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International Law Advisory - OFAC Request for Public Comments on Exports of Agricultural Commodities, Medicine, and Medicinal Devices to Sudan and Iran

December 11, 2006

On December 11, 2006, the Office of Foreign Assets Control ("OFAC") of the U.S. Treasury Department requested the submission of comments regarding exports of agricultural commodities, medicine, and medicinal devices to Sudan and Iran. 71 Fed. Reg. 71,500-501.

Current procedures for exportation of the subject merchandise are provided at 31 C.F.R. §§ 538.523-526 and 31 C.F.R. §§ 560.530-533. Pursuant to requirements set forth at § 906(c) of the Trade Sanctions Reform and Export Enhancement Act of 2000 (22 U.S.C. 7201 et seq.), OFAC is required to submit a biennial report to Congress about the number and types of licenses to Sudan and Iran applied for, the number and types of licenses approved, and the average amount of time elapsed from the date of filing of a license application until its approval. Additionally, OFAC must utilize public comments from interested parties regarding the extent to which the licensing procedures are effective.

In this regard, OFAC will be accepting written comments regarding the effectiveness of licensing procedures for the export of agricultural commodities, medicine, and medical devices to Sudan and Iran until January 10, 2007. The comments will be considered by OFAC in developing its report to Congress. All comments submitted will be a matter of public record, which cannot be afforded confidential or business proprietary treatment, and are encouraged to be as specific as possible.

Because the prohibitions of the Libyan Sanctions Regulations, 31 C.F.R. Part 550, have been lifted, licenses for the export of agricultural commodities, medicine, and medical devices to Libya are no longer required. Therefore, OFAC is not soliciting comments regarding the effectiveness of licensing procedures for exports of the covered merchandise to Libya.

Should you have any questions regarding this request of comments by OFAC, please contact Edward Krauland at (202) 429 -8083 or Jack Hayes at (202) 429-6491.

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