EMBARGOED!

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.

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Questions? Contact us at [email protected].

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

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.

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Questions? Contact us at [email protected].

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

47:40 Lightning Round

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.

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Questions? Contact us at [email protected].

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!

1:00:36 Lightning Round

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).

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Questions? Contact us at [email protected].

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!

1:07:17 Lightning Round

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.

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Questions? Contact us at [email protected].

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

1:01:47 Lightning Round

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).

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Questions? Contact us at [email protected].

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

1:02:13 Lightning Round

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.

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Questions? Contact us at [email protected].

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!

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."

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Questions? Contact us at [email protected].

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

51:40 Lightning Round

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.

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Questions? Contact us at [email protected].

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 

Timestamps:

The Rundown

39:39 Lightning Round: 

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.

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Questions? Contact us at [email protected].

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

Timestamps:

***Stay sanctions free.***