OPINION

WARDLAW, Circuit Judge:

These consolidated cross-appeals arise from a challenge to

the pre-2003 United States sanctions prohibiting both travel to

and the unlicensed donation of humanitarian medical supplies

to Iraq. We affirm the district court’s decision that Bertram

Sacks has standing to challenge the ban on travel and that the

travel ban regulation was validly promulgated. Sacks fails,

however, to demonstrate a concrete and imminent likelihood

that he will be penalized for violations of the restriction on

medical donations. Therefore, his challenge to the restriction

on medical donations does not fulfill the constitutional

requirements of standing and ripeness. We also affirm the district

court’s holding that the Office of Foreign Assets Control (OFAC)

regulation in effect at the time prohibited the government from

referring Sacks’s unpaid penalty to a private collection agency.