Last week, The United States Department of the Treasury Office of Foreign Assets Control (OFAC) removed Ali Abdul Mutalib Ali from the OFAC Specially Designated Nationals (SDN) List; a list of thousands of individuals and entities who have been targeted for sanctions by the U.S. government.

The interesting thing about Mr. Ali’s removal, besides the fact that it shows SDN removals do occur from time to time, is that he was designated under the Iraq 2 sanctions program. I thought this was particularly interesting in light of the fact that in 2004, the Iraqi regime of Saddam Hussein was removed and since that time the U.S. has maintained a military presence in that country. Moreover, it has maintained some form of sanctions against Iraq since that time.

Over the last week or so the UK, EU, and UN have been quick in removing sanctions against Libya and/or unblocking funds frozen pursuant to the Libya sanctions. Of course, these actions took place due to the overthrow of the Qaddafhi regime. Despite these actions by the UK, EU and UN, the United States has not yet removed the sanctions against Libya. Nor have they unblocked any significant amounts of funds blocked pursuant to the Libya program, although they did encourage and support the UN’s unblocking of frozen Libya funds last week. The U.S. has not provided any indication that it will remove the Libya sanctions. The question is will Libya sanctions disappear any time soon? Or, like Iraq, will sanctions in some form or another still be imposed against Libya years from now?

While those questions are likely better left to foreign policy analysts, the questions for OFAC practitioners and compliance personnel remains the same: the Libya sanctions are still in effect and need to be followed. While the Libya sanctions program could be removed tomorrow, it is still U.S. law and could be so for a very long time.

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.