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  • OFAC, Zimbabwe Sanctions

We Read the Zimbabwe Herald So You Don’t Have To

ABOVE: Robert Mugabe The Zimbabwe Herald, the alleged newspaper and confirmed propaganda organ of the sanctioned Mugabe regime, is all excited by the launch of the China International Payment System (CIPS). The system, which was launched earlier this month, seeks…

  • Clif Burns
  • October 13, 2015
  • North Korea Sanctions

New Sanctions Against the Norks Introduced in Congress

Yesterday Senator Cory Gardner introduced S.2144, entitled the “North Korea Sanctions Enforcement Act.” (The official text of the proposed bill is not yet available at congress.gov but a discussion draft can be found here.) Not surprisingly, the new bill seems…

  • Clif Burns
  • October 7, 2015
  • DDTC

That Was Then; This is Now: DDTC’s Shifting Definition of “Public Domain”

As discussed here in a previous post, the proposed definition of “public domain” by the Directorate of Defense Trade Controls (“DDTC”) has a Catch-22. Information that is in the “public domain,” i.e. information that has been published on the Internet…

  • Clif Burns
  • October 6, 2015
  • 1 Comment
  • Cuba Sanctions, OFAC

Cuba Sanctions Confuse Miami Television Station

The NBC affiliate in Miami on September 29 issued an “investigative report” with the title “Millions of Dollars Sent to Cubans Abroad Being Blocked by U.S. Government.”  It starts as follows: As the U.S. continues to ease sanctions against Cuba,…

  • Clif Burns
  • October 2, 2015
  • BIS, Iran Sanctions, OFAC

Voluntary Disclosure Serves as Chum for Derivative Suit Plaintiffs’ Lawyers

An unfortunate issue for publicly traded companies that file voluntary disclosures is what seems to be an increasing trend: plaintiffs’ lawyers specializing in derivative shareholder suits circling the company looking for a kill. This seems to be particularly true if…

  • Clif Burns
  • September 28, 2015
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