Clif Burns

Clif Burns

Maybe My Dog Ate the Service Copy

The Bureau of Industry and Security (“BIS”) recently set aside a default judgment denying export privileges to S.P. Equipamentos de Protecao ao Trabalho Ltda (“SPE”), a Brazilian firm charged with violating U.S. export laws by re-exporting night vision equipment to…

No Cigar!

The Office of Foreign Assets Control (“OFAC”) yesterday released its monthly report on penalties imposed by the agency last month. And, for the first time since the invention of the Internet, no one got fined for buying Cohibas over the…

Nightmare on Compliance Street, Directed by BIS

If any company considering its first export transaction actually read and tried to understand the recordkeeping requirements of Part 762 of the Export Administration Regulations (“EAR”), it is unlikely that anything would ever be exported from the United States. And…

Better Late Than Never

Last week, on October 31, the Office of Foreign Assets Control issued a final rule amending the Sudanese Sanctions to permit exports to the semi-autonomous region of Southern Sudan. These rules implemented Executive Order 13412 issued by the White House…