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  • 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
  • BIS, Export Control Proposals, Export Reform

The Export Control Nightmare Act of 2018 (UPDATED)

ABOVE: Rep. Ed Royce When the Export Administration Act lapsed years ago, it meant that every year the President had to issue an executive order under the International Emergency Economic Powers Act (“IEEPA”) resurrecting the Export Administration Regulations for another…

  • Clif Burns
  • April 3, 2018
  • 2 Comments
  • Criminal Penalties, Iran Sanctions, OFAC

Indictment of Iranian over Housing Project in Venezuela Raises Questions

ABOVE: Ali Sadr Hasheminejad Last week, Iranian national Ali Sadr Hasheminejad was arrested at Dulles Airport outside Washington DC in connection with a Venezuelan housing construction project undertaken by his family’s business in Iran. According to the indictment, the governments of…

  • Clif Burns
  • March 27, 2018
  • 2 Comments
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