Update for exporters on prolonged US government shutdown
The prolonged partial shutdown of the US government is still affecting the functions of the Treasury’s Office of Foreign Assets Control (‘OFAC’), Commerce’s Bureau of Industry and Security (‘BIS’), the Directorate of Defense Trade Controls (‘DDTC’) as well as the Financial Crimes Enforcement Network (‘FinCEN’). The shutdown, now the longest in history, began on 22 December. Licence applications submitted through OFAC’s online License Application System are not being processed, although financial sanctions and the Specially Designated Nationals (‘SDN’) List should still be being updated.
Export enforcement by BIS – ‘the ongoing conduct of criminal investigations, and prosecutions, and coordination with other law enforcement and intelligence agencies in furtherance of our national security’ – should be on-going. BIS’s SNAP-R system for the electronic filing of expert and reexport applications and commodity classification requests is not in use, nor is the Directorate of Defense Trade Controls’ D-Trade electronic submissions system.
See here for Treasury’s Lapse in Appropriations Contingency Plan: https://home.treasury.gov/system/files/266/DO-Lapse-Contingency-Plan-2018-12-18.pdf
See: https://licensing.ofac.treas.gov/
See: https://www.commerce.gov/news/blog/2018/12/shutdown-due-lapse-congressional-appropriations
