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…
The Bureau of Industry and Security has announced that, starting on December 8, a new license condition will appear on all validated licenses. That condition reads as follows: Unless limited by a condition set forth below, the export, reexport or…
In an advisory opinion dated November 13, 2014, the Bureau of Industry and Security (“BIS”) rode once again into the cloud computing breach to confront the tricky metaphysical question of when software that lives in the cloud is exported. At…
In our prior post on the Russia sanctions and export of equipment to be used in oil production and exploration in shale, we noted that BIS had not yet weighed in on whether its export ban, like OFAC’s restriction, covered…
OFAC today released a new FAQ on the Ukraine Sanctions and shale formations. The purpose of FAQs, at least outside the Treasury Department, is to present clear and concise answers to resolve questions that many people might have. OFAC seems…