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  • 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
  • DDTC, Deemed Exports

Well, That Didn’t Last Long: DDTC Finds Backdoor To Reimpose Access Rule

Yesterday the Directorate of Defense Trade Controls (“DDTC”) and FLIR entered into a consent agreement under which FLIR consented to a civil penalty of $30 million, half of which was suspended on the condition that this amount was and would…

  • Clif Burns
  • April 25, 2018
  • 2 Comments
  • BIS, Civil Penalties

ZTE Snapback Order Based on Condition Not In Original Order

Earlier this week, the Bureau of Industry and Security re-imposed on Chinese telecom giant ZTE a seven-year export denial order which the agency imposed and suspended on March 23. 2017. That March 2017 order noted that the suspension could be…

  • Clif Burns
  • April 18, 2018
  • BIS, Criminal Penalties, Cuba Sanctions

Cuba Export Indictment Mangles U.S. Export Laws

Last week Bryan Singer, a Texas resident, was indicted for attempting to export to Cuba certain items that U.S. Customs found on his boat in a harbor in the Florida keys. The items are involved are Ubiquiti Nanostation M2 modems…

  • Clif Burns
  • April 11, 2018
  • 5 Comments
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