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.***

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.***

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.***

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.***

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.***

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.***

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 provocations with respect to Ukraine and Europe's energy supply. Finally, in the Lightning Round, Brian and Tim briefly consider a possible U.S. diplomatic boycott of the Beijing Olympics and the end of OFAC's Burundi sanctions program. ******** 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 Ethiopia E.O. and Designations Cambodia Business Advisory Election Interference by Iranian Cyber Actors Warning Russia on Ukraine and EU Energy Supply Lightning Round U.S. Close to Announcing Diplomatic Boycott of Beijing Olympics? End of the Burundi Sanctions Program Final Thoughts ***Stay sanctions free.***

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 Taiwan. In the middle of all that China content, Brian and Tim also discuss the possible implications of a recent FSIA ruling in the Halkbank case.   ******** 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 BIS Interim Final Rule re: Cybersecurity Items and New Entity Lists Additions Supplying Huawei Team Telecom and China Telecom Halkbank Ruling re: FSIA Lightning Round U.S. Support for Taiwan at the UN Final Thoughts ***Stay sanctions free.***

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 Enforcement Team and redoubled efforts to investigate and prosecute export controls and sanctions violations. We then move to China to consider the messy circumstances surrounding ZTE’s court-appointed monitor and an even messier foreign policy situation currently brewing between the U.S. and China over Taiwan. Finally, in the Lightning Round, we share quick thoughts on the extradition of Alex Saab and the impact on the Maduro regime before turning to JCPOA 2.0 to ponder whether the door to a deal is just about closed. ******** 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 OFAC Guidance for Virtual Currency Industry DOJ Enforcement ZTE's Forever Monitorship A Dangerous Game of Chicken Over Taiwan Lightning Round Extradition of Alex Saab and Impact on Maduro Regime Requiem for JCPOA 2.0? Final Thoughts ***Stay sanctions free.***

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 case against Huawei’s CFO with a DPA. Finally, in the Lightning Round, they share quick thoughts on the guilty plea entered by a cryptocurrency expert for conspiring to violate the North Korea sanctions.   ******** 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 Ransomware Advisory and Designation OFAC Settlement - Directive 4 and Facilitation Huawei CFO Gets a DPA Lightning Round  Ethereum Developer Pleads Guilty to DPRK Sanctions Final Thoughts

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.   ******** 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 JCPOA 2.0 Update Afghanistan Update More Nord Stream 2 Sanctions and Navalny Anniversary Expanded Belarus Sanctions CFIUS Set to Block China Semiconductor Deal OFAC Settlement with First Bank and JC Flowers New Ethiopia E.O. Final Thoughts ***Stay sanctions free.***

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 like in the face of Taliban rule and what measures the U.S. may take to avoid a full blown humanitarian crisis. ********* 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!

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 administration. ********* 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! Timestamps: 0:10 Introduction and Roadmap The Rundown4:30 Hong Kong Business Advisory14:38 The Cuban People Rise Up... and Sanctions Follow27:34 U.S.-Germany Agreement on Nord Stream 239:10 The Latest on JCPOA 2.0 52:45 Lightning Round: Early Trends in Biden Era Enforcement 1:05:55 Final Thoughts ***Stay sanctions free.***

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 of U.S. policy aimed at decoupling from China), examine the recent spike in forced labor-related enforcement led by CBP, and discuss practical challenges and strategies for multinational companies to develop effective compliance programs in this area of increasing importance. Thanks to our guests: Richard Mojica: https://www.millerchevalier.com/professional/richard-mojica Nate Lankford: https://www.millerchevalier.com/professional/nate-lankford ********* 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! Timestamps: 0:10 Introduction and Roadmap1:38 Guest Introductions: Richard Mojica and Nate Lankford The Rundown3:52 Background on Business & Human Rights and Forced Labor19:52 Customs and Border Protection Enforcement47:22 Compliance Considerations 1:11:43 Final Thoughts ***Stay sanctions free.***

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. targeting forced labor. Finally, in the Lightning Round, we do a quick dissection of the court decision dismissing Oleg Deripaska’s challenge to his SDN listing and offer thoughts on OFAC’s recent COVID-related general licenses and guidance. ********* 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 for new bi-weekly episodes so you don't miss out! Roadmap: Introduction The RundownIs JCPOA 2.0 Going Down in Flames?New Belarus SanctionsEnd of TikTok Ban and New E.O. Protecting Sensitive DataLatest U.S. Actions Targeting Forced Labor in Xinjiang Lightning RoundDeripaska Lawsuit DismissedOFAC GLs and Guidance re COVID Relief Final Thoughts ***Stay sanctions free.***

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 targeting corruption and check in on the future of the Burma sanctions program in light of the deepening crisis. Finally, in the Lightning Round, we decipher the latest news on JCPOA 2.0, discuss the possible repercussions of Hamas touting its digital currency fundraising efforts, and evaluate recent criticism of the glacial pace of ECRA implementation. ********* 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 for new bi-weekly episodes so you don't miss out! Timestamps: 0:10 Introduction and Roadmap The Rundown5:00 New Chinese Military Company E.O.27:41 White House Anti-Corruption Directive36:52 Burma Sanctions Regulations (and Burma Update) 44:57 Lightning Round45:09 Checking in on JCPOA 2.049:27 Hamas Bitcoin Donations55:10 ECRA Implementation Fail 1:05:44 Final Thoughts ***Stay sanctions free.***

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 consider OFAC’s ransomware guidance following recent high profile attacks and share our initial thoughts on the possible fallout from the diversion of a Ryanair flight by Belarus to arrest an opposition journalist. ********* 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 for new bi-weekly episodes so you don't miss out! Timestamps:0:10 Introduction and Roadmap The Rundown4:50 PEESA Sanctions and Nord Stream 219:00 Inching Toward JCPOA 2.026:18 Xiaomi Updates and Another CCMC Lawsuit34:21 Recent Hong Kong Autonomy Act Report 45:10 Lightning Round45:24 Colonial Pipeline Attack and Ransomware Epidemic58:03 Belarus and Ryanair  1:06:24 Final Thoughts ***Stay sanctions free.***

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 Venezuela and Cuba, and the winding down of an important general license for Belarus. ********* 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 for new bi-weekly episodes so you don't miss out! Timestamps: 0:10 Introduction and Roadmap The Rundown4:27 SAP NPA and OFAC Settlement21:38 MoneyGram OFAC Settlement28:28 Alliance Steel OFAC Settlement33:25 Honeywell DDTC Settlement40:46 Luokung Takes Another Bite Out of the CCMC List 58:00 Lightning Round58:12 JCPOA 2.01:11:26 Signals on Venezuela and Cuba1:16:43 Belarus GL 2H 1:20:52 Final Thoughts   ***Stay sanctions free.***

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 introduction of the digital yuan. Finally, in the Lightning Round, we share quick thoughts on the recent removal of the UAE from Treasury’s list of boycotting countries and a new legislative proposal that would expand CFIUS jurisdiction to certain transactions with U.S. institutions of higher education. ********* 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 for new bi-weekly episodes so you don't miss out! Timestamps: 0:10 Introduction and Roadmap The Rundown 4:56 New Russia Sanctions 29:36 Update on JCPOA 2.0 39:25 China's Cryptocurrency 54:30 Lightning Round 54:52 UAE Removed from Boycotting Countries List 1:02:07 The Strategic Competition Act of 2021 1:09:49 Final Thoughts ***Stay sanctions free.***

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 end of the ICC sanctions program, and a recent OFAC enforcement action against Nordgas.   ********* 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 for new bi-weekly episodes so you don't miss out! Roadmap: Introduction JCPOA 2.0 Lightning RoundHong Kong is Still Part of the PRCMore Burma SanctionsA Belarus Segment!ICC E.O. May Be RevokedOFAC Settlement with Nordgas Final Thoughts  

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. federal election.  Finally, in the Lightning Round, we cover the latest on Nord Stream 2 and new BIS restrictions on Burma. ********* 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 for new bi-weekly episodes so you don't miss out! Timestamps:0:10 Introduction and Roadmap The Rundown6:07 Xiaomi23:26 Hong Kong Designations and Sparring in Alaska36:42 Venezuela Sanctions Sentence48:56 Findings of Russia Election Interference 58:50 Lightning Round59:03 Nord Stream 2 Warnings1:08:32 BIS Restrictions on Burma 1:14:25 Final Thoughts  ***Stay sanctions free.***

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, and the rise of OFSI as a sanctions enforcer to be reckoned with. Then, in the Lightning Round, we quickly touch on the new Burma sanctions program, a full U.S. reversal on Yemen, and the (possible) death knell for the TikTok and WeChat EOs. Thanks to our guests: Sue Millar: https://www.shlegal.com/en/people/sue-millar Tom Stocker: 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, 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 for new bi-weekly episodes so you don't miss out! Timestamps: 0:10 Introduction and Roadmap3:52 Meet Our Guests - Sue Millar and Tom Stocker 5:27 What's Happening in the U.K.?  U.K. Trade Policy Post-BrexitU.K. vs. U.S.Looking Ahead to the U.K.'s Approach onPChinaRussiaIranGlobal Magnitsky Act/Human Rights-Based Sanctions 51:32 Final Thoughts and Goodbyes 55:42 Lightning Round56:03 Burma Executive Order59:32 Full Reversal on Yemen1:02:46 Review of WeChat and TikTok Executive Orders 1:08:52 Final Thoughts ***Stay sanctions free***

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 designation as a Communist Chinese military company. Finally, in the Lightning Round, we briefly touch on the new U.S. approach to Yemen and spend a few minutes wondering whether the CFIUS SWAT Team is coming after us. ********* 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 for new bi-weekly episodes so you don't miss out! Timestamps: 0:10 Introduction and Roadmap The Rundown5:43 Military Coup in Myanmar35:50 A New Approach to Venezuela50:23 Xiaomi Lawsuit 1:05:09 Lightning Round1:05:30 Update on Yemen1:09:55 CFIUS SWAT Team 1:20:39 Final Thoughts ***Stay sanctions free.***

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 few final pokes in the eye to Iran, the imprisonment of Alexei Navalny and a possible new era for sanctions targeting Russia, designations impacting the humanitarian crisis in Yemen, an amended (but still ambiguous) E.O. relating to publicly traded securities of CCMCs, provocative moves relating to Taiwan and the South China Sea, and a brand new regulatory regime meant to protect the ICTS supply chain from foreign adversaries. ********* 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. Timestamps: 0:10 Introduction and Roadmap 5:57 Lightning Round-Style Recap8:47 Cuba Designated a State Sponsor of Terror14:43 Pronouncement that China is Committing Genocide21:03 Latest from Hong Kong26:20 Final Pokes in the Eye to Iran32:38 Russia after Navalny's Arrest39:58 Designating Houthis as an FTO/SDGT?46:53 Amended CCMC EO56:25 Taiwan and the South China Sea1:03:30 Interim Final ICTS Rule 1:10:28  Final Thoughts ***Stay sanctions free.***  

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 in a rare North Korea sanctions prosecution in SDNY and then wrap up, in the Lightning Round, by briefly covering a successful court challenge to the ICC-related sanctions program and the passage of expanded Nord Stream 2 sanctions. ********* 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. Timestamps: 0:10 Introduction and Roadmap 4:30 Some Brief Reflections on Treason, Sedition, and Insurrection by POTUS The Rundown 16:54 New E.O. re: AliPay and Other Chinese Apps 28:47 The Military End User List 39:00 Latest Guidance on CCMC E.O. 51:10 Prosecution of Crypto Bro in SDNY 59:52 Lightning Round 1:00:18 PI in ICC Litigation in SDNY 1:05:57 Expanded Nord Stream 2 Sanctions 1:12:40 Final Thoughts ***Stay sanctions free.***