Clif Burns

Clif Burns

Export Control Reform For and By Dummies

Having ignored the export control reforms initiated by the executive branch over the last seven or so years, the geniuses on the Hill have now decided to wade into the field with, as you might imagine, not entirely salubrious results.…

I’ll See You in C.U.B.A.

Several people have been wondering if I would write something about the allegation that Trump may have violated the Cuban embargo back in 1998. This blog expresses no opinion on political campaigns or figures, so I hesitate to wade into…

If It Were Real, It Wouldn’t Be “Deemed”

The Fifth Circuit last week released an opinion upholding the District Court’s decision not to grant Defense Distributed’s motion for a preliminary injunction.  Defense Distributed had sought a preliminary injunction against enforcement by the Directorate of Defense Trade Controls (“DDTC”) of its order prohibiting the…

Bad News For Anyone Named Paul Davis

ABOVE: Paul Davis Yesterday, the Office of Foreign Assets Control (“OFAC”) designated PacNet Services, a Canadian payments processing company, and many of its officers and employees as SDNs under the Transnational Criminal Organization (TCO) program. According to OFAC’s press release,…