http://www.exportlawblog.com/archives/396 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/396/comment-page-1#comment-20559 Mike Deal Wed, 24 Sep 2008 18:35:02 +0000 http://www.exportlawblog.com/?p=396#comment-20559 Given that the helmuts were going to Venezuela, it does make you wonder why BIS didn't squeeze a little harder. Loss of license FMC license is not one of the statutory penalties: It would require a full hearing by the FMC, and its not at all clear that a violation of the EAR is a lawful grounds for revocation of an FMC license (there are plenty of forwarders with priors out there). Whereas, if the EAA was still in force, BIS could have issued a valid denial order after an ALJ hearing that would have had the same effect. If the Export Administration Act is ever re-enacted, it might be a good idea to include loss of other federal licenses as added penalties. Nothing like thinning the herd to keep things competitive. Given that the helmuts were going to Venezuela, it does make you wonder why BIS didn’t squeeze a little harder. Loss of license FMC license is not one of the statutory penalties: It would require a full hearing by the FMC, and its not at all clear that a violation of the EAR is a lawful grounds for revocation of an FMC license (there are plenty of forwarders with priors out there). Whereas, if the EAA was still in force, BIS could have issued a valid denial order after an ALJ hearing that would have had the same effect. If the Export Administration Act is ever re-enacted, it might be a good idea to include loss of other federal licenses as added penalties. Nothing like thinning the herd to keep things competitive.

]]> http://www.exportlawblog.com/archives/396/comment-page-1#comment-20556 Jean Poole Wed, 24 Sep 2008 03:45:58 +0000 http://www.exportlawblog.com/?p=396#comment-20556 I hope she does quit the biz. She should have had all her FMC licences revoked for Gross Stupidity as part of her "settlement". I can understand some n00b untrained floorling screwing up but an NVO owner? Come on! I hope she does quit the biz. She should have had all her FMC licences revoked for Gross Stupidity as part of her “settlement”. I can understand some n00b untrained floorling screwing up but an NVO owner? Come on!

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