ZETA provided the following comments to DOE requesting additional guidance related to how the Department will implement the FEOC sub-definition of “a current or former senior foreign political figure.” The comment raises the concern that the proposed interpretation is broad and creates significant uncertainty for industry and recommends a set of questions that DOE could answer to further clarify the term. The comment also urges DOE to use caution when exercising its authority under Section 40207(a)(5)(E) of the Bipartisan Infrastructure Law when making determinations on 'unauthorized conduct.' [Full Text Here]
