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Emmanuelle, you make the mistake of assume that the congress passed a new law. That is just not the case. What you have here is an administrative clarification of an existing law - basically they are explaining what paperwork is truly needed. The wording and contents of this administrative clarification have been shot down in court before (sundance vs reno), but this is not an Ex Post Facto law, because congress, the house, and the president were not involved in passing a new law.
Don't bet your (american based) business on tricky out clauses and flashy legal game playing.
Alex
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