Keys to Compliance

126.1 List

  The U.S. Government has some sort of objection to doing international business with the countries included in the list above. The objection could be human rights violations on that countries part, regional governments, supporting terrorist activities, or supporting a U.N. embargo. Whatever the reason, doing business in these countries requires special authorizations — and in most cases a Presidential Waiver.

The U.S. Department of State allows for exports on a case-by-case basis to some countries on this list, your compliance professional will know which countries have a better chance of getting a license approved versus getting a denial for National Security reasons. The list changes with U.S. foreign policy — your export expert will be required to keep current with the countries and entities that are on these lists.

Countries such as Iraq and Afghanistan are reviewed on a case-by-case basis, those applications that support Operation Enduring or Iraqi Freedom will most likely be approved, applications not in support of those operations may have a harder time gaining authorization or be rejected based on National Security.

Failing to identify individuals or entities from these countries prior to beginning any business discussions can have severe negative consequences for your organization. There are fewer ways to truly violate U.S. Export and Import regulations than to allow your organization to interact with a denied, debarred, or embargoed country or their representative.