Joseph D. Gustavus

Joseph D. Gustavus

Miller Canfield

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Latest Publications


What U.S. and Chinese companies need to know about U.S. export control laws applicable to China

According to a recently published report of the U.S. Congressional Research Service, the United States and the People’s Republic of China (‘China’) expanded economic ties substantially over the past three decades. Total...more

11/13/2013 - China Export Controls Exports Extraterritoriality Rules ITAR Trade Policy US Munitions List

Export Control Compliance Sharing Sensitive Technologies Between International Affiliates General Concepts and Transfer Patterns

In the normal course of operations between U.S. and foreign affiliates, inter-company communications and data conveyances are frequent and occur both intentionally and inadvertently. The U.S.-foreign affiliation can be in the...more

9/20/2013 - Compliance Export Controls Exports Foreign Affiliates Information Sharing ITAR Technology

U.S. Export Control Reforms to Become Effective

The first significant reforms to the U.S. export control regulations in International Traffic in Arms Regulations (ITAR) and U.S. Export Administration Regulations (EAR) are about to take effect....more

5/13/2013 - Export Administration Regulations Export Controls Exports ITAR

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

U.S. Sanctions on Iran Extended: U.S. Companies Now Liable if Foreign Affiliates Have Business Dealings with Iran

The recently enacted Iran Threat Reduction and Syria Human Rights Act of 2012 (ITRSHRA) holds U.S. companies liable if foreign affiliates they own or control conduct business with Iran. Section 218 of ITRSHRA effectively...more


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