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United States Department of Agriculture	April 6, 2000
Farm and Foreign Agricultural Services	MAP 00-005 FMD 00-005
Foreign Agricultural Services	SUBJECT: TO:	Procedures for Proposing Market Development Activities in Iran, Libya, Sudan, and Cuba All MAP Participants and FMD Cooperators

1400 Independence Ave., SW Stop 1042 Washington. DC 20250-1042	BACKGROUND:	For several years, FAS has issued program notices listing countries in which market development activities under MAP and FMD were forbidden due to economic sanctions. Recent policy and regulatory changes now allow licensed commercial sales of agricultural commodities and products to Iran, Libya, Sudan, and Cuba.

	POLICY:	Program participants, if properly licensed by the U.S. Department of Treasury=s Office of Foreign Asset Control (OFAC), can conduct market development activities in Iran, Libya, Sudan, and Cuba. Program participants are responsible for determining which licenses are necessary and for acquiring those licenses. When a cooperator/participant applies for an OFAC license to perform a market development activity in a sanctioned country, OFAC reviews the proposed activity against its regulations. If OFAC determines a proposal is legal under its regulations, the proposal is forwarded to the Department of State (State) for general foreign policy review. If an activity is proposed to be reimbursed under one of FAS= foreign market development programs, State must also review whether U.S. government funding of the activity is consistent with U.S. foreign policy. State reviews OFAC referrals on a case-by-case basis, and no blanket approvals of a class of activity will be given. To expedite the review process, FAS will provide proposed MAP/FMD activities which it deems appropriate directly to State so they can begin their review in advance of receiving the OFAC referral. Market development activities in Iraq and North Korea remain forbidden under MAP and FMD.
	PROCEDURES:	First, a participant should contact OFAC=s licensing division at (202) 622-2480 to determine which licenses are necessary and initiate the licensing process. A participant then should submit to its commodity division a proposal containing country information, market analysis, constraint and activity descriptions, etc. This submission is required whether the participant is requesting reimbursement with CCC funds or proposing to use its own funds to claim as a program contribution. Unlike activities in non-sanctioned countries, FAS approval will be necessary for each activity undertaken. OFAC and State review all proposals on a case-by-case basis, i.e., there are no blanket approvals. The commodity division will provide a copy of the proposal to the Marketing Operations Staff (MOS) and each office will begin its review. As appropriate, the commodity division will work with the participant and the Agricultural Marketing Service to determine if checkoff or marketing order funds can be used to fund the proposed activity. MOS will promptly contact State and provide a copy of the proposal so that State can review the proposed activity and our reimbursement, if proposed. MOS will provide the commodity division with the result of the State and OFAC reviews and any other pertinent information that has been gathered. MOS will serve as the central contact point so that the other agencies are not receiving calls from dozens of FAS personnel. FAS will then complete its review of the proposal, and the commodity division will promptly inform the participant of the determination.
	KENT D. SISSON Director Marketing Operations Staff

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