Comments on: The Boycotts from Brazil

By: FormerOFAC (and OAC)

FormerOFAC (and OAC) — Fri, 18 May 2007 21:46:49 +0000

Ah, OAC…. I made my trade compliance bones there under Bill and Dexter, parsing and stacking and pre-charging. Memories….

By: Clif Burns

Clif Burns — Thu, 17 May 2007 10:58:29 +0000

Mike, you are being uncharacteristically optimistic in believing that the charging letter and settlement agreement will provide any detail on the language at issue.

By: Mike Deal

Mike Deal — Thu, 17 May 2007 10:12:42 +0000

What makes the Cooper case particularly noteworthy is the low penalty, even for a voluntary disclosure. Perhaps I misread the press report, but if the violations were anything other than negative certificates, the penalties are lower than the usual 50% discount for voluntary disclosures that’s been in effect since the days of Bill Skidmore. Hopefully, the settlement and draft charging letter will be posted to the FOIA reading room soon so we can see the language at issue.