Comments on: GAO Report on Iran Sanctions Blasts OFAC’s Dead Tree Licensing System

By: Mike Liberto

Mike Liberto — Sat, 13 Mar 2010 17:43:29 +0000

It wont take too many trips to Dubai (especially in Winter) to be awakened by “the call” from your open window in the dawn and see the 30 ft Dows being loaded on the canal with every conceivable type of merchandise Made in USA and elsewhere, leaving for Iran. It has been this way forever, before there was a USA. Not unlike the OFAC desk, it is no far stretch to understand that even a buyer in UAE will not know if a few of the items being purchased will eventually go to Iran, or if he would be able to read a dows manifest if they were.

By: John Pisa-Relli

John Pisa-Relli — Thu, 11 Mar 2010 17:15:53 +0000

Hey, Clif, I didn’t give you permission to use that archive photo of my old desk at OFAC…. Seriously, I worked at OFAC in the mid/late-90s, and I can tell you that while certainly they are not on par with DDTC and BIS regarding licensing automation, they continue to slouch toward the 21st century. At one point in my OFAC youth, I handled blocked assets licensing requests, and my big claim to fame was designing the PDF application form that they ended up using to make disposition of such cases more routine. At the time, there was great resistance to my effort to impose such formality on the licensing process by using a standard application. One manager there who shall remain unnamed chided me by saying words to the effect that “we’re not bureaucrats like the folks at State and Commerce”, with the implication being that OFAC licensing matters were lofty, unique, and not susceptible of being reduced to a routine exercise.

Indeed…. For what it’s worth, my current portfolio in-house is almost exclusively ITAR-related, so undoubtedly I’m being punished for whatever sins I committed when I was a bureaucrat myself.

Just an anecdote from my wayward days at the Treasury Annex. Back to your regularly scheduled programming….

By: Erich Ferrari

Erich Ferrari — Thu, 11 Mar 2010 13:42:18 +0000

The U.A.E. huh? You don’t say……

As for the mass of paper clogging up the halls of the the Treasury Annex, quite a bit of it has gone through my printer at some point. When doing document productions for responses to OFAC administrative subpoenas, I always ask the investigator: can I just put these documents on a disc for you? I inevitably get the same answer everytime: “We like everything in hard copy.” Worth a shot I guess…maybe someday.

I can only imagine how many trees have given their lives for the enforcement and administration of U.S. economic sanctions.

By: Clif Burns

Clif Burns — Thu, 11 Mar 2010 12:39:28 +0000

@Hillbilly: Excellent point. In that regard, the picture illustrating the post is an imaginative reconstruction of OFAC’s licensing office and shouldn’t be introduced as actual evidence.

By: Hillbilly

Hillbilly — Thu, 11 Mar 2010 11:40:26 +0000

When I read the GAO report last week, I thought back to the criminal cases in which OFAC would send a licensing officer to testify for the prosecution that the defendant had not applied for or received a license. With the GAO report in hand, Defense counsel should cross-examine that OFAC licensing officer and ask: “How do you know?”