Yesterday, the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) released their TSRA licensing reports for the 2nd and 3rd quarters of 2011. For those new to OFAC or to this blog, TSRA stands for Trade Sanctions Reform and Export Enhancement Act of 2000, and is the law allowing OFAC to license exports of agricultural commodities, medicine, and medical devices to Iran, Cuba, and Sudan.

Those reading OFAC’s announcement yesterday may have also noticed that OFAC referred to these reports as belonging to the 3rd and 4th quarters, however, they reflect the time periods between April to June 2011 and July to September 2011 respectively.

What is remarkable about this announcement is that it almost brings OFAC’s release of these reports current, whereas in the past they have typically been released many quarters after the quarter which they reflect. Also amazing is the leap in processing times between the 2nd and 3rd quarter of last year, particularly since they were receiving a similar number of license applications during that time.

In the 2nd quarter of 2011, OFAC granted 330 TSRA licenses, amended 48 TSRA licenses, and denied 2 such licenses. Their average processing time for a license authorization was 102 days. Compare these numbers with those of the 3rd quarter of 2011, where OFAC granted 30l TSRA licenses, amended 51 such licenses and denied only 1 TSRA license, while averaging an 81 day processing time for license authorizations, and you see that OFAC was much faster processing TSRA applications last summer than they were last spring.

I personally have found in my practice that the TSRA office, compared to the rest of OFAC’s licensing division, moves pretty fast. OF course, this likely has to do with the fact that they have a more focused area of authorizations to concentrate on. The rest of OFAC licensing has to worry about the more complicated and policy driven license authorizations and likely has to interface with the State Department more frequently to obtain policy guidance on the licensing requests they receive. It could also be because the TSRA office within the Licensing Division use an online application process that streamlines the process. Or it could be because the staff in the TSRA office is just that good. Anyway you slice it, the decreasing processing times in the TSRA office are a good thing.

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.