302 briefs
KalshiEX must operate BTCPERP under full CEA and CFTC compliance; all other DCMs must obtain separate Regulation 40.3 approval before listing any perpetual contract on assets outside the Order.
DCMs, SEFs, DCOs, and FCMs must satisfy CFTC staff expectations and conduct asset-class suitability assessments before extending operations to 24/7 trading, clearing, or settlement — proceeding without that pre-compliance creates enforcement exposure.
FCMs posting customer-owned digital commodities or stablecoins with affiliated foreign brokers as margin must satisfy MPD's specified conditions and ensure the foreign broker holds a right of re-use — transfers outside those conditions carry full enforcement exposure.
Sanctions screening teams must update SDN lists for OFAC's 76-entry modernization removal effective 28 May 2026
US persons must block all transactions with the SDN-listed individual; US service providers must screen before engaging or paying her
Importers that paid IEEPA tariffs must submit CAPE refund claims or file protests within statutory deadlines to recover duties; treasury and tax teams must process $85bn in refunds plus interest
US persons must block PERSIAN GULF STRAIT AUTHORITY and any entity 50%+ owned by it; non-US financial institutions and maritime operators face secondary-sanctions exposure under EO 13224 §1(b)
State licensing agencies must pause or deny non-domiciled CDL issuance unless applicants hold H-2A, H-2B or E-2 status
Adjustment applicants must generally use consular processing unless extraordinary circumstances apply
Raw cane sugar exporters must route USA TRQ exports through APEDA-backed quota allocation
U.S. admission officials must apply the 21-day Ebola travel restriction to lawful permanent residents
Cuba-linked operators must treat use of confiscated property as Title III liability exposure
