Despite recent efforts to repeal the U.S. ban on crude oil exports, the restrictions remain firmly in place. Recently, however, the Bureau of Industry & Security (“BIS”) authorized exports of U.S. light crude oil in exchange for imports of Mexican heavy crude, causing a stir in the industry and some confusion regarding the legal context … Continue Reading
The European Union has made further additions to the list of sanctioned parties under the regime put in place in response to the Russian Federation’s actions in the Crimea (Regulation 269/2014 and subsequent amendments). On 12 May 2014, the Council of the European Union published Regulation 477/2014, which added an additional 13 individuals to the … Continue Reading
On April 9th, the Bureau of Industry and Security (“BIS”) proposed a rule that would remove certain documentation requirements in connection with Export Administration Regulations (“EAR”) license applications. Export nerds are well aware that changing these requirements would go a long way toward streamlining the license application process (which is ridiculous and complicated). As the … Continue Reading
On November 23, 2013, the White House issued a Press Release (“the Announcement”) outlining the first of a two-step negotiation process between Iran and the United States, the United Kingdom, Germany, France, Russia, and China (the “P5+1”). The Announcement calls for the P5+1 countries to provide limited sanctions relief to Iran in exchange for Iran’s … Continue Reading
A little clarity on CBP Regulations. For those of you not paying attention, the UK would really like bribery payments to stop. Here is my post, about a post, about a post. Follow the rabbit hole, for a discussion about small businesses being impacted by premium payments to government contractors. What’s going on with satellites? … Continue Reading
This post was written Christopher B. Monahan. The new Form I-129 has highlighted the restrictions on deemed exports of technology to foreign national employees. Originally effective December 23, 2010, the new form requires employers to certify that they will not “release” controlled technology or data to an H-1B, L-1 or O-1 worker without the appropriate … Continue Reading
*Attention* government contracts attorneys: If your friends and loved ones stare blankly at you when you explain what it is you do, it turns out they are not the only ones who are confused. Check out this amusing breakdown of confused experts. New Year, new Congress, new rumblings about government fraud . An attorney involved … Continue Reading
This post was written by Anne Borkovic. After months of intense global negotiations, and facing increased sanctions from the United States, the EU, and the United Nations, what is life like in Iran? As expected, Iranians are experiencing increased gas prices, and the Iranian Revolutionary Guard is having some financing difficulties. Some of the more interesting effects, … Continue Reading
On July 1, 2010, President Barack Obama, preceded by Congressional voting signaling overwhelming support, signed into law the Comprehensive Iran Sanctions Accountability and Divestment Act (“Act”). The Act is an effort by the United States to hinder what appears to be Iran’s intent to develop nuclear weapons. Action by the United States comes at a … Continue Reading
This post was also written by Anne Borkovic. The United States Congress is currently considering legislation that would increase the scope and application of the U.S. sanctions against Iran: The Comprehensive Iran Sanctions, Accountability and Divestment Act of 2009 (S. 2799) and the Iran Refined Petroleum Sanctions Act of 2009 (H.R. 2194). These changes could significantly … Continue Reading