Many companies are only beginning to grapple with the United
States' export control implications of "cloud
computing," a method of using the Internet to access
third-party information technology resources for using and
developing software applications and for obtaining storage,
processing, and bandwidth resources. Cloud computing providers
offer various services, including webmail, back-up storage
capacity, and tools for software development to users seeking to
outsource selected information technology functions, facilitate
ease of data access, and/or collaborate on software and technology
Cloud computing, like any activity using remote computing
access, might involve technology and software exports, but certain
aspects of cloud computing – for example, users not
always being aware of where their data is being stored in the cloud
– implicate U.S. export control regulations in unique
ways. "U.S. Export Controls and Cloud Computing," an
article written by Hogan Lovells US LLP lawyer Brian Curran,
highlights some of the key cloud computing issues that arise under
the Export Administration Regulations and outlines compliance
measures that companies might consider if they are engaged in or
are considering cloud computing. To read the full article, please
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On May 5, 2016, the U.S. Department of Treasury, Office of Foreign Assets Control (OFAC) announced sanctions against 77 entities and individuals associated with the Waked Money Laundering Organization.
DOJ Civil Rights Division issued a letter highlighting the risk of discrimination claims when employers request citizenship or national origin information from applicants and employees to comply with U.S. export control laws.
Congress and the president just closed a loophole in a customs law that will make it easier for any party to petition U.S. Customs and Border Protection successfully to detain, seize and forfeit imported merchandise shown to have been produced by convict, forced or indentured labor.
On April 15, Adam Szubin, OFAC Acting Under Secretary for Terrorism and Financial Intelligence, spoke at the Center for a New American Security (CNAS) on key lessons learned from U.S. sanctions programs.
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