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  • BIS, Civil Penalties, Entity List

BIS, For One, Does Not Welcome Our New Robot Overlords

The Bureau of Industry and Security (“BIS”) recently announced that Pilot Air Freight had agreed to a $175,000 fine ($75,000 of which was suspended) to settle charges that it had aided and abetted an attempted unlicensed export by one of…

  • Clif Burns
  • December 7, 2017
  • Iran Sanctions, OFAC

OFAC Issues Finding of Violation to Foreign Ship Registry for Dealings with Iran

Last Tuesday the Office of Foreign Assets Control (“OFAC”) issued a “finding of violation” (but not a fine) against the Dominica Maritime Registry (“DMR”) for entering into a “Binding Memorandum of Understanding” with the National Iranian Tanker Company (“NITC”), an…

  • Clif Burns
  • December 5, 2017
  • Cuba Sanctions, Foreign Countermeasures, General, OFAC

OFAC Fines Foreign Company for Following Applicable Foreign Law

The Office of Foreign Assets Control (“OFAC”) recently announced that it has extracted $204,277 from American Express as a result of 1,818 credit card transactions in the amount of $583,649.43 for purchases made in Cuba. At issue were Mastercard and…

  • Clif Burns
  • December 1, 2017
  • 1 Comment
  • OFAC, SDN List, Zimbabwe Sanctions

Mugabe Leaves, Mnangagwa Arrives, Sanctions Remain

ABOVE: Emmerson Mnangagwa Last Tuesday, while you were thinking about the upcoming Thanksgiving holiday, Robert Mugabe, who has been dictator of Zimbabwe for the last 37 years, resigned.  Then while you were storming the doors of a local brick and mortar on Black…

  • Clif Burns
  • November 27, 2017
  • BIS, CFIUS, DDTC

Proposed CFIUS Legislation: Good News for Cattle Prod Makers, Bad News for Cows

On November 8, 2017, the House and Senate introduced the Foreign Investment Risk Review Modernization Act of 2017 (FIRRMA) proposing the first amendments to the CFIUS process since the Foreign Investment and National Security Act was passed in 2007. Although…

  • Clif Burns
  • November 17, 2017
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