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The American Civil Liberties Union has raised concerns that a ban would "foster an underground market" for menthol cigarettes and "disproportionately impact Black and Brown communities." Aamra Ahmad, a senior legislative counsel at the ACLU, said on Wednesday: "There are serious concerns that the ban implemented by the Biden administration will eventually foster an underground market that is sure to trigger criminal penalties which will disproportionately impact people of color and prioritize criminalization over public health and harm reduction

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