|After the UK Brexit referendum of 23 June the implications on the political, economic and legal relations between the UK and the EU have been discussed from many angles. But what about...|
Commerce Department Issues Guidance on Exports in the Cloud
The recent advisory opinion also points out that accessing software in the cloud still might involve an export of technology, a cautionary note worth considering. Although in some cases technology transferred through use of a commercial SaaS offering might be subject to minimal export restrictions or might not even be subject to the EAR, it also is possible that the SaaS software, depending on its sophistication, could generate and then lead to the export of highly controlled EAR technology. As always, cloud users should understand the export restrictions applicable to their technology flowing in and out of the cloud.
The Department of Energy (DOE) recently published its revised Part 810 Guidance on compliance with the amended Part 810 Regulations on nuclear export controls (10 C.F.R. Part 810). The 2015 ...24 June 2016
FinCEN Designates North Korea as a Jurisdiction of Primary Money Laundering Concern, Triggering Additional Due Diligence Requirements for Financial Institutions
Pursuant to the North Korea Sanctions and Policy Enhancement Act of 2016’s requirement that the Secretary of the Treasury determine whether North Korea is a jurisdiction of...16 June 2016