United States:
BIS Addresses 'Commingling' In Crude Oil Exports
08 January 2015
Reed Smith
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On December 30, 2014, the U.S. Department of Commerce, Bureau of
Industry and Security ("BIS") issued its first-ever
published guidance on the Short Supply Controls, the regulations
that limit the export of crude oil out of the United States. The
guidance, provided in the form of Frequently Asked Questions
("FAQs"), is of particular interest to many because it
addresses the timely question of what kind of distillation process
is sufficient to transform crude oil into a product that is
exportable without a BIS license. The FAQs, however, also address
the important but often misunderstood legal issue of
"commingling."
Click
here for the issued Client Alert.
This article is presented for informational purposes only
and is not intended to constitute legal advice.
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