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Overview and Implications of the Interim Final Rule Implementing Executive Order 13873 | Morgan Lewis

Venezuelan politician Nicolas Maduro It further clarifies that this list of “foreign adversaries” is to be used only for purposes of the Executive Order, the Interim Rule, and any subsequent rules and not for other purposes. Commerce will periodically review the list and make changes as appropriate. ICTS Transaction: The Interim Rule enhances the definition of “ICTS Transaction” by identifying the specific categories of transactions that are subject to the Executive Order: Ongoing activities, such as managed services, data transmission, software updates, repairs, or the platforming or data hosting of applications for consumer download Any other transaction, the structure of which is designed or intended to evade or circumvent the application of the Executive Order

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