April 2014

Features

Keys to Effective Denied-Party Screening for Targeted Sanctions
Awareness of denied-party lists should be a key component of your company's export control and economic sanctions compliance program, including which lists to screen; who to screen; when to screen; and how to screen.
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Focus on Enforcement

Va. Man Pleads Guilty to Exporting High-Tech Goods to Iran Without Licenses
A naturalized U.S. citizen born in Iran has pleaded guilty to violating Iran sanctions by exporting various high-tech goods to Iran via United Arab...
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Esterline Pays $20 Million Penalty to Settle 282 DDTC Charges Tied to Subsidiaries
In an administrative consent agreement announced March 6, 2014, with State's Directorate of Defense Trade Controls (DDTC), Esterline Technologies...
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Arkema's Dutch Branch Pays $16,000 to Settle BIS Charge of Reexporting Chemical to Syria
The Dutch arm of French chemical giant Arkema, has agreed to settle charges of ordering chemicals from its U.S. sister company and then reexporting...
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French Citizen Pleads Guilty to Obstructing Bribery Investigation in Guinea
After a year in custody, French citizen Frederic Cilins pleaded guilty March 10, 2014, in Manhattan U.S. District Court to reduced charges of...
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San Jose Network Provider Ubiquiti Settles OFAC Charges of Violating Iran Sanctions
Even though some sanctions on Iran have been temporarily lifted, companies are still held accountable for prior unauthorized exports to that...
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Marubeni Agrees to Pay $88 Million, Plead Guilty to Foreign Bribery Charges
Another shoe has dropped in the case against Japanese trading company Marubeni Corporation for its role in a multi-company scheme to bribe...
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Thai Citizen Sentenced to Seven Months in Prison for Illegal Firearms Export
The last conspirator of two Thai brothers was sentenced in Seattle U.S. District Court Feb. 28, 2014 for her role in an operation that exported...
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Inside BIS

USML-CCL Transition Leaves Some Cat. XI Electronics in Limbo Awaiting Final Transfer
Because a final rule transferring some electronic items from U.S. Munitions List (USML) Category XI to the Commerce Control List (CCL) hasn't been...
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Commercial Spaceflight Industry Seeks Role in Export Reforms to Assure Future Trade
The still infant commercial spaceflight industry wants to make sure that rules being developed as part of the administration's export control...
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ETRAC Considers Implications of Crowdsourcing, 3D Printing for Future Export Controls
The influence of the Bureau of Industry and Security's (BIS) Emerging Technology and Research Advisory Committee (ETRAC) is being felt by other...
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Government Defends Not Releasing EAR Licensing Data under FOIA Exemption
In another round of briefs filed in a suit seeking release of Commerce export licensing data under the Freedom of Information Act (FOIA), the...
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"Required" Applies to All Controlled Technology, BIS Says in Advisory Opinion
The Wassenaar Arrangement's General Technology Note (GTN) and the defined term "required" applies to all "technology" controlled under the Export...
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Policy Briefs

CBP Plans to Launch C-TPAT for Exporters by End of Year But Lacks Benefits for Participants
Customs and Border Protection (CBP) is aiming to create an "export entity" under its current Customs-Trade Partnership Against Terrorism (C-TPAT)...
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Justice FCPA Advisory Opinion Says It Won't Prosecute Buyout of Foreign Official's Stock
Trying to get out of a business deal by buying the shares of a former partner, who is now a foreign government official, would not warrant...
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Professor Roth Gets Six-Month Reduction in Sentence for Failing Health Reasons
Former University of Tennessee Professor J. Reece Roth will likely spend six months less in prison following a March 10, 2014, ruling by Knoxville...
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Senators Want U.S. to Cut Ties with Russian Arms Dealer Rosoboronexport
One of the ironies of current U.S. sanctions against Russia for its annexation of Crimea is the Pentagon's reliance on a Russian arms exporter to...
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U.S., UK Stop Processing Export Licenses for Russia As Ukraine Crisis Continues
In addition to economic sanctions imposed on Russian and Ukraine individuals and entities involved in Moscow's annexation of Crimea, the U.S. and...
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U.S., Allies Impose Measured Sanctions Against Russia in Reaction to Ukraine Crisis
The attempt by the U.S., European Union (EU) and Canada to impose economic sanctions slowly and incrementally against Russian and Ukrainian...
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Exporting from Europe

Is it Time to Start Afresh?
By David Hayes* "Begin, be bold, and venture to be wise." -- Horace The question I would like to pose is this: Would global business...
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Regulatory Briefs

BIS Will Continue to Accept Comments on Interim-Final Satellite Rule after It is Published
The final rule transferring many items from Category XV (satellites) of the U.S. Munitions List (USML) to the Commerce Control List (CCL) was on...
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Fewer Licenses Expected for Chemical Exports to Mexico Since it Joined Australia Group
In a final rule published March 26, 2014, in the Federal Register, the Bureau of Industry and Security (BIS) updated the Export Administration...
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ATF Removes Low-Threat, Domestically Available Items from Munitions Import List
As part of the ongoing export control reform effort, Justice has amended Bureau of Alcohol, Tobacco, Firearms, and Explosives (ATF) regulations to...
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End Notes

END NOTES
600 SERIES : Based on very preliminary data during first five months since first USML-CCL transfers became effective in October 2013, exporters...
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