The Bureau of Industry and Security (“BIS”) has issued rules governing exports to Crimea and there’s good news and bad news. The bad news (for exporters): the BIS rule is incomprehensibly written and, arguably, may require you to have a…
The recent OFAC amendments to the Cuba embargo regulations, and related statements by OFAC, went to great pains to make clear that, notwithstanding these changes, the embargo was still in place. That being said, it is somewhat perplexing that the…
The recent revisions to the U.S. sanctions on Cuba has generated a great deal of press coverage and, not surprisingly, more enthusiasm than accuracy. Here are a few bloopers I’ve seen recently. The NBC outlet in Miami announced that the…
Some of you may know that, when I have spare time, I like to spend it behind the lens of a camera, so I was a bit dispirited to see a recent enforcement action by the Bureau of Industry and…
Breaking News: the Commerce Department has finally figured out how the Internet works. Or, perhaps more accurately, the Commerce Department has figured out that clouds aren’t just fluffy things that float in the sky from time to time. Readers of…