Nightmare on Compliance Street, Directed by BIS

If any company considering its first export transaction actually read and tried to understand the recordkeeping requirements of Part 762 of the Export Administration Regulations (“EAR”), it is unlikely that anything would ever be exported from the United States. And…

Better Late Than Never

Last week, on October 31, the Office of Foreign Assets Control issued a final rule amending the Sudanese Sanctions to permit exports to the semi-autonomous region of Southern Sudan. These rules implemented Executive Order 13412 issued by the White House…

Microwave Power Modules Added to CCL

Almost a year after the last plenary of the Wassenaar Arrangement approved and adopted changes to the Wassenaar List of Dual-Use Goods and Technologies, the Bureau of Industry and Security (“BIS”) yesterday released a final rule implementing those changes on…

There’s No Place Like Home

A criminal complaint was filed yesterday in federal court in Newark against Xu Bing, a Chinese national and resident of Nanjing, for attempted export of night vision equipment to China. Not surprisingly, the arrest was the result of a sting…