By Judith A. Lee, Alan Platt and Andrea Dynes

On May 27, 2003, the United States Treasury Department's Office of Foreign Assets Control (OFAC) issued a General License, amending the Iraqi Sanctions Regulations, 31 C.F.R. Part 575, and lifting most remaining U.S. economic sanctions against Iraq. Issuance of the General License implements United Nations Resolution 1483, which ended the UN's Iraq sanctions, and is the final step in aligning U.S. law with the new, less restrictive UN regime.

The General License will permit most trade between U.S. and Iraqi companies and individuals, while maintaining bans on trade in arms, and cultural artifacts illegally removed from Iraqi museums since August 6, 1990. A ban on trade with certain Iraqi persons, including senior officials of Iraq's former ruling Baath Party, will also remain in effect. An up-to-date list of so-called Specially Designated Nationals, is maintained on the OFAC website at http://www.treas.gov/ofac.

The Department of Commerce's Export Administration Regulations (EAR) and State Department restrictions on export of certain goods and technology (including technical data and other information) controlled for national security purposes, are not altered by the General License. As a result, export of goods or technology subject to a license requirement under either agency's regulations must be separately authorized.

The General License is effective May 23, 2003.

The text of the general license is available at http://www.ustreas.gov/offices/enforcement/ofac/actions/20030523.html.

This article has been prepared for general informational purposes only and is not intended as legal advice

Copyright © 2003 Gibson, Dunn & Crutcher LLP