Internalizing BIS Policy On Crude Oil Exports

Law360, New York (January 13, 2015, 10:58 AM EST) -- On Dec. 30, 2014, the U.S. Department of Commerce's Bureau of Industry and Security issued a long-awaited guidance related to the export of crude oil and crude oil condensate. In particular, the guidance, which was issued in the form of a FAQ on the BIS' website,[1] provides factors the bureau will consider in determining whether crude oil, including condensate, has been sufficiently processed so as to be considered a petroleum product and no longer subject to crude oil's strict export licensing requirements. The BIS also provided guidance as to whether foreign origin crude oil can be commingled with any amount of U.S.-origin crude and still be eligible for export....

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