EMBARGOED!

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, each participant then unpacks favorite and obscure sanctions programs and targets from Southern Rhodesia to unregulated fishing.

Roadmap:

• Update to Episode 98: Two Minutes about Tehran
• Trivia
  • OFAC Predecessors
  • OFAC FAQ 1
  • Where to apply for a specific license
  • Precursor to the SDN List
  • Why are they called “Specially Designated Nationals”?
  • On this date: February 18, 2020
  • Definitions of the United States/OFAC's historic jurisdiction
  • British comprehensive embargo of the U.S.
  • First U.S. countersanctions and first U.S. embargo
• Draft Picks
  • Southern Rhodesia and South Africa
  • Danzig and Democratic Kampuchea
  • Illegal, unreported, and unregulated fishing
  • Revolutionary War sanctions

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Thanks to our guests for joining us!

Rachel Alpert: https://www.jenner.com/en/people/rachel-alpert 

Melissa Burgess: https://www.millerchevalier.com/professional/melissa-burgess

Collmann Griffin: https://www.millerchevalier.com/professional/collmann-griffin 

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! is intelligent talk about sanctions, export controls, and all things international trade for trade nerds and normal human beings alike. Each episode will feature deep thoughts and hot takes about the latest headline-grabbing developments in this area of the law, as well as some below-the-radar items to keep an eye on. Subscribe wherever you get your podcasts for new episodes so you don't miss out!

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 brief tour through the nearly 50-year history of sanctions on Iran and some of the key sanctions authorities. They discuss a sampling of reporting, waiver, and certification considerations, examine General License X, and share thoughts on some of the more difficult potential sanctions delistings.

Roadmap:

• Paragraphs 7 and 10 of the MOU
• Where do the Iran sanctions come from?
  • Carter EO, Clinton EO, IEEPA, Iran Sanctions Act
• INARA and CISADA: certifications, waivers, and statutory sunset considerations
• General License X
• Hardest delistings

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Thanks to Melissa for joining us! https://www.millerchevalier.com/professional/melissa-burgess

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! is intelligent talk about sanctions, export controls, and all things international trade for trade nerds and normal human beings alike. Each episode will feature deep thoughts and hot takes about the latest headline-grabbing developments in this area of the law, as well as some below-the-radar items to keep an eye on. Subscribe wherever you get your podcasts for new episodes so you don't miss out!

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 also examine gold as a payment mechanism throughout history, and gold's function in foreign exchange transactions. Along the way, the episode dives into restrictions on gold in sanctions programs from the early days of the Trading with the Enemy Act through current Russia and Venezuela sanctions, cartel involvement in the gold supply chain, and use of gold as a hedge against sanctions.

Roadmap:

• Gold 101
• What are the risks related to Venezuela gold, despite the recent sanctions lifting in that sector?
• What are the connections between gold and cartels?
• How did Russia seek to use gold as part of its countersanctions strategy?  How did the United States respond?
• What is the connection between gold and conflict, for example in the DRC and Sudan?  How can sanctions counter this?  

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Thanks to our guests for joining us!

Brad Brooks-Rubin: https://www.arktouros.co/team/bbr

Dr. David Soud: https://irconsilium.com/david-soud/ 

Melissa Burgess: https://www.millerchevalier.com/professional/melissa-burgess

Collmann Griffin: https://www.millerchevalier.com/professional/collmann-griffin 

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! is intelligent talk about sanctions, export controls, and all things international trade for trade nerds and normal human beings alike. Each episode will feature deep thoughts and hot takes about the latest headline-grabbing developments in this area of the law, as well as some below-the-radar items to keep an eye on. Subscribe wherever you get your podcasts for new episodes so you don't miss out!

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 several years as the lead sanctions attorney in the Office of the Legal Adviser at State). In part 2 of their discussion of State's role in sanctions, Erik and Josh address an unanswered question from part 1, then explain the coordination and separation between State and OFAC in licensing and enforcement. The discussion also covers a recent case addressing State’s power to designate and delist, as well as State's role when one of its decisions is challenged in court.  

Roadmap:

• Separation between OFAC and State in enforcement
• State’s general role in sanctions license adjudication
• Sanctions enforcement versus sanctions implementation
• Challenging State designations, and the inherent power to delist

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Thanks to our guest for joining us:

Joshua Kretman: https://www.dentons.com/en/joshua-kretman 

Erik Woodhouse: https://www.crowell.com/en/professionals/erik-woodhouse 

Melissa Burgess: https://www.millerchevalier.com/professional/melissa-burgess

Collmann Griffin: https://www.millerchevalier.com/professional/collmann-griffin 

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! is intelligent talk about sanctions, export controls, and all things international trade for trade nerds and normal human beings alike. Each episode will feature deep thoughts and hot takes about the latest headline-grabbing developments in this area of the law, as well as some below-the-radar items to keep an eye on. Subscribe wherever you get your podcasts for new episodes so you don't miss out!

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 several years as the lead sanctions attorney in the Office of the Legal Adviser at State). In part 1 of this discussion, Erik and Josh explain the structure and various players working on sanctions within State, walk through the process of creating a new sanctions program, and discuss State's role in sanctions targeting.

Roadmap:

• Introductions and former positions at State
• Background on the State Department
• What role does State play in sanctions?
• Are there issues where State would want to hear from clients? What kinds of issues would you consider raising with State
• Venezuela: What role do you think State will play/is playing in this space?

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Thanks to our guest for joining us:

Joshua Kretman: https://www.dentons.com/en/joshua-kretman 

Erik Woodhouse: https://www.crowell.com/en/professionals/erik-woodhouse 

Melissa Burgess: https://www.millerchevalier.com/professional/melissa-burgess

Collmann Griffin: https://www.millerchevalier.com/professional/collmann-griffin 

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! is intelligent talk about sanctions, export controls, and all things international trade for trade nerds and normal human beings alike. Each episode will feature deep thoughts and hot takes about the latest headline-grabbing developments in this area of the law, as well as some below-the-radar items to keep an eye on. Subscribe wherever you get your podcasts for new episodes so you don't miss out!

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 countries, rather than foreign investment in the U.S.). Tim and Melissa also shared their thoughts on what might be coming in 2026.

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Thanks to our guest for joining us:

Melissa Burgess: https://www.millerchevalier.com/professional/melissa-burgess

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! is intelligent talk about sanctions, export controls, and all things international trade for trade nerds and normal human beings alike. Each episode will feature deep thoughts and hot takes about the latest headline-grabbing developments in this area of the law, as well as some below-the-radar items to keep an eye on. Subscribe wherever you get your podcasts for new episodes so you don't miss out!

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 agents. Picks include what BIS didn't do in 2025, the Affiliates Rule, and lifting comprehensive sanctions on Syria.

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Thanks to our guests for joining us:

Michael Burton: https://www.jbktradelaw.com/michael-l-burton 

Melissa Burgess: https://www.millerchevalier.com/professional/melissa-burgess 

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! is intelligent talk about sanctions, export controls, and all things international trade for trade nerds and normal human beings alike. Each episode will feature deep thoughts and hot takes about the latest headline-grabbing developments in this area of the law, as well as some below-the-radar items to keep an eye on. Subscribe wherever you get your podcasts for new episodes so you don't miss out!

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 Griffin: https://www.millerchevalier.com/professional/collmann-griffin 

Caroline Watson: https://www.millerchevalier.com/professional/caroline-j-watson 

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! is intelligent talk about sanctions, export controls, and all things international trade for trade nerds and normal human beings alike. Each episode will feature deep thoughts and hot takes about the latest headline-grabbing developments in this area of the law, as well as some below-the-radar items to keep an eye on. Subscribe wherever you get your podcasts for new episodes so you don't miss out!

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 insurers
    • Price cap
    • EU/U.S. divergence
    • Foreign Terrorist Organizations (FTOs)/cartels
  • Tips for flag registries
  • Are S2S transfers ever okay? 

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Thanks to our guests for joining us: 

Claire O'Neill McCleskey: https://www.linkedin.com/in/claire-o-neill-mccleskey/ 

Collmann Griffin: https://www.millerchevalier.com/professional/collmann-griffin 

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! is intelligent talk about sanctions, export controls, and all things international trade for trade nerds and normal human beings alike. Each episode will feature deep thoughts and hot takes about the latest headline-grabbing developments in this area of the law, as well as some below-the-radar items to keep an eye on. Subscribe wherever you get your podcasts for new episodes so you don't miss out!

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), particularly CAR's work in Ukraine
• Western components that end up in Russian, Iranian, North Korean, and other weapons systems and how this overlaps with the BIS Common High Priority List (CHPL)
• A walkthrough of how an item makes its way from a U.S.-owned fabricator to a foreign weapons system
• Screening/due diligence steps recommended for manufacturers and distributors of high-priority items

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Thanks to our guests for joining us: 

Damien Spleeters: https://www.linkedin.com/in/damienspleeters/

Collmann Griffin: https://www.millerchevalier.com/professional/collmann-griffin 

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! is intelligent talk about sanctions, export controls, and all things international trade for trade nerds and normal human beings alike. Each episode will feature deep thoughts and hot takes about the latest headline-grabbing developments in this area of the law, as well as some below-the-radar items to keep an eye on. Subscribe wherever you get your podcasts for new episodes so you don't miss out!