OFAC, EAR & ITAR - Embargoed Countries, Entities and Persons

September 25, 2013 0 Comments Bloggies by Graham Penrose

Certain organizations and individuals are subject to trade sanctions, embargoes, and other restrictions under US law. These restrictions apply to both domestic and foreign transactions. In addition, certain countries are subject to either comprehensive embargoes or targeted sanctions. Comprehensive embargoes prohibit virtually ALL exports/imports and other transactions without a license or other US Government authorization. Targeted sanctions are prohibitions on trade in specified goods, technologies, and services with specific organizations (including foreign governments) and persons.

US DOD ITAR

Some acronyms to understand:

OFAC - The Office of Foreign Assets Control (OFAC) is an agency of the United States Department of the Treasury under the auspices of the Under Secretary of the Treasury for Terrorism and Financial Intelligence. OFAC administers and enforces economic and trade sanctions based on U.S. foreign policy and national security goals against targeted foreign states, organizations, and individuals.

EAR - The Bureau of Industry and Security (BIS) is responsible for implementing and enforcing the Code of Federal Regulations Title 15 chapter VII, subchapter C, also known as Export Administration Regulations (EAR), in the United States.

ITAR - International Traffic in Arms Regulations is a set of United States government regulations that control the export and import of defense-related articles and services on the United States Munitions List (USML).

Items on Lists

At time of writing the following is the status of the OFAC, EAR and ITAR lists:

  • Comprehensively Embargoed Countries: OFAC - Iran, Cuba, Syria; EAR - Iran, Cuba, Syria;
  • Targeted Sanctions Countries: OFAC - Libya, Lebanon, Somalia, Belarus, Sudan, North Korea, Iraq, Yemen, Myanmar (formerly Burma), Liberia, Zimbabwe, Balkans, the Cote D'Ivoire (formerly Ivory Coast); EAR - North Korea, Iraq;
  • Countries with Restricted Entities on the EAR Entity Chart - China, Canada, Germany, Iran, India, Israel, Pakistan, Russia, Egypt, Malaysia, Hong Kong, Kuwait, Lebanon, Singapore, South Korea, Syria, United Arab Emirates the United Kingdom;
  • ITAR Prohibited Countries - Afghanistan, Belarus, Cuba, Cyprus, Eritrea, Fiji, Iran, Iraq, Cote d'Ivoire, Lebanon, Libya, North Korea, Syria, Vietnam, Myanmar, China, Haiti, Liberia, Rwanda, Somalia, Sri Lanka, Republic of the Sudan (Northern Sudan), Yemen, Zimbabwe, Venezuela, Democratic Republic of the Congo.