Comments on: A Cotton-Pickin’ Shame http://www.exportlawblog.com/archives/223 Latest News on DDTC, BIS, OFAC, and other export law matters Thu, 09 Sep 2010 18:58:42 +0000 hourly 1 http://wordpress.org/?v=3.0 By: Clif Burns http://www.exportlawblog.com/archives/223/comment-page-1#comment-3953 Clif Burns Tue, 11 Sep 2007 22:28:14 +0000 http://www.exportlawblog.com/archives/223#comment-3953 Mike - I am not sure that a lawyer drafted the Parkdale reply mainly because it was filed something like 4 days after the prepenalty notice was received. I think Parkdale would have been better to have said that it was a breakdown of internal compliance procedures and that it had strengthened those procedures and educated its buyers. Mous, anony -- section 538.210 of the Sudan regs makes an attempt a violation. Clearly, though, OFAC sees an attempt as a less serious offense and takes it into accout as a mitigating factor Mike – I am not sure that a lawyer drafted the Parkdale reply mainly because it was filed something like 4 days after the prepenalty notice was received. I think Parkdale would have been better to have said that it was a breakdown of internal compliance procedures and that it had strengthened those procedures and educated its buyers.

Mous, anony — section 538.210 of the Sudan regs makes an attempt a violation. Clearly, though, OFAC sees an attempt as a less serious offense and takes it into accout as a mitigating factor

]]> By: mous, anony http://www.exportlawblog.com/archives/223/comment-page-1#comment-3951 mous, anony Tue, 11 Sep 2007 21:44:04 +0000 http://www.exportlawblog.com/archives/223#comment-3951 I'm relatively new to this field. Is an ATTEMPT to import, with no actual importing actually occurring, still a violation? I’m relatively new to this field. Is an ATTEMPT to import, with no actual importing actually occurring, still a violation?

]]> By: Mike Deal http://www.exportlawblog.com/archives/223/comment-page-1#comment-3949 Mike Deal Tue, 11 Sep 2007 21:25:39 +0000 http://www.exportlawblog.com/archives/223#comment-3949 Clif: Thou dost violate the 11th Commandment, never criticize another lawyer, especially if the argument worked (25% mitigation probably paid his or her fee). Counsel probably wisely figured that the Yankees at OFAC thought all of us Southerners are stupid rednecks and would accept at face value the assertion that we don't read. Clif: Thou dost violate the 11th Commandment, never criticize another lawyer, especially if the argument worked (25% mitigation probably paid his or her fee). Counsel probably wisely figured that the Yankees at OFAC thought all of us Southerners are stupid rednecks and would accept at face value the assertion that we don’t read.

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