FACT AND FICTION OF EXEMPTIONS: LDA AND COMMERCIAL

Part II: The Biggest Misunderstandings About the Commercial Exemption

September 25, 2019 1:30pm

Amy Jeffress
Partner
Arnold & Porter Kaye Scholer LLP

Kate Sawyer Keane
Partner, Political Law Group
Perkins Coie LLP

  • What are the parameters of this exemption? The biggest misconceptions
  • Clarifying the term “purely commercial activity not in support of a foreign government”
  • At what point is an entity considered as working for a foreign government?