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California Divests Iranian Investors
During summer 2010, many of the developed nations initiated sanctions against Iran, a signal that their political discourse was supported by economic realities.
United States
17 May 2011
2
Export, Customs & Trade - Enforcement Highlights
On October 5, 2005, the Department of Commerce, Bureau of Industry and Security ("BIS") entered an order under which ProChem (Proprietary), Limited ("ProChem") (as the successor to Protea Chemicals (Proprietary), Limited ("Protea")) of South Africa, agreed to pay $1,540,000 in civil penalties to settle charges that Protea had committed 220 violations of the Export Administration Regulations ("EAR") from 1999 to 2003 in connection with exports of potassium cyanide and sodium cyanide to South Afri
United States
7 Apr 2006
3
OFAC Reissues Burma Sanctions Regulations
The Office of Foreign Assets Control ("OFAC") issued an interim final rule on August 16, 2005, revising the Burmese Sanctions Regulations (the "Regulations"). While Burma has been subject to sanctions since 1997, the passage of the Burmese Freedom and Democracy Act of 2003 (the "Act"), plus President Bush’s Executive Order of July 28, 2003, led to extensive revisions of the Burmese sanctions program. As a result of these amendments, OFAC decided to reissue the Regulations in their entirety.
United States
30 Nov 2005
4
FinCEN Issues New Guidance on Anti-Money Laundering Program Requirements for Foreign Agents and Foreign Counterparts
On December 8, 2004, the U.S. Department of the Treasury Financial Crimes Enforcement Network ("FinCEN") issued interpretive Guidance requiring Money Services Businesses that use overseas agents to move funds in and out of the United States to establish, as part of their anti-money laundering procedures, appropriate measures to address the risks of money laundering and terrorism financing posed by relationships with foreign parties. Businesses are expected to be fully compliant with this Guidanc
United States
11 Mar 2005
5
Deconstructing Encryption: Department of Commerce Revises Encryption Regulations
The export of encryption products, software, and technology has long been one of the most opaque sectors of export controls. While U.S. origin encryption is tightly controlled, exporters can avail themselves of numerous exceptions depending on such factors as the overall strength of the encryption, the type of entity involved (government versus non-government), and the location of the end-user. Over the past few years, the Department of Commerce, Bureau of Industry and Security ("BIS") generally
United States
11 Mar 2005
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