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  • 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
  • Cryptocurrencies, OFAC, Venezuela

OFAC Doesn’t Understand How Digital Currencies Work

ABOVE: Nicolas Maduro Yesterday the White House issued an executive order prohibiting U.S. persons from transactions in the Petro, the new Venezuelan digital currency. As you might recall, OFAC initially suggested that dealings in the Petro would violate restrictions on…

  • Clif Burns
  • March 20, 2018
  • CFIUS

White House Sides with Qualcomm and Tries to Block Broadcom Hostile Takeover

Late yesterday, the White House issued an order forbidding Broadcom from continuing with its efforts to takeover Qualcomm. The surprise move by the White House seems to have been designed to prevent Broadcom from playing its, er, trump card by…

  • Clif Burns
  • March 13, 2018
  • North Korea Sanctions, OFAC

The Norky Horror Picture Show: Let’s Do The UNPA Warp Again

On March 5, the Office of Foreign Assets Control (“OFAC”) released a completely revised and revamped version of the North Korea Sanctions Regulations. The intent of the revision was to catch up with Executive Orders 13687, 13722, and 13810, as…

  • Clif Burns
  • March 8, 2018
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