Response from Greystone, Ltd.

The Director of Greystone, Ltd., Chris Burgess, contacted me regarding the previous post,  "101 Uses of an Offshore Special Forces Unit."  He wrote to clarify and made no requests for changes.  In the interest of fairness, I'm publishing his comments and an apology and I did make some changes to the post in question.  He writes: 

[Y]ou assert that Greystone will market services "U.S. interests be damned."  Beyond the fact that our compliance with U.S. export regulations precludes this possibility, Greystone is firmly committed to supporting U.S. interests and only provides support to friendly foreign-nation clients.

I"ll fall on my Ka-Bar on this one.  I was wrong to have written "U.S. interests be damned" and I have deleted it from the post.  This was too flippant.  The parent company, Blackwater, has been very careful to act only within US interests.  Those who I know who have worked for it are very patriotic and that aside, the firm has over a half-billion dollars of USG contracts riding on not crossing this line.  That's Blackwater.  Now with Greystone, I have every reason to believe that what their Director writes is true.  The finer point, which I was thinking when I wrote the quip, was about how easy it is to stumble over US interests in grey areas where it is not so clearly defined and it is evolving.  This is a much more complex issue that deserves more serious treatment.  My apologies to Greystone.

Mr. Burgess also writes:

Your March 6, 2007 blog entry asserts that Greystone is not subject to U.S. export and sanctions restrictions.  To the contrary, Greystone is subject to DDTC jurisdiction and regulation, pursuant to Part 120 of the International Traffic in Arms Regulations (ITAR), by virtue of the fact that it employs U.S. citizens.  In point of fact, the relevant management entity is a U.S.-registered exporter, and required licensing is sought prior to performance of any regulated contract.

This is very interesting.  My question is what contracts are regulated. I was aware of Greystone employing Third Country Nationals, but not US citizens.  It is not clear to me if the employ of citizens reclassifies an organization under CFR Part 120.15 and 120.16.  I welcome emails or comments from readers with specialized expertise.  I am researching:

(1.) under what conditions are contracts of a foreign person, as defined by the DDTC, subject to DDTC?
(2.) how does the employment of US citizens affect the classification of a corporation that is otherwise classified as a foreign person under the DDTC?

What I have been able to determine conclusively, is that  Blackwater needs to raise its minimum job requirements for its open position for an export compliance officer.  This stuff is dense.  A high school diploma and less than a year's experience is not adequate preparation to sift through the regs I'm slogging through right now and to perform the duties listed in the current job posting. 

High school and less than a year's experience would be the educational and experience level I would look for in someone I had to have around to point to at RFP time, but wanted to be able to steamroll as needed.  It's the background level in a paraprofessional that you want when you want to be able to control those PITA positions that can drive you nuts like QA and safety.  However, to be done correctly, IMHO, such a position requires a professional with a law degree.

Comments

[Travis Moore]

Bogus is just a word.

If you go looking into certain charities like the International Christian Response, you come across a Christian news agency called Compass Direct News.

Googling Compass Direct News gets you a series of items written by Compass Direct News except for a Wikipedia article.
http://en.wikipedia.org/wiki/Compass_Direct

The people at Wikipedia warn that 1. it reads like an advertisement and 2. it is orphaned, or is not linked to much.

Looks like a plant.

Is it a coincidence that the International Christian Response sounds a lot like Christian Response International and Christian Solidarity International. Both of which were used as names by the Christian Freedom International which is fronted by Blackwater.

If it looks like it, tastes like it, smells like it , then let's investigate it a little more.

It is a plant. The wording is the same as that on their web page.

http://www.compassdirect.org/en/display.php?page=compass&lang=en&length=short&idelement=4508

I find this a little suspicious and have been trying to let people know my suspicions in a low key manner.

[Travis Moore]

Bogus is just a word.

If you go looking into certain charities like the International Christian Response, you come across a Christian news agency called Compass Direct News.

Googling Compass Direct News gets you a series of items written by Compass Direct News except for a Wikipedia article.
http://en.wikipedia.org/wiki/Compass_Direct

The people at Wikipedia warn that 1. it reads like an advertisement and 2. it is orphaned, or is not linked to much.

Looks like a plant.

Is it a coincidence that the International Christian Response sounds a lot like Christian Response International and Christian Solidarity International. Both of which were used as names by the Christian Freedom International which is fronted by Blackwater.

If it looks like it, tastes like it, smells like it , then let's investigate it a little more.

It is a plant. The wording is the same as that on their web page.

http://www.compassdirect.org/en/display.php?page=compass&lang=en&length=short&idelement=4508

I find this a little suspicious and have been trying to let people know my suspicions in a low key manner.