http://www.exportlawblog.com/archives/394 Latest News on DDTC, BIS, OFAC, and other export law matters Thu, 29 Jul 2010 15:45:32 +0000 hourly 1 http://wordpress.org/?v=3.0 http://www.exportlawblog.com/archives/394/comment-page-1#comment-20541 Mike Deal Sat, 20 Sep 2008 17:47:08 +0000 http://www.exportlawblog.com/?p=394#comment-20541 OKAY, lets all agree that I'm having a senior moment, but, even if we assume that the EAA had not expired 7 years and four Congresses ago, even if we ignore the language in Regan v. Wald to the effect that a change in the Cuban regulations would not have been authorized by IEEPA without a declaration of national emergency had those "authorities" not been grandfathered in, just what is the statutory authority for the Entities List and such an expansion of it without a declaration of national emergency? OKAY, lets all agree that I’m having a senior moment, but, even if we assume that the EAA had not expired 7 years and four Congresses ago, even if we ignore the language in Regan v. Wald to the effect that a change in the Cuban regulations would not have been authorized by IEEPA without a declaration of national emergency had those “authorities” not been grandfathered in, just what is the statutory authority for the Entities List and such an expansion of it without a declaration of national emergency?

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