« Update Day 2: Enforcement Plenary | Main | Aerospace Execs Talk Global Defense Trade »


Just a word of thanks for your thorough and incisive reporting. It's a real public service for those of us who missed the boat on registration (in my case by a couple of hours).

OFAC ducked any and all questions related to authorization for its controls on technology transfers. The basic rule laid out in the text of IEEPA (50 USC 1702) is that if its not a list based control, i.e., controlled under the EAA for national security (Sec. 5) or certain foreign policy controls Sec. 6), OFAC has no statutory authority to control it. Even sanctions within that statutory standard may run afoul of the constitutional standard. See the 6th Circuit's opinion in Junger v. Daley. Let's face it, only the boys in Beijing benefit from OFAC.

Verify your Comment

Previewing your Comment

This is only a preview. Your comment has not yet been posted.

Your comment could not be posted. Error type:
Your comment has been saved. Comments are moderated and will not appear until approved by the author. Post another comment

The letters and numbers you entered did not match the image. Please try again.

As a final step before posting your comment, enter the letters and numbers you see in the image below. This prevents automated programs from posting comments.

Having trouble reading this image? View an alternate.


Post a comment

Comments are moderated, and will not appear until the author has approved them.

Your Information

(Name and email address are required. Email address will not be displayed with the comment.)

ECTI Blog Ad 1

Corporate ExCon

Ads by Indeed