Clif Burns

Clif Burns

BIS Imposes Fine for Export of Coal to Newcastle

Well, close, but not exactly. The fine arose from export of bubonic plague toxins to Tanzania where, like coal in Newcastle, bubonic plague (both in the wild and in the laboratory) is plentiful. In the September 14 Federal Register, the…

Keystone Kops Krime Kontrols

An excellent article in the current Business Week underlines the indefensibility of current export controls imposed by BIS on commodities which are listed in the “Crime Control” category. But another striking form of tech commerce with China is taking place…

No More U-Turns for Bank Saderat

In today’s Federal Register, OFAC announced new restrictions it is imposing on Iran’s Bank Saderat. The bank, which is state-owned, is one of the largest banks in Iran. Under the new rules, effective retroactively to September 8, 2006, exceptions in…

BIS Liberalizes Policy on Exports to Libya

Right before the Labor Day Holiday, BIS issued amendments to the EAR which changed considerably the treatment of exports of items on the CCL to Libya. These changes were the inevitable result of the action of the State Department on…