Clif Burns

Clif Burns

Mystery Solved (Maybe)

In a post back in December titled “Imaginary Numbers,” I noted that the list of commodity jurisdiction determinations by the Directorate of Defense Trade Controls had some puzzling entries: Three entries on the list, two for a high mobility electron…

FedEx Agrees To Pay $370,000 Export Penalty

Federal Express has agreed to pay to the Bureau of Industry and Security (“BIS”) a penalty of $370,000 in connection with charges that it aided and abetted one export and five attempted exports between 2004 and 2006 without required export…

We’re Not Done Yet

Another problem with the arms brokering regulations proposed by the Directorate of Defense Trade Controls (“DDTC”) is their jurisdictional scope, which is impossibly vague and far exceeds the scope of permissible regulation under the Brokering Amendment which was passed by…