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.  

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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 wherever you get your podcasts for new bi-weekly episodes so you don't miss out!

Roadmap:

• Introduction

• New Ransomware Advisory and Designation

• Ethereum Developer Pleads Guilty to DPRK Sanctions