Clif Burns

Clif Burns

Missing Link Found

On Monday we complained about a broken link at the BIS website to its report of a settlement agreement entered into by Olympiad Line LLC, a Non-Vessel Operating Common Carrier (“NVOCC”). The link had been broken for almost a month.…

All in a Name

The Treasury Department announced today the imposition of sanctions on Iran’s fifth-largest state-owned bank, Bank Sepah, because of its financial support of Iranian firms engaged in nuclear and missile proliferation. According to Treasury, Bank Sepah has been involved, among other…

The Missing Link

Last month BIS added a new entry to the Hall of Shame: the BIS listing of export violations. The entry was for a case brought against Olympiad Lines LLC, an “NVOCC” in maritime speak (i.e., a Non-Vessel Operating Common Carrier,…

The Navy Made Me Do It

Lockheed Martin agreed in December to a $3 million civil penalty in connection with ITAR violations committed by its subsidiary Sippican. The order imposing the fine was entered on December 12. Sippican was involved in developing the electronic payload for…

A Penny Not Exported Is a Penny Saved

Just when you thought you had a pretty good idea of all the things that can’t be exported, the Treasury Department issued, on December 20, interim rules forbidding the export of pennies and nickels. The Department based its authority to…