“nevertheless be sustained on the ground that its exclusive aim is to afford a remedy for a hurtful condition within foreign territory.” Curtiss-Wright, 299 U.S. at 315, 57 S.Ct. 216. This indulgence stems from the Constitution: “In this vast external realm, with its important, complicated, delicate and manifold problems, the President alone has the power to speak or listen as a representative of the nation.” Id. at 319, 57 S.Ct. 216; see also Zemel, 381 U.S. at 17, 85 S.Ct. 1271. The Supreme Court has upheld Congressional delegation to the executive— under the IEEPA — to nullify certain attachments and transfers of assets. See Dames & Moore v. Regan, 453 U.S. 654, 675, 101 S.Ct. 2972, 69 L.Ed.2d 918 (1981); Regan v. Wald, 468 U.S. 222, 232-33, 104 S.Ct. 3026, 82 L.Ed.2d 171 (1984) (<HOLDING>); see also Zemel, 381 U.S. 1, 85 S.Ct. 1271, 14
holding that the trading with the enemy acts provisions for judicial review are exclusive of any other remedy and rejecting arguments that judicial review of actions taken under the trading with the enemy act is available via the administrative procedure act holding that regulations promulgated pursuant to the ieepa and the trading with the ene my act were constitutional holding that retroactive application of agency regulations promulgated after the conduct at issue is disfavored holding that no implied private right of action exists under the nha and noting that the district of columbia first sixth and ninth circuits have held that the housing act and regulations promulgated thereunder do not satisfy the fourpart cort test and thus have refused to create a right of action for private parties who wish to sue to enforce the statute or regulations promulgated thereunder holding that regulations promulgated pursuant to an express congressional grant of rulemaking authority will be upheld unless they are arbitrary capricious or manifestly contrary to the statute