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Just a word of thanks for your thorough and incisive reporting. It's a real public service for those of us who missed the boat on registration (in my case by a couple of hours).

OFAC ducked any and all questions related to authorization for its controls on technology transfers. The basic rule laid out in the text of IEEPA (50 USC 1702) is that if its not a list based control, i.e., controlled under the EAA for national security (Sec. 5) or certain foreign policy controls Sec. 6), OFAC has no statutory authority to control it. Even sanctions within that statutory standard may run afoul of the constitutional standard. See the 6th Circuit's opinion in Junger v. Daley. Let's face it, only the boys in Beijing benefit from OFAC.

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