Comments on: This Isn’t the Transparency You Were Hoping For? http://www.exportlawblog.com/archives/1236 Latest News on DDTC, BIS, OFAC, and other export law matters Fri, 10 Feb 2012 10:06:23 +0000 hourly 1 http://wordpress.org/?v=3.0 By: Hillbilly http://www.exportlawblog.com/archives/1236/comment-page-1#comment-92401 Hillbilly Sat, 30 Jan 2010 03:13:19 +0000 http://www.exportlawblog.com/?p=1236#comment-92401 Why should export licenses be more confidential than law licenses? Keeping export licenses confidential invites abuse, most especially favoritism and corruption. Why should export licenses be more confidential than law licenses? Keeping export licenses confidential invites abuse, most especially favoritism and corruption.

]]> By: Peter Quinter http://www.exportlawblog.com/archives/1236/comment-page-1#comment-92397 Peter Quinter Fri, 29 Jan 2010 18:15:41 +0000 http://www.exportlawblog.com/?p=1236#comment-92397 I am very surprised by the OFAC change in policy. License application information and licenses should remain confidential. OFAC is out of step with other Federal agencies. I am very surprised by the OFAC change in policy. License application information and licenses should remain confidential.

OFAC is out of step with other Federal agencies.

]]> By: Hillbilly http://www.exportlawblog.com/archives/1236/comment-page-1#comment-92386 Hillbilly Fri, 29 Jan 2010 01:13:25 +0000 http://www.exportlawblog.com/?p=1236#comment-92386 Applicants will just have to invoke the trade secrets exemption proerly. Disclosing applications may cause heartburn for some, but disclosing actual licenses just evens the playing field. What I would really like to see is for OFAC to comply with 5 USC 552(a)(2), and publish their opinions, manuals and instructions to staff. Licensing decisions are adjudications under the APA, and those determinations ought to be published so that we all can be sure that everyone is getting equal treatment, and we can all have some sens of what OFAC considers to be determinative. Applicants will just have to invoke the trade secrets exemption proerly. Disclosing applications may cause heartburn for some, but disclosing actual licenses just evens the playing field. What I would really like to see is for OFAC to comply with 5 USC 552(a)(2), and publish their opinions, manuals and instructions to staff. Licensing decisions are adjudications under the APA, and those determinations ought to be published so that we all can be sure that everyone is getting equal treatment, and we can all have some sens of what OFAC considers to be determinative.

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