Today, the U.S. Department of Commerce, Bureau of Industry and Security (“BIS”) issued the 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”), sheds light on a number of issues, including the definition of “crude oil” under BIS regulations and the extent to which crude oil must be processed in order to qualify as a product that is exportable without prior BIS authorization.
Click here for the issued Client Alert.