Archive for the ‘Iraq’ Category

Treasury Lists – Countries Requiring Cooperation with an International Boycott

Wednesday, October 5th, 2011 by Holly Thorne

The Department of the Treasury has published a current list of countries which require or may require participation in, or cooperation with, an international boycott (within the meaning of section 999(b)(3) of the Internal Revenue Code of 1986).

The countries are:

  • Kuwait
  • Lebanon
  • Libya
  • Qatar
  • Saudi Arabia
  • Syria
  • United Arab Emirates
  • Yemen

Republic of Iraq is not included in this list, but its status with respect to future lists remains under review by the Department of the Treasury.

While this list officially applies to the Internal Revenue Service (IRS) antiboycott rules, it is a reasonable indicator of the high risk countries for the EAR antiboycott regulations.

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Posted in Antiboycott, Iraq, Kuwait, Lebanon, Libya, Qatar, Saudi Arabia, Syria, Treasury Dept, UAE, Yemen | Comments Off

New DDTC Guidelines for Exports, Reexports and Retransfers to Iraq and Afghanistan

Thursday, October 28th, 2010 by John Black

More new guidelines for applications:  And, as you may have guessed, new doesn’t necessarily mean new and improved, at least not from the standpoint of the applicant.  There are streamlined application processing procedures for certain exports for the good guys in Afghanistan and Iraq, but to get the benefit of the streamlined processing, you have to do a lot more than simply reference Operation New Dawn (“OND”) or Operation Enduring Freedom (“OEF”).

To get all of the details of the specific application procedures and extensive requirements for supporting documentation, to: http://pmddtc.state.gov/licensing/documents/gl_OND-OEF.pdf

Posted in Afghanistan, DDTC, Defense Trade Controls, Defense Trade Controls, Export License, Iraq | Comments Off

OFAC Updates List of Countries Supporting International Terrorism

Monday, May 18th, 2009 by Danielle McClellan

OFAC recently amended the Terrorism List Governments Sanctions Regulations to remove Iraq, Libya, and North Korea from the list of countries designated as supporting international terrorism. Cuba, Iran, Sudan and Syria will remain on the list. This change is effective May 18, 2009.

Posted in Cuba, Iran, Iraq, Libya, North Korea, OFAC, Sanctions, Sudan, Syria | Comments Off

OFAC Notices on Its Iraq Sanctions

Sunday, July 20th, 2008 by Danielle McClellan

OFAC has posted guidance and legal sources pertaining to Iraq Sanctions on their website. These sanctions apply to all US persons, companies, non- profit groups, and government agencies, simply put EVERYONE.

The site offers guidance by offering copies of applications for the Release of Blocked Funds and general licenses. Several Adobe PDF documents can be found under “Interpretive Guidance” which offers a little more insight for the savvy.

Posted in Iraq, Sanctions | Comments Off

State Clarifies UN Sanctioned Countries in ITAR

Wednesday, December 19th, 2007 by Danielle McClellan

On December 19, 2007, the Department of State issued an amendment to the International Traffic in Arms Regulations concerning exports and sales which were prohibited by United Nations Security Council embargoes. The amended list will add countries subject to such embargos. The current list includes: Cote d’Ivoire, Democratic Republic of Congo, Iraq, Iran, Lebanon, Liberia, North Korea, Rwanda, Sierra Leone, Somalia, and Sudan.

More information:

Federal Register 72FR71575.pdf (PDF)

Posted in Congo, Defense Trade Controls, Embargoes, Iran, Iraq, ITAR, Lebanon, North Korea, State Dept, Sudan, USA Regulations | Comments Off

Chevron Nailed for Misconduct in Iraq Oil for Food Program

Wednesday, November 14th, 2007 by Danielle McClellan

November 14, 2007 the United States Attorney for the Southern District of New York and the Securities and Exchange Commission announced that an agreement had been reached with the Chevron Corporation involving the company’s alleged misconduct involving the United Nations Oil-for-food Program.The SEC claims that Chevron failed to maintain adequate internal controls when it relied on its trader’s representations and certifications from the third parties. The company also violated the Foreign Corrupt Practices Act when it incorrectly recorded the surcharge payments to Iraq as premiums. These charges arose from allegations that Chevron purchased oil from third parties who paid secret, illegal surcharges to the former government of Iraq. Now whether or not the Chevron Corporation was aware of these undisclosed payments to Iraq is unknown.

(more…)

Posted in Energy, Iraq, Violations & Fines | Comments Off

Export Enforcement Highlights from Commerce/BIS Regulations and Procedures Technical Advisory Committee Meeting

Tuesday, December 5th, 2006 by Jill Kincaid

At the December 5, 2006 meeting of the Regulations and Procedures Technical Advisory Committee, the following enforcement issues were discussed:

  1. The increase in boycott requests from Iraq and Libya. Since power has transferred from the Coalition Provisional Authority to the new Iraqi government, boycott requests there have increased significantly since falling in 2004. Closing the Libyan boycott compliance office has resulted in increased requests from Libya as well. The biggest of the boycotting countries is U.A.E.
  2. The Office of Export Enforcement reported that one of their highest priorities is the renewal of the Export Administration Act (EAA). Proposed changes for the act upon renewal include penalties increased from $11,000 to $50,000 as well as imposing criminal penalties for violations. They will continue to encourage Voluntary Self-disclosures (VSDs) with the policy that penalties will be reduced by 50% with the option to consider other factors which could reduce penalties even further. From 2004-2006 only 5% of VSDs resulted in any penalty at all. Half of the other 95% resulted in the conclusion that no violation had occurred.

Posted in Antiboycott, BIS, Commerce Dept, Iraq, Libya, Violations & Fines | Comments Off

State Sets New Iraq and Afghanistan Application Procedure

Tuesday, May 30th, 2006 by John Black

DDTC has new guidance on its web site for license applications for Operating Enduring Freedom (Afghanistan) and Operating Enduring Freedom (Iraq). Generally speaking, an important point is that State tells applicants to use D-Trade if they want to get their applications approved relatively quickly. When you submit your application via D-Trade and EllieNet, the Transaction ID should begin with the letters “OIF” or “OEF” (OIF — Operation Iraqi Freedom — for Iraq, OEF — Operation Enduring Freedom — for Afghanistan). The new document includes a good deal of additional details that you should read and heed if you want to apply for a license for OIF or OEF.
www.pmddtc.state.gov/licenses.htm

Posted in Afghanistan, DDTC, Defense Trade Controls, Export License, Iraq, USA Regulations | Comments Off

ITAR Drops Embargo on UNITA and Adds Iraq Policy

Friday, November 21st, 2003 by John Black

In the November 21 Federal Register the State Department revised the ITAR to drop its policy of denying all applications destined for UNITA, the terrorist/freedom fighter organization in Angola.  At the same time the State Department revised the ITAR to reflect its new policy for approving applications for items Iraq if the items are “nonlethal military equipment or lethal military equipment for use in support of a reconstituted (or interim) Iraqi military or police force required by the Coalition Provisional Authority.”

Posted in DDTC, Defense Trade Controls, Federal Register, Iraq, ITAR, State Dept, USA Regulations | Comments Off

Update on New Country Requirements and Policies

Saturday, August 30th, 2003 by Maarten Sengers

Here is a rundown of changes to US Government trade control policy for certain countries:

India and Pakistan ITAR Licensing Policy

In a Federal Register Notice dated June 20, DDTC declared that defense export licenses to India and Pakistan would now be reviewed on a case-by-case basis. According to information posted on the www.pmddtc.state.gov website, the previous licensing policy had been one of denial.

Rwanda Licensing Policy Changes

Both DDTC and EAR changed their regulations to loosen restrictions surrounding the lifting of the UN Arms Embargo on Rwanda. The ITAR changes essentially enunciate a new case-by-case license policy for the Government of Rwanda only. For all non-Government exports, all other 126.1 ITAR proscribed country restrictions remain, including a policy of denial for licenses. Likewise, exemptions may not be used for non-Government end users.

Burma

On July 29, 2003, President Bush issued an Executive Order that place further trade restrictions on Burma (a.k.a. Myanmar). Previous to this order, the Foreign Assets Control regulations restricted investment by US firms in Burma. The Executive Order expands Burma trade restrictions. First the order freezes all assets of the Government of Burma that enter the US or are in the possession of US Persons (which includes US branch offices overseas). Second, all imports from Burma into the United States (but not exports or reexports to Burma) are prohibited effective August 28, 2003. The order also prohibits the export or import of financial services. The order contains restrictions of any facilitation of any activity by a third person that a US person could not engage in.

So you may continue to export commercial products to Burma, but dealing with the Government and Government entities will be tricky as Government assets are frozen and related financial services, such as confirming or negotiating a Letter of Credit, are restricted. No barter deals: imports into the US from Burma will soon be prohibited. Burma continues to remain an ITAR proscribed country, so defense article exports are prohibited.

Iraq

On June 27, OFAC formally amended its regulations on Iraq that now basically allow most EAR99 and “xx991″ export and reexports to Iraq under a General License. We described these changes last month, and this regulation adds nothing new.

Posted in Burma/Myanmar, DDTC, Defense Trade Controls, EAR, Federal Register, India, Iraq, ITAR, OFAC, Pakistan, USA Regulations | Comments Off

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