International Trade Law News /title <!DOCTYPE html PUBLIC "-//W3C//DTD XHTML 1.0 Strict//EN" "http://www.w3.org/TR/xhtml1/DTD/xhtml1-strict.dtd"> <html xmlns="http://www.w3.org/1999/xhtml" xml:lang="en" lang="en"> <head> <title>International Trade Law News

April 24, 2008 

OFAC Issues Quarterly TSRA Licensing Report

Today the Treasury Department's Office of Foreign Assets Control (OAFC) issued its most recent quarterly report of export licenses related to agricultural commodities, medicine and medical devices to Iran and Sudan under the Trade Sanctions Reform and Enhancement Act of 200 (commonly known as TSRA).

OFAC's report for the period October through December 2007 indicates that the average licensing time increased to 80 business days and that OFAC issued 100 licenses during the quarter. During the previous quarter (July-September 2007) OFAC issued 183 licenses with an average turnaround time of 70 business days.

By contrast, during the October-December 2005 quarter, OFAC issued 233 licenses with an average turnaround time of only 24.5 business days.

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March 14, 2008 

Bahrain-Based Bank Designated by Treasury Department Cannot be Used to Finance TSRA Licensed Transactions

Earlier this week the Treasury Department designated Bahrain-based Future Bank B.S.C. and all its branch offices pursuant to Executive Order 13382 of June 28, 2005, “Blocking Property of Weapons of Mass Destruction Proliferators and Their Supporters.”

Future Bank was established in 2004 as a joint venture between two Iranian banks, Bank Melli and Bank Saderat, and a private bank based in Bahrain. According to the Treasury Department, Bank Melli and Bank Saderat, both of which have been designated by OFAC, hold 33.3 percent of Future Bank's outstanding shares and Future Bank is controlled by Bank Melli.

OFAC announced today that holders of valid OFAC licenses authorizing the exportation or reexportation of agricultural commodities, medicine or medical devices to Iran or Sudan are no longer permitted to engage in any transactions, directly or indirectly, with Future Bank B.S.C.

As a result of OFAC’s various actions against financial institutions to date, the following banks cannot be involved in payments associated with Ag/Med licenses issued pursuant to the Trade Sanctions Reform and Export Enhancement Act of 2000 (TSRA):

* Future Bank B.S.C.
* Bank Sepah
* Bank Saderat (including, Iran Export Bank, Bank Saderat PLC)
* Bank Melli Iran Zao
* Bank Kargoshaee (also known as Kargosa’i Bank)
* Bank Melli
* Melli Bank PLC
* Arian Bank (also known as Aryan Bank)
* Bank Mellat
* Mellat Bank SB CJSC (including Mellat Bank DB AOZT)
* Persia International Bank PLC

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