EMBARGOED! Miller & Chevalier
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Intelligent talk about international trade for trade geeks and regular people alike, hosted by Miller & Chevalier.
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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
Second anniversary designation announcements (February 23, 2024)
Recent subpoenas to maker of semiconductor manufacturing equipment
Commerce’s March 1, 2024, ICTS supply chain ANPRM on “Connected Vehicles”
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Thanks to Melissa Burgess 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! -
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)
Service-related designations under E.O. 14071 Sections 1(a)(ii), 1(b), and 5
Import-related restrictions under E.O. 14068 1(a)(i)(B), as amended
Import-related restrictions under E.O. 14068 Sections 1(a)(i)(A) and 1(a)(i)(D)
E.O. 14114 (amendment to E.O. 14024 and 14068)
Price cap
IRAN
VENEZUELA
VIRTUAL CURRENCY
COUNTER-TERRORISM SANCTIONS
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Thanks to Laura Deegan for joining us: https://www.millerchevalier.com/professional/laura-deegan
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! -
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 into the U.S., the growing compliance challenges of the deemed export rule, the recently revised Directorate of Defense Trade Controls (DDTC) compliance guidelines and risk matrices, the reorganization of the ITAR, the 10-year anniversary of export control reform (ECR), and the effect ECR has had on the Export Administration Regulations (EAR).
Roadmap:
Introduction
Defense services abroad
Subject to the ITAR from coming into the U.S.
Deemed export/SpaceX
ITAR Part 120 rewrite
DDTC revised compliance program guidance/risk matrix
10-year anniversary of ECR
Complexity at the Bureau of Industry and Security (BIS)
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Thanks to Scott Gearity for joining us: https://www.learnexportcompliance.com/people/scott-gearity/
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! -
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 Control (OFAC) designations generally.
Roadmap:
Introduction
Tornado Cash
OFAC Designation
Storm and Semenov charged with conspiracy to commit sanctions violations
FinCEN proposes new regulation to enhance transparency in convertible virtual currency mixing and combat terrorist financing
Hamas virtual currency fundraising and sanctions
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Thanks to Leah Moushey for joining us: https://www.millerchevalier.com/professional/leah-moushey
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! -
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 Venezuelan economy: oil and gas, gold, and finance.
Oil and Gas Sector/GL 44
Gold Sector/GL 43
Financial Sector/GL 3I and GL 9H
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Thanks to Laura Deegan for joining us: https://www.millerchevalier.com/professional/laura-deegan
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! -
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 2023 Russia sanctions
Russia sanctions in 2023 have been very different
Unprecedented coordination
Key differences between U.S. and EU Russia sanctions
Issuance
Jurisdiction
Licensing
Seizure/expropriation of assets
Recourse for sanctioned parties
Challenges with divestment from Russia
Export controls
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Thanks to our guests for joining us:
Dr. Laura Louca: https://www.blomstein.com/en/team.php?p=dr-laura-louca
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 bi-weekly episodes so you don't miss out!
Customer Reviews
One of the best sanctions podcast out there
There are several sanctions/export control sanctions podcasts. This one is one of my favorite ones.
Great podcast
Thank you for helping crystallize complex topics in an ever-changing compliance landscape.
A podcast for the workday!
As a newbie export control practitioner and long time podcast enthusiast, the intersection of export control knowledge and updates in a podcast is so relevant to me! Easy to follow and enjoyable to listen. A definite work-day listening requirement.