About Cole Blumer

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So far Cole Blumer has created 18 blog entries.

DoJ Guidance on Voluntary Disclosures

Here is some interesting and applicable information on Voluntary Disclosures that was just issued by the DoJ on December 13, 2019.  It explains that filing a voluntary self-disclosure in a complete and timely manner creates the presumption that the company will receive a non-prosecution agreement and not pay a fine, absent aggravating factors.  If aggravating [...]

By |2019-12-20T13:08:47-05:00December 20th, 2019|Voluntary Disclosure|0 Comments

New Proposed Rules for EAR and ITAR Data Security

On June 3, 2015, the State and Commerce Department issued proposed regulations to harmonize key terms used in the International Traffic In Arms Regulations ("ITAR") and the Export Administration Regulations ("EAR") to include the definition of the term "export".   By contrast, they also included what would not constitute an export.  As an important part of [...]

U.S. Export Controls and Data Storage in Non-US Locations

In accordance with the International Traffic in Arms Regulations (22 CFR 120-130 - herein, “ITAR”) technical data may not be exported to any Non-US Person, including to any location outside of the United States, without a specific authorization by the U.S. State Department. Managing the physical location of any servers used for email or data [...]

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