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The Export Practitioner introduces a web-based format for easier review, research and sharing.
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– Frank Ruffing, Editor
The International Trade and Security group of Morgan Lewis brings to our attention the following: The Fifth Circuit Court of Appeals ruled that immutable smart contracts on Tornado Cash, a cryptocurrency transaction protocol, are not “property” under the jurisdiction of the Office of Foreign Assets Control (OFAC). This decision restricts OFAC’s ability to sanction Tornado Cash based on such contracts. The court relied on the Supreme Court’s Loper Bright Enterprises v. Raimondo decision, emphasizing that immutable smart contracts lack traditional characteristics of property, such as ownership and control.
For the first time in fifteen years, the State Department proposes to revise and increase the registration fees charged to those required to register with DDTC. During the 45-day public comment period, the feedback, primarily from individuals and small businesses, raised concerns about the financial burden on small enterprises, barriers to entry, and the disproportionate impact on manufacturers who must register to meet private-sector contracting requirements.
The Bureau of Industry and Security (BIS) is seeking public comments on the impact that implementation of the Chemical Weapons Convention (CWC), through the Chemical Weapons Convention Implementation Act of 1998 and the Chemical Weapons Convention Regulations (CWCR), has had on commercial activities involving “Schedule 1” chemicals during calendar year 2024. Schedule 1 chemicals are chemicals that are considered a high risk to the Chemical Weapons Convention (CWC) and have little to no peaceful use. They include chemicals that have been used as weapons, such as sarin, mustard, VX, and ricin, as well as precursor chemicals that can be used to produce these chemicals
Bureau of Industry and Security (BIS) issued a final rule cementing the procedures it will follow in investigating foreign adversary threats to information and communications technology and services (ICTS) transactions that may harm U.S. national security
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