Clif Burns

Clif Burns

New Processing Time Exception Announced by DDTC

The Directorate of Defense Trade Controls (“DDTC”) published today in the Federal Register a Notice indicating that it was adding a sixth exception to National Security Presidential Directive–56 which mandated a 60-day processing time for export license applications. According to…

Answered Prayers (Part 2)

In addition to changing the definition of “broker,” the proposed new rules under Part 129 of the International Traffic in Arms Regulations expand the jurisdictional reach of those rules over foreign persons. Part 129 currently covers brokering activities by U.S.…

Answered Prayers

As the saying goes, more tears are shed over answered prayers than unanswered ones. And a sad example of this may be the amendments that the Directorate of Defense Trade Controls (“DDTC”) has proposed to the definition of brokering activities…

Update to 11/25/09 Post

The previous post, dated November 25, quoted an article in Crain’s Chicago Business in which an export attorney was quoted as saying: “At the very least, you should have your freight forwarder check compliance, so if they identify a problem,…

Worst. Advice. Ever.

The title of this post is not really meant to be hyperbole. The advice given in Crain’s Chicago Business in an article titled “Liars and terrorists and drug traffickers, oh my!” is without doubt the single worst piece of advice…