Iran-a-palooza
Lots of news lately on Iran sanctions, so here’s a summary and some links. Here’s a link to the OFAC letter we mentioned last week disputing some of the charges made by the New York State Department of Financial Services…
We Apologize for the Inconvenience
ABOVE: DDTC offices in DC The Directorate of Defense Trade Controls (“DDTC”) has just revised its guidance on licensing foreign persons employed by U.S. persons. Foreign persons that will have access to ITAR-controlled technical data need to be licensed by…
Another Way Cigars Are Bad for You
If for some reason or other you were thinking that perhaps the next time you were in Dunhill’s in Paris or London you might just slip a few Cubans into your briefcase and bring them back to the U.S., think…
Another Exporter Trips over the Entity List
Two weeks ago I reported on a settlement agreement between two shipping companies and the Bureau of Industry and Security (“BIS”) with respect to unlicensed exports of scrap steel to People Steel Mill, a company in Pakistan on BIS’s Entity…
New Law Eliminates Foreign Sub Loophole in Iran Sanctions
The just-passed Iran Sanctions, Accountability, and Human Rights Act of 2012 for the most part merely decorates the Iran sanctions cake with a few more sprinkles and cherries, but one provision is likely to have a significant impact, namely the…