Comments on: iPods to Iran: A How-To Guide

By: JL

JL — Tue, 19 Feb 2008 10:10:31 +0000

That somebody can still think that the UAE is not known for that sort of operation is rather “interesting”. Besides “ignorance of the law is no excuse” as we would say back home

By: fred

fred — Tue, 19 Feb 2008 09:10:13 +0000

annmarie you state “It is clearly stated in the EAR and ITAR that it is the duty of the exporter to know and inquire about who is receiving their products”. However, smugglers obviously lie and so, despite the law or any precautions a company might take, they still can not control where their products will ultimately end up. The point of the WSJ article is that everyone’s products are in Iran.

By: Pamela

Pamela — Mon, 18 Feb 2008 19:55:02 +0000

I just have to say oh my goodness.

Red flags all over that and then some.

By: Frank

Frank — Thu, 14 Feb 2008 19:51:18 +0000

Ladyx - think of your comment as job security for all of the people who play in the compliance arena!

By: Ladyx

Ladyx — Thu, 14 Feb 2008 19:34:39 +0000

We, the people who play in the compliance arena, expect everyone to at least know that the EAR and ITAR exist. You wouldn’t believe how many Griffin Techs there are in the land….

By: Steve

Steve — Thu, 14 Feb 2008 19:04:51 +0000

Article appeared in the Journal today? Bet the next knock on Griffin’s door will not be yet another Valentines flower delivery !!

By: annmarie

annmarie — Thu, 14 Feb 2008 14:53:12 +0000

The comment of we don’t know where are products are going to end up really strikes a cord. It is clearlu stated in the EAR and ITAR that it is the duty of the exporter to know and inquire about who is receiving their products. They even give red flags to look for. ICE needs to step up and make an examples of exporters like these before one of these products comes back to bite us.

By: Clif Burns

Clif Burns — Thu, 14 Feb 2008 14:29:25 +0000

Mike, I agree that my viewpoint is one of an inside-the-beltway lawyer who counsels clients on compliance. And part of the purpose of this blog is to identify compliance issues to exporters who might not be aware of them.

That being said, I don’t think one could make a case that Griffin consciously flaunted the law based on what we know from the anecdote in the WSJ and that they may well be unaware of the EAR and red flags. That just means that, if true, Griffin shouldn’t be subject to a significant fine, although in theory they could be on the hook here for a $250,000 fine.

By: Mike Deal

Mike Deal — Thu, 14 Feb 2008 14:20:24 +0000

Clif: With respect, that’s a very within-the-beltway point of view. Griffin very likely hasn’t even heard of the EAR, let alone OEE’s “red flags”. The ICE RAIC in Nashville has barely heard of it, and doesn’t much care: Even the legacy Customs agents there are far more concerned with drugs and kiddie porn and avoiding being roped into immigration enforcement than with export controls. OEE’s WAFO, which has Tennessee in its territory, hasn’t held an outreach meeting or forum, in Nashville since 2003 and BIS cancelled its last scheduled seminar there. Although the local US FCS/ITA office offers its assistance to anyone who asks, few know to ask.