that assumes that his talk constituted a financial transaction. it's not clear that this is the case. if he was paid to speak, then it does seem plausible, but

that assumes that his talk constituted a financial transaction. it's not clear that this is the case. if he was paid to speak, then it does seem plausible, but that doesn't seem to be disclosed in the press release. if he went for free (and, one would assume, would have needed to pay for the ordinary admission fee), then it's possible to consider it as non-commercial, so that would be only 15-21 months. edit (can't reply yet): I arrived at this number by searching for USC and U.S.C in the press release, then googling IEEPA, finding https://en.wikipedia.org/wiki/International_Emergency_Economic_Powers_Act https://en.wikipedia.org/wiki/International_Emergency_Econom..., then finding 50 U.S.C. § 1701, then going to https://guidelines.ussc.gov/si https://guidelines.ussc.gov/si, putting in 50 U.S.C. § 1705, figuring §2M5.1 is relevant, then putting 14 in https://guidelines.ussc.gov/grc https://guidelines.ussc.gov/grc.