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Private Client Services associate Crist Malekyan authored “Trapped Wealth: An Estate Planner’s Guide to Iran-Connected Matters” in the November 2026 issue of Estate Planning Journal.

The article examines how U.S. sanctions can leave Iranian-American families unable to receive, sell, or transfer inherited property and other assets connected to Iran. It walks through six common inbound and outbound scenarios under OFAC rules and the Iranian Transactions and Sanctions Regulations (ITSR). Crist covers bank de-risking, the difference between planning during life and after death, tax and reporting obligations, and protective drafting, as well as OFAC’s August 2026 stay of the personal-remittance general license.

This article was originally published in Estate Planning, a Thomson Reuters journal.

Excerpts:

For most U.S. estate planners who encounter Iran-connected matters, the work begins where every cross-border estate matter begins: with a death in the family, a probate, a gift, or a routine support arrangement. A father has died in Tehran. The U.S.-citizen daughter — naturalized decades earlier — expects to receive her share of a small estate consisting of a residential apartment, a savings deposit at an Iranian bank, household goods, and a few pieces of gold jewelry. There is no dispute among the heirs, and the Iranian lawyer or family member handling the local end says the local paperwork is moving. For U.S. counsel, that local-law posture is only the beginning; it does not establish that U.S. sanctions law authorizes the transfer or that a bank will execute it. The question the client puts to U.S. counsel is when the money will arrive and what to do with the apartment.

This is the matter. It is not a sanctions question on its face, and most clients do not present it as one. But under U.S. law it is one of the most regulated transactions an estate planner is likely to touch — more regulated than the typical foreign decedent matter, more regulated than nearly any private wealth movement that does not involve a publicly traded security or a real estate closing. The ordinary tools of cross-border estate practice — situs analysis, treaty work, foreign tax credits, marital deduction structuring — operate against an additional and dominant layer: the U.S. economic sanctions program against Iran.