Clif Burns

Clif Burns

Blackwater Story Goes to the Dogs

After ABC News alleged that Blackwater was exporting weapons and other defense articles to Iraq hidden inside bags of dog food, Blackwater issued a press release with the following reply to that charge: Blackwater has never hidden anything inside a…

BIS Stab At Body Armor Definition Misses Mark

The Bureau of Industry and Security (“BIS”) recently released an advisory opinion stating that stab vests are classified under ECCN 1A005. That ECCN controls “body armor … not manufactured to military standards or specifications.” According to that advisory opinion: ECCN…

Scope Seller Winds Up in BIS’s Sights

Cabela’s, the mammoth hunting and outdoor supplies retailer, was recently smacked with an equally mammoth $680,000 fine by the Bureau of Industry and Security (“BIS”). The fine was paid by Cabela’s to settle charges that it exported rifle scopes without…

OFAC Cracks Down on U-Turns

The Office of Foreign Assets Control (“OFAC”) announced today that it was eliminating the general license for so-called U-turn transactions involving Iran. A U-Turn transaction, formerly permitted under section 560.516(a)(1) of the Iranian Transaction Regulations, is one which starts and…

BIS Warning Letters Lack Warnings

“Warning, Warning!!” The Electronic Freedom of Information Act Reading Room on the website of the Bureau of Industry and Security (“BIS”) has been recently updated and now includes anti-boycott warning letters for 2008. I’m not certain when the 2008 warning…