EMBARGOED!
Russia Roundup + Cuba and Iran | EMBARGOED! Episode 50

Russia Roundup + Cuba and Iran | EMBARGOED! Episode 50

June 22, 2022

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.

********

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, hosted by Miller & Chevalier Members Brian Fleming and Tim O'Toole. 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 bi-weekly episodes so you don't miss out!

Roadmap:

  • Introduction
  • The Rundown
    • Russia Roundup
    • Cuba
    • Point of No Return for JCPOA 2.0?
  • Final Thoughts

***Stay sanctions free.***

Don’t Worry, We Haven’t Forgotten About China | EMBARGOED! Episode 49

Don’t Worry, We Haven’t Forgotten About China | EMBARGOED! Episode 49

June 1, 2022

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" process to review outbound investment to China and other countries of concern. Finally, Brian and Tim cover two new U.S. government advisories focused on North Korean IT workers and Sudan, respectively. 

********

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, hosted by Miller & Chevalier Members Brian Fleming and Tim O'Toole. 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 bi-weekly episodes so you don't miss out!

Roadmap:

  • Introduction
  • The Rundown
    • Biden Vows to Defend Taiwan
    • Chinese Exports to Russia Decline
    • Reverse CFIUS
    • DPRK IT Worker Advisory
  • Lightning Round: Sudan Business Advisory
  • Final Thoughts

***Stay sanctions free.***

OFAC’s Victory Day Present for Putin and Sanctions Are the New FCPA | EMBARGOED Episode 48

OFAC’s Victory Day Present for Putin and Sanctions Are the New FCPA | EMBARGOED Episode 48

May 12, 2022

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 what China has been up to lately (with respect to Russia) and share a few thoughts on the recently issued Ukraine-/Russia-Related Sanctions Regulations. Finally, in the Lightning Round, they briefly cover the unsealing of indictments against Virgil Griffith's alleged co-conspirators and debate what it could mean that Nicaragua's ruling family has reportedly reached out to the U.S. seeking sanctions relief.

********

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, hosted by Miller & Chevalier Members Brian Fleming and Tim O'Toole. 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 bi-weekly episodes so you don't miss out!

Roadmap: 

  • Introduction
  • The Rundown
    • Sanctions are the New FCPA
    • China and Russia
    • New Ukraine-/Russia-Related Sanctions Regulations Issued
  • Lightning Round
    • European Co-Conspirators of Virgil Griffith Charged
    • Nicaragua Reaches Out for Sanctions Relief
  • Final Thoughts

***Stay sanctions free.***

The Evolving U.S. Response to Russia’s Invasion of Ukraine | EMBARGOED! Episode 47

The Evolving U.S. Response to Russia’s Invasion of Ukraine | EMBARGOED! Episode 47

April 27, 2022

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 sanctions-like bans in the world of international sports.

********

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, hosted by Miller & Chevalier Members Brian Fleming and Tim O'Toole. 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 bi-weekly episodes so you don't miss out!

Roadmap: 

  • Introduction
  • The Rundown
    • Latest on the U.S. Response to the Russian Invasion of Ukraine
    • Sentencing of Virgil Griffith in SDNY
  • Lightning Round: U.S. v. Iran in the World Cup
  • Final Thoughts

***Stay sanctions free.***

Addressing the Russia Conundrum | EMBARGOED! Episode 46

Addressing the Russia Conundrum | EMBARGOED! Episode 46

March 23, 2022

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 most significant actions of the past few weeks and ponder what could be coming next.  Finally, in the Lightning Round, Brian and Tim cover the latest on JCPOA 2.0 and reports that a deal is within reach.

********

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, hosted by Miller & Chevalier Members Brian Fleming and Tim O'Toole. 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 bi-weekly episodes so you don't miss out!

Roadmap: 

  • Introduction
  • Deep thoughts and latest updates on all things Russia
  • Lightning Round: JCPOA 2.0
  • Final thoughts

***Stay sanctions free.***

Russia Invades Ukraine and Triggers the Biggest Week in Economic Sanctions History | EMBARGOED! Episode 45

Russia Invades Ukraine and Triggers the Biggest Week in Economic Sanctions History | EMBARGOED! Episode 45

March 3, 2022

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 significant expansion of export controls implicating Russia and discuss the likely impact. Finally, in the Lightning Round, Brian and Tim bid farewell to DOJ's China Initiative and read between the lines to decipher DOJ's ongoing priorities.

********

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, hosted by Miller & Chevalier Members Brian Fleming and Tim O'Toole. 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 bi-weekly episodes so you don't miss out!

Roadmap: 

  • Introduction
  • The Rundown
    • U.S. Response to Russian Invasion of Ukraine (Sanctions)
    • U.S. Response to Russian Invasion of Ukraine (Export Controls)
  • Lightning Round
    • DOJ's China Initiative = DONE
  • Final Thoughts

***Stay sanctions free.***

Afghanistan In the Spotlight (while Iran, Russia, and China Lurk Offstage) | EMBARGOED! Episode 44

Afghanistan In the Spotlight (while Iran, Russia, and China Lurk Offstage) | EMBARGOED! Episode 44

February 17, 2022

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 Russia. Finally, Brian and Tim stick with China to briefly cover the recently unsealed trade secret theft charges against Hytera Communications and an atypical CFIUS review initiated by a U.S. company unhappy with its Chinese investors.  

********

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, hosted by Miller & Chevalier Members Brian Fleming and Tim O'Toole. 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 bi-weekly episodes so you don't miss out!

Roadmap: 

  • Introduction
  • The Rundown
    • New Afghanistan E.O.
    • JCPOA 2.0 Predictions
    • Russia and China are BFFs?
    • Hytera TS Theft Indictment
    • The Curious Case of Icon Aircraft and CFIUS
  • Final Thoughts

***Stay sanctions free.***

Russia and Iran and China, Oh My! | EMBARGOED! Episode 43

Russia and Iran and China, Oh My! | EMBARGOED! Episode 43

January 31, 2022

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. Finally, in the Lightning Round, Brian and Tim go below deck to provide some perspective on recent developments in a Helms-Burton lawsuit targeting major players in the cruise industry and share some quick thoughts on the new U.S. government advisory regarding Burma (Myanmar).  

********

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, hosted by Miller & Chevalier Members Brian Fleming and Tim O'Toole. 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 bi-weekly episodes so you don't miss out!

Roadmap: 

  • Introduction
  • The Rundown
    • FDPR Weaponized Against Russia
    • Now or Never for JCPOA 2.0
    • The End of DOJ's China Initiative?
  • Lightning Round
    • Helms-Burton Litigation Update - Havana Docks v. the Cruise Lines
    • Newly Issued Burma Business Advisory
  • Final Thoughts

***Stay sanctions free.***

Russia-stravaganza! | EMBARGOED! Episode 42

Russia-stravaganza! | EMBARGOED! Episode 42

January 13, 2022

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, new Commerce Department appointments, and OFAC's recent enforcement action against Airbnb Payments.

********

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, hosted by Miller & Chevalier Members Brian Fleming and Tim O'Toole. 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 bi-weekly episodes so you don't miss out!

Roadmap:

  • Introduction
  • The Rundown: RUSSIA!
  • Lightning Round
    • Enactment of the Uyghur Forced Labor Prevention Act
    • New Commerce Department Appointments Take Their Posts
    • OFAC Settlement with Airbnb
  • Final Thoughts

***Stay sanctions free.***

Top 10 Stories of 2021 | EMBARGOED! Episode 41

Top 10 Stories of 2021 | EMBARGOED! Episode 41

December 28, 2021

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 sanctions programs and policies, Huawei's CFO gets a DPA, all quiet in the Americas, and a renewed focus on anti-corruption, democracy, and human rights. See you in 2022! Stay sanctions free!

********

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, hosted by Miller & Chevalier Members Brian Fleming and Tim O'Toole. 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 bi-weekly episodes so you don't miss out!

Roadmap:

  • Introduction
  • Hitting the Reset Button (Treasury sanctions review, end of ICC E.O., end of TikTok ban, big refresh on E.O. 13959)
  • Successful Court Challenges to Less Than Successful Policies and E.O.s (Xiaomi, Lukong, TikTok/WeChat, ICC E.O.)
  • China, China, China
  • No JCPOA 2.0
  • Virtual Currency and Ransomware
  • Russia Back in Focus
  • Turbulent Times = Lots of New Sanctions Programs/Actions (Afghanistan, Burma, Ethiopia, Yemen)
  • Huawei CFO DPA
  • Venezuela/Cuba/Nicaragua
  • Focus on Anti-corruption, Democracy, and Human Rights
  • Honorable Mentions - North Korea, DOJ Enforcement Focus
  • Final Thoughts

***Stay sanctions free.***