As regular readers probably know, the Office of Foreign Assets Control (“OFAC”) has issued a list of medical devices and items that are eligible to be exported to otherwise sanctioned countries under a general license, such as this list of medical devices and items that can be exported to the Crimea region of Ukraine.
There has been considerable criticism of these lists because of what appears to be arbitrary omissions of necessary and common medical items that should be eligible for a general license. But no one has put it better than Kathleen Palma, GE’s senior counsel for international trade compliance, did on Monday at meeting of the President’s Export Council Subcommittee on Export Administration [WARNING: EXPLICIT LANGUAGE AHEAD! NSFW!!] when she said this:
I would note that condoms are on the list but baby warmers and units for neonatal intensive care are not on the list.
Unflustered, an OFAC official at the meeting said that the agency was in the process of reviewing proposals to add more items to the list. No time frame, other than sometime before the zombie apocalypse, was given, nor was any indication offered of what items might be added.