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	<description>Latest News on DDTC, BIS, OFAC, and other export law matters</description>
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		<title>Florida Man Charged With &#8220;Brokering&#8221; His Own Defense Exports</title>
		<description>This recently unsealed criminal complaint against a Florida man shows that the FBI agents and the federal prosecutors haven't a clue as to the correct reading of the definition of a "broker" in Part 129 of the International Traffic in Arms Regulations (the "ITAR").  In fact, it appears that ...</description>
		<link>http://www.exportlawblog.com/archives/335</link>
			</item>
	<item>
		<title>Weatherford in Cuba</title>
		<description>An article in today's CNN Money contains some interesting tidbits about Weatherford's operations in sanctioned countries, which we first reported here, and which have been the subject of a governmental investigation.    

First, the article notes that Weatherford's divestment of its operations in Sudan allowed it to donate ...</description>
		<link>http://www.exportlawblog.com/archives/334</link>
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		<title>Is There A Secret United States Munitions List?</title>
		<description>A magistrate hearing pretrial motions in the criminal export case against Doli Syarief Pulungan wondered in a recently issued  Report and Recommendation1 whether there might be a secret version of the USML which lists actual items rather than categories of items.  Of course it's impossible for me to ...</description>
		<link>http://www.exportlawblog.com/archives/333</link>
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		<title>Man Bites Dog? (Part 2)</title>
		<description>Mr. Sasan Azodi, mentioned in yesterday's post, called me just a few minutes ago to give me his side of the dispute between him and Dräger Safety as to who was at fault for the export of the VisioWave security monitoring software to Iran.  As you may recall, I ...</description>
		<link>http://www.exportlawblog.com/archives/332</link>
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	<item>
		<title>Man Bites Dog?</title>
		<description>When companies wind up with products in Iran, they usually claim that they were hoodwinked by their overseas sales reps or agents.  In a case involving the German security firm Dräger Safety, the situation appears reversed.  According to this article in Deutsche Welle, Dräger's agent is claiming that ...</description>
		<link>http://www.exportlawblog.com/archives/331</link>
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		<title>Give Pearls Away and Rubies</title>
		<description>Today the Office of Foreign Assets Control ("OFAC") added three Burmese entities to the Specially Designated Nationals and Blocked Persons List, i.e., the SDN List.  Among the three entities was the Myanmar Gem Enterprise, the state-owned monopoly that is in charge of gem sales in Burma.  As you ...</description>
		<link>http://www.exportlawblog.com/archives/330</link>
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		<title>Engineering Dynamics Agrees to $132,791.39 Penalty for Sales to Iran</title>
		<description>The Bureau of Industry and Security ("BIS") released yesterday a Settlement Agreement with Engineering Dynamics, Inc., a Louisiana-based company that writes and distributes computer-assisted design software used for the design of oil and gas drilling platforms and rigs.  Under the Settlement Agreement, Engineering Dynamics admitted to a one-count charge ...</description>
		<link>http://www.exportlawblog.com/archives/329</link>
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		<title>DDTC Announces New License Documentation Requirements</title>
		<description>Yesterday the Directorate of Defense Trade Controls ("DDTC") announced new documentation requirements for export licenses.  Failure to meet this requirement can result in an export license being returned without action although DDTC says that for an "interim" period of unspecified length it will decide on a case-by-case basis whether ...</description>
		<link>http://www.exportlawblog.com/archives/328</link>
			</item>
	<item>
		<title>The Sweet Power of Music</title>
		<description>The Wall Street Journal's Law Blog had an interesting post last Friday regarding Iranian santurs (a dulcimer-like instrument) that a UCLA professor of ethnomusicology had been importing from Tehran.  These instruments had been sailing through customs until last August when somebody in customs woke up and seized the instruments. ...</description>
		<link>http://www.exportlawblog.com/archives/327</link>
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		<title>Bag and Baggage</title>
		<description>A recent settlement agreement between the Bureau of Industry and Security ("BIS") with Miami-based Aviktor Trading Corporation involved both a charge of an unlicensed export of a thermal imaging camera and a charge of failure to file a Shipper's Export Declaration.  The latter charge is fairly rare.  After ...</description>
		<link>http://www.exportlawblog.com/archives/326</link>
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