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  • OFAC

NYDFS Disciplines Consulting Group for Engaging in Legal Analysis

The saga of the over-reaching New York Department of Financial Services (“NYDFS”) and Standard Chartered Bank, chronicled on this blog here, here, and here, is the blogging gift that just keeps on giving. Standard Chartered Bank hired Promontory Financial Group…

  • Clif Burns
  • August 10, 2015
  • OFAC

I’m from the Government and I’m Here To Fine You

Today the Office of Foreign Assets Control (“OFAC”) announced that it fined Production Products, Inc., a small family-run business in Maryland, the sum of $78,500 in connection with charges that the company exported HVAC duct manufacturing equipment to a company…

  • Clif Burns
  • August 5, 2015
  • 4 Comments
  • DDTC

Breaking News: Two U.S. Senators Flunk ITAR Literacy Test

ABOVE: Sen. Chuck Grassley Plenty of people are upset by the proposal by the Directorate of Defense Trade Controls (“DDTC”) to revise the definition of public domain to exclude technical data about defense articles released to the public without the…

  • Clif Burns
  • August 4, 2015
  • 3 Comments
  • BIS, Criminal Penalties, Iran Sanctions

Don’t Believe Everything You Read in the Newspaper

From the Republican Herald (Pottsvile, PA) story on a guilty plea by Falcon Instrumentation and Machinery FZE in connection with an attempted shipment by Pennsylvania-based Hetran, Inc. of a bar peeling machine to Iran: Federal prosecutors allege the machine, valued…

  • Clif Burns
  • July 27, 2015
  • BIS, Cuba Sanctions

BIS Amends EAR to Remove Cuba as a State Sponsor of Terrorism

On Wednesday, the Bureau of Industry and Security amended the EAR to reflect the removal of Cuba from the list of state sponsors of terrorism. Somewhat surprisingly, the impact of this removal is much less than might be imagined. Of…

  • Clif Burns
  • July 23, 2015
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