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  • FARA, OFAC

DOJ Limits What Lawyers Can Say to OFAC without Registering as a Foreign Agent

Now that DOJ has started more actively prosecuting FARA violations, it decided to upload to its website a bunch of advisory opinions that apparently had been languishing in a file cabinet somewhere in the depths of Main Justice. Whether or…

  • Clif Burns
  • June 15, 2018
  • Foreign Countermeasures, Iran Sanctions, OFAC

EU Commission Menacingly Threatens Toothless Blocking Regulation

On June 6, the European Union Commission adopted a delegated regulation amending the Annex to Council Regulation (EC) No. 2271/96 of 22 November 1996.  Council Regulation (EC) No. 2271/96 is the notorious EU blocking regulation which forbids individuals and companies in EU…

  • Clif Burns
  • June 8, 2018
  • 3 Comments
  • General

DDTC’s Buzzer Beater to Save Brokering Authority over Firearms Misses the Hoop

As noted in my post yesterday on the proposed rules to transition certain Category I, II and III items from the United States Munitions List to the Commerce Control List, DDTC attempted to preserve its brokering authority over the transferred…

  • Clif Burns
  • May 16, 2018
  • BIS, CCL, DDTC, Export Reform, USMIL, USML

Export Control Reform Finally Announced for Guns and Ammo

The Directorate of Defense Trade Controls and the Bureau of Industry and Security today announced the proposed rules for the long awaited export control reform of Categories I, II and III of the United States Munitions List.  The proposed rules…

  • Clif Burns
  • May 15, 2018
  • BIS, CBP

CBP Sued Over Requiring Hold Harmless Agreement for Return of Seized Property

Okay, exporters, raise your hands if this has happened to you. You are exporting goods and some over excited and under informed U.S. Customs and Border Patrol Agent wrongfully seizes the item. For example, he decides that the EAR99 spark…

  • Clif Burns
  • May 11, 2018
  • 2 Comments
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