More APO/FPO Export Confusion

If there is anything that qualifies as a true urban legend in the export areas, it’s the surprisingly widespread belief that shipments to overseas APO and FPO addresses aren’t exports. Of course, that’s no more true than the belief that…

Oh Where, Oh Where, Has My CCL Gone?

Let’s say that you were an agency like the Bureau of Industry and Security (“BIS”) and you had a huge and complex list of sensitive items that needed a license for export. Now, unless your administrative goal was to collect…

Once More Unto the Breach

The Bureau of Industry and Security (“BIS”) previously did battle with cloud computing in an advisory opinion it released in January 2009. Almost two years later BIS charges into battle yet again, and yet again there is no clear victor.…