As any OFAC attorney can relate they have been busy these days. The new Libya sanctions and their implementation have sent all of us in the field scrambling to answer client’s questions, update compliance programs, and generally provide a sense to anyone and everyone of what these new sanctions entail. But it’s not only practitioners and compliance officers who have been busy, from all reports I’m hearing OFAC itself has been incredibly busy as well. Not only have there been a slew of designations under the Libya sanctions; there have also been several general licenses promulgated under this program. In addition, I have heard from some OFAC officials that they are incredibly busy dealing with all the new issues surrounding the Libya program.

Although there was no insight provided by those officials as to what they were doing (OFAC officials are notoriously tight lipped), I did get the sense that there would be delays in some of their functions. As such, those applying for licenses or waiting for opinions on requests for interpretative guidance may experience delays in the processing of those submissions. Please keep in mind this isn’t OFAC’s official position, this is merely my speculation and is offered to provide a possible explanation as to why you may be waiting for sometime before getting a response on your recently submitted OFAC license application.

In other news, OFAC released a number of Specially Designated Global Terrorists from the OFAC SDN List today. As I have explained time and time again on this blog, removal from the OFAC SDN List is possible, however, it does take time and really requires the knowledge of an attorney who has been through the process before.

The author of this blog is Erich Ferrari, an attorney specializing in OFAC matters. If you have any questions please contact him at 202-280-6370 or ferrari@ferrari-legal.com.