In an advisory opinion dated November 13, 2014, the Bureau of Industry and Security (“BIS”) rode once again into the cloud computing breach to confront the tricky metaphysical question of when software that lives in the cloud is exported. At…
Some wag once said that the difference between soccer and rugby is that rugby is a game played by hooligans and watched by gentlemen while soccer is played by gentlemen and watched by hooligans. Well, another difference is that no…
In our prior post on the Russia sanctions and export of equipment to be used in oil production and exploration in shale, we noted that BIS had not yet weighed in on whether its export ban, like OFAC’s restriction, covered…
OFAC today released a new FAQ on the Ukraine Sanctions and shale formations. The purpose of FAQs, at least outside the Treasury Department, is to present clear and concise answers to resolve questions that many people might have. OFAC seems…
According to various news reports, like this one, the latest federal agency to have been hacked is the State Department. The suspected attack was detected on Friday, causing the State Department to shut down its entire unclassified email system. The…