Fun Furlough Facts
So, you may be wondering which export agencies are up and which are down now that the Federal Government is shutdown. The answer isn’t altogether clear at this point (still!) but here is what appears to be the current rundown…
Clif Burns
Treasury’s Bore
Juan Zarate’s new book on OFAC, Treasury’s War, is a crashing bore and I have to admit that about half way into it I gave up. Zarate had taken my money to buy the book; I wasn’t going to let…
Say It’s Not So, Joe
ABOVE: Joe Wolverton II J.D. Various press reports have suggested that the White House recently waived restrictions on providing arms to the Syrian rebels, but a review of the Presidential Determination itself reveals something much more limited. In fact, the…
I’m Going to Disney World!
You may think of “I’m Going to Disney World!” as an iconic slogan from a Superbowl ad, but in many cases they are instead the famous last words of foreign export defendants. Consider Sergei Baltutski, a Belarusian, who said this…
First Thing We Do, Let’s Register All the Lawyers
One of the issues that has haunted the efforts by the Directorate of Defense Trade Controls (“DDTC”) to amend its brokering rules has been what to do with lawyers. Are lawyers that assist their clients with transactions involving defense articles brokers…