http://www.exportlawblog.com/archives/943 Latest News on DDTC, BIS, OFAC, and other export law matters Thu, 11 Mar 2010 17:15:53 +0000 http://wordpress.org/?v=2.9.1 hourly 1 http://www.exportlawblog.com/archives/943/comment-page-1#comment-91972 Hillbilly Mon, 23 Nov 2009 15:33:09 +0000 http://www.exportlawblog.com/?p=943#comment-91972 Having been a practitioner, internal compliance, and enforcer, it continues to amaze me how many companies that go to the effort to classify their end-products nonetheless fail to classify parts, components and production equipment even when exporting the goods or the technology to their foreign subsidiaries, even nearly a decade after the Alcoa case in which the ALF ignored the government's suggested peanlty level and imposed the maximum fines for "undocumented" shipments of precursors to subsidiaries and contract manufacturers in non-Australia Group countries. There is a persistent false assumption that shipments to subsidiaries are not exports, or are at least somehow exempt. This false assumption persists even among some very large Fortune 500 (R) companies. Having been a practitioner, internal compliance, and enforcer, it continues to amaze me how many companies that go to the effort to classify their end-products nonetheless fail to classify parts, components and production equipment even when exporting the goods or the technology to their foreign subsidiaries, even nearly a decade after the Alcoa case in which the ALF ignored the government’s suggested peanlty level and imposed the maximum fines for “undocumented” shipments of precursors to subsidiaries and contract manufacturers in non-Australia Group countries. There is a persistent false assumption that shipments to subsidiaries are not exports, or are at least somehow exempt. This false assumption persists even among some very large Fortune 500 (R) companies.

]]> http://www.exportlawblog.com/archives/943/comment-page-1#comment-91962 Jeroop Fri, 20 Nov 2009 14:59:26 +0000 http://www.exportlawblog.com/?p=943#comment-91962 Well done, Clif! Next to the de minimus rule, this is one of the least-understood elements of the EAR by practitioners and industry alike. Hopefully your angle on this case will make waves within industry. Well done, Clif! Next to the de minimus rule, this is one of the least-understood elements of the EAR by practitioners and industry alike. Hopefully your angle on this case will make waves within industry.

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