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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
  • Iran Sanctions, OFAC

Wind Down Woes By Any Other Name Would Smell As Rotten

Today’s revocation of U.S. participation in the Iran nuclear deal principally resurrects a number of secondary sanctions aimed at European allies and other countries. Those that relied on the nuclear deal will now see that commercial arrangements with Iran that…

  • Clif Burns
  • May 8, 2018
  • BIS, Denied Party List

De Minimis Rules Create De Maximis Confusion for ZTE Exports

Trade wars, like all wars, inevitably inflict collateral damage on unintended targets. This article in the Wall Street Journal provides an interesting run-down of the collateral damage that the ZTE denial order has had on U.S. companies.  These are companies…

  • Clif Burns
  • May 3, 2018
  • 3 Comments
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