Clif Burns

Clif Burns

Naming Names

The Bureau of Industry and Security has released new guidance on deemed re-exports which is intended to deal with issues arising when a U.S. company exports technology to a foreign company that then re-exports that technology to its own employees…

Good Luck Collecting That Fine

The Office of Foreign Assets Control (“OFAC”) recently announced a whopping $1.5 million fine against “Alma Investment LLC, a UAE-based investment and advising company” for violations of U.S. sanctions on Iran. Since the case involved six electronic funds transfers for…