Thu, May. 29, 2003

Ben Flowe on Iraq Sanctions Liberalization

If you are touched by export controls, you know of Benjamin Flowe, or you should. Ben has just released an update on the Iraq sanctions and their liberalization. Topics include: AES Will Be Mandatory, with Certification to File Export Documents; Microprocessor Liberalization with NLR Military End-Use Controls; Current Export Legislation; Bush Administration Defense Trade Review; Enforcement Cases; CCL and Other Changes. The thrust of his arguments is:

First, U.S. forces liberalized the people of Iraq, then the benefits should flow. One clear change is the liberalization of long time economic sanctions and export controls. Ben's new Export Licensing Clients Memorandum describes (1) the current state of liberalization of export controls on Iraq (with more to follow in about a week), plus the following major export control and sanctions changes: (2) increased penalties for false statements on SEDs, mandatory electronic submission of export documents via AES, and upcoming certification requirement for same; (3) liberalization of controls on general purpose microprocessors with unprecedented military end-use/r restrictions on NLR shipments; (4) EAA, Sudan, and Syria legislation; (5) implementation of State-BIS settlement on "space-qualified" items; (6) Bush Administration review of defense trade policy; (7) ITAR USML Review; (8) revisions to ITAR Canadian Exemption; (9) State proliferation sanctions; (10) significant enforcement cases; (11) changes to Unverified List and Best Practices for Transshipments; (12) Commerce Control List revisions for Wassenaar, Missile Technology, Nuclear, and other reasons; (13) effect of General Accounting Office reports on current and future policy; and (14) OFAC unblocking of most assets frozen under the Federal Republic of Yugoslavia Sanctions Programs.

Request your copy from Ben at 202 293 5555.

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