24 U.S. 184, 191-192 (1998) (holding that the term “willfully” in 18 U.S.C. § 924(a)(1)(D) requires proof only that the accused knew his conduct was unlawful, and not that the accused also knew of a specific licensing requirement); see also United States v. Bishop, 740 F.3d 927 (4th Cir. 2013) (holding that “willfulness” under the AECA, 22 U.S.C. § 2778, requires only general knowledge of illegality and not knowledge of whether a particular item is on the USML); United States v. Roth, 628 F.3d 827, 835 (6th Cir. 2011) (“Section 2778(c) does not require a defendant to know that the items being exported are on the [USML]. Rather, it only requires knowledge that the underlying action is unlawful.”)See Nat’l Security Division, Dep’t Just., Enforcement Policy for Business Organizations, footnote 2, (Mar. 1, 2023), available at . Civil monetary penalty amounts for ITAR violations are annually adjusted for inflation. See Department of State 2023 Civil Monetary Penalties Inflation Adjustment, 88 Fed. Reg. 1,505 (Jan. 11, 2023), available at https://www.federalregister.gov/documents/2023/01/11/2023-00353/department-of-state-2023-civil-monetary-penalties-inflationary-adjustment. The ITAR mandates disclosures for certain types of violations, including cases involving countries listed in § 126.1 and unreturned temporary exports of personal protective gear. Failure to disclose in such cases may itself constitute an ITAR violation. See DDTC Violations and Disclosures FAQs, “Am I required to disclose the violation to DDTC?” (Nov. 2021), available athttps://www.pmddtc.state.gov/ddtc_public/ddtc_public?id=ddtc_public_portal_faq_detail&sys_id=9b16755f1b373050c6c3866ae54bcbaa.See International Traffic in Arms Regulations: U.S. Munitions List Categories I, II, and III, U.S. Dept. of State, 85 Fed. Reg. 3,819 (Jan. 23, 2020), available at https://www.federalregister.gov/documents/2020/01/23/2020-00574/international-traffic-in-arms-regulations-us-munitions-list-categories-i-ii-and-iii (final rule amending the ITAR effect

th upstream and downstream) GHG emissions that contribute to climate change.”14 When discussing the need to analyze the effects of climate change on a proposed action (and not just the impacts of the proposed action on climate change), CEQ gives as an example a project that may require water from a source with diminishing quantities available and advises the agency consider such issues to “inform decisions on siting, whether to proceed with and how to design potential actions and reasonable alternatives, and to eliminate or mitigate effects exacerbated by climate change.”15ConclusionRobust comments are likely to be filed to further inform CEQ’s effort on the GHG Guidance. Nevertheless, CEQ has directed agencies to apply the guidance to all new proposed actions and to consider applying it to proposed actions that are currently under NEPA review. Comments on the interim guidance are due March 10, 2023.1. CEQ, National Environmental Policy Act Guidance on Consideration of Greenhouse Gas, 88 Fed. Reg. 1,196 (Jan. 9, 2023), https://www.govinfo.gov/content/pkg/FR-2023-01-09/pdf/2023-00158.pdf (“GHG Guidance”).2. Id.3. Note that CEQ has announced its intention to further revise its existing NEPA regulations in 2023, after having issued an earlier round of regulatory amendments in 2022. See CEQ Fall 2022 Regulatory Agenda, National Environmental Policy Act Implementing Regulations Revisions Phase 2, RIN No. 0331-AA07, https://www.reginfo.gov/public/do/eAgendaViewRule?pubId=202210&RIN=0331-AA07; CEQ, National Environmental Policy Act Implementing Regulations Revisions, 87 Fed. Reg. 23,453 (Apr. 20, 2022), https://www.govinfo.gov/content/pkg/FR-2022-04-20/pdf/2022-08288.pdf.4. GHG Guidance at 1,201.5. Id. at 1,202-03.6. Id. at 1,203, 1,211.7. Id. at 1,205.8. Id. at 1,204.9. Id.10. Id.11. Id. at 1,206.12. Id.13. Id. at 1,202.14. Id. at 1,204 n.86.15. Id. at 1,208.