The pardon has to be for specific actions of a specific person, though the actions can be broadly defined (again, I point to Nixon).
I simply cannot see how being the shipping broker for the oil-for-food scandal would fit under his pardon, and even if it did, it could be successfully argued that each new manifest was a new criminal violation and would thus be outside the terms of his pardon as the events are known to have started in February 2001.
Afternoon.