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	<title>Comments on: New Cuba Rules Out Today, er, Tomorrow, er, Really Soon (Maybe)</title>
	<atom:link href="http://www.exportlawblog.com/archives/554/feed" rel="self" type="application/rss+xml" />
	<link>http://www.exportlawblog.com/archives/554</link>
	<description>Latest News on DDTC, BIS, OFAC, and other export law matters</description>
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		<title>By: Hillbilly</title>
		<link>http://www.exportlawblog.com/archives/554/comment-page-1#comment-90080</link>
		<dc:creator>Hillbilly</dc:creator>
		<pubDate>Mon, 07 Sep 2009 18:53:20 +0000</pubDate>
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		<description>I suggest that the portions of this rule granting special privileges to Cuban colonists in Cuban-Occupied Florida, whoops, I mean Cuban-Americans[sic], is unconstitutional because it extends special privileges to one class of Americans solely on account of their national origin.  The purpose of this rule is simply to pander to a swing voting block in a swing state and help fill the coffers of the incumbent.</description>
		<content:encoded><![CDATA[<p>I suggest that the portions of this rule granting special privileges to Cuban colonists in Cuban-Occupied Florida, whoops, I mean Cuban-Americans[sic], is unconstitutional because it extends special privileges to one class of Americans solely on account of their national origin.  The purpose of this rule is simply to pander to a swing voting block in a swing state and help fill the coffers of the incumbent.</p>
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		<title>By: Ex-OFAC</title>
		<link>http://www.exportlawblog.com/archives/554/comment-page-1#comment-89730</link>
		<dc:creator>Ex-OFAC</dc:creator>
		<pubDate>Mon, 07 Sep 2009 00:05:40 +0000</pubDate>
		<guid isPermaLink="false">http://www.exportlawblog.com/?p=554#comment-89730</guid>
		<description>Another aspect of policy that didn&#039;t get &quot;unmade&quot; is the continued treatment of Cuban expatriates as though they were still in Cuba -- even if they have become citizens of another country since their departure from Cuba.  OFAC still insists on licensing their unblocking one by one -- something that is not done with any other set of territorial sanctions (Iran, Sudan, Burma...).  Someday human rights will catch up with our Cuba foreign policy.</description>
		<content:encoded><![CDATA[<p>Another aspect of policy that didn&#8217;t get &#8220;unmade&#8221; is the continued treatment of Cuban expatriates as though they were still in Cuba &#8212; even if they have become citizens of another country since their departure from Cuba.  OFAC still insists on licensing their unblocking one by one &#8212; something that is not done with any other set of territorial sanctions (Iran, Sudan, Burma&#8230;).  Someday human rights will catch up with our Cuba foreign policy.</p>
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		<title>By: John McAuliff</title>
		<link>http://www.exportlawblog.com/archives/554/comment-page-1#comment-89062</link>
		<dc:creator>John McAuliff</dc:creator>
		<pubDate>Sat, 05 Sep 2009 14:55:48 +0000</pubDate>
		<guid isPermaLink="false">http://www.exportlawblog.com/?p=554#comment-89062</guid>
		<description>The big anomaly in the OFAC announcement was that, despite rumors to the contrary, nothing was done to provide similar general licenses for the rest of non-tourist travel, i.e. for educational, cultural, religious, humanitarian and other people-to-people purposes.

We are left with a double standard.  Americans with close friends and professional colleagues in Cuba are still not able to visit them or send them assistance.

John McAuliff
Fund for Reconciliation and Development</description>
		<content:encoded><![CDATA[<p>The big anomaly in the OFAC announcement was that, despite rumors to the contrary, nothing was done to provide similar general licenses for the rest of non-tourist travel, i.e. for educational, cultural, religious, humanitarian and other people-to-people purposes.</p>
<p>We are left with a double standard.  Americans with close friends and professional colleagues in Cuba are still not able to visit them or send them assistance.</p>
<p>John McAuliff<br />
Fund for Reconciliation and Development</p>
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	<item>
		<title>By: efroh</title>
		<link>http://www.exportlawblog.com/archives/554/comment-page-1#comment-88643</link>
		<dc:creator>efroh</dc:creator>
		<pubDate>Fri, 04 Sep 2009 16:13:55 +0000</pubDate>
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		<description>I thought I had missed them, but if you didn&#039;t see them either, it seems more like they just slipped them in this morning.  BIS&#039;s website still has nothing.  The only thing that Commerce put out that I could find was the press release:

http://www.commerce.gov/NewsRoom/PressReleases_FactSheets/PROD01_008383

Have a good weekend and thanks for the great blogging!</description>
		<content:encoded><![CDATA[<p>I thought I had missed them, but if you didn&#8217;t see them either, it seems more like they just slipped them in this morning.  BIS&#8217;s website still has nothing.  The only thing that Commerce put out that I could find was the press release:</p>
<p><a href="http://www.commerce.gov/NewsRoom/PressReleases_FactSheets/PROD01_008383" rel="nofollow">http://www.commerce.gov/NewsRoom/PressReleases_FactSheets/PROD01_008383</a></p>
<p>Have a good weekend and thanks for the great blogging!</p>
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		<title>By: Clif Burns</title>
		<link>http://www.exportlawblog.com/archives/554/comment-page-1#comment-88640</link>
		<dc:creator>Clif Burns</dc:creator>
		<pubDate>Fri, 04 Sep 2009 16:08:06 +0000</pubDate>
		<guid isPermaLink="false">http://www.exportlawblog.com/?p=554#comment-88640</guid>
		<description>Indeed they are, efroh.  It looks they were posted while I was writing this post, because I didn&#039;t see them an hour or so ago.  I&#039;ll give my take on them in more detail next week.  Thanks for the catch.</description>
		<content:encoded><![CDATA[<p>Indeed they are, efroh.  It looks they were posted while I was writing this post, because I didn&#8217;t see them an hour or so ago.  I&#8217;ll give my take on them in more detail next week.  Thanks for the catch.</p>
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	<item>
		<title>By: efroh</title>
		<link>http://www.exportlawblog.com/archives/554/comment-page-1#comment-88635</link>
		<dc:creator>efroh</dc:creator>
		<pubDate>Fri, 04 Sep 2009 15:59:43 +0000</pubDate>
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		<description>The BIS regulations are up at the Pub. Inspection site, but they weren&#039;t last night (at least I don&#039;t think so - I checked multiple times).

http://www.federalregister.gov/OFRUpload/OFRData/2009-21402_PI.pdf

effective 9/3/2009, to be published 9/8/2009</description>
		<content:encoded><![CDATA[<p>The BIS regulations are up at the Pub. Inspection site, but they weren&#8217;t last night (at least I don&#8217;t think so &#8211; I checked multiple times).</p>
<p><a href="http://www.federalregister.gov/OFRUpload/OFRData/2009-21402_PI.pdf" rel="nofollow">http://www.federalregister.gov/OFRUpload/OFRData/2009-21402_PI.pdf</a></p>
<p>effective 9/3/2009, to be published 9/8/2009</p>
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