By: Devin Sefton, Senior Associate Attorney, Braumiller Law Group The ever-shifting sands of U.S. sanctions and export controls can make it challenging to know the current restrictions that exist with respect to a given country. With each new administration comes newly imposed restrictions and newly lifted restrictions. This problem was particularly exacerbated by the 180-degree
By Devin Sefton, Senior Associate Attorney, Braumiller Law Group
Although 2020 is not over yet (unfortunately), the Bureau of Industry and Security (“BIS”) has had a busy year by any measure.
By: Devin Sefton, Senior Associate Attorney and Lowell DeFrance, Of Counsel, BLG The ongoing COVID-19 crisis has presented unique challenges for the U.S. supply chain, and for the U.S. economy as a whole. Front and center is the shortage of critical medical equipment and personal protective equipment (“PPE”), including ventilators, respirators, masks, gloves, swabs and
By: Devin Sefton, Senior Associate Attorney, Braumiller Law Group Since the emergence of COVID-19 in the U.S. beginning in February of 2020, there is general uncertainty over how the pandemic could affect the regulatory landscape, including regulations relating to U.S. sanctions and export controls. A review of the actions taken to date suggest that little
On October 8, 2014 BIS announced that it issued a penalty of $750,000 against Wind River Systems, a subsidiary of Intel, for the unlawful exportation of encryption software products to foreign government end-users and to organizations on the BIS Entity List.
By Devin Sefton, Associate Attorney The deemed export rules create a dizzying maze of challenges for businesses seeking to hire and retain the best and brightest from around the world. Normal business operations require companies to provide proprietary information to employees, foreign national or not, on how their products are produced, and this information is
We are well aware of the frustration many exporters face when managing the challenges created by export control regulations. These regulations are vast, difficult to dissect, and at times, exceedingly vague. To make matters worse, exporters do not always agree with DDTC and BIS on their interpretation of the regulations or with the administrative actions
The International Traffic in Arms Regulations don’t usually garner national attention from the press, but when they do, they do so with a bang. A recent case involving University of Texas law student Cody Wilson has brought the ITAR into the national spotlight in a way that few events have. The State Department alleges that
The 1st Circuit Appeals court found in a recent case that juries may sometimes decide whether certain products are covered by the United States Munitions List. In United States v. Zhen Zhou Wu, the defendant was convicted of multiple counts of willful violations of the International Traffic in Arms Regulations and Export Administration Regulations. The