Episodes

Friday Oct 28, 2022
Emergency Pod: Sanctions Building in Nicaragua | EMBARGOED! Episode 54
Friday Oct 28, 2022
Friday Oct 28, 2022
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 and the region.
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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! 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 bi-weekly episodes so you don't miss out!

Friday Oct 21, 2022
EU and Dutch Sanctions Enforcement | EMBARGOED! Episode 53
Friday Oct 21, 2022
Friday Oct 21, 2022
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
- Challenges
- Blocking statute
- New EU Limitation on legal services to Russia
- Governing law out of EU will that work for divestment?
- Lighting Round: Bittrex
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Thanks to our guest, Neyah van der Aa, for joining us: https://www.vandoorne.com/en/specialists/neyah-van-der-aa/
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 bi-weekly episodes so you don't miss out!

Tuesday Oct 04, 2022
A Multi-Lateral Approach to Podcasting and Price Caps | EMBARGOED Episode 52
Tuesday Oct 04, 2022
Tuesday Oct 04, 2022
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
- Russian countermeasures update: Novation of contracts, payments through SDN banks, forced sales
- Predictions about energy-related sanctions
- Predictions about financial institution sanctions
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Thanks to our guest, Tom Stocker, for joining us: https://www.pinsentmasons.com/people/tom-stocker
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 bi-weekly episodes so you don't miss out!

Thursday Aug 11, 2022
A Brief Hiatus | EMBARGOED! Episode 51
Thursday Aug 11, 2022
Thursday Aug 11, 2022
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! 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 bi-weekly episodes so you don't miss out!

Wednesday Jun 22, 2022
Russia Roundup + Cuba and Iran | EMBARGOED! Episode 50
Wednesday Jun 22, 2022
Wednesday Jun 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.
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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! 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.***

Wednesday Jun 01, 2022
Don’t Worry, We Haven’t Forgotten About China | EMBARGOED! Episode 49
Wednesday Jun 01, 2022
Wednesday Jun 01, 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.
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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! 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.***

Thursday May 12, 2022
Thursday 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.
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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! 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.***

Wednesday Apr 27, 2022
The Evolving U.S. Response to Russia’s Invasion of Ukraine | EMBARGOED! Episode 47
Wednesday Apr 27, 2022
Wednesday Apr 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.
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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! 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.***

Wednesday Mar 23, 2022
Addressing the Russia Conundrum | EMBARGOED! Episode 46
Wednesday Mar 23, 2022
Wednesday Mar 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.
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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! 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.***

Thursday Mar 03, 2022
Thursday Mar 03, 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.
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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! 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.***