, and just wanted to say that I enjoyed this post.

    Reply

Leave a ReplyCancel reply

This site uses Akismet to reduce spam. Learn how your comment data is processed.

Search for Stuff

Recent Stories

  • Neither Admit Nor Deny To Be No Longer
  • What Will Form PF Look Like Next Year?
  • Is It a Chipset or Is It a Security?
  • When the Lawyer Is Breaking Bad
  • Will Investors Have an Appetite for Semi-Annual Reporting?
  • Special Forces Trading on Insider Knowledge
  • Prediction Markets and Compliance Programs
  • The One with the Line That Goes Straight Up and Right
  • The One with the Crypto Paying for a Mega-Shilling Package
  • The Performance of the SEC in 2025

Fight Cancer

Please support my Pan-Mass Challenge
Make a donation to fight cancer. donate.pmc.org/DC0176
pan-mass challenge badge

I am a lawyer, but I am not your lawyer. Since I’m a lawyer, this website may be considered attorney advertising under the ethical rules of certain jurisdictions. Please read my disclaimers page before taking any action. And then, don't take any action based on what I wrote.

Creative Commons logo with the text 'Some Rights Reserved' and three symbols representing attribution, non-commercial use, and share alike.

Compliance Building - by Doug Cornelius is licensed under a Creative Commons Attribution-Noncommercial 3.0 United States License.