Are the licenses previously issued to me by OFAC for transactions involving Iraq still valid?
Yes. BIS will recognize the validity of any specific license authorized by OFAC for an export or reexport to Iraq, or transfer within Iraq, until the expiration date specified by OFAC. OFAC licenses issued without specified expiration dates will be valid through July 30, 2005. No additional BIS license is required for transactions within the scope of a previously-issued OFAC license. Such licenses are valid for purposes of the EAR, although a new recordkeeping requirement in Section 746.3 of the EAR applies (See item 6, below).
