Archive for the ‘General’ Category


Apr

30

A Cosmetic Solution


Posted by at 11:49 am on April 30, 2010
Category: General

Lysistrata (Safe for Work)From the London Evening Standard we have this proposal for new sanctions on Iran to deter that country’s nuclear ambitions

[A]n Israeli journalist has come up with an ingenious idea: a boycott on the export of cosmetics and toiletries to Iran. Apparently, Iran is the world’s seventh largest consumer of beauty products, spending no less than $2.1 billion (£1.4 billion) a year on creams, lotions, shampoos, conditioner, lipstick and mascara. Iran alone accounts for a third of the total sales in the Middle East — and the vast majority of them are imported.

The argument put forward by Zvi Barel in Haaretz is that, threatened with the loss of their precious supplies, Iranian women would put pressure on their menfolk to stop the development of the bomb.

Clearly Mr. Barel clearly has Lysistrata in mind. What next? A proposal to consult with the oracle of Delphi to divine a plan to defeat the Iranian navy in the Straits of Salamis?

I hope Mr. Barel has his misogynistic tongue planted firmly in his cheek when proposing that depriving Iranian women of lipstick would be an effective way to influence nuclear policy in Iran. It all sounds more like I Love Lucy than Lysistrata.

Seriously, if we’ve learned anything about economic sanctions, it’s that targeting the general (and innocent) populace of a country never succeeds in reforming that country’s foreign policies or nuclear ambitions.

[Thanks to my colleague in London, Anita Esslinger, for pointing out the blurb in the Evening Standard]

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Copyright © 2010 Clif Burns. All Rights Reserved.
(No republication, syndication or use permitted without my consent.)

Apr

21

Website Updates


Posted by at 7:01 am on April 21, 2010
Category: General

Follow UsAs you may have noticed, we have recently made a few changes to Export Law Blog. First, we’ve spiffed up the visual design of the site a bit, having been more or less forced to redesign the look of the site when an update to WordPress nuked our old design.

Second, after many requests, we’ve added a search tool in the column on the right. The search bar uses a custom Google search. After some testing the custom Google search bar appeared to provide search results that were better than the native search engine supplied by WordPress.

In the subscriptions section, again in the right-hand column, in addition to the email and RSS options for subscribing, there is now a Twitter icon which, if clicked, will take you to our new Twitter page. Each new post will be, er, tweeted, which would allow you to receive notification on your mobile device, if you’d like, either by SMS or through the Twitter app available for iPhone and Blackberry smart phones. (Not that I’d imagine that anyone really needs to get updates from here with that much urgency!) Not to worry, there will never be a Facebook fan page for this blog.

Finally, some readers have reported that their email notifications have stopped working. It appears that some notifications are being trapped in certain spam filters. I’m working on some adjustments to the email notification program that may prevent that. In the meantime, please ask your IT department to white list “clif atsymbol exportlawblog period com,” which is the address from which these notifications originate. Also, if anyone is still having problems with the notifications, please let me know so I can continue to make sure that this function operates properly.

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Copyright © 2010 Clif Burns. All Rights Reserved.
(No republication, syndication or use permitted without my consent.)

Jan

31

Upgrade Blues


Posted by at 6:20 pm on January 31, 2010
Category: General

In upgrading to WordPress 2.9.1 today, I had a bit of a problem and lost some of the files that control how this blog looks. I’ve recreated most of them, but the blog is still looking a little odd and behaving a bit strangely. I should have time to get everything back in working order over the next few days and while I’m doing that I’ll try to add some new features like a search box.

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Copyright © 2010 Clif Burns. All Rights Reserved.
(No republication, syndication or use permitted without my consent.)

Dec

31

Top 10 Export Stories of 2009


Posted by at 12:40 pm on December 31, 2009
Category: General

Happy New Year!After seeing that CNN was doing a feature on the top ten YouTube videos of 2009, the staff at Export Law Blog decided that we no longer had an excuse not to recount the top 10 export stories of 2009. However, we can’t guarantee anything quite as awesome as the YouTube video of the toddler dancing to Beyoncé’s Single Ladies (Put A Ring On It). But here goes anyway, in reverse order:

10. Nobody really knows what Part 129’s definition of arms broker includes but it certainly included a website from a Portland yacht broker trying to find customers for an armed hovercraft being sold by somebody in Eastern Europe for $60 million. Several days after the web page appeared, it was yanked.

9. BIS amended its rules to control the export of tonfas and sjamboks. And, no, these are not menu items found in Asian restaurants.

8. Canada actually prosecuted someone for an export violation.

7. Iran used eBay to buy military aircraft parts from eBay dealers who, apparently, thought that DDTC stands for Dauphin Dog Training Club.

6. OFAC and BIS amended the rules implementing the Cuba sanctions to allow more exports of cellphones, computers, peripherals and digital devices to Cuba. Three months later Cuba arrested a U.S. citizen distributing laptops and cellphones in Cuba to Cuban citizens.

5. French export control officer for Luxembourg-based Qioptiq SARL urged company employees not to consult U.S. export lawyers because they “play by the book” and will “push you to” disclose export violations. DDTC briefly abandoned its distaste for export lawyers and fined Qioptiq $25 million dollars.

4. DDTC finally released its amended brokering regulations. The entire world wished it hadn’t.

3. OFAC and the State Department finally discovered the Internet and realized that letting ordinary people in sanctioned countries use Twitter, Facebook and YouTube might actually be good for world democracy.

2. The United States Court of Appeals for the Seventh Circuit smacked down the DOJ’s outrageous (and routine) assertion that courts can’t review DDTC’s determination that a particular item fits in a particular USML category. The money quote:

A designation by an unnamed official, using unspecified criteria, that is put in a desk drawer, taken out only for use at a criminal trial, and immune from any evaluation by the judiciary, is the sort of tactic usually associated with totalitarian régimes.

1. U.S. authorities liberated $536 million from Swiss bank vaults after Credit Suisse was caught lying to U.S. banks in order to clear U.S. dollar transactions for Iran. “Neutrality,” the Swiss learned yet again, isn’t free.

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Nov

30

Update to 11/25/09 Post


Posted by at 5:38 pm on November 30, 2009
Category: General

The previous post, dated November 25, quoted an article in Crain’s Chicago Business in which an export attorney was quoted as saying:

“At the very least, you should have your freight forwarder check compliance, so if they identify a problem, they can stop the order before it ships.”

I said in that post that, knowing what I did about the law firm in question, I was “absolutely certain” that the lawyer was misquoted or the statement was taken completely out of context. The attorney involved has since spoken with me and confirmed that I was right and that the article misquoted the lawyer.

Significantly, during the interview the lawyer had become concerned that the reporter was not understanding what was being said and asked to review any attributed quotations prior to publication, a request that the reporter did not honor. Another reason, of course, not to believe everything you read in a newspaper or magazine. Blogs, on the other hand, can always be trusted completely.

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Copyright © 2009 Clif Burns. All Rights Reserved.
(No republication, syndication or use permitted without my consent.)