I have an account that we have restricted due to the fact that the signers list their residency in Iran. They have requested the account be closed. We typically issue the account closure check to Signer A and Signer B when there are 2 signers on an account. Do we have to have both signers present (verified outside of Iran) when we issue this check and close the account? Can we give the check to the signer living here in the U.S. while the other signer is living in Iran? Any thoughts are appreciated!!

Please don't take this as a cop-out, but I would strongly recommend that you call OFAC to get a specific answer regarding the scenario.

My understanding from past conversations with OFAC is that where the accountholders are physically located could determine how you are permitted to go about closing the account by check. I also understand that, regardless of where they are located, you can close the account and wire the funds to the accountholders to a non-US (and non-OFAC-sanctioned country) account.

Although it can sometimes be frustrating to try to reach OFAC, I have found them to be very helpful in answering questions about the do's and don't's for those confusing country sanctions!