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.***

On the final EMBARGOED! episode of 2020, Brian and Tim present their Top 10 sanctions and export controls stories of the year (in Lightning Round fashion). There are no winners and losers here, but the list includes: Huawei, sanctions targeting China, expanded MEUser/MEUse restrictions, the maximum pressure campaign against Iran, TikTok and WeChat EOs, disappearing Russia, U.S. v. Sadr, ExxonMobil v. OFAC, efforts to undercut the so-called Troika of Tyranny, and the state of OFAC enforcement. ********* 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 Top 10 Sanctions and Export Controls Stories of 2020 5:50 Huawei (FPDP Rule and CFO Meng Wanzhou) 9:05 Sanctions targeted at China (Hong Kong/Uyghurs, statutes/EOs) 14:10 Military End User/Military End Use restrictions 19:30 Has Iran pressure been maxed out? 25:04 TikTok/WeChat EOs 29:57 Disappearing Russia (will it be back on the radar in 2021?) 35:50 Throwing out the Sadr conviction in SDNY 44:15 ExxonMobil v. OFAC ("fair notice" for all!) 53:12 Continued focus on the "Troika of Tyranny" (Venezuela, Cuba, Nicaragua) 57:23 OFAC enforcement (or lack thereof) 1:03:53 Honorable mentions 1:08:45 Final Thoughts  ***Stay sanctions free.***

In the penultimate episode of 2020, Brian and Tim share their initial impressions of the new E.O. restricting U.S. person securities transactions involving Communist Chinese Military Companies, discuss the "phantom" Military End-User List that may or may not be issued by BIS, and ask "What's up with TikTok?" after another preliminary injunction and near radio silence from CFIUS. Then, in the Lightning Round, we give quick takes on the assassination of Iran's top nuclear scientist and its possible impact on President-elect Biden's Iran agenda and bring things back around to China with brief reflections on the latest Hong Kong- and North Korea-related sanctions designations. ********* 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 6:09 EO 13959 re: securities investments in CCMCs 22:25 The "Phantom" MEU List 33:42 What's up with TikTok? 47:40 Lightning Round 48:00 Will the assassination of Iran's top nuclear scientist prevent Biden from reentering the JCPOA? 55:50 Latest Hong Kong and North Korea designations from OFAC 1:03:34 Final Thoughts ***Stay sanctions free.***

We had to wait an extra week for the results, but we're finally ready to unpack what President-elect Biden's victory means for U.S. international trade priorities in 2021 and beyond. Our friend and very special guest, Richard Mojica, helps us break down what to expect in the U.S., China, and the EU, including what may and may not change with respect to the current era of protectionism, tariffs, free trade agreements, reshoring of supply chains, human rights, and much more. Brian and Tim then revisit their recent predictions on Iran and Cuba to add some new insights based on the events of the past few weeks. Plus, in the Lightning Round, we check in on what’s happening with TikTok (no one seems to know, including the U.S. government) and briefly gaze upon OFAC's recent advisory regarding high-value artwork to ponder what it all means. ********* 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: Post-election-palooza! 4:48 Beyond sanctions and export controls: what to expect from a Biden administration (with very special guest Richard Mojica) 44:40 Revisiting some of our pre-election predictions (Iran and Cuba) 1:00:36 Lightning Round 1:01:03 Checking In on TikTok 1:10:15 OFAC Art Advisory 1:17:42 Final Thoughts ***Stay sanctions free.***

With the U.S. presidential election right around the corner, Brian and Tim explore what the results could mean for U.S. trade and economic sanctions policy over the next four years with respect to China, Iran, Russia, Venezuela, and Cuba. Then, in the Lightning Round, we take a quick look at the upcoming, likely historic, IPO of Ant Group and whether the U.S. government can do anything to slow it down, and we bring you another round of sanctions trivia (back by popular demand). ********* 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: Election-palooza! 6:58 What will trade policy towards... - 7:13 China - 24:11 Iran - 39:11 Russia - 48:45 Venezuela - 57:55 Cuba ...look like if Biden wins? If Trump wins? 1:07:17 Lightning Round 1:07:30 Is Ant Group going on the Entity List? 1:21:00 Trivia! 1:27:43 Final Thoughts ***Stay sanctions free.***  

Brian and Tim drop the gavel to render verdicts on the litigation impacting the TikTok and WeChat bans and a lawsuit challenging the legal bases for the new ICC-related sanctions program. We also discuss OFAC's recent ransomware advisory and give some thoughts on a recent OFAC enforcement action focused on Cuba. Then, in the Lightning Round, we share our initial impressions on brand new U.S. sanctions targeting Iran's financial sector and dissect the outcome of a lawsuit challenging the foundations of the Commerce Department's authority to enforce the export controls framework established by the EAR. ********* 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 5:38 Quick Check-in on TikTok and WeChat 18:54 Lawsuit Challenging ICC Sanctions 39:36 OFAC and FinCEN Randomware Advisory 53:41 OFAC Settlement with Generali Global 1:01:47 Lightning Round 1:02:05 More Sanctions Coming Against Iranian Banks? 1:12:43 FedEx v. BIS 1:25:21 Final Thoughts ***Stay sanctions free.***

In the latest episode of EMBARGOED!, Brian and Tim return to China in a big way as they dive headlong into the TikTok and WeChat bans to analyze what transactions are actually prohibited, the status of the various court proceedings seeking to delay the bans, where things stand with CFIUS review of TikTok's "divestiture," and, last but not least, China's countermoves to try to ensure it will have the last word. Next, we turn to Iran and the U.S.'s attempt to unilaterally reimpose U.N. sanctions under the JCPOA more than two years after withdrawing from the deal. Finally, in the Lightning Round, we share a few quick thoughts on recent sanctions aimed at countering foreign interference in U.S. elections and discuss the latest travel-related restrictions on Cuba (Hint: Don't stick rum or cigars in your suitcase before returning to the States unless you have an OFAC license). ******** 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 7:01 More TikTok and WeChat (Commerce rules, state of the "bans," CFIUS and the TikTok "divestiture," China's Unreliable Entities List) 46:17 Iran Snapback 1:02:13 Lightning Round 1:02:25 Cyber designations relating to election interference by (GASP!) Russia 1:10:17 CACR amendments to further restrict aspects of Cuba travel 1:17:34 Final Thoughts *Stay sanctions free.*

On this episode of EMBARGOED!, Brian and Tim keep their promise to stay China free (for this week, at least) and change things up to bring you an entire Lightning Round-style episode. With the whole world at our disposal (other than China), we cover the following topics in lightning fashion: the latest U.S. advisory on North Korea, the first U.S. sanctions imposed on the ICC, OFAC's MOU with the State of Delaware, two recent OFAC enforcement actions against an individual and a financial institution, respectively, the latest on Nord Stream 2 and Venezuela, and, finally, a wild card segment featuring our first foray into sanctions trivia. ********* 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 A Full Episode of Lightning Round!4:49 North Korea Advisory 9:27 International Criminal Court Sanctions 17:13 OFAC Memorandum of Understanding with Delaware 21:18 OFAC Settlement (Individual) 25:26 OFAC Settlement (Russia/Ukraine/Deutsche Bank Trust Co. Americas) 30:00 Nord Stream 2 36:44 Latest Venezuela Sanctions 41:20 Wild Card! 51:55 Final Thoughts ***Stay sanctions free.***

EMBARGOED! is back! After a brief, socially-distanced summer vacation, Brian and Tim return to tackle the messy, unprecedented U.S. government actions targeting TikTok and WeChat. Next, we return to one of our favorite topics, Huawei, to analyze the impact of the BIS final rule, which makes another attempt to disrupt the company's supply chain by further expanding the foreign direct product rule. We also discuss the first wave of sanctions targeting Hong Kong and its top officials and ponder whether this was anything more than a symbolic gesture. Plus, in the Lightning Round we share some thoughts on recent Entity List additions targeting, for the first time, activities in the South China Sea, a Xinjiang-related addition to the SDN List causing significant due diligence headaches, and, at long last, the publication of the Advance Notice of Proposed Rulemaking regarding "foundational technologies." ********* 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 5:36 TikTok and WeChat 30:00 Final BIS Rule re: Huawei and Foreign Direct Product Rule 42:52 First Hong Kong Sanctions 51:40 Lightning Round 52:00 BIS Addition of 24 Chinese Companies to the Entity List re: South China Sea 56:56 Xinjiang-related Additions to the SDN List 1:02:00 Commerce (Finally) Issues ANPRM re: Foundational Technologies 1:09:00 Final Thoughts ***Stay sanctions free.***

On the latest episode of EMBARGOED!, Brian and Tim dissect the continued downward spiral of U.S.-China relations, including the sweeping new Executive Order aimed at "normalizing" U.S. relations with Hong Kong and the latest tit-for-tat sanctions imposed by the U.S. and China, respectively. Next, we cover two notable recent enforcement actions: OFAC's settlement with Amazon and a joint DOJ/OFAC resolution with Essentra FZE relating to North Korea sanctions violations. Finally, in the Lightning Round, we share quick thoughts on recent OFAC designations targeting Nicaragua and some personal reflections on the United States' reliance on human rights as a basis for economic sanctions policies. ********* 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! Apple Podcasts: https://apple.co/3bDJnmU Spotify: https://spoti.fi/2xAJ9ye Google Play: https://bit.ly/3bAU0Hc Stitcher: https://bit.ly/3awf95i  Timestamps:0:10 Introduction and Roadmap The Rundown4:21 China Round-up22:30 Amazon OFAC Enforcement Action30:51 North Korea Enforcement Action by DOJ/OFAC 39:39 Lightning Round: 40:00 Ortega's Inner Circle Targeted by OFAC43:59 A Few Words on Human Rights and the Death Penalty 55:45 Final Thoughts ***Stay sanctions free.***

On the latest episode of EMBARGOED!, Brian and Tim break down the early days of China's new national security law aimed at Hong Kong and the U.S. response, including the suspension of preferential export control treatment for Hong Kong and new sanctions on the horizon that take aim at financial institutions. Next, we revisit BIS's new military end user/military end use rules and try to decipher the recently issued BIS guidance. Finally, we unpack the somewhat unorthodox multi-agency advisory warning U.S. businesses of supply chain risks relating to forced labor and human rights abuses in the Xinjiang region of China. Plus, the Lightning Round features quick thoughts on continued U.S. efforts to disrupt deepening ties between Venezuela and Iran and what the rest of the world is doing with respect to Huawei. ********* 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! Apple Podcasts: https://apple.co/3bDJnmUSpotify: https://spoti.fi/2xAJ9yeGoogle Play: https://bit.ly/3bAU0HcStitcher: https://bit.ly/3awf95i Timestamps: 0:11 Introduction and Roadmap   The Rundown 3:49 The Other Shoe Drops for Hong Kong 23:19 New BIS FAQs re: Military End Use/User Rules 39:01 U.S. Government Advisory re: Xinjiang Supply Chain Risk   49:11 Lightning Round 49:37 More Venezuela-Iran Links 53:13 What Does the Rest of the World Think of Huawei   59:47 Final Thoughts ***Stay sanctions free.***