​Here are a few recent odds and ends that are worth a mention (and to catch up on a few things I missed while on vacation):

  • The Directorate of Defense Trade Controls (“DDTC”) issued guidance as to which activities are “gunsmithing” that do not require registration under part 122 and which are “manufacturing” and do require registration. This guidance defines “gunsmithing” and “manufacturing” completely differently from the definitions used by the Bureau of Alcohol, Tobacco and Firearms (“ATF”). For example, assembling kits into guns is “manufacturing” according to ATF but not according to DDTC. On behalf of lawyers everywhere: Thanks, DDTC, for keeping us busy!
  • More revisions to the TAA Guidelines, which are longer and less interesting than all six volumes of Proust, were announced. These mostly take into account the new definitions of export, re-export and retransfer that were recently adopted as an interim final rule by DDTC. I’ve said it before, and I’ll say it again, true export reform would get rid of the ridiculous TAA process entirely and make it similar to the process used by the Bureau of Industry and Security (“BIS”) for licensing technology exports.
  • The United States Marshals Service (“USMS”) is auctioning off 2,719.32669068 bitcoins. You will be, I’m sure, relieved to know that the auction notice explicitly states that the USMS won’t accept any bids from anyone on OFAC’s SDN List. I wouldn’t want Eliot Ness going after Rooster Cogburn, even if it would make a better movie than Batman v. Superman.

Copyright © 2016 Clif Burns. All Rights Reserved.

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