BIS’s dismissal of an appeal by a Belgian businessman and his company is procedurally narrow, but its compliance lesson is broader: an expired, non-renewed temporary denial order cannot be used as a vehicle for collateral relief under EAR § 766.24, even where the respondent disputes the factual basis for the original order. The decision also underscores the separate legal effect of BIS tools. A temporary denial order may lapse, but later Entity List restrictions, OFAC sanctions and criminal proceedings can continue to carry the operative compliance risk.
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