Comments on: California Man Sentenced to Two Years for Brokering Violations http://www.exportlawblog.com/archives/262 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: Jim Slear http://www.exportlawblog.com/archives/262/comment-page-1#comment-8182 Jim Slear Thu, 21 Feb 2008 15:23:06 +0000 http://www.exportlawblog.com/archives/262#comment-8182 Great Blog site! That said, with regard to your report, it should be noted that a license is required for all brokering activity (however broadly DDTC is interpreting that) taking place or directed outside of NATO, Japan, Australia, or New Zealand under 129.6(a). 129.7(a) serves to trigger prior approval obligations in these areas. Also, as another comment indicates, China is a prohibited country under 126.1 and 129.5(b). This all points out, however, tthat there is an unfortuate lack of guidance from DDTC about brokering; in particular what amounts to brokering and how to apply for licenses when the there is no specific transaction at issue (e.g., pure marketing, which DDTC has stated can be brokering under some circumstances). The field is really in need of specfic guidance because many of the people at risk fro violations are not U.S. persons and have little or no source of export compliance advice. Great Blog site! That said, with regard to your report, it should be noted that a license is required for all brokering activity (however broadly DDTC is interpreting that) taking place or directed outside of NATO, Japan, Australia, or New Zealand under 129.6(a). 129.7(a) serves to trigger prior approval obligations in these areas. Also, as another comment indicates, China is a prohibited country under 126.1 and 129.5(b). This all points out, however, tthat there is an unfortuate lack of guidance from DDTC about brokering; in particular what amounts to brokering and how to apply for licenses when the there is no specific transaction at issue (e.g., pure marketing, which DDTC has stated can be brokering under some circumstances). The field is really in need of specfic guidance because many of the people at risk fro violations are not U.S. persons and have little or no source of export compliance advice.

]]> By: Matthew J. Lancaster http://www.exportlawblog.com/archives/262/comment-page-1#comment-6527 Matthew J. Lancaster Thu, 13 Dec 2007 06:29:36 +0000 http://www.exportlawblog.com/archives/262#comment-6527 Clif, Don’t forget 129.5(b). China is a 126.1 country. Clif,

Don’t forget 129.5(b). China is a 126.1 country.

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