Clif Burns

Clif Burns

Don’t Forget Croatia

Yesterday, the Bureau of Industry and Security (“BIS”) announced various amendments to the encryption rules. I realize that the encryption rules are a sprawling mess, scattered through various sections of the EAR and written in an incomprehensible jargon that sounds…

Get in Line

OFAC just released reports for the second, third and fourth quarters of 2015 on its licensing activities under the Trade Sanctions Reform and Export Enhancement Act of 2000 (“TSRA”). These reports are required by TSRA, although they are required in…

Flowers for Ahmadinejad

The Office of Foreign Assets Control (“OFAC”) today fined a company a whopping $4,320,000 for selling things to Iran. Oh wow, you say, this must have been some really bad stuff like, say, high-powered computers or drones, right? Yep, really…