A memorandum opinion of the Ninth Circuit, filed on March 30, 2012, reaches a somewhat paradoxical conclusion. It held that a party that had been indicted for violations of the Arms Export Control Act had no right, even though the…
Back when the Bureau of Industry and Security (“BIS”) was begging Congress to give it authority to increase the amount of penalties it could impose, it said that higher penalties would avoid the need for creative charging letters which allege…
Last week, the Office of Foreign Assets Control (“OFAC”) issued an interpretative guidance on section 560.545 of the Iranian Transactions Regulations which permits exports from the United States to Iran of services incidental to the exchange of personal information over…
A number of news reports, like this one, indicate that MV Eglantine was hijacked by Somali pirates yesterday near the Maldives and about 460 nautical miles west south west of India’s Cape Comorin. The scene of the hijacking was 1,800…
A report from the Associated Press suggests that private military and security companies providing protection to commercial shipping in pirate-infested waters have come up with a novel way of arming themselves without running into import and export restrictions of countries…