EMBARGOED!
EMBARGOED! is a podcast about international trade hosted by the law firm Miller & Chevalier. It offers intelligent discussion of trade policy, regulation, and enforcement for both trade professionals and general listeners. Episodes cover topics such as tariffs, sanctions, export controls, and global supply chains. The show aims to make complex trade issues accessible and engaging.
Episodes
100th Episode Extravaganza | EMBARGOED! Episode 100
Happy 100th Episode! Tim O'Toole is joined by EMBARGOED! co-founder and co-host emeritus Brian Fleming (Steptoe LLP), plus colleagues Melissa Burgess and Collmann Griffin (Miller & Chevalier), for a celebratory recording of the 100th episode of the podcast. In a special edition of the Lightning Round, the team shares thoughts about developments in Iran, Russia, and Cuba sanctions. Along the wa
Sanctions History Trivia | EMBARGOED! Episode 99
Host Tim O'Toole is joined by colleagues Melissa Burgess and Collmann Griffin (Miller & Chevalier) and guest Rachel Alpert (Jenner & Block) to dive into the history of U.S. economic sanctions. Kicking off the episode, the group tackles a range of trivia questions about predecessors to OFAC, sanctions licensing, sanctions measures dating back to the Revolutionary War, and more. Draft-style,
Emergency Pod: Iran MOU | EMBARGOED! Episode 98
In this emergency episode, host Tim O'Toole is joined again by colleague Melissa Burgess (Miller & Chevalier) to discuss sanctions aspects of the June 17, 2026, Islamabad Memorandum of Understanding (MOU) between the U.S. and Iran and legal considerations impacting the lifting of sanctions against the Islamic Republic of Iran. The episode reviews paragraphs 7 and 10 of the MOU before taking a
The Gold Episode | EMBARGOED! Episode 97
In this episode, host Tim O'Toole is joined by special guests Brad Brooks-Rubin (Arktouros) and Dr. David Soud (I.R. Consilium), as well as colleagues Collmann Griffin and Melissa Burgess (Miller & Chevalier), to discuss the many connections between gold and sanctions. The episode begins by exploring gold as a natural resource, the gold supply chain, and the difficulties of tracing gold. We al
Sanctions and the State Department – Part 2 | EMBARGOED! Episode 96
In this episode, host Tim O'Toole is again joined by colleagues Collmann Griffin and Melissa Burgess (Miller & Chevalier) and special guests Erik Woodhouse (former Deputy Assistant Secretary for Counter Threat Finance and Sanctions in the Bureau of Economic and Business Affairs (EB) at the Department of State) and Joshua Kretman (former Deputy Assistant Secretary (Acting) in EB, who also spent
Sanctions and the State Department – Part 1 | EMBARGOED! Episode 95
In this episode, host Tim O’Toole is joined by colleagues Collmann Griffin and Melissa Burgess (Miller & Chevalier), and special guests Erik Woodhouse (former Deputy Assistant Secretary for Counter Threat Finance and Sanctions in the Bureau of Economic and Business Affairs (EB) at the Department of State) and Joshua Kretman (former Deputy Assistant Secretary (Acting) in EB, who also spent seve
CFIUS (and Reverse CFIUS) in 2025: A Year in Review | EMBARGOED! Episode 94
In this episode, Host Tim O'Toole is once again joined by Melissa Burgess, Counsel at Miller & Chevalier. Tim and Melissa discuss the major events and developments in 2025 for the Committee on Foreign Investment in the United States (CFIUS) and the Outbound Investment program that is sometimes referred to as "Reverse CFIUS" (because it involves restrictions on U.S. investment into foreign coun
BIS 2025 Year in Review | EMBARGOED! Episode 93
Host Tim O'Toole is joined by guests Melissa Burgess (Counsel at Miller & Chevalier) and Michael Burton (Partner at Jacobsen Burton Kelley) to make their draft picks from a pool of Bureau of Industry and Security (BIS) actions in 2025. Throughout the draft, they dissect each other’s choices, issue some compliments, suggest New Year's resolutions for the agency, and propose a new test for BIS a
OFAC 2025 Year in Review | EMBARGOED! Episode 92
Happy new year from your friends at EMBARGOED! Tim and Miller & Chevalier's Caroline Watson and Collmann Griffin draft the most significant OFAC events of 2025. The draft is three rounds and picks include sanctions relating to Iran, narco-trafficking, Yemen, Russia, Venezuela, Syria, China, and the International Criminal Court (ICC).
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Thanks to our guests for joining us:
Collmann Griffi
Shipping Compliance with Sanctions Expert Claire O'Neill McCleskey | EMBARGOED! Episode 91
On this episode of EMBARGOED!, host Tim O'Toole is joined by Miller & Chevalier's Collmann Griffin and Claire O'Neill McCleskey, former Head of the OFAC Compliance Division, to discuss sanctions compliance in the shipping industry.
Roadmap:
Typologies
Iran
Russia, including Lukoil/Rosneft and price cap
North Korea
How can you protect yourself?
Best commercial screening tools
Tips for insu
Sanctions & Export Control Evasion with Conflict Armament Research's Damien Spleeters | EMBARGOED! Episode 90
This week, host Tim O'Toole chats with Damien Spleeters (Conflict Armament Research) and return guest Collmann Griffin (Miller & Chevalier) about how bad actors use sophisticated evasion tactics to circumvent U.S. export controls and sanctions to obtain components America's adversaries need for missiles, drones, and other weapons systems.
Roadmap:
Background on Conflict Armament Research (CAR
South of the Border | EMBARGOED! Episode 89
On this episode of EMBARGOED!, host Tim O'Toole is joined by Matteson Ellis (Latin America Practice Lead at Miller & Chevalier) discuss all the sanctions news from Latin America, with a focus on recent developments in Mexico.
Roadmap:
Introduction, Matt goes to Mexico
Foreign Terrorist Organizations (FTOs) and LatAm
Mexico, FTOs, and FinCEN orders
What's happening on the ground
The rest of La
Semiconductor Export Controls (Part 2): AI, SME, and the BIS 50% Rule | EMBARGOED! Episode 88
On this episode of EMBARGOED!, host Tim O'Toole, Miller & Chevalier Counsel Melissa Burgess and Collmann Griffin, and guest Chris Chamberlain of Morrison & Foerster continue their discussion of AI chip-related export controls, musing about Infrastructure-as-a-Service (IaaS) considerations, semiconductor manufacturing equipment (SME), and the much-anticipated BIS release of a 50 Percent Rul
Semiconductor Export Controls (Part 1): AI Chips and the "Secret Entity List" | EMBARGOED! Episode 87
On this episode of EMBARGOED!, host Tim O'Toole is joined by Miller & Chevalier Counsel Melissa Burgess and Collmann Griffin, and guest Chris Chamberlain of Morrison & Foerster to review the evolution of export controls on AI chips from October 2022 to the present. The discussion explores the variety of tools BIS has employed as it wrestles with tailoring controls, the value of BIS "is inf
EU Sanctions for American Lawyers | Episode 86
Host Tim O'Toole discusses the latest EU sanctions on Russia with returning guests Collmann Griffin (Miller & Chevalier) and Dr. Tobias Ackermann (BLOMSTEIN). They focus on EU sanctions on Russia imposed that may be stricter than or conflict with their U.S. counterparts.
Roadmap:
Logistics of the sanctions
Imports and purchase - aluminum and Russian petroleum
Software
Finance and crypto
"Best
Die Kunst Des Erfolgs: Navigating Foreign Investment Deals Through U.S., EU, and German Regulators | EMBARGOED! Episode 85
On this episode of EMBARGOED! Host Tim O'Toole is joined by guests Melissa Burgess (Miller & Chevalier) and Dr. Tobias Ackerman (BLOMSTEIN) to compare and contrast the foreign investment review regimes in the EU and Germany with the CFIUS process in the U.S.
Roadmap:
Brief introduction to Germany's FDI regime and the EU regime
A quick history of CFIUS
Exploration of the types of transactions
Mixing It Up with Tornado Cash, Part 2 | EMBARGOED! Episode 84
Host Tim O'Toole is joined by fellow Miller & Chevalier Member Leah Moushey to unpack the recent conviction of Tornado Cash co-founder Roman Storm for operating an unlicensed money transmitting business, an outcome that surprised many given the jury's deadlock on the more severe money laundering and sanctions charges.
The discussion explores how this case reflects the evolving enforcement la
Looking Into the Sanctions and Export Controls Crystal Ball | EMBARGOED! Episode 83
In this episode of EMBARGOED!, host Tim O'Toole and his guest, Miller & Chevalier Counsel Collmann Griffin, make predictions of what's next in sanctions and export controls, including Russia, Iran, Latin America, and AI chips.
Roadmap:
Intro
Upcoming Russia sanctions and tariffs
Likelihood of an Iran deal
Latin America, Foreign Terrorist Organizations, Mexico, Brazil, and human rights sanctio
Winding Down Sanctions: A To-Do List When a Program Comes to an End | EMBARGOED! Episode 82
On this episode of EMBAROGED!, host Tim O'Toole and his guests, Miller & Chevalier Counsel Melissa Burgess and Collmann Griffin, explore the various ways the U.S. government lifts sanctions programs and corresponding export controls.
Roadmap:
So you want to lift sanctions: How can you do it? What complexities might be involved?
A quick tour of history:
Lifting sanctions under TWEA Section 5(
U.S. and EU Divergence in Trade and Enforcement | EMBARGOED! Episode 81
This week on EMBARGOED!, host Tim O'Toole is joined by Dr. Tobias Ackermann (BLOMSTEIN) and Caroline Watson (Miller & Chevalier) discuss the growing divergence between the U.S. and EU on key trade issues including economic sanctions on Russia, reciprocal tariffs, and export controls.
Roadmap:
Increasing disparity between U.S. and EU regulations and policies, regarding Russia
EU's release of
Talking China, Cars, and Tech | EMBARGOED! Episode 80
On this episode of EMBARGOED!, Tim and guests Matt Fogarty (Lead Counsel – Trade & Human Rights, General Motors) and Caroline Watson (Counsel, Miller & Chevalier) talking about the new Information and Communications Technology and Services (ICTS) regulations with a focus on China, cars, and tech.
Roadmap:
Background and rationale of ICTS regulations
The amended ICTS transaction review reg
ITAR Year in Review | EMBARGOED! Episode 79
Host Tim O'Toole and guests Melissa Burgess (Miller & Chevalier) and Johanna Reeves (Reeves & Dola, LLP) discuss changes to the ITAR that came into effect in 2024, proposed rules that could be finalized in 2025, and the enforcement outlook for the new year.
Roadmap:
Updates: Addition of Nicaragua as a 126.1 country and new DDTC guidance for universities
Deeper dives
Expansion of § 120.54
Predictions for Trade in 2025: Tariffs and Sanctions Outlook | EMBARGOED! Episode 78
On this episode, host Tim O'Toole and guests Richard Mojica and Laura Deegan of Miller & Chevalier discuss potential tariffs (including IEEPA and China) and sanctions changes (including Venezuela and Iran) in a second Trump term.
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Thanks to our guests for joining us:
Richard Mojica: https://www.millerchevalier.com/professional/richard-mojica
Laura Deegan: https://www.millerchevalier
BIS Enforcement Actions: Everything You've Ever Wanted to Ask a (Former) BIS Special Agent | EMBARGOED Ep. 77
On this week's EMBARGOED!, host Tim O'Toole and Miller & Chevalier's Melissa Burgess, with guest Don Pearce, currently a Senior Advisor with Torres Trade Advisory and a retired BIS Special Agent, discuss the role of BIS Special Agents in enforcement actions, plus updates to BIS enforcement policies, recent enforcement actions, and best practices for industry.
Roadmap:
Introduction
The role of
Sanctions on the Ballot | EMBARGOED! Ep. 76
On this episode of EMBARGOED!, host Tim O'Toole and Miller & Chevalier Counsel Laura Deegan discuss how the upcoming U.S. elections could affect sanctions policy.
Roadmap:
Introduction
A new administration is coming - What would a President Harris do? What would a President Trump do?
Changes in Treasury and State appointees
Country by Country: Iran, Russia, North Korea, Venezuela, Cuba
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Back to School | EMBARGOED! Episode 75
Host Tim O'Toole and Miller & Chevalier Senior Associate Melissa Burgess discuss export control considerations for universities, plus new export controls on advanced tech and revisions to the BIS voluntary self-disclosure regulations.
Roadmap:
Introduction
Upcoming speaking, podcasts, and events
New BIS export control compliance resources for the academic community
Compliance Note and Compendi
Lucky 14: The 14th Sanctions Package Against Russia & What it Means on Both Sides of the Atlantic | EMBARGOED! Ep. 74
This week on EMBARGOED!, host Tim O'Toole is joined by BLOMSTEIN's Dr. Florian Wolf and Hanna Sophie Kurtz to discuss the 14th EU sanctions package against Russia and other sanctions topics.
Roadmap:
Introduction
Background to the 14th EU sanctions package against Russia: Why was it necessary? Why was it delayed? What is its purpose, scope, and applicability? What are details of its legal framewor
A Deep Dive into CFIUS and Reverse CFIUS | EMBARGOED! Ep. 73
On this episode of EMBARGOED!, host Tim O'Toole is joined by Miller & Chevalier attorneys Caroline Watson and Melissa Burgess to discuss U.S. controls on investment transactions under the CFIUS program and the new reverse CFIUS program, as well as the potential impact of the Supreme Court’s recent decision in SEC v. Jarkesy on enforcement by civil penalties.
Roadmap:
Intro
CFIUS
Outbound Inve
Sanctions Compliance on the High Seas: Shipping, Insurance, Price Caps and the Dark Fleet | EMBARGOED! 72
In this episode of EMBARGOED!, host Tim O'Toole and guests Eric Orsini (Lloyd's List Intelligence), Laura Deegan (Miller & Chevalier), and Manny Levitt (Miller & Chevalier) focus on the shipping industry and sanctions compliance. They talk about shipping, insurance, price caps and have an extended discussion of the Dark Fleet.
Road map:
Introductions
Introduction to the Price Cap
Achieving
Demystifying the OFAC Lists: Talking De-listing With Erich Ferrari | EMBARGOED! Episode 71
In this episode of EMBARGOED, host Tim O'Toole and guest Erich Ferrari discuss common questions and issues related to the OFAC delisting process.
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Thanks to Erich Ferrari for joining us: https://www.ferrariassociatespc.com/our-team/erich-ferrari/
Questions? Contact us at podcasts@milchev.com.
EMBARGOED! is not intended and cannot be relied on as legal advice; the content only reflects the
An Update from Update 2024 | EMBARGOED! Episode 70
In this episode, host Tim O'Toole is joined by guest Doug Jacobson as they podcast live from the last day of the 2024 BIS Update Conference.
Roadmap:
China
Russia
Semiconductors
ICTS
Part 744
DDTC Update
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Thanks to Doug Jacobson for joining us: https://www.jbktradelaw.com/douglas-n-jacobson
Questions? Contact us at podcasts@milchev.com.
EMBARGOED! is not intended and cannot be relied on a
If Sanctions are the New FCPA, are Export Controls the New Sanctions? | EMBARGOED! Episode 69
On this episode of EMBARGOED!, host Tim O'Toole is joined by Miller & Chevalier Senior Associate Melissa Burgess explore the evolving role played by export controls in U.S. sanctions policy, and discuss a few recent developments.
Roadmap:
"Sanctions are the New FCPA"
OFAC’s revised approach to sanctions: 2021 to the present
The role of BIS and export controls in response to Russia/Ukraine
Seco
2023 Year in Review: The Good, the Bad, and the Ugly in U.S. Sanctions | EMBARGOED! Ep. 68
In this episode of EMBAROGED!, host Tim O'Toole and his guest, fellow Miller & Chevalier attorney Laura Deegan, recap sanctions developments in 2023, focusing on developments in U.S. sanctions against Russia, Iran, Venezuela, and virtual currency companies.
Roadmap:
RUSSIA
Sanctions designation trends
New directive/determinations
Sector-wide determinations under E.O. 14024 Section 1(a)(i)
Serv
The ITAR Episode (for the Real Trade Nerds) | EMBARGOED! Episode 67
In this episode, host Tim O'Toole and guest Scott Gearity, President of the Export Compliance Training Institute (ECTI), talk in-depth about the International Traffic in Arms Regulations (ITAR). They discuss the growing importance of the regulations related to the provision of defense services abroad by U.S. persons, the jurisdictional implications of importing of foreign made defense articles int
Blowing in the Wind: The Tornado Cash Designation, Mixers, and Federal Litigation | EMBARGOED! Ep. 66
On this episode of EMBARGOED!, host Tim O'Toole and guest Leah Moushey (Counsel, Miller & Chevalier) return to the subject of cryptocurrency mixers, specifically in the context of Tornado Cash and recent agency guidance. Their discussion looks at the recent federal ruling in a challenge to its designation brought by Tornado Cash and the subject of cryptocurrency and Office of Foreign Assets C
Changes in Venezuela: Emergency Pod! | EMBARGOED! Ep. 65
Tim and this week's guest, Miller & Chevalier Counsel Laura Deegan, talk about big recent changes to Venezuela sanctions, including a discussion of what happened, how long its expected to last, and what companies can do to better understand and comply with the changed sanctioned regime in Venezuela.
Roadmap:
The U.S. government suspended certain sanctions measures in three sectors of the Venez
Why Can’t We Be Friends? The Growth of Multi-Lateral Coordination in U.S. Sanctions Policy Toward Russia | EMBARGOED! Ep. 64
This week on EMBARGOED! host Tim O'Toole is joined by guests Dr. Laura Louca of Blomstein and Caroline Watson of Miller & Chevalier to talk about how EU and U.S. sanctions have evolved in the past 18 months in a time of growing sanctions infrastructure in Europe and growing coordination of policy in the U.S. They'll focus on similarities and differences in U.S. and EU regimes.
Roadmap:
Before
Taking It to the Banks: The Role of Financial Institutions in Sanctions Compliance | EMBARGOED!
This week, in light of the expanding multi-lateral sanctions against Russia and the focus on financial institutions as the front lines of sanctions compliance, host Tim O'Toole and guest Stéphanie Broekaart (Magara Sanctions and Export Controls Compliance Counseling) take a close look at the role of financial institutions in export controls and sanctions compliance.
Roadmap
First things first:
Takeoff: Staying Sanctions Free on the Canadian Side of the Border | EMBARGOED! Episode 62
In this week's episode, Tim and guests John Boscariol (Partner, McCarthy Tetrault) and Stacy Keen (Partner, Pinsent Masons) focus on Canadian sanctions, including the evolution of the Russia sanctions, a comparison of Canadian and U.S. approaches to ownership and control issues, and a look at unique compliance challenges.
Roadmap:
50,000 foot primer on Canadian sanctions, including sanctions autho
Russia, Russia, Russia, Russia | EMBARGOED! Episode 61
In the wake of most recent round of sanctions against Russia, host Tim O'Toole and guest Dara Fernandez Perez (General Counsel – Trade Sanctions, EMEAI at Honeywell) discuss the impact of earlier sanctions packages, the challenges and opportunities those sanctions have created for the sanctions compliance and legal communities, and the particulars of the latest sanctions on both sides of the Atlan
The 2023 Sequel to Episode 19: What’s Up with TikTok? | EMBARGOED! Episode 60
Host Tim O'Toole is joined by guest Art Dicker (Senior Counsel with R&P China Lawyers in Shanghai) to discuss the ongoing TikTok legal saga. They'll outline the history of regulation and executive orders regarding TikTok and the proposed legislation addressing it moving forward.
Roadmap:
History
Commerce Department executive order under IEEPA
CFIUS (music.ly acquisition)
Supply Chain Notice of Ru
2022: The Year Sanctions Came of Age in Germany? | EMBARGOED! Episode 59
This week, host Tim O'Toole and our guest Roland Stein of the Blomstein law firm in Berlin review trade-related developments in Germany in 2022, particularly with regard to sanctions against Russia.
Roadmap:
German export controls and sanctions
German enforcement agency
History of German enforcement pre-Russia
IT prohibition
Legal services prohibition
Price caps
Germany's Sanctions Enforcement Act
Price Caps! On Both Sides of the Atlantic | EMBARGOED! Episode 58
Host Tim O'Toole is joined by Stephenson Harwood's Sue Millar to discuss the relatively new price caps on Russian crude oil and the coming price caps on petroleum products in both the U.S. and the U.K.
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Thanks to our guest, Sue Millar, for joining us: https://www.shlegal.com/en/people/sue-millar
Questions? Contact us at podcasts@milchev.com.
EMBARGOED! is not intended and cannot be relied
2022: The Good, the Bad, and the Ugly in U.S. Export Controls | EMBARGOED! Episode 57
Happy New Year from EMBARGOED! In this episode, host Tim O'Toole is once again joined by Doug Jacobson from Jacobson Burton Kelley PLLC, this time to go over 2022's major U.S. export controls developments. They'll cover:
Global developments
BIS June 30, 2022 Administrative Enforcement Memo
December 5, 2022 ITAR Compliance Program Guidelines
Notable enforcement cases
Country-specific developments
China Redux: What Could Be Lurking in the Supply Chain? | EMBARGOED! Episode 56
In this episode, Tim is joined by Kate Yin (Fangda Partners) and Miller & Chevalier's Richard Mojica and Virginia Newman to discuss due diligence and other issues arising from the newly implemented Uyghur Forced Labor Prevention Act. The group walks through the basics of the UFLPA, the challenges it creates for U.S. importers, the industries it targets for enforcement, and the rebuttable presumpti
New Export Controls Related to China and Big Changes to the EAR | EMBARGOED! Episode 55
This week, Tim is joined by Doug Jacobson from Jacobson Burton Kelley PLLC to discuss new export controls related to China that were put out on October 13, 2022. They'll cover:
Unverified List and Entity List changes
New export controls for certain advanced computing integrated circuits, supercomputer end uses, and Entity List modifications
New cont
Emergency Pod: Sanctions Building in Nicaragua | EMBARGOED! Episode 54
On October 24, 2022, President Biden issued an executive order that created infrastructure that could lead to a significant increase in Nicaragua sanctions. In this emergency podcast, Tim is joined by fellow Miller & Chevalier Member Alejandra Montenegro Almonte and Senior Associate Manuel Levitt to discuss the specifics of the new sanctions order, and talk about what that could mean for Nicaragua
EU and Dutch Sanctions Enforcement | EMBARGOED! Episode 53
Tim is joined by Van Doorne's Neyah van der Aa for an in-depth discussion of current EU and Dutch sanctions enforcement. They'll touch on the new EU facilitation provision and the new EU limitation on legal services to Russia. In the lightning round, we're back to crypto with Bittrex.
Roadmap:
EU sanctions enforcement
Dutch sanctions enforcement
New EU facilitation provision
What does it mean
Cha
A Multi-Lateral Approach to Podcasting and Price Caps | EMBARGOED Episode 52
And we're back! Tim and guest Tom Stocker of Pinsent Masons in Edinburgh discuss recent and forthcoming Russia sanctions developments in the U.S. and U.K.
Roadmap:
Russia sanctions and multilateralism
U.K. enforcement post-Brexit generally and how it could/has affected Russia sanctions enforcement
Price caps! Sept. 2 G7 Agreement and OFAC guidance
Quantum computing sanctions
Lightning round
Russi
A Brief Hiatus | EMBARGOED! Episode 51
EMBARGOED! is going on hiatus for August and will be back in September with a new format. In the meantime, check out our back catalog and keep up to date with our trade alerts on millerchevalier.com.
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Questions? Contact us at podcasts@milchev.com.
EMBARGOED! is not intended and cannot be relied on as legal advice; the content only reflects the thoughts and opinions of its hosts.
EMBARGOED!
Russia Roundup + Cuba and Iran | EMBARGOED! Episode 50
In a landmark EMBARGOED! episode (our 50th!), Brian and Tim start with a Russia roundup to discuss the latest actions from OFAC, BIS, and DOJ. Next, they pivot to Cuba and discuss recent changes to the CACR and debate the likely impact. Finally, Brian and Tim cover the latest news out of Iran and prognosticate, once again, whether JCPOA 2.0 is dead or just on life support.
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Questions? Cont
Don’t Worry, We Haven’t Forgotten About China | EMBARGOED! Episode 49
In a refreshing change of pace, Brian and Tim spend time on one of their favorite non-Russia topics, China. First, they discuss President Biden's pledge to defend Taiwan from a PRC invasion and what it means (if anything). Next, they discuss the state of China's imports to Russia following the invasion of Ukraine and the growing debate over various proposals in the U.S. to create a "reverse CFIUS"
OFAC’s Victory Day Present for Putin and Sanctions Are the New FCPA | EMBARGOED Episode 48
Brian and Tim kick things off by briefly covering OFAC's issuance, on the eve of Victory Day, of two determinations aimed at disrupting Russia's use of accounting, trust and corporate formation, and management consulting services. Next, they discuss recent public comments by the Deputy Attorney General proclaiming that, as a DOJ enforcement priority, sanctions are the new FCPA. We also check in on
The Evolving U.S. Response to Russia’s Invasion of Ukraine | EMBARGOED! Episode 47
After a brief break, Brian and Tim are back to catch up on all things Russia, including the biggest compliance challenges thus far, the recent U.S. ban on "new investment," and where things could be headed in the coming months. Next, they head to SDNY to discuss a notable recent sentencing in a North Korea sanctions case. Finally, in the Lightning Round, Brian and Tim debate the role and impact of
Addressing the Russia Conundrum | EMBARGOED! Episode 46
With escalating U.S. and international sanctions and export controls further isolating Russia, and no end in sight to the conflict in Ukraine, Brian and Tim share their thoughts on surprising developments thus far, as well as the regulatory and practical challenges faced by companies whether they are seeking to wind down operations in Russia or stick it out. They also provide a brief recap of the
Russia Invades Ukraine and Triggers the Biggest Week in Economic Sanctions History | EMBARGOED! Episode 45
After a tumultuous and historic week, Brian and Tim gather themselves to discuss the U.S. (and global) response to Russia's invasion of Ukraine. They start by diving in to the broad, coordinated economic sanctions aimed at debilitating Russia's financial sector and Putin's inner circle, debate how well the new measures will work, and contemplate what could be coming next. They next turn to the sig
Afghanistan In the Spotlight (while Iran, Russia, and China Lurk Offstage) | EMBARGOED! Episode 44
Brian and Tim discuss the new E.O. aimed at resolving the question of what to do with Da Afghanistan Bank’s assets in the U.S. and debate whether it will work as intended. Next, they place bets on whether it’s too late for JCPOA 2.0 to happen and discuss how far the U.S. may be prepared to go to impose costs on China if it disregards the (possible) “crushing” sanctions that could be imposed upon R
Russia and Iran and China, Oh My! | EMBARGOED! Episode 43
This week on EMBARGOED!, Brian and Tim cover three of their favorite topics: Russia, Iran, and China. First, they discuss the latest U.S. threat to deploy Huawei-style foreign direct product rule restrictions on exports to Russia. Next, they consider whether it is truly now or never for JCPOA 2.0 and, then, contemplate the future of DOJ’s China Initiative in the wake of a high-profile dismissal. F
Russia-stravaganza! | EMBARGOED! Episode 42
Brian and Tim kick off 2022 by diving deep on Russia and the crisis brewing at Ukraine's border. They discuss the "punishing" sanctions that could be coming if Russia invades Ukraine, Nord Stream 2 (of course), and what companies should be doing right now to prepare for the worst and mitigate risk. In the Lightning Round, Brian and Tim share quick thoughts on the Uyghur Forced Labor Prevention Act
Top 10 Stories of 2021 | EMBARGOED! Episode 41
In the year's final episode, Brian and Tim run through a Lightning Round-style discussion of the top economic sanctions and export controls stories of 2021. In no particular order, they discuss: the U.S. hitting the policy reset button, successful court challenges, China!, the slow death of JCPOA 2.0, virtual currency and ransomware, Russia's reemergence, turbulent times yield lots of new sanction
Fresh New Topics and Old Favorites | EMBARGOED! Episode 40
Before turning to some old favorites, Brian and Tim cover some fresh new topics, including the first designations under, and tailored aims of, the new Ethiopia-related sanctions program and the Cambodia Business Advisory on High-Risk Investments and Interactions. Next, they discuss recent actions to combat Iran's attempts to interfere in the 2020 U.S. presidential election and Russia's latest prov
A Heaping Helping of China with a Side of Turkey | EMBARGOED! Episode 39
Brian and Tim give thanks for having no shortage of China topics to cover (ever), which include BIS's new interim final rule establishing controls on certain items that can be used for malicious cyber activities, authorized (and possibly unauthorized) exports to Huawei, the FCC's revocation and termination of China Telecom Americas' license, and a brief Lightning Round discussion of the latest on
Dawn of a New Era for U.S. Sanctions? | EMBARGOED! Episode 38
Brian and Tim kick things off by dissecting the results of The Treasury 2021 Sanctions Review, which charts a (somewhat) new path for OFAC-administered sanctions. We debate what it all means and where things could be headed in the future. Next, we focus on OFAC’s latest guidance for the virtual currency industry and how that ties together with DOJ’s announcement of a new National Cryptocurrency En
On Ransoms, Virtual and Diplomatic | EMBARGOED! Episode 37
Brian and Tim are back to discuss ransoms of all shapes and sizes. First, they tackle OFAC’s new ransomware guidance and contemplate what it means for the risk faced by victims and others within the ransomware payment ecosystem. Next, Brian and Tim discuss recent OFAC settlements addressing Directive 4 and facilitation and, then, dive deep on the big announcement that DOJ resolved the criminal cas
All Lightning Round, End-of-Summer Edition | EMBARGOED! Episode 36
On this all Lightning Round episode, Brian and Tim check in on JCPOA 2.0, the latest on Afghanistan, more sanctions targeting Russia, a new Belarus E.O., CFIUS’s continued focus on China and semiconductors, a recent OFAC enforcement action highlighting risks for non-U.S. subsidiaries of U.S. companies, and a brand new OFAC sanctions program relating to Ethiopia.
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Questions? Contact us at
GIR‘s Enforcement Action Survey and What‘s Next in Afghanistan | EMBARGOED! Episode 35
Back from summer vacation, Brian and Tim welcome guest Michael Griffiths of Global Investigations Review (GIR) to discuss his recent survey of U.S. trade practitioners, who were asked to identify the most influential OFAC and BIS enforcement actions of the past few years. Then, Brian and Tim focus on the top story of the past month, Afghanistan, to forecast what U.S. sanctions policy may look lik
Around the World in 60 Minutes: Hong Kong, Cuba, Russia, Iran (and China) | EMBARGOED! Episode 34
Brian and Tim check in on a wide range of topics, including the newly issued Hong Kong Business Advisory, the U.S. response to the crackdown in Cuba, the fate of Nord Stream 2, and the (possibly dimming?) prospects for JCPOA 2.0. Then, in the Lightning Round, we spend a few minutes sharing our thoughts on the first six months of sanctions and export controls enforcement activity under the Biden a
A Deep Dive on Forced Labor | EMBARGOED! Episode 33
Brian and Tim are joined by their Miller & Chevalier colleagues, Richard Mojica and Nate Lankford, to dive deep on the problem of forced labor and the ways multinational companies are reckoning with this human rights crisis (in Xinjiang and beyond). Specifically, we dig in on the broader universe of business and human rights considerations that global actors must now manage (including the impact o
Is JCPOA 2.0 Going Down In Flames? | EMBARGOED! Episode 32
Brian and Tim try to decipher recent signals that JCPOA 2.0 may be in trouble and share their thoughts on what to look for during the coming weeks. We next turn to the new multilateral sanctions recently imposed on Belarus before checking in on China to discuss the merciful end of the #tiktokban (and what’s on the horizon under E.O. 14034), as well as recent aggressive actions by the U.S. targetin
Hitting Reset on E.O. 13959 | EMBARGOED! Episode 31
Brian and Tim kick things off by analyzing the complete do-over called by the Biden administration with respect to E.O. 13959 and contemplate what that means for the future of U.S. person restrictions relating to investments in publicly traded securities of Chinese Military-Industrial Complex Companies. Next, we consider the possible sanctions implications of the new White House directive targetin
Waving the White Flag on Nord Stream 2? | EMBARGOED! Episode 30
Brian and Tim kick off this episode by digging in to the implications of the newly announced U.S. sanctions targeting the Nord Stream 2 project and why they may amount to an admission of defeat. Next, we check in on the seemingly imminent JCPOA 2.0, the latest court challenge to the CCMC List, and a recent report issued pursuant to the Hong Kong Autonomy Act. Finally, in the Lightning Round, we co
Enforcement-palooza 2.0! | EMBARGOED! Episode 29
We are long overdue for a deep dive on the latest enforcement actions, so we’re covering the DOJ-led joint resolution with SAP, OFAC settlements with MoneyGram and Alliance Steel, DDTC’s consent agreement with Honeywell, and, last but not least, Luokung Technology’s successful court challenge to its CCMC listing. Then, in the Lightning Round, we check in on JCPOA 2.0, the U.S. approach to Venezue
To Russia With Love (and Sanctions) | EMBARGOED! Episode 28
On the latest episode, Brian and Tim dig in to the sweeping new Executive Order targeting Russian Harmful Foreign Activities to decipher what it means for the sanctions risk landscape in Russia and what may be coming next. We also check in on JCPOA 2.0 after an explosive week (literally) away from the negotiating table and go down the rabbit hole on the possible implications of China’s introductio
First Steps Toward JCPOA 2.0 | EMBARGOED! Episode 27
Brian and Tim tackle the big news that formal talks are finally starting on JCPOA 2.0. We break down what that means for the U.S., Iran, and what sanctions relief may look like under a revised deal. Then, we give the Lightning Round treatment to the latest U.S. announcement regarding Hong Kong, more Burma sanctions, the possible elimination of an important OFAC general license in Belarus, the en
A War of Words in Alaska | EMBARGOED! Episode 26
On the latest episode, Brian and Tim return their focus to China by analyzing Xiaomi’s successful court challenge to its CCMC listing and the possible repercussions of the contentious U.S.-China diplomatic session in Anchorage. We then examine a recent sentencing in a sanctions case connected to the Maduro regime and discuss the release of official findings on foreign interference in the 2020 U.S.
Are the Gloves Off With Respect to Russia? | EMBARGOED! Episode 25
On the latest episode, Brian and Tim review the recent series of U.S. actions targeting Russia for its treatment of Aleksey Navalny and debate whether U.S.-Russia relations have now reached a tipping point. Next, we discuss the first failed attempt to get JCPOA 2.0 off the ground, ponder what the U.S. will do about Myanmar in the face of worsening post-coup conditions, and share some key takeaways
A (Post-Brexit) U.K. Extravaganza! | EMBARGOED Episode 24
On the latest episode of EMBARGOED!, Brian and Tim are joined by special guests Sue Millar (Stephenson Harwood) and Tom Stocker (Pinsent Masons) to dive deep on what’s happening in the U.K. now that Brexit is (sort of) behind us. Topics include U.K. sanctions and export controls policy, the future of U.K.-U.S. and U.K.-EU trade relations, possible new U.K. approaches to Iran, China, and Russia, an
What Will the U.S. Do in Response to the Coup in Myanmar? | EMBARGOED! Episode 23
Because there is never a dull moment in the world of economic sanctions, Brian and Tim dive deep on possible U.S. responses to the military coup in Myanmar and how China looms large in that decision. Next, we discuss early signals from the Biden Administration on its approach to the Venezuela sanctions program, and we examine the potential impact of a lawsuit from Xiaomi challenging its recent des
What Just Happened? Recapping a Chaotic Transition | EMBARGOED! Episode 22
Following President Biden's inauguration, Brian and Tim look back at the chaotic final two weeks of the Trump administration to examine the flurry of trade and foreign policy actions taken on the way out the door. In Lightning Round fashion, we cover: Cuba's re-designation as a State Sponsor of Terror, statements about China committing genocide, more actions targeting the crackdown in Hong Kong, a
Trump's Parting Shots at Democracy and China | EMBARGOED! Episode 21
EMBARGOED! kicks off 2021 with somber reflections on the riot at the U.S. Capitol before pivoting to (what else?) China to consider the new E.O. targeting AliPay, WeChat Pay, and other Chinese apps, the official arrival of BIS’s MEU List, and the latest guidance from OFAC relating to securities investments in Chinese Military Companies. After that, Brian and Tim check in on the latest developments
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