Clif Burns

Clif Burns

OFAC Gives Two Thumbs Down to Oliver Stone Film

Tucked away in the penalty notices released by OFAC last week was this typically terse and unhelpful entry: IXTLAN Corporation and Four Individuals Settle Cuban Embargo Allegations: IXTLAN Corporation, Santa Monica, California (“IXTLAN”), and four individuals have agreed to a…

Shake, Rattle and Roll

I was going to title this post “Exporter Temporarily Loses Export Privileges for Having Copy of the EAR in Its Offices.” However, after the uproar that a similar title (“BIS Fines Exporter for Filing Voluntary Disclosure“) created at BIS, I…

No More Nanos for Pyongyang

A headline to an article in today’s Washington Post breathlessly announced: “U.S. Bans Sale of iPods to North Korea.” The copy editor at the WaPo, however, jumped the gun since the ban is not yet in place. The article was…