Most Canadian export controls and controlled goods compliance programs are built with the assumption that relevant employees who have access to controlled goods and technical data will be working in an on-site work environment and use work computers and in-house servers where information is securely stored with access and release restrictions and where work-related activities
Controlled Goods Registrants must notify the Minister of data breaches
Persons who are registered with the Controlled Goods Directorate must notify the Minister of Public Services and Procurement of any actual or potential data breach within 3 days of discovery of the breach. Since the requirement includes potential data breaches, Controlled Goods Registrants should report any hacking incidents, potential data breaches, employees taking company data,
Controlled Goods Registrants must report ownership changes
Canadian companies whose business operations involve Controlled Goods must report changes to their Controlled Goods Directorate registration before an acquisition. This means that companies and their in-house and outside lawyers must ensure that the closing checklist includes the Controlled Goods Directorate reporting requirement. The due diligence checklist should also include questions about Controlled Goods registrations
Warning to Employers When Staffing Special Projects
There are many ways employers may run afoul of the anti-discrimination provisions in U.S. immigration law. As a very clear starting point, the general rule for a long time has been and remains an employer may not make hiring, firing, or recruitment / referral decisions based on a worker’s citizenship status. However, there are notable
OFAC Brings the Hammer
In March, there was a good deal of consternation in the general press trying to understand news that President Trump had overruled the actions of the Office of Foreign Assets Control (“OFAC”) to impose additional sanctions on North Korea. Beside the oddity of a President overruling actions by a part of the Executive branch after
Happy New Year – Now Let’s Get Back to Business!
Originally published by the Journal of Commerce in January 2019
One of the topics that consistently makes the top 5 in just about every survey of issues of concern to companies is the cost of regulatory compliance. This is true in large measure because the complexity of the issues covered by those regulations keeps increasing
Maybe and Maybe Not – IOR Challenges
Originally published by the Journal of Commerce in November 2018
One of the many frustrations facing international traders trying to import goods into the U.S. is whether or not they will be accepted as importer of record by Customs and Border Protection (“CBP”). CBP established a program to deal with what it views as the
To Tariff or Not to Tariff – That Is The Question!
In the current tit for tat environment that overhangs international trade, below is an update regarding the 232 tariffs on steel and aluminum, the 301 tariffs related to China’s intellectual property rights and other business practices, and the 232 tariffs threatened on automobiles and parts.
Steel and Aluminum Tariffs:
As everyone by now knows,
Here Come Those New Steel and Aluminum Tariffs!
Earlier today, March 8, 2018, President Trump signed two Presidential Proclamations, one dealing with additional tariffs on steel and the other with additional tariffs on aluminum. As has been widely reported in the general press, those rates are 25% on steel and 10% on aluminum. The only countries exempted are Canada and Mexico.
Steel articles
He Said What ?????
Originally published by the Journal of Commerce in December 2017
While Special Counsel Robert Mueller continues his investigation, the recent guilty plea entered by Trump former National Security Advisor Lt. Gen. Michael Flynn (Ret.) serves as a reminder that when you are interviewed by a law enforcement agent, you better be sure what you say