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	<title>Comments on: Employee Hit With Significant Fine For Lying To BIS</title>
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	<description>Latest News on DDTC, BIS, OFAC, and other export law matters</description>
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		<title>By: Clif Burns</title>
		<link>http://www.exportlawblog.com/archives/371/comment-page-1#comment-19927</link>
		<dc:creator>Clif Burns</dc:creator>
		<pubDate>Sun, 03 Aug 2008 07:49:11 +0000</pubDate>
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		<description>Leaving aside that State doesn&#039;t process any licenses to send anything to Iran, whether or not OFAC licenses to ship things to Iran are easy to obtain or not is, I suppose, a relative question.  I&#039;ve been seeing AgMed applications take around 2-3 months to obtain, and it doesn&#039;t seem to me that such a delay is worth risking a $250,000 civil fine (or even higher criminal penalties).</description>
		<content:encoded><![CDATA[<p>Leaving aside that State doesn&#8217;t process any licenses to send anything to Iran, whether or not OFAC licenses to ship things to Iran are easy to obtain or not is, I suppose, a relative question.  I&#8217;ve been seeing AgMed applications take around 2-3 months to obtain, and it doesn&#8217;t seem to me that such a delay is worth risking a $250,000 civil fine (or even higher criminal penalties).</p>
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		<title>By: Eric Hirschhorn</title>
		<link>http://www.exportlawblog.com/archives/371/comment-page-1#comment-19926</link>
		<dc:creator>Eric Hirschhorn</dc:creator>
		<pubDate>Sun, 03 Aug 2008 02:51:27 +0000</pubDate>
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		<description>It&#039;s true that OFAC generally grants licenses to export medical equipment to Iran.  This is because Congress has required them to do it, not because they think it&#039;s a good idea.  

It&#039;s NOT true, though, that licenses are easy to obtain.  OFAC and the State Department typically take many, many, many months to process such applications.  Each agency privately blames the other, and/or staff shortages, for the delays but their institutional hostility toward the program probably doesn&#039;t help, either.</description>
		<content:encoded><![CDATA[<p>It&#8217;s true that OFAC generally grants licenses to export medical equipment to Iran.  This is because Congress has required them to do it, not because they think it&#8217;s a good idea.  </p>
<p>It&#8217;s NOT true, though, that licenses are easy to obtain.  OFAC and the State Department typically take many, many, many months to process such applications.  Each agency privately blames the other, and/or staff shortages, for the delays but their institutional hostility toward the program probably doesn&#8217;t help, either.</p>
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