OFAC has published a Biennial Report of licensing activities pursuant to Section 906(c) of the Trade Sanctions Reform and Export Enhancement Act of 2000 (TSRA), which covers activities undertaken by OFAC from October 2014 to September 2016. The report focuses on licence applications requesting authorisation to export agricultural commodities, medicine, and medical devices to Iran and Sudan under Section 906 of the Act. OFAC Notice.
The report shows an increase in the average processing time for issuing a licence of 75 business days rather than 64 from 2012 – 2014, and an increase from 46 to 53 business days for issuing licence determinations (including amendments and refusals). Out of 1911 licence applications in the reporting period, the overwhelming majority (83.5%) were for Iran to supply medical equipment (78.1% of Iranian licences). In total, 27 applications were denied.
Maya Lester QC is a senior barrister (Queen’s Counsel) at Brick Court Chambers with a wide-ranging practice in public law, European law, competition law, international law, human rights & civil liberties. She has a particular expertise in sanctions. The legal directories say she is the...See profile for Maya Lester QC >