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  • Criminal Penalties, Cuba Sanctions, OFAC

Voluntary Disclosure Leads to Criminal Prosecution (UPDATED)

SEE IMPORTANT UPDATE AT THE END OF THIS POST The headline to this post — “Voluntary Disclosure Leads to Criminal Prosecution” — will probably send a chill down the spine of every export and sanctions lawyer who reads this post.…

  • Clif Burns
  • March 18, 2010
  • 3 Comments
  • BIS, North Korea Sanctions

The Washington Times Makes a Shocking Discovery

Rev. Sun Myung Moon’s media arm, the Washington Times, has made a shocking discovery: lawyers represent clients. Washington Times reporter Jim McElhatton reveals this horrifying discovery in a piece he wrote on Eric Hirschhorn, the Obama administration’s nominee to head…

  • Clif Burns
  • March 17, 2010
  • 3 Comments
  • BIS, DDTC, Deemed Exports, Encryption

Obama Hints at Specific Export Reforms

Last week, in his speech before the Ex-Im Bank, President Obama provided some details about the specific export control reforms which might be in the offing. The first relates to our ludicrously archaic and burdensome system of encryption controls. Obama…

  • Clif Burns
  • March 15, 2010
  • 2 Comments
  • Cuba Sanctions

OFAC Returns To Its Senses On Cuba Ag Export Payments (Temporarily)

Yesterday the Office of Federal Assets Control (“OFAC”) published a notice in the Federal Register that reversed, at least temporarily, the absurd interpretation that it had adopted of the statutory requirement in the Trade Sanctions Reform and Export Enhancement Act…

  • Clif Burns
  • March 11, 2010
  • Iran Sanctions

GAO Report on Iran Sanctions Blasts OFAC’s Dead Tree Licensing System

The Government Accountability Office released a report last Thursday on the Iran Sanctions and there is, you might say, good news, bad news and old news in the report. First, the good news. The GAO’s audit of the licensing process…

  • Clif Burns
  • March 10, 2010
  • 5 Comments
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