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  • BIS, OFAC, Sudan

Two Agencies Are Never Better Than One

One of the most indefensible parts of the U.S. export control regime, and one that is not even addressed by the export control reform initiative, is the overlapping jurisdiction of two separate agencies — the Bureau of Industry and Security…

  • Clif Burns
  • February 25, 2015
  • 3 Comments
  • Arms Export, DDTC, ITAR, USML

The Sledgehammer Exception

When the Marines evacuated the U.S. Embassy in Sanaá, Yemen, there were reports that they left some of their weapons behind, in large measure because they were leaving on a commercial flight. At first the military said that crew-served weapons…

  • Clif Burns
  • February 18, 2015
  • 8 Comments
  • Deemed Exports, Iran Sanctions

UMass Bans Iranian Students

[UPDATES BELOW] Why solve a problem with a scalpel when there is a sledgehammer nearby? That is the question that UMass Amherst administrators must have asked themselves when they decided to ban all Iranian students from their graduate-level science and…

  • Clif Burns
  • February 17, 2015
  • 1 Comment
  • Cuba Sanctions, OFAC

House of Castro: Francis Underwood Goes to Havana

Netflix just announced that it was going to offer its streaming service in Cuba, starting at $7.99 per month. Of course, under the information exception of the Berman Amendment, Netflix has always been able to stream its movies to Cuba…

  • Clif Burns
  • February 11, 2015
  • 1 Comment
  • Criminal Penalties, Iran Sanctions

Because, Er, 9/11, That’s Why!

Did you know that Iran attacked us on September 11? No, neither did I, but Judge Richard Leon apparently thinks so, because 9-11 appears to be the central reason he rejected the Deferred Prosecution Agreement in the case against Fokker…

  • Clif Burns
  • February 10, 2015
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