FAR regs do not even require it to have a jettison system.
Are you sure about that part? It may not be spelled out in the FARs, but good luck certifying without one if there is a big delta between MTOW and Max Landing.
At EIS, the 767 didn't have a fuel jettison - but Max TO was 330k lbs., and Max Landing was 320k lbs. - so no big deal. But then Boeing started jacking the max TO weight - eventually getting over 400k lbs., but max landing didn't change. The FAA mandated Boeing install a fuel jettison system, and even went so far as to force it be retrofit to a few already delivered aircraft.