http://www.exportlawblog.com/archives/330 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 http://www.exportlawblog.com/archives/330/comment-page-1#comment-10154 Mike Deal Thu, 01 May 2008 22:49:25 +0000 http://www.exportlawblog.com/archives/330#comment-10154 Clif: Once again you do a great service. I have to wonder though, whether OFAC's willingness to adopt Customs definitions of subtantial transformation for purposes of the Burmese sanctions would be mirrored in its interpretation of, oh say, the Iranian Transaction Regs. OFAC has often stated that one should not assume that undefined terms in its regulations may have the same meaning as the same terms used in other regulations, including but not limited to EAR and the Customs regs, so that OFAC can use its old trick of issuing ex post facto interpretations of terms it didn't bother to define in the first place, like substantial transformation. OFAC now may be may be in a box. Well done Cliff! Clif: Once again you do a great service. I have to wonder though, whether OFAC’s willingness to adopt Customs definitions of subtantial transformation for purposes of the Burmese sanctions would be mirrored in its interpretation of, oh say, the Iranian Transaction Regs. OFAC has often stated that one should not assume that undefined terms in its regulations may have the same meaning as the same terms used in other regulations, including but not limited to EAR and the Customs regs, so that OFAC can use its old trick of issuing ex post facto interpretations of terms it didn’t bother to define in the first place, like substantial transformation. OFAC now may be may be in a box. Well done Cliff!

]]>