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The other thing to consider would be US-based affiliates sending traffic to non-US based sponsor programs.
They would have little need to comply with 2257 laws as it becomes quite easy to cloud the ownership of sites & traffic sources if you have a sponsor program outside of the DOJ's jurisdiction cutting your cheques.
The affiliate would still be at risk but it would be a much lower risk than if he was sending his traffic to a US-based sponsor who could be bullied into giving up his information to the US government.
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