Comments on: Don’t Forget Liechtenstein!

By: CR

CR — Mon, 06 Oct 2008 16:12:43 +0000

I read the proposed rule the same. The Applicant only needs to be incoporated in or have its principal place of business in the 37 countries.

By: KP

KP — Mon, 06 Oct 2008 14:37:31 +0000

The way I read the proposed rule applicants must be from the listed companies but “users” and “recipients” do not have to be. Compare (b)(1), (2) and (3) in the proposed rule. This could be more clear and may be a good comment to submit to BIS.

By: KC

KC — Sun, 05 Oct 2008 16:27:36 +0000

Liechtenstein is in good company considering the fact that Monaco didn’t make the grade either.

By: Clif Burns

Clif Burns — Fri, 03 Oct 2008 15:57:30 +0000

Probably H.S.H. Prince Han-Adam II is not amused, but a bit embarrased to be the head of state of country known for money laundering and a tax evasion shelter. That might be the reason for ineligibility. Comment by Jairo Leon — October 2, 2008 @ 10:44 pm

The State Department lists both Luxembourg and Liechtenstein as money-laundering "countries of primary concern." See the report here.

By: Anna Madjeski

Anna Madjeski — Fri, 03 Oct 2008 14:19:30 +0000

You obviously don’t know that Liechtenstein is a feared Global Nuclear Power….

http://www.boreme.com/boreme/funny-2007/liechtenstein-nukes-p1.php

By: Robot Economist

Robot Economist — Fri, 03 Oct 2008 14:09:10 +0000

Agrentina is a member of the Australia Group, MTCR, Wassenaar Arrangement, and Nuclear Suppliers Group, whereas Liechtenstein is not.

Maybe His Royal Highness needs to get his export controls act together before he gets upset…

By: Jairo Leon

Jairo Leon — Fri, 03 Oct 2008 02:44:54 +0000

Probably H.S.H. Prince Han-Adam II is not amused, but a bit embarrased to be the head of state of country known for money laundering and a tax evasion shelter. That might be the reason for ineligibility.

By: extegral

extegral — Fri, 03 Oct 2008 00:31:26 +0000

To call this a license exception is an Orwellian misnomer. It is a form of a Special Comprehensive License and, unless substantially revised, is much more likely to be as warmly welcomed and as widely used by the U.S. exporting community as SCLs are – all 10 of them.

For example, in regard to intracompany technology transfers, the ICT offers less freedom to operate yet imposes absurdly more reporting and compliance costs on U.S. subsidiaries then those imposed on unrelated third parties under TSRs. The “foreign national employees” related requirements alone will cause many a European lawyer’s head to spin and coffers to bulge as U.S. companies will struggle to define their legality and “workability” under various European laws.