Welcome!

News Feed Item

General Authorization to Export Medicine to Iran Has Pitfalls

WASHINGTON, Nov. 8, 2012 /PRNewswire-iReach/ -- On October 22, 2012 the United States Department of the Treasury's Office of Foreign Assets Control ("OFAC") completely revised and reissued the foundation of the U.S. economic sanctions program prohibiting trade with Iran: the Iranian Transactions Regulations (ITR). One of the key changes that occurred as result of the revisions to the ITR, now re-named the Iranian Transactions and Sanctions Regulations (ITSR), is the issuance of a general license which authorizes the exportation and reexportation of medicine and basic medical supplies to Iran. Prior to this action, U.S. exporters of these products were required to secure a specific license from the Treasury Department's Office of Foreign Assets Control (OFAC) in order to trade with Iran. Notably, the new regulations also contain general authorization for a variety of payment and financing methods for these exports. However, while the ITSR now opens up a number of opportunities for U.S. medical companies, restrictions on certain products remain, which require the procurement of a specific license to export.  

For example, some of the more notable medicines which fall under the exclusions to this authorization include: Xanax, Vicodin, OxyContin, Percocet, Wellbuterin, Dramamine, Wellbuterin, Advil PM, Benadryl, and Oral Steroid Painkillers. These medicines all fall under the several categories of medicine which are not covered by the general license. Those categories include Non-NSAID analgesics, anticholinergics, opiods, benzodiazepines, legal narcotics, and bioactive peptides. In order to export any of these items, U.S. companies must first obtain a specific license from OFAC.

OFAC also provides a list of basic medical supplies which fall under the general license. This list covers only the most rudimentary devices, such as bandages, tongue depressors, scalpels and other items which previously did not require an Official Commodity Classification of EAR99 from the Department of Commerce's Bureau of Industry and Security (BIS). For exporters of medical devices not contained in the list of basic medical supplies, a specific license and a BIS EAR99 classification are still required before any trade with Iran may be conducted.

Finally, while these new authorizations may seem like a boon for U.S. exporters and a god send for those in Iran who need such products, there is still great difficulty in finding U.S. banks to process payments for these exports. Since they can no longer rely on a specific license issued by OFAC, U.S. banks have to trust that the transactions for which they are requested to process payments are authorized under these new regulations. As such, the risk of processing a payment which may be in violation of the sanctions could be greater than ever. Therefore, compliance measures should be bolstered both by the exporters and the banking community to ensure all facets of the new authorizations are adhered to.

The ITSR is an exceptionally complex set of regulations and it is suggested that exporters seek out an attorney specializing in export and OFAC-related matters before going through with any transactions related to Iran.

Ferrari & Associates, P.C. is a boutique law firm in Washington, DC specializing in OFAC matters. If you have any questions regarding this press release please contact them at 202-280-6370 or [email protected].

Media Contact: Erich Ferrari, Ferrari & Associates, P.C., 202-280-6370, [email protected]

News distributed by PR Newswire iReach: https://ireach.prnewswire.com

SOURCE Ferrari & Associates, P.C.

More Stories By PR Newswire

Copyright © 2007 PR Newswire. All rights reserved. Republication or redistribution of PRNewswire content is expressly prohibited without the prior written consent of PRNewswire. PRNewswire shall not be liable for any errors or delays in the content, or for any actions taken in reliance thereon.

Latest Stories
The Internet of Things can drive efficiency for airlines and airports. In their session at @ThingsExpo, Shyam Varan Nath, Principal Architect with GE, and Sudip Majumder, senior director of development at Oracle, will discuss the technical details of the connected airline baggage and related social media solutions. These IoT applications will enhance travelers' journey experience and drive efficiency for the airlines and the airports. The session will include a working demo and a technical d...
SYS-CON Events announced today that Commvault, a global leader in enterprise data protection and information management, has been named “Bronze Sponsor” of SYS-CON's 19th International Cloud Expo, which will take place on November 1–3, 2016, at the Santa Clara Convention Center in Santa Clara, CA. Commvault is a leading provider of data protection and information management solutions, helping companies worldwide activate their data to drive more value and business insight and to transform moder...
The Transparent Cloud-computing Consortium (abbreviation: T-Cloud Consortium) will conduct research activities into changes in the computing model as a result of collaboration between "device" and "cloud" and the creation of new value and markets through organic data processing High speed and high quality networks, and dramatic improvements in computer processing capabilities, have greatly changed the nature of applications and made the storing and processing of data on the network commonplace.
DevOps at Cloud Expo – being held November 1-3, 2016, at the Santa Clara Convention Center in Santa Clara, CA – announces that its Call for Papers is open. Born out of proven success in agile development, cloud computing, and process automation, DevOps is a macro trend you cannot afford to miss. From showcase success stories from early adopters and web-scale businesses, DevOps is expanding to organizations of all sizes, including the world's largest enterprises – and delivering real results. Am...
SYS-CON Events announced today that Bsquare has been named “Silver Sponsor” of SYS-CON's @ThingsExpo, which will take place on November 1–3, 2016, at the Santa Clara Convention Center in Santa Clara, CA. For more than two decades, Bsquare has helped its customers extract business value from a broad array of physical assets by making them intelligent, connecting them, and using the data they generate to optimize business processes.
I'm a lonely sensor. I spend all day telling the world how I'm feeling, but none of the other sensors seem to care. I want to be connected. I want to build relationships with other sensors to be more useful for my human. I want my human to understand that when my friends next door are too hot for a while, I'll soon be flaming. And when all my friends go outside without me, I may be left behind. Don't just log my data; use the relationship graph. In his session at @ThingsExpo, Ryan Boyd, Engi...
SYS-CON Events announced today that Pulzze Systems will exhibit at the 19th International Cloud Expo, which will take place on November 1–3, 2016, at the Santa Clara Convention Center in Santa Clara, CA. Pulzze Systems, Inc. provides infrastructure products for the Internet of Things to enable any connected device and system to carry out matched operations without programming. For more information, visit http://www.pulzzesystems.com.
Fact is, enterprises have significant legacy voice infrastructure that’s costly to replace with pure IP solutions. How can we bring this analog infrastructure into our shiny new cloud applications? There are proven methods to bind both legacy voice applications and traditional PSTN audio into cloud-based applications and services at a carrier scale. Some of the most successful implementations leverage WebRTC, WebSockets, SIP and other open source technologies. In his session at @ThingsExpo, Da...
SYS-CON Events announced today that Secure Channels will exhibit at the 19th International Cloud Expo, which will take place on November 1–3, 2016, at the Santa Clara Convention Center in Santa Clara, CA. The bedrock of Secure Channels Technology is a uniquely modified and enhanced process based on superencipherment. Superencipherment is the process of encrypting an already encrypted message one or more times, either using the same or a different algorithm.
Traditional on-premises data centers have long been the domain of modern data platforms like Apache Hadoop, meaning companies who build their business on public cloud were challenged to run Big Data processing and analytics at scale. But recent advancements in Hadoop performance, security, and most importantly cloud-native integrations, are giving organizations the ability to truly gain value from all their data. In his session at 19th Cloud Expo, David Tishgart, Director of Product Marketing ...
Almost two-thirds of companies either have or soon will have IoT as the backbone of their business in 2016. However, IoT is far more complex than most firms expected. How can you not get trapped in the pitfalls? In his session at @ThingsExpo, Tony Shan, a renowned visionary and thought leader, will introduce a holistic method of IoTification, which is the process of IoTifying the existing technology and business models to adopt and leverage IoT. He will drill down to the components in this fra...
The vision of a connected smart home is becoming reality with the application of integrated wireless technologies in devices and appliances. The use of standardized and TCP/IP networked wireless technologies in line-powered and battery operated sensors and controls has led to the adoption of radios in the 2.4GHz band, including Wi-Fi, BT/BLE and 802.15.4 applied ZigBee and Thread. This is driving the need for robust wireless coexistence for multiple radios to ensure throughput performance and th...
SYS-CON Events announced today the Kubernetes and Google Container Engine Workshop, being held November 3, 2016, in conjunction with @DevOpsSummit at 19th Cloud Expo at the Santa Clara Convention Center in Santa Clara, CA. This workshop led by Sebastian Scheele introduces participants to Kubernetes and Google Container Engine (GKE). Through a combination of instructor-led presentations, demonstrations, and hands-on labs, students learn the key concepts and practices for deploying and maintainin...
Enterprise IT has been in the era of Hybrid Cloud for some time now. But it seems most conversations about Hybrid are focused on integrating AWS, Microsoft Azure, or Google ECM into existing on-premises systems. Where is all the Private Cloud? What do technology providers need to do to make their offerings more compelling? How should enterprise IT executives and buyers define their focus, needs, and roadmap, and communicate that clearly to the providers?
SYS-CON Events announced today that SoftLayer, an IBM Company, has been named “Gold Sponsor” of SYS-CON's 18th Cloud Expo, which will take place on June 7-9, 2016, at the Javits Center in New York, New York. SoftLayer, an IBM Company, provides cloud infrastructure as a service from a growing number of data centers and network points of presence around the world. SoftLayer’s customers range from Web startups to global enterprises.