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ARTICLE · 18 NOVEMBER 2004

International Client Alert- November 2004

Powell Goldstein LLP
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The Bureau of Industry and Security ("BIS") has requested comments from businesses on several proposed changes to the Export Administration Regulations ("EAR"). The request for comments states that the goal of the proposed changes is to clarify existing regulations, without changing their substance, even though the proposals in fact appear to be substantive revisions that would increase exporter liability for violations of BIS rules, while at the same time proposing a "s

United StatesInternational Law
Clif Burns
Clif Burns

BIS PROPOSES NEW RULES EXPANDING EXPORTER LIABILITY

Rules Would Add a Reasonable Person Standard of Liability, a Safe Harbor Procedure, and 11 New Red Flags

The Bureau of Industry and Security ("BIS") has requested comments from businesses on several proposed changes to the Export Administration Regulations ("EAR"). The request for comments states that the goal of the proposed changes is to clarify existing regulations, without changing their substance, even though the proposals in fact appear to be substantive revisions that would increase exporter liability for violations of BIS rules, while at the same time proposing a "safe harbor" mechanism for exporters to avoid the expanded liability.

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