68. Export Control Fundamental for Compliance Managers ICPA Jasper Helder, Baker & McKenzie, Amsterdam [email_address]
Notas do Editor
Under the EAR Not limited to exports/reexports to sanctioned countries Whether a license is required depends on combination of: - classification - destination - restricted end-user - restricted end-uses Cf. EU – if on list license requirement exists
- Last in time rule e.g. Iranian national with UK permanent residency - Office of Inspector General Proposal to change to country of birth met huge resistance and dropped. - Possible modified rule.