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Enforcement Insights by Mark Menefee

Mark D. Menefee is the former director of the BIS Office of Export Enforcement. Mark wrote this column for The Export Practitioner from 2004-2011.

The Last Word By Mark D. Menefee* One irony about export controls is how little information governments have concerning the transactions they are so keen on regulating. The information gap is far worse than most people have imagined. Governments and exporters need to talk more with each other than... Read more...
Where is the Trust? By Mark D. Menefee* I want all you women, to listen to me Don't trust your man, no further than your eyes can see. I trusted my man, with my best friend But that was a bad bargain, in the end. He'll say that he loves you, and swear that it's true The very next minute, he'll... Read more...
What Do Y'all Know 'Bout I-ran? By Mark D. Menefee* Question: "As President, what would you do if you received a 3:00 a.m. phone call that the Taliban had gotten nuclear weapons from Pakistan?" Answer: "Well obviously, before you ever get to that point you have to build a relationship in that region. That's one of... Read more...
The Public Announcement By Mark D. Menefee* "Ulrich Davis, Ulrich Davis, please come to the Information Desk for a message." - Public Announcement at Newark International Airport, Aug. 6, 2011 Returning to Amsterdam after a business trip, Ulrich Davis, a 50-year-old sales and business development manager... Read more...
Export Control Reform's Biggest Losers By Mark D. Menefee* "Johnny's in the basement, Mixin' up the medicine I'm on the pavement, Thinkin' about the government." - Subterranean Homesick Blues, by Bob Dylan (1965) The Obama administration's July 15, 2011, proposed rule, which presents a methodology for transferring some... Read more...
A Skeptic Explains the Najfi Case By Mark D. Menefee* "It is very unusual and very difficult for deception to create new concepts for an enemy. It is much easier and more effective to reinforce those which already exist." - War Strategy and Intelligence, by Michael I. Handel (1989) Deceivers hate to be deceived.... Read more...
A Cynic Explains BAE Systems' Settlement By Mark D. Menefee* "Compromise, n. Such an adjustment of conflicting interests as gives each adversary the satisfaction of thinking he has got what he ought not to have, and is deprived of nothing except what was justly his due." -- The Devil's Dictionary, by Ambrose Bierce, 1911 In... Read more...
Gowadia Gets in Line By Mark D. Menefee* After I died, and the make-up had dried, I went back to my place. No moon that night, but a heavenly light shone on my face. Still I thought it was odd, there was no sign of God, just to usher me in. Then a voice from above, sugar coated with Love, said, "Let us... Read more...
Jafari Needs a Donkey By Mark D. Menefee* One day Nasreddin Hodja tied his donkey in front of the court house and went shopping. While he was gone, the Kadi sentenced a thief to wear a sign that retold his crime and ordered his assistants to cruise him around the town seated backwards on a donkey. Kadi's assistants... Read more...
Pride and Prosecution By Mark D. Menefee* "Happiness in marriage is entirely a matter of chance. If the dispositions of the parties are ever so well known to each other or ever so similar beforehand, it does not advance their felicity in the least. They always continue to grow sufficiently unlike afterwards to... Read more...
No Respect, No Export Privileges By Mark D. Menefee* "Montgomery admits to the violations of the Regulations alleged in Charges 1-9 and 11-14 of the Charging Letter…." -- Settlement Agreement between Yuri I. Montgomery and the Bureau of Industry and Security, December 20, 2010 Yuri Montgomery traveled a slow and rough... Read more...
Defining the Violation By Mark D. Menefee* "Hear ye! Hear ye! This honorable court's now in session; and if any galoot wants to snort afore we start, let him step up to the bar and name his pizen." -- Judge Roy Bean (1825-1903), opening a proceeding in his combination court and saloon in Val Verde County, Texas... Read more...
Defining the Violator By Mark D. Menefee* "The income tax has made more liars out of the American people than golf has." -- Will Rogers (1879-1935) When a government defines a rule it also defines the criminal who violates the rule. Will Rogers might observe today that the export regulations have made... Read more...
ICE Jumps the Gun By Mark D. Menefee* "Yo VIP let's kick it! Ice ice baby, Ice ice baby All right stop, collaborate, and listen Ice is back with my brand new invention." -- Robert Matthew Van Winkle, aka "Vanilla Ice" (1990) Some members of the U.S. law enforcement community were surprised by... Read more...
Thank You for Exporting By Mark D. Menefee* "Be patient, Rome wasn't burnt in a day." --Anonymous Regulations don't explain themselves. They don't enforce themselves, either. For the U.S. export control reform initiative to succeed, the government will have to inform exporters of their new legal obligations.... Read more...
Subjects and States By Mark D. Menefee* "For government consists mainly in so keeping your subjects that they shall be neither able, nor disposed to injure you. . . ." -- Nicollò Machiavelli, "Discourses on the First Decade of Titus Livy", ca. 1513 These days Victor Bout, Christopher Tappin and Erik... Read more...
Sorting Devils and Angels By Mark D. Menefee* "You look just like an angel, you sound so bright and true. You seem so sweet coming down my street, but the devil is an angel too. The devil is an angel too." -- Janiva Magness, 2010 It's August and the sky over Washington is hazy with law. Congress has been... Read more...
You Get What You Need By Mark D. Menefee* "You can't always get what you want. You can't always get what you want. You can't always get what you want. But if you try sometimes you just might find You get what you need." -- M. Jagger & K. Richards, 1969 Apparently Wu Zhenzhou is a man driven by... Read more...
TDO Causes Conspiracy Crash By Mark D. Menefee* "The breakdown in the relationship between Balli and Mahan occurred after the United States Department of Commerce issued a Temporary Denial Order on the Balli parties and Mahan for what it said were violations of the United States Export Administration Regulations by... Read more...
Fingerprint Blues By Mark D. Menefee* "I been slipping and dodging, Going from town to town. Well I been sad now, Since my fingerprints been found. When they found my gun, They found my switchblade knife. When they found my gun, They found my switchblade knife. Well you know about that, They got my... Read more...
The Buddha Explains BAE Systems Case By Mark D. Menefee* "Are you a god?" they asked. "No." "An angel?" "No." "A saint?" "No." "Then what are you?" The Buddha answered, "I am awake." When you settle a criminal case, be awake. Analyze the broader situation to determine whether your criminal plea agreement might... Read more...
Sanctions Work By Mark D. Menefee* "We pronounce, judge, and declare, that you, the said Galileo . . . have rendered yourself vehemently suspected by this Holy Office of heresy, that is, of having believed and held the doctrine (which is false and contrary to the Holy and Divine Scriptures) that the sun is... Read more...
Litigating for National Security By Mark D. Menefee* "For years I thought that what was good for our country was good for General Motors, and vice versa." -- Charles Erwin Wilson, Chairman of General Motors, at his confirmation hearing to be Secretary of Defense in the Eisenhower Administration (1953) "We help... Read more...
Reconsidering Reexport Controls By Mark D. Menefee* Congress loves reexport controls. So do lawyers and consultants, for different reasons. Businesses and non-U.S. governments hate them. Reexport controls, that is. While people eagerly await details of the Obama administration's proposals for export reform, their... Read more...
The Story of Laura and Brian By Mark D. Menefee* You've read the story of Jesse James - Of how he lived and died. If you're still in need of something to read, Here's the story of Bonnie and Clyde. -- "The Story of Bonnie and Clyde" by Bonnie Parker (1934) Returning to the U.S. to visit her elderly mother for... Read more...
The Sword Is Mightier than the Pen By Mark D. Menefee* 'True, This! Beneath the rule of men entirely great, The pen is mightier than the sword. Behold the arch-enchanter's wand! - itself a nothing! But taking sorcery from the master-hand To paralyse the Caesars, and to strike The loud earth breathless! -Take away... Read more...
How Hard Can It Be? By Mark D. Menefee* How Hard Can It Be? -- Campaign slogan of Kinky Friedman (singer, songwriter, author, and occasional candidate for governor of Texas) Sometimes people make mistakes with export controls that, if they were playing tennis, would be described as "unforced errors."... Read more...
Recordkeeping and Forgiveness By Mark D. Menefee* Will Munny [Clint Eastwood]: It's a hell of a thing, killing a man. Take away all he's got and all he's ever gonna have. The Schofield Kid [Jaimz Woolvett]: Yeah, well, I guess they had it coming. Will Munny: We all got it coming, kid. -- "Unforgiven" (1992) On... Read more...
Logic Behind the Lists By Mark D. Menefee* It is a very inconvenient habit of kittens (Alice had once made the remark) that, whatever you say to them, they always purr. "If they would only purr for 'yes,' and mew for 'no,' or any rule of that sort," she had said, "so that one could keep up a conversation! But how... Read more...
May We Have a Word with You? By Mark D. Menefee* Flowpoke (Flow + Poke) noun: A driver who ignores the rules of the road by driving very slowly (i.e., at the legal limit) in the fast lane. Verb: to strictly observe the "suggested" speed limits, even when using the fast lane. Example: The flowpoke ignored the... Read more...
Trapped Ready to Rap By Mark D. Menefee* "Now I'm trapped and want to find a getaway All I need is a 'G' and somewhere safe to stay Can't use the phone 'cause I'm sure someone is tappin' in Did it before, ain't scared to use my gat again." -- Tupac Shakur, "Trapped" 1991 Juwhan Yun, aka JW Yun, was... Read more...
Export Crimes and Domestic Sales By Mark D. Menefee* "Those who are incapable of committing great crimes do not readily suspect them in others." - François de la Rochefoucauld (1613-1680) It was a simple scheme as export diversions go. Use phony end-use certificates to support a domestic purchase. The fake... Read more...
Small Crimes Don't Pay Much By Mark D. Menefee* Petty crime is everywhere. We tend to focus our attention on major crimes, and for good reason. But a law enforcement agency must deal with all the crimes occurring within its area of responsibility. Small violations of law and law enforcement's response can tell us a... Read more...
Fortunes Told By Mark D. Menefee* "Went to the fortune teller To have my fortune read I didn't know what to tell her I had a dizzy feeling in my head" -- Allen Toussaint, "Fortune Teller" (1962) The pattern of export violations your company will commit this year and next year will be different than in... Read more...
Encore Iran By Mark D. Menefee* "Bis" Definition: (French adv) - (music) repeat, again, encore. Example: "A la fin du concert, le groupe a joue deux bis." (At the end of the concert, the group played two encores.) Pronounced "beees." [Dear readers, to assist you in understanding the U.S. government's... Read more...
Hard Times By Mark D. Menefee* In the shadow of the steeple I saw my people, By the relief office I seen my people; As they stood there hungry, I stood there asking Is this land made for you and me? -- Woody Guthrie, "This Land is Your Land" Administrative export enforcement cases may have to be... Read more...
The Tragedy of Exports By Mark D. Menefee* Strategic rivalries are most likely to revolve around trade, investments and technological innovation and acquisition, but we cannot rule out a 19th century-like scenario of arms races, territorial expansion and military rivalries…Types of conflict we have not seen for a... Read more...
Quantum of Cases By Mark D. Menefee* James Bond: Skewered. One sympathizes. Casino Royale (2006) On October 28, 2008, the U.S. Department of Justice issued its "Fact Sheet: Major U.S. Export Enforcement Prosecutions during the Past Two Years." The Fact Sheet can be found on the department's... Read more...
Compliance and Honest Services By Mark D. Menefee* "Well the boys all call me Doctor Professor Longhair, but the girls all call me a little ol' lovin' man. Well they know I'm not a doctor baby, but they know I'll give it all I can." -- Professor Longhair (1949) On September 3, 2008 a federal jury of his peers convicted John... Read more...
A Day at the Games By Mark D. Menefee* "It is a strange enterprise to make respectable people laugh." -- Moliere I couldn't stay up late to watch the Beijing Olympics live, so I recorded the broadcasts. When I hit playback to watch my favorite events, here's what I found. "Welcome to the viewers who are... Read more...
Nuevo Terrorismo By Mark D. Menefee* "Few things are harder to put up with than the annoyance of a good example." - Mark Twain, 1894 What country has experienced all of the following: mass murders of civilians, assassinations of high level government officials, large lawless areas of borderlands and rugged... Read more...
Habeas License By Mark D. Menefee* "At the still point of the turning world. Neither flesh nor fleshless; Neither from nor towards; at the still point, there the dance is." - T.S. Eliot, "Four Quartets It is July in Washington. The weather is hot and humid. It is an election year. Members of Congress are... Read more...
People Get Ready By Mark D. Menefee* People get ready, there's a train a comin' You don't need no baggage, you just get on board All you need is faith to hear the diesels hummin' Don't need no ticket, you just thank the Lord - Curtis Mayfield, 1965 On June 2, 2008, the Census Bureau revised... Read more...
A French Company's Time Has Come by Mark D. Menefee * Neo: What is the Matrix? Trinity: The answer is out there, Neo, and it's looking for you, and it will find you, if you want it to. -- from the movie "The Matrix", 1999 The time finally came for Cryostar SAS to face justice in the United States.... Read more...
DoJ's Guidelines for Compliance Monitors By Mark D. Menefee* The Department of Justice (DoJ) recently issued guidance on the selection and use of compliance monitors in Deferred Prosecution Agreements (DPAs) and Non-Prosecution Agreements (NPAs) with corporations. Expressed in a March 7, 2008 memorandum from Acting Deputy... Read more...
Who Are You? By Mark D. Menefee* He who knows only his own side of the case, knows little of that. His reasons may be good, and no one may have been able to refute them. But if he is equally unable to refute the reasons on the opposite side; if he does not so much as know what they are, he has no ground... Read more...
Pleased to Meet You By Mark D. Menefee* Please allow me to introduce myself, I'm a man of wealth and taste. I've been around for a long, long year, Stole many a man's soul and faith. -- "Sympathy for the Devil", Mick Jagger/Keith Richards 1968 John Knight, a British arms dealer, was sentenced to... Read more...
Qing Li's Long Flight By Mark D. Menefee* Sit down and shut up, will ya? Try not to live up to all my expectations. -- From the movie "The Sting", 1973 Qing Li's flight from the U.S. to China was delayed but she will get there eventually. On October 14, 2007, she was arrested by special agents with the... Read more...
BIS Bites Dental Suppliers By Mark D. Menefee* "Politics is the art of looking for trouble, finding it everywhere, diagnosing it incorrectly and applying the wrong remedies." --Groucho Marx The Yen and Yang of enforcement penalties is that the higher the maximum authorized fine, the more we want assurances that... Read more...
Trade Secrets and Export Enforcement By Mark D. Menefee* "Quantum3D appreciates and supports the efforts of the Department of Justice in prosecuting this case. The technologies in question not only represent significant economic value to our company, but, in some cases, are also controlled under U.S. export regulations. We... Read more...
Public Domain By Mark D. Menefee* "If ever you betray what you are entrusted with…you forfeit my malevolence for ever…" -- Mrs. Malaprop, a character in the play The Rivals, by Richard Sheridan (1775) Sheridan's delightful comedy gave us the word "malapropism", defined in the dictionary now as a... Read more...
For Whom the Case Tolls By Mark D. Menefee* It seems to me you do not understand politics, Inglés, nor guerilla warfare. In politics and this other, the first thing is to continue to exist. - For Whom the Bell Tolls by Ernest Hemingway (1940) Hemingway loved Cuba. In 1939 he began writing the quoted book... Read more...
Voodoo Compliance By Mark D. Menefee* I got a black cat bone, I got a mojo too I got John the Conqueror, I'm gonna mess with you I'm gonna make you, pretty girl, lead me by the hand Then the world will know, the Hoochie-Coochie Man. -- Hoochie-Coochie Man, as sung by Muddy Waters (1954), written by... Read more...
Hang Him Twice By Mark D. Menefee* On May 23, 1891, the only legal execution to take place in Custer County was held on the South side of the new courthouse. Albert Hauenstine, from West of Callaway, hanged for shooting two men over missing items from a schoolhouse. Sheriff J.B. Jones had to hang him... Read more...
As Time Goes By By Mark D. Menefee* "The fundamental things apply, as time goes by." Although most of the talk about China these days concerns its breathtaking rate of modernization, both civilian and military, you still can step back in time at the Peace Hotel on the Bund in Shanghai. Just off the... Read more...
EAR, EXW, OMG! By Mark D. Menefee* "What we got here…is a failure to communicate." -- The Captain, in Cool Hand Luke In managing your company's export compliance program, you might bump into a trade acronym like "EXW" occasionally. Usually you apologize and hurry along. Occasionally, you might... Read more...
Terrorism, Treason, Greed, Naivety By Mark D. Menefee* What was Tomer Grinberg thinking as he stepped off the plane in Tel Aviv at 5:30 a.m. on January 4, 2007? Born in Israel 33 years earlier, his life could be summed up in a short list of what he had been before: former member of Kibbutz Evron, former Israeli soldier,... Read more...
DOD's New Suit By Mark D. Menefee* As the 109th U.S. Congress trudged to a close, it told the Department of Defense to quit violating the export control laws. This was a remarkable mandate to issue after more than four years of war in Afghanistan and Iraq. In order to conduct its essential mission... Read more...
REAL RISKS By Mark D. Menefee* "Figures often beguile me, particularly when I have the arranging of them myself; in which case, the remark attributed to Disraeli would often apply with justice and force: 'There are three kinds of lies: lies, damned lies and statistics.'" - Autobiography of... Read more...
RED FLAGS By Mark D. Menefee* You can thank Frank W. Deliberti, the smartest person ever to work in the Bureau of Industry and Security or its predecessor, the Bureau of Export Administration, for the "Know Your Customer" guidance now codified in Supplement No. 3 to part 732 of the Export... Read more...
SCREEN TEST By Mark D. Menefee* You see the picture of a blown up vehicle. Carnage and debris everywhere. The announcer says it was caused by an Improvised Explosive Device (IED). People died or were horribly maimed for the rest of their lives. From the perspective of broader military... Read more...
FACE THE MUSIC By Mark D. Menefee* "There may be trouble ahead, but while there's music and moonlight, and love and romance, let's face the music and dance." -- Irving Berlin For more than a year, exporters and freight forwarders have become increasingly frustrated over what they perceive as... Read more...
CONSPIRACY AND COMMON SENSE By Mark D. Menefee* "Everybody gets so much information all day long that they lose their common sense." -- Gertrude Stein Although we may live in a divided, fractious world, perhaps most export practitioners would agree on these rules of common sense: Don't export toxins to... Read more...
SOMEONE'S GOING TO PAY By Mark D. Menefee* "Someone's gonna get hurt before you're through. Someone's gonna pay for the things you do." -- Waylon Jennings & Willie Nelson If you spent more time buying your automobile than you did selecting a freight forwarder, you probably have repeatedly violated the... Read more...
THE WAY OF THE WORLD by Mark D. Menefee * [Dear Readers, applying the jurisdictional rules of ITAR can be a challenging task for even the most experienced export practitioners. How difficult is it to explain these rules to someone who has no experience with defense articles? Let's see…] The Hummer's tire... Read more...
EXPORT COMPLIANCE IN SHANGHAI by Mark D. Menefee * In the innumerable discussions taking place about export controls to China, what has been overlooked is the positive story of how some Chinese and U.S. companies are trying to comply with U.S. export control laws. One question that will never make a headline would be: What... Read more...
CHANGE AND ANTIBOYCOTT COMPLIANCE by Mark D. Menefee * Men themselves have made a law for themselves, not knowing what they made it about but the gods have ordered the nature of all things. Now the arrangements which men have made are never constant, neither when they are right they are wrong; but all the arrangements which... Read more...
WHAT'S YOUR ECCN? by Mark D. Menefee * "She said she'd always been a dancer, She worked in 15 clubs a day. And though she thought I knew the answer, Well, I knew what I could not say." -- The Beatles Why are some U.S. manufacturers secretive about the Export Control Classification Number... Read more...
PREVENTING EXPORT DIVERSIONS AND IP PIRACY by Mark D. Menefee * Theft of a company's intellectual property (IP) or "crown jewels" can destroy its ability to compete. Violating export control laws can destroy the company. Sometimes these events intersect and export enforcement comes to the aid of IP protection. Perhaps a company can... Read more...
THE END OF SCIENTER? by Mark D. Menefee * Brigid O'Shaughnessy: I haven't lived a good life. I've been bad, worse than you could know. Sam Spade: You know, that's good, because if you actually were as innocent as you pretend to be, we'd never get anywhere. -- from the movie "The Maltese Falcon"... Read more...
NO SOLICITING! by Mark D. Menefee * Here is a tale of two types of procurement networks Iran uses to obtain equipment and parts illegally from the U.S. Both ran afoul of the Export Administration Regulations (EAR) and the Iranian Transactions Regulations (ITR), but not in ways that some export practitioners... Read more...
WELL WHAT DO YOU KNOW? By Mark D. Menefee* Many export practitioners are familiar with the Bureau of Industry and Security's (BIS) practice of including in its administrative cases the charge of violating Section 764.2(e) of the Export Administration Regulations (EAR), acting with knowledge that a violation has... Read more...
THE HUMAN CONDITION By Mark D. Menefee* Temple bells die out. The fragrant blossoms remain. A perfect evening! -- Matsuo Basho Export practitioners are familiar with the beautiful minimalist insight of haiku, a traditional Japanese form of poetry consisting of verses arranged into three metrical units... Read more...
SMALL BIG THINGS By Mark D. Menefee * From Small Things (Big Things One Day Come) --Bruce Springsteen August 6, 2005, brought to a close a remarkable enforcement action involving violations of export control laws, public health laws, and plain old fraud and lying. Maine Biological Laboratories, Inc.... Read more...
PUMPED By Mark D. Menefee "I know what you're thinking. 'Did he fire six shots or only five?' Well, to tell you the truth, in all this excitement I kind of lost track myself. But being as this is a .44 Magnum, the most powerful handgun in the world, and would blow your head clean off, you've... Read more...
FOR THE RECORD By Mark D. Menefee* "Knowledge is of two kinds. We know a subject ourselves, or we know where we can find information on it." -- Samuel Johnson (1709-1784), quoted in Boswell's Life of Johnson Non-U.S. companies have been shocked recently by two cases where the Bureau of... Read more...
DRIVING US CRAZY By Mark D. Menefee * Prologue The Bureau of Industry and Security's (BIS) controversial call for comments in the March 28, 2005, Federal Register on possible changes to its "deemed export" rules has stirred up a lot of angst in the exporting and research communities. If implemented... Read more...
THE MASK OF HUMAYUN KHAN By Mark D. Menefee "There is a saying we have, that robbers and thieves wear masks. Would I openly go and ask this man for something that I wanted to put in a nuclear system and use my own name? It is absurd." -- Humayun A. Khan, as quoted in the Washington Post on April 9, 2005... Read more...
LINKING TO CHINA WITH A STRING AND A BRIDGE By Mark D. Menefee* Among the other events at this year's SEMICON China 2005 Conference in Shanghai in mid-March -- right there with sessions on CMOS nanoelectronics, lithography and advanced processing -- was a seminar called "Managing Export Control Requirements for Technology... Read more...
TEEMING AGENCIES By Mark D. Menefee* Gunther Kohlke was not happy. The sophisticated and reserved Swiss businessman and smuggler of aircraft parts to Iran was handcuffed to a group of Mexican illegales in Arizona. After hiking through the Sonora desert for days before being caught by the U.S. Border... Read more...
THE YAKOU PRECEDENT By Mark D. Menefee PRECEDENT, n. In law, a previous decision, rule or practice which, in the absence of a definite statute, has whatever force and authority a judge may choose to give it, thereby greatly simplifying his task of doing as he pleases. As there are precedents for everything, he... Read more...
PATHS TO PERDITION by Mark D. Menefee * "There are many ways of being wrong but only one way of being right." -- Paul Ziff When Export Practitioners seek insights into export enforcement cases for the purposes of compliance training or testing the effectiveness of their company's current compliance... Read more...
THE YEAR 2004 IN PERSPECTIVE by Mark D. Menefee * "I am, indeed, far from desiring to increase in this kingdom the number of executions; yet I cannot but think, that they who destroy the confidence of society, weaken the credit of intelligence, and interrupt the security of life; harass the delicate with shame, and perplex... Read more...
LIGHTS OUT FOR NIGHT VISION MANUFACTURERS? by Mark D. Menefee * A fascinating and important debate is occurring in the night vision sector of export controls. Although this industry has high military tactical significance and not insignificant economic importance, the debate has not received much attention in the broader export... Read more...
THE DILEMMA OF SELF-DISCLOSURE FOR GOVERNMENT AND INDUSTRY By Mark D. Menefee You just discovered that your company committed an export control violation. What should you do? Your compliance personnel were well trained, you thought. They work hard at their jobs, they think. "We have an outstanding export management system," your boss reported.... Read more...
WRITING TOMORROW'S FABLES FROM TODAY'S HEADLINES By Mark D. Menefee * What can export compliance managers learn from Aesop, Uncle Remus and Native American culture? Looking back at government export enforcement actions over the past decade, we can often see a moral or life lesson that can be learned. These lessons can be seen... Read more...
EXPORTERS AND FORWARDERS: CAN'T WE ALL GET ALONG? By Mark D. Menefee * Even for the most earnest export practitioner, a safe haven cannot be found by merely cutting and pasting export compliance advice into your compliance plan. You could follow the best guidance available and still run off a string of export violations significant enough... Read more...