Clif Burns

Clif Burns

GAO Says EPA CRT Rule Is MIA

While some in the export community have charged the Bureau of Industry and Security (“BIS”), the Office of Foreign Assets Control (“OFAC”) and the Directorate of Defense Trade Controls (“DDTC”) of being overzealous in their enforcement activities, it is a…

And the Winner Is . . .

. . . the United Arab Emirates. With the publication today by the Bureau of Industry and Security (“BIS”) of the additions to the Entity List announced on Wednesday, the UAE moves into first place in terms of the single…

A Hard Lesson

The common wisdom is that the Directorate of Defense Trade Controls (“DDTC”) has a “see-through” rule for exports of defense articles, but that the Bureau of Industry and Security (“BIS”) does not have a see-through rule for exports of dual…