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  • Iran Sanctions, OFAC

OFAC v. ATP: Game, Set, Match to OFAC

In its quest to keep the world safe from an Iranian nuclear bomb, the Office of Foreign Assets Control has focused its laser-like scrutiny on an Iranian tennis referee. Obviously, the same skills required to call a ball out or…

  • Clif Burns
  • June 25, 2013
  • 1 Comment
  • Criminal Penalties, DoJ, Economic Sanctions, FCPA, Iran Sanctions, OECD, SEC

FCPA Totally Useful As a Secondary Sanctions Program

The U.S. Department of Justice recently announced that Total, S.A., the French oil and gas company, agreed to pay $245.2 million to resolve charges that it paid bribes to an Iranian government official by way of purported consulting agreements from…

  • George Murphy
  • June 17, 2013
  • 1 Comment
  • BIS, OFAC, Syria

Syria Sanctions Loosened To Benefit Rebels and Civilian Population

ABOVE: Destruction in Homs, Syria Just as the Assad government appears to be gaining ground back from the rebels, the White House announced certain measures loosening the sanctions on Syria. Yesterday, BIS issued a notice on its website that it would…

  • Clif Burns
  • June 13, 2013
  • General

Section 219 Iran Notices: Down the “Affiliate” Slippery Slope

ABOVE: Carlyle Group DC HQ A major headache in complying with the notice requirement in section 219 of the Iran Threat Reduction and Syria Human Rights Act of 2012 has been determining the scope of the statutory requirement for publicly…

  • Clif Burns
  • June 12, 2013
  • Export Reform

Export Control Reform Roundtable in Boulder

Next Tuesday, June 11, I’ll be in Boulder leading a round-table discussion on export control reform. And the best part: it’s free. So, if you’re in the area, please feel free to come and join in. The format for the…

  • Clif Burns
  • June 6, 2013
  • 2 Comments
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