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International Trade
Newsletter - June 11, 2003
 
In this Issue...
OFAC Removes Most Iraq Sanctions
 
 June 11, 2003
 

On May 23, 2003, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued a notice that removes most of the Iraqi sanctions embargo.  This comprehensive removal of the Iraqi embargo comes after several earlier, more limited changes over the last several weeks.  This removal also coincides with the lifting of United Nations sanctions on May 22, 2003.  The U.S. embargo was first set in place following the 1990 Iraqi invasion of Kuwait.

It is important to note that this authorization does not eliminate the need to comply with other provisions of 31 CFR chapter V or with other applicable provisions of law, including any aviation, financial or trade requirements of agencies other than OFAC.  Included in these requirements are those of the International Traffic in Arms Regulations administered by the U.S. Department of State.  Also, all property and interests in property that are currently blocked continue to be blocked.

Any goods or technology (including technical data or other information) controlled by the U.S. Department of Commerce under the Export Administration Regulations to be exported from the U.S. to Iraq must be separately authorized by or pursuant to 31 CFR 575.  This rule also applies to any goods or technology, as described above, for exportation or re-exportation to Iraq from a third country, if such goods or technology are subject to U.S. jurisdiction.

Transactions with the following remain prohibited:  (1) persons or organizations determined by the Director of the OFAC to be specially designated nationals (SDNs) of the Government of Iraq, (2) persons on the U.S. Department of Defense 55-person Watch List, (3) persons identified by the 661 Committee of the United Nations Security Council, and (4) transactions dealing with Iraqi cultural property or other items of archaeological, historical, cultural, rare scientific and religious importance illegally removed from the Iraq National Museum, the National Library and other locations in Iraq since August 6, 1990.

Although OFAC has seemingly eased the restrictions on transactions with Iraq, it is very important that any person or entity that wishes to engage in such transactions be cognizant of the requirements set forth by the Regulations, as well as other applicable laws of the U.S. Government, given the current sensitive nature of the U.S./Iraq relationship.