OFAC Begins Process Of Lifting Sanctions In Post-War Iraq
On September 13, 2010, the Office of Foreign Assets Control (“OFAC”) of the US Department of the Treasury announced the removal of the Iraqi Sanctions Regulations from the Code of Federal Regulations, 31 C.F.R. Part 575, and added the Iraq Stabilization and Insurgency Sanctions Regulations (“ISISR”) to the Code at 31 C.F.R. Part 576. The new regulations implement Executive Order 13350 terminating the national emergency declared in Iraq by the US in 1990 in Executive Order 12722.
Prior to the new regulations US law prohibited the importation of any goods or services from Iraq to the US and prohibited the exportation of goods, services, or technology from the US to Iraq. ISISR authorizes all transactions involving property and interests in property that were previously prohibited under Executive Order 12722. However, importers and exporters should be aware that certain transactions relating to Iraq remain subject to sanctions. OFAC announced that the removal of 31 C.F.R. Part 575 from the Code of Federal Regulations will neither affect ongoing enforcement proceedings nor prevent the initiation of enforcement proceedings where the statute of limitations has not run. A full copy of ISISR can be read in the Federal Register at: Federal Register Announcement.
For more information regarding OFAC and strategies on maintaining compliance with federal regulations, please contact Fuerst Ittleman at 305-350-5690 or contact@fidjlaw.com.