DIFFERENT ANGLE by Kenneth Rijock
As you may know, American businesses can obtain a license from OFAC to ship medicine, medical supplies and agricultural commodities to Iran and Sudan. This is provided for in section 906 of the Trade Sanctions Reform & Export Enhancement Act of 2000. Perhaps your bank has customers who operate under such licenses. What you should remember, though, is that those OFAC licenses have only a one-year lifespan. It would be prudent for you to check the status of licenses held by clients for such exports. A notice appearing in the Federal Register this week warned that application response times will no longer be 9 business days, which may tempt exporters to work with expired licenses.
In remarks prepared for delivery today before the Senate Committee on Banking, Housing and Urban Affairs. Treasury Undersecretary Stuart Levey, who is responsible for terrorism and intelligence, was quite direct, and even blunt about the current US position regarding Iran. You do not want to have OFAC looking at your clients, because they will also be looking closely at you, and other regulatory agencies will soon learn about it.
If you want to check at OFAC to see if a client has a valid OFAC license, the Assistant Director for Licensing can be reached at : (202) 622-2480.
Research Note: for details on the new delays in processing, 72 Federal Register 12981 ( 20 March 2007).
The facts and opinions stated in this article are those of the author and not those of World-Check. World-Check does not warrant the accuracy of any facts and opinions stated in this article, does not endorse them, and accepts no responsibility for them.
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