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	<title>Comments on: Arrest Ye Merry Gentlemen</title>
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	<description>Latest News on DDTC, BIS, OFAC, and other export law matters</description>
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		<title>By: Clif Burns</title>
		<link>http://www.exportlawblog.com/archives/80/comment-page-1#comment-639</link>
		<dc:creator>Clif Burns</dc:creator>
		<pubDate>Tue, 13 Feb 2007 15:20:06 +0000</pubDate>
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		<description>For the record, I agree with Lee.   Although I have been critical of unilateral sanctions programs and of certain aspects by which OFAC implements them, I do not believe that the folks at OFAC are &quot;traitorous&quot; or are &quot;lackeys&quot; for Cubans.</description>
		<content:encoded><![CDATA[<p>For the record, I agree with Lee.   Although I have been critical of unilateral sanctions programs and of certain aspects by which OFAC implements them, I do not believe that the folks at OFAC are &#8220;traitorous&#8221; or are &#8220;lackeys&#8221; for Cubans.</p>
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		<title>By: Lee Miller</title>
		<link>http://www.exportlawblog.com/archives/80/comment-page-1#comment-638</link>
		<dc:creator>Lee Miller</dc:creator>
		<pubDate>Tue, 13 Feb 2007 15:12:12 +0000</pubDate>
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		<description>Hey, Mike.  I agree with your definition of a &quot;real American&quot; in that I am a US person and I have proudly sworn my unswerving loyalty and allegiance to the United States as a grateful immigrant and I have devoted my lifetime to public service as a career military officer and as a federal civil servant.  My employment at OFAC, however, does not make me &quot;traitorous&quot; or a &quot;lackey&quot; for the &quot;Cuban colonists&quot;.  In fact, I have the utmost respect and admiration for my colleagues here at OFAC.  Dedicated professionals come to my mind to describe them.</description>
		<content:encoded><![CDATA[<p>Hey, Mike.  I agree with your definition of a &#8220;real American&#8221; in that I am a US person and I have proudly sworn my unswerving loyalty and allegiance to the United States as a grateful immigrant and I have devoted my lifetime to public service as a career military officer and as a federal civil servant.  My employment at OFAC, however, does not make me &#8220;traitorous&#8221; or a &#8220;lackey&#8221; for the &#8220;Cuban colonists&#8221;.  In fact, I have the utmost respect and admiration for my colleagues here at OFAC.  Dedicated professionals come to my mind to describe them.</p>
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		<title>By: Mike Deal</title>
		<link>http://www.exportlawblog.com/archives/80/comment-page-1#comment-305</link>
		<dc:creator>Mike Deal</dc:creator>
		<pubDate>Sat, 30 Dec 2006 00:17:38 +0000</pubDate>
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		<description>A &quot;real American&quot; is a US person whose first and undivided loyalty is to the United States and their fellow Americans, instead of to other ethnic, religious or national groups.  This would exclude the Cuban colonists in Occupied Florida and other ingrate expatriate or ethnic groups who consider their feuds with their enemies back home to be more important than the livelihoods of the Americans who gave them a refuge in the first place, plus their corrupt, traitorous lackeys at OFAC.</description>
		<content:encoded><![CDATA[<p>A &#8220;real American&#8221; is a US person whose first and undivided loyalty is to the United States and their fellow Americans, instead of to other ethnic, religious or national groups.  This would exclude the Cuban colonists in Occupied Florida and other ingrate expatriate or ethnic groups who consider their feuds with their enemies back home to be more important than the livelihoods of the Americans who gave them a refuge in the first place, plus their corrupt, traitorous lackeys at OFAC.</p>
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		<title>By: mous, anony</title>
		<link>http://www.exportlawblog.com/archives/80/comment-page-1#comment-300</link>
		<dc:creator>mous, anony</dc:creator>
		<pubDate>Thu, 28 Dec 2006 19:59:29 +0000</pubDate>
		<guid isPermaLink="false">http://www.exportlawblog.com/archives/80#comment-300</guid>
		<description>Pray tell, what is a &quot;real American?&quot;</description>
		<content:encoded><![CDATA[<p>Pray tell, what is a &#8220;real American?&#8221;</p>
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		<title>By: Mike Deal</title>
		<link>http://www.exportlawblog.com/archives/80/comment-page-1#comment-299</link>
		<dc:creator>Mike Deal</dc:creator>
		<pubDate>Thu, 28 Dec 2006 17:36:08 +0000</pubDate>
		<guid isPermaLink="false">http://www.exportlawblog.com/archives/80#comment-299</guid>
		<description>After some reflection upon reading and rereading this GAO report, it occurs to me that should any other Boeing read this report, they may be mystified as to why Boeing agreed to a huge fine levied by DDTC under its &quot;tranparency doctrine&quot;, when DDTC doesn&#039;t have an effective civil penalty procedure AND the transactions were clearly legal as per section 17 of the EAA.  My point is not about one questionable decision.  My point is that the Federal export control agencies routinely violate the laws under which they assert the right to sanction real Americans; but, even the largest exporters won&#039;t take them to task and make the Yankee bastards follow the law.  Until exporters develop a spine and are willing to fight, we can expect export enforcement apparatus to run roughshod over Americans, which will make the boys at the trade ministry in Beijing only too happy.</description>
		<content:encoded><![CDATA[<p>After some reflection upon reading and rereading this GAO report, it occurs to me that should any other Boeing read this report, they may be mystified as to why Boeing agreed to a huge fine levied by DDTC under its &#8220;tranparency doctrine&#8221;, when DDTC doesn&#8217;t have an effective civil penalty procedure AND the transactions were clearly legal as per section 17 of the EAA.  My point is not about one questionable decision.  My point is that the Federal export control agencies routinely violate the laws under which they assert the right to sanction real Americans; but, even the largest exporters won&#8217;t take them to task and make the Yankee bastards follow the law.  Until exporters develop a spine and are willing to fight, we can expect export enforcement apparatus to run roughshod over Americans, which will make the boys at the trade ministry in Beijing only too happy.</p>
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		<title>By: Mike Deal</title>
		<link>http://www.exportlawblog.com/archives/80/comment-page-1#comment-262</link>
		<dc:creator>Mike Deal</dc:creator>
		<pubDate>Sat, 23 Dec 2006 15:08:40 +0000</pubDate>
		<guid isPermaLink="false">http://www.exportlawblog.com/archives/80#comment-262</guid>
		<description>Thanks for bringing this GAO report to the light of day.  Its another example of how the GAO has become politicized. The report clearly tries to suck up to anti-export, pro-sanctions proclivities of Chairman Hyde.  I find it interesting that GAO did not speak with anyone in the private sector who deals with the enforcement agencies.  Asking ICE, OEE,CBP, DoJ and FBI to evaluate themselves is useful, but its never going to give them an objective assessment. Hopefully, the new majority in the 110th Congress will not be deceived by this GAO Report.</description>
		<content:encoded><![CDATA[<p>Thanks for bringing this GAO report to the light of day.  Its another example of how the GAO has become politicized. The report clearly tries to suck up to anti-export, pro-sanctions proclivities of Chairman Hyde.  I find it interesting that GAO did not speak with anyone in the private sector who deals with the enforcement agencies.  Asking ICE, OEE,CBP, DoJ and FBI to evaluate themselves is useful, but its never going to give them an objective assessment. Hopefully, the new majority in the 110th Congress will not be deceived by this GAO Report.</p>
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