export-controls 10 January 2019

US government shutdown hampering export licensing and SDN list removals

The extended US government shutdown is having a negative effect on exporters. The US Treasury’s Office of Foreign Assets Control (‘OFAC’), Commerce’s Bureau of Industry and Security (‘BIS’) and State’s Directorate of Defense Trade Controls (‘DDTC’) have all been affected, with ‘curtailed’ services for licence requests, advisory opinions and commodity classifications ‘except for those that provide direct support to the military, humanitarian aid, or other similar emergencies.’ (DDTC).

‘Any US and non-US companies are adversely impacted due to OFAC, BIS and DDTC not processing export/reexport license applications and requests for removals from SDN and Entity Lists,’ tweeted Doug Jacobson from US international trade law firm Jacobson Burton PLLC.

US government services have been subject to a partial shutdown since 22 December, after Democrats stymied funding for President Trump’s promised wall along the Mexican border. On 8 January, OFAC made its first designation since the shutdown, targeting seven Venezuelan individuals and 23 entities for their participation in a corrupt currency exchange scheme.


OFAC’s Notice can be found here:

The Treasury press release can be found here: