Jeffrey Richardson

Jeffrey Richardson

Miller Canfield

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Is Your Software a Defense Article?

The International Traffic in Arms Regulations, or ITAR, control the export of software classified as a “defense article.” The United States Munitions List [USML] contains items regulated by the ITAR, including a range...more

1/15/2015 - Defense Sector Exports ITAR Software Source Code USML

Export Controls in UK Offshore Centers

Many private equity and investment funds are organized as limited partnerships or companies of offshore entities. Similarly, companies may structure mergers and acquisitions by utilizing offshore holding entities. The British...more

7/15/2014 - BVI Business Companies Choice of Entity EU European Commission Investment Funds Limited Partnerships Offshore Companies Private Equity Sanctions UK

It’s Time For Ground Vehicle and Related Commodities Manufacturers to Embrace Export Control Reform

The Arms Export Control Act (AECA) requires the President of the United States to periodically review controls set for munitions on the United States Munitions List (USML). If the controls no longer remain warranted, the...more

1/15/2014 - AECA BIS DOD Export Controls Exports Manufacturers US Munitions List

Are Your Software Transfers Compliant with U.S. Economic Sanctions?

The international nature of information technology has led to the globalization of software. Globalization can have unintended negative consequences on an organization, if a company’s software should find its way to a...more

1/8/2014 - Foreign Policy OFAC Sanctions Software Technology

Use Caution When Traveling With Encryption Software

"If you bring a laptop or smartphone outside of the United States, you need a basic understanding of how international export control laws may apply to your device’s encryption software."...more

7/12/2013 - Encryption Export Controls Mobile Devices Software Travel

Is Your Software Transmission Subject to U.S. Export Controls under the EAR?

The release of software may require an export control license from the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) under the Export Administration Regulations (the “EAR”). Software delivery has...more

4/15/2013 - BIS Export Administration Regulations Export Controls Licenses Software Software Transmissions Tangible Property

Wire Stripping: What is Old is New Again

Recently, Standard Chartered Bank (SCB) was in the news again for stripping original wire details so that payments would go undetected by the U.S. Department of Treasury's Office of Foreign Assets Control (OFAC)....more

1/29/2013 - Fraudulent Wire Transfers Iran Sanctions Iran Threat Reduction and Syria Human Rights Act OFAC Oil & Gas Standard Chartered Bank SWIFT

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