How is BIS implementing the arms embargo?
As described above, Section 746.3 of the EAR imposes a license requirement for all items controlled on the Commerce Control List for UN reasons. Furthermore, any item that requires a license for export or reexport to Iraq, or transfer within Iraq, that is destined for Iraqi civil nuclear or military nuclear activity (except for use of isotopes for medical, industrial or agricultural purposes) are subject to a policy of denial. Additionally, machine tools controlled for national security (NS) or nuclear non-proliferation (NP) reasons, as well as any items controlled for crime control (CC) or United Nations (UN) reasons or ECCNs that end in the number “018”, that would make a material contribution to the production, research, design, development, support, maintenance or manufacture of Iraqi weapons of mass destruction, ballistic missiles or arms and related matériel are subject to a general policy of denial. In addition, a license is required for the export, reexport or transfer of items
