15 CFR 764.2(h) Intepretation and Application

An interesting article appeared on ExportLawBlog with respect to 15 CFR 764.2(h) application ("No person may engage in any transaction or take any other action with intent to evade the provisions of the EAA, the EAR, or any order, license or authorization issued thereunder.").  It is a good reading for those who like to engage in interpretative methodology of EAR regulations.  Based on the facts of discussed settlement, it seems that one violates 15 CFR 764.2(h) if one acts as a broker for party or parties subject to denial orders... irrespective of intent prong?  Read the posting.