Oct

3

Shutdown Blues


Posted by at 6:52 pm on October 3, 2013
Category: General

Based on photograph By Daderot (Own work) [CC0], via Wikimedia Commons http://commons.wikimedia.org/wiki/File%3APatent_quote_-_United_States_Department_of_Commerce_-_DSC05103.JPGMore on the 2013 shutdown and export issues:

Commerce: BIS yesterday updated its website to inform exporters that the SNAP-R licensing page was closed until the government shutdown is ended. Emergency license applications will be accepted but only if justified on grounds of national security. It is probably safe to say that your need to export cattle prods to Estonia won’t meet that standard.

Treasury: News reports (like this one) indicate that the offices of OFAC have been pretty much emptied out by the shutdown. The folks on the Hill are lamenting that these means that OFAC won’t be deterring Iran from its nuclear ambitions. No one seems to mention that it also means that means that medicines and medical devices not covered by the general licenses but eligible for specific licenses won’t be making it to Iran. No big surprise there, I suppose.

State: DDTC is still saying it has staff through Friday, October 4, and only emergency licenses after that.

With export licensing and classification decisions shut down for the duration, you have to wonder whether the result of the Shutdown of 2013 will be a bumper crop of voluntary disclosures in the same way that there was a bumper crop of babies after the Great Blackout of 1965*

*Yes, I know that’s an urban legend.

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2 Comments:


I saw a similar question to your VSD rhetorical one. If an exporter is left to rely on their printed regs. because they don’t have access to a more recent version. Is that a defense if they do something wrong due to a change?

Comment by LDM on October 3rd, 2013 @ 7:19 pm

    The current versions of all the export regulations are currently still available on the websites. Only the HTSUS and Schedule B are down at the moment.

    Comment by Clif Burns on October 3rd, 2013 @ 11:18 pm