Harry Clark

Harry Clark

Orrick, Herrington & Sutcliffe LLP

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Latest Publications


U.S. Export Policy for Commercial and Military Unmanned Aerial Vehicles

On February 17, the Obama Administration announced a new U.S. export control policy for military and commercial Unmanned Aerial Vehicles ("UAVs"). The policy, the details of which have not been released, reportedly includes...more

2/24/2015 - Commercial Use Defense Sector Drones EAR Export Controls ITAR New Regulations Unmanned Aircraft Systems

Update on Russia-Ukraine Sanctions: Significant Expansion of Sanctions Presents Additional Compliance Challenges

On July 16, 2014, the United States announced another expansion of sanctions in response to events in southern and eastern Ukraine. The United States for the first time imposed sanctions against major Russian companies and...more

7/22/2014 - EU Foreign Policy Russia Sanctions Ukraine

Department of Defense Renewable Energy Program - Exploring the Challenges and Opportunities

Orrick and Clean Energy Pipeline have launched a series of reports dedicated to exploring investment opportunities and challenges in the U.S. renewable energy sector. In this first issue, we analyze the exciting investment...more

5/13/2014 - DOD Energy Infrastructure Power Purchase Agreements Renewable Energy Utilities Sector

Update on Russia-Ukraine Sanctions – Multiple Legal Challenges

In response to Russia's actions relating to Crimea, the United States and the European Union have expanded their lists of sanctioned parties and their legal bases for broader sanctions. These sanctions are beginning to...more

3/25/2014 - EU Russia Sanctions Ukraine

U. S. Government Penalizes Company for Alleged "Deemed Export" and Other Technology Export Violations

In February 2014, the U.S. government imposed a US$115,000 penalty against Intevac, Inc., for alleged export control violations. The government's enforcement action against Intevac reflects far-reaching positions on...more

3/11/2014 - Export Controls Exports ITAR Penalties

United States and EU Establish Sanctions Arrangements to Address Ukraine Developments

The United States and the European Union have issued sanctions measures in response to actions by Ukrainian and Russian officials. Both measures are designed to impose sanctions against individuals and entities rather than...more

3/10/2014 - EU Foreign Policy Sanctions Ukraine

Sanctions Relaxation Implemented for Iran Nuclear Agreement

On January 20, 2014, after the International Atomic Energy Agency determined that Iran had begun to meet its obligations to curtail nuclear development activities, the United States and the European Union implemented...more

1/23/2014 - EU Iran Iran Sanctions Nuclear Weapons U.N. Security Council United Nations

The DoD Issues New Interim Rule on PV Devices

The Department of Defense (DoD) recently issued an interim rule amending the applicable Defense Federal Regulation Acquisition Supplement (DFARS) related to country of origin determinations for photovoltaic (PV) devices...more

1/8/2014 - Country of Origin DFARS DOD Photovoltaic Solar Panels

New Solar Panel Unfair Trade Cases

On December 31, 2013, SolarWorld Industries America Inc. filed petitions with the U.S. government seeking antidumping and countervailing (anti-subsidy) duties on U.S. imports of Chinese and Taiwanese crystalline silicon...more

1/6/2014 - Anti-Dumping Duty China Countervailing Duties Imports Solar Panels Unfair or Deceptive Trade Practices

Iran Nuclear Agreement & Sanctions Suspension

The November 23 "Joint Plan of Action" regarding Iran's nuclear program (the "Agreement") contemplates that the United States and the European Union ("EU") will suspend some sanctions measures regarding Iran. This advisory...more

11/27/2013 - EU Humanitarian Assistance International Trade Agreements Iran Sanctions Joint Plan of Action Nuclear Power

Antidumping Cases: Commerce Department To Employ Sampling For Respondent Selection

On November 4, 2013, the U.S. Department of Commerce ("Commerce") published changes to procedures for selecting respondents for administrative reviews of antidumping duty orders. A new sampling approach to respondent...more

11/14/2013 - Antidumping Duties U.S. Commerce Department

Export Control Reform Regulations to Become Effective October 15

As described in our April 25, 2013 International Trade & Compliance Advisory, the U.S. government is engaged in a broad export control reform initiative. On October 15, 2013, the first regulatory amendments implementing...more

10/15/2013 - Aircraft Aircraft Sales Aviation Industry Export Administration Regulations Export Controls Exports ITAR

Aeroflex ITAR Settlement Illustrates Export Control Compliance Challenges

Aeroflex, Inc., a U.S. producer of microelectronics devices, recently settled allegations that its exports of certain types of semiconductor devices violated the International Traffic in Arms Regulations (“ITAR”). The...more

8/29/2013 - Compliance Export Controls ITAR Settlement

International Trade & Compliance - April 2013

The U.S. State and Commerce Departments have published amendments to the International Traffic in Arms Regulations (“ITAR”) and Export Administration Regulations (“EAR”) as a major step in implementing changes to export...more

4/26/2013 - Barack Obama Export Administration Regulations Export Controls Exports ITAR National Security US Munitions List

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