Comments on: GAO Report Questions Effectiveness of U.S. Sanctions on Iran http://www.exportlawblog.com/archives/280 Latest News on DDTC, BIS, OFAC, and other export law matters Fri, 10 Feb 2012 10:06:23 +0000 hourly 1 http://wordpress.org/?v=3.0 By: Mike Deal http://www.exportlawblog.com/archives/280/comment-page-1#comment-7239 Mike Deal Sat, 19 Jan 2008 18:07:00 +0000 http://www.exportlawblog.com/archives/280#comment-7239 Like most recent GAO reports, this one only consults industry and a few academics. The GAO seems to be allergic to contacting industry, especially small business. Having represented companies and individuals prosecuted for violating OFAC's ITR, I find it telling that GAO never contacted counsel or the defendants. This is probably because the "emergency" that was stated justification for the Clinton embargo was non-existent. As 4 of the justices stated in the dissent to Regan v. Wald, which was not contradicted by the majority opinion which rested on the clause grandfathering the Cuban sanctions promulgated under TWEA, IEEPA was never intended by Congress to be authority for ongoing regulation of trade, but was intended solely for sudden and emergent threats. OFAC has always been in the "give us an inch and we'll steal a mile" game. There's not a one of them that doesn't think that they're smarter and better looking and more entitled to rule than anyone on the planet. There's not a one of them that doesn't gicve a damn about all the jobs they ruin as long as they keep and expand their own. The denizens of OFAC are sewlf-important, hypocritical parasites, pure and simple. Like most recent GAO reports, this one only consults industry and a few academics. The GAO seems to be allergic to contacting industry, especially small business. Having represented companies and individuals prosecuted for violating OFAC’s ITR, I find it telling that GAO never contacted counsel or the defendants. This is probably because the “emergency” that was stated justification for the Clinton embargo was non-existent. As 4 of the justices stated in the dissent to Regan v. Wald, which was not contradicted by the majority opinion which rested on the clause grandfathering the Cuban sanctions promulgated under TWEA, IEEPA was never intended by Congress to be authority for ongoing regulation of trade, but was intended solely for sudden and emergent threats.

OFAC has always been in the “give us an inch and we’ll steal a mile” game. There’s not a one of them that doesn’t think that they’re smarter and better looking and more entitled to rule than anyone on the planet. There’s not a one of them that doesn’t gicve a damn about all the jobs they ruin as long as they keep and expand their own. The denizens of OFAC are sewlf-important, hypocritical parasites, pure and simple.

]]>