On December 30, 2014, the U.S. Department of Commerce, Bureau of Industry and Security (“BIS”) issued its first-ever published guidance on the Short Supply Controls, the regulations that limit the export of crude oil out of the United States. The guidance, provided in the form of Frequently Asked Questions (“FAQs”), is of particular interest to many because it addresses the timely question of what kind of distillation process is sufficient to transform crude oil into a product that is exportable without a BIS license. The FAQs, however, also address the important but often misunderstood legal issue of “commingling.”

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