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  • Part 122

ITAR Registration Puffery: XAND Raises the Bar

An ongoing feature of this blog has been, for some time, to highlight ITAR registration press releases where companies breathlessly announce their registration under part 122 of the ITAR as if it were equivalent to having been awarded the Nobel…

  • Clif Burns
  • June 4, 2014
  • 4 Comments
  • Criminal Penalties, DoJ, Economic Sanctions, Iran Sanctions, Sanctions

Having Baggage Is Not A Crime

A federal jury in Ft. Lauderdale, Florida recently acquitted Patrick Campbell on charges that alleged he attempted and conspired to violate U.S. economic sanctions against Iran.  As we reported at the time of his arrest last year, Campbell, who is from Sierra…

  • George Murphy
  • May 30, 2014
  • Criminal Penalties, DoJ, Iran Sanctions

DoJ Miffs Description of Iran Sanctions

In a recent DoJ press release correcting a previous press release that incorrectly stated that the DoJ had indicted someone on export charges that they hadn’t actually indicted him on (oops!), the DoJ took the opportunity to try to explain…

  • Clif Burns
  • May 28, 2014
  • 4 Comments
  • BIS, Syria

Universal Jurisdiction: Export Denial Order Edition

BIS recently announced a consent agreement with Aramex Emirates under which Aramex agreed to cough up $125,000 in connection with its export of network equipment from the U.A.E. to Syria. Of course, for the few of us remaining that do…

  • Clif Burns
  • May 27, 2014
  • 2 Comments
  • Economic Sanctions, OFAC, Russia Designations, Russia Sanctions

The First Thing We Do, Let’s (Not) Kill All the Lawyers

ABOVE: Sergei Magnitsky Today the Office of Foreign Assets Control (“OFAC”) announced more Russia designations, this time under the Magnitsky sanctions. The Sergei Magnitsky Rule of Law Accountability Act of 2012 (H.R. 4405) authorizes sanctions on those individuals responsible for…

  • Clif Burns
  • May 20, 2014
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