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	<title>Comments on: Washington Times Stumped by OFAC Regulations</title>
	<atom:link href="http://www.exportlawblog.com/archives/230/feed" rel="self" type="application/rss+xml" />
	<link>http://www.exportlawblog.com/archives/230</link>
	<description>Latest News on DDTC, BIS, OFAC, and other export law matters</description>
	<pubDate>Wed, 07 Jan 2009 12:06:14 +0000</pubDate>
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		<title>By: Mike Deal</title>
		<link>http://www.exportlawblog.com/archives/230#comment-4457</link>
		<dc:creator>Mike Deal</dc:creator>
		<pubDate>Wed, 03 Oct 2007 23:53:19 +0000</pubDate>
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		<description>S.1612 passed the House on a voice vote, and is headed to signature.</description>
		<content:encoded><![CDATA[<p>S.1612 passed the House on a voice vote, and is headed to signature.</p>
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		<title>By: Mike Deal</title>
		<link>http://www.exportlawblog.com/archives/230#comment-4338</link>
		<dc:creator>Mike Deal</dc:creator>
		<pubDate>Fri, 28 Sep 2007 19:08:46 +0000</pubDate>
		<guid isPermaLink="false">http://www.exportlawblog.com/archives/230#comment-4338</guid>
		<description>I never thought of the Moonie Times as main stream journalism.  Its more like Lush Rumbaugh.</description>
		<content:encoded><![CDATA[<p>I never thought of the Moonie Times as main stream journalism.  Its more like Lush Rumbaugh.</p>
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		<title>By: Mike Deal</title>
		<link>http://www.exportlawblog.com/archives/230#comment-4331</link>
		<dc:creator>Mike Deal</dc:creator>
		<pubDate>Fri, 28 Sep 2007 15:46:05 +0000</pubDate>
		<guid isPermaLink="false">http://www.exportlawblog.com/archives/230#comment-4331</guid>
		<description>The House Committee on Foreign Affairs approve s.1612, the International Economic Emergency Powers Enhancement Act, on Wednesday, with a request that it be brought to the floor under a suspension of rules for a voice vote, which is a good indication that no opposition is expected.  S.1612 raises the civil penalties for violation of IEEPA from $50,000 to $250,000, and the criminal penalties to $1,000,000 and 20 years in prison.  It has already passed the Senate, so unless there are any unexpected amendments on the floor of the House, once it passes the House it will go straight for signature and become law.  By an amendment added on the floor of the Senate, S.1612 provides that the increased IEEPA penalties will apply to any enforcement actions pending on the date of enactment, as well as violations that occur afterwards.  This provision may violate the  constitutional prohibition on ex post facto penalties.
For those who, like me, find the extension of the EAA under IEEPA to be of questionable legality, the Senate report notes that S.1612 should not be considered to be a substitution for revision and renewal of the EAA.</description>
		<content:encoded><![CDATA[<p>The House Committee on Foreign Affairs approve s.1612, the International Economic Emergency Powers Enhancement Act, on Wednesday, with a request that it be brought to the floor under a suspension of rules for a voice vote, which is a good indication that no opposition is expected.  S.1612 raises the civil penalties for violation of IEEPA from $50,000 to $250,000, and the criminal penalties to $1,000,000 and 20 years in prison.  It has already passed the Senate, so unless there are any unexpected amendments on the floor of the House, once it passes the House it will go straight for signature and become law.  By an amendment added on the floor of the Senate, S.1612 provides that the increased IEEPA penalties will apply to any enforcement actions pending on the date of enactment, as well as violations that occur afterwards.  This provision may violate the  constitutional prohibition on ex post facto penalties.<br />
For those who, like me, find the extension of the EAA under IEEPA to be of questionable legality, the Senate report notes that S.1612 should not be considered to be a substitution for revision and renewal of the EAA.</p>
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		<title>By: mous, anony</title>
		<link>http://www.exportlawblog.com/archives/230#comment-4307</link>
		<dc:creator>mous, anony</dc:creator>
		<pubDate>Thu, 27 Sep 2007 20:01:00 +0000</pubDate>
		<guid isPermaLink="false">http://www.exportlawblog.com/archives/230#comment-4307</guid>
		<description>Yes, actually.  We need say a LOT more.  The MSM is not some monolithic entity.  The world of journalism is not so black and white as "MSM=bad and blogs=good."  Despite this one very specific instance, there is a lot of smart investigative writing done by the MSM.  Just look at Rajiv Chandrasekaran and Dana Priest at the WashPost, just to name two.</description>
		<content:encoded><![CDATA[<p>Yes, actually.  We need say a LOT more.  The MSM is not some monolithic entity.  The world of journalism is not so black and white as &#8220;MSM=bad and blogs=good.&#8221;  Despite this one very specific instance, there is a lot of smart investigative writing done by the MSM.  Just look at Rajiv Chandrasekaran and Dana Priest at the WashPost, just to name two.</p>
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		<title>By: RS</title>
		<link>http://www.exportlawblog.com/archives/230#comment-4303</link>
		<dc:creator>RS</dc:creator>
		<pubDate>Thu, 27 Sep 2007 15:58:27 +0000</pubDate>
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		<description>It's the main stream media....need we say more?</description>
		<content:encoded><![CDATA[<p>It&#8217;s the main stream media&#8230;.need we say more?</p>
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		<title>By: Scott K.</title>
		<link>http://www.exportlawblog.com/archives/230#comment-4302</link>
		<dc:creator>Scott K.</dc:creator>
		<pubDate>Thu, 27 Sep 2007 13:54:28 +0000</pubDate>
		<guid isPermaLink="false">http://www.exportlawblog.com/archives/230#comment-4302</guid>
		<description>Besides "bad reporter", the banks might be in for a scolding as well;

"On all three occasions, the charities were advised by U.S. banks that the money was being held because the groups might be on a watch list maintained by the U.S. Treasury Department's Office of Foreign Asset Control (OFAC). "

The bank would certainly be able to say that the transaction ran afoul of a country sanction.</description>
		<content:encoded><![CDATA[<p>Besides &#8220;bad reporter&#8221;, the banks might be in for a scolding as well;</p>
<p>&#8220;On all three occasions, the charities were advised by U.S. banks that the money was being held because the groups might be on a watch list maintained by the U.S. Treasury Department&#8217;s Office of Foreign Asset Control (OFAC). &#8221;</p>
<p>The bank would certainly be able to say that the transaction ran afoul of a country sanction.</p>
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		<title>By: Shawn Wheatfill</title>
		<link>http://www.exportlawblog.com/archives/230#comment-4292</link>
		<dc:creator>Shawn Wheatfill</dc:creator>
		<pubDate>Thu, 27 Sep 2007 04:06:31 +0000</pubDate>
		<guid isPermaLink="false">http://www.exportlawblog.com/archives/230#comment-4292</guid>
		<description>I believe that type of reporting is considered to be within the genre of, "Drive-by Media". Sub-standard reporting perpetuates &#124;"silly"&#124; rhetoric by those, who read and trust Cajsa Collin, who see no value in the factual matters of OFAC's decision - I wonder if the editor ought to get a copy of your post Clif?</description>
		<content:encoded><![CDATA[<p>I believe that type of reporting is considered to be within the genre of, &#8220;Drive-by Media&#8221;. Sub-standard reporting perpetuates |&#8221;silly&#8221;| rhetoric by those, who read and trust Cajsa Collin, who see no value in the factual matters of OFAC&#8217;s decision - I wonder if the editor ought to get a copy of your post Clif?</p>
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