ABOVE: Cyan Headquarters Today’s question is this: say you are a UK-based company that manufactures a product with U.S.-origin content which you want to sell to Iran? How do you do it? According to this article, you sell the stuff…
We have followed the saga of Epsilon Electronics extensively, beginning with the The Auto Sound and the OFAC Fury Part I and Part II and ending most recently with Epsilon, Epsilon. Well, it seems that the story may be drawing to…
The Bureau of Industry and Security (“BIS”) is placing Chinese telecom giant ZTE (and three related companies) on the Entity List tomorrow according to this pre-release version of the Federal Register notice announcing the action. As a result, all items…
ABOVE: Erdal Kuyumcu Erdal Kuyumcu, the CEO of Global Metallurgy LLC, was indicted this week on charges that he shipped an EAR99 chemical to Iran through a middleman in Turkey. The criminal complaint provides the details of the government’s case,…
I have spoken before about the weirdness surrounding the E.O. 13599 List, which has some (but unaccountably not all) of the entities controlled by the Government of Iran that were removed by the Office of Foreign Assets Control from the…