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  • DDTC, Part 129

ITAR? What’s An ITAR? Isn’t That a News Bureau in Russia or Something?

ABOVE: Matthew VanDyke A guy named Matthew VanDyke announced this on Facebook: I have been in ‪#‎Iraq‬ helping to raise and train a Christian army to fight ‪#‎ISIS‬. Sons of Liberty International (SOLI), my new company that provides free military…

  • Clif Burns
  • June 2, 2015
  • 2 Comments
  • Bureau of Economic Analysis

Last Second Reprieve For BEA Victims, Er, Filers

ABOVE: Dr. Brian Moyer, BEA Director We have previously reported on the impending deadline of May 29, 2015 for all U.S. individuals and entities with 10% or greater interest in any “foreign affiliate” to file Form BE-10 with the U.S.…

  • Clif Burns and Lloyd Grove
  • May 29, 2015
  • General

Are You A Natural Person or an Unnatural One?

DDTC issued proposed rules yesterday dealing, mostly, with the conundrum of what to do with U.S. citizens who work, either in the U.S. or abroad, for foreign defense contractors. Since most normal people (viz., natural persons) do not pore over…

  • Clif Burns
  • May 27, 2015
  • 1 Comment
  • BIS, Cyber Weapons

BIS Finally Releases Proposed Cybersecurity Rules

At long last, and well after the E.U. and many other members of the Wassenaar Arrangement, BIS has released proposed (but not final) rules implementing the December 2013 changes adopted by the Arrangement and which imposed export controls on “intrusion…

  • Clif Burns
  • May 20, 2015
  • BIS, Russia Sanctions

BIS Publishes Tips You Can Use (or Not) to Unmask Russian Straw Purchasers

The Bureau of Industry and Security (“BIS”) just released new guidance, snappily titled “Guidance on Due Diligence to Prevent Unauthorized Transshipment/Reexport of Controlled Items to Russia,” which attempts to reveal ways in which U.S. exporters can detect whether a purchaser…

  • Clif Burns
  • May 19, 2015
  • 1 Comment
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