Clif Burns

Clif Burns

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…

Cuba Study Provider Settles OFAC Charges

According to the latest civil penalty information released by the Office of Foreign Assets Control (“OFAC”), the Center for Cross-Cultural Studies (“CC-CS”), a Massachusetts-based company specializing in arranging university study programs abroad, agreed to pay $15,000 to settle allegations that…

Nice Work, If You Can Get It

An indictment was returned on October 28, charging three men with conspiring to export carbon-fiber material to the China Academy of Space Technology (“CAST”). Certain types of carbon-fiber materials are covered by ECCNs 1A002, 1C010, 1C210, and 1C990. The DOJ…

BIS Fries Rice

The Office of Antiboycott Compliance of the Bureau of Industry and Security (“BIS”) released a settlement agreement that it recently entered into with American Rice, Inc., pursuant to which American Rice agreed to pay $30,000 to settle charges that American…