June 16, 2025

Winding Down Sanctions: A To-Do List When a Program Comes to an End | EMBARGOED! Episode 82

44 minutes

On this episode of EMBAROGED!, host Tim O'Toole and his guests, Miller & Chevalier Counsel Melissa Burgess and Collmann Griffin, explore the various ways the U.S. government lifts sanctions programs and corresponding export controls.

Roadmap:

So you want to lift sanctions: How can you do it? What complexities might be involved?

A quick tour of history:

Lifting sanctions under TWEA Section 5(b) in 1917

Lifting sanctions on China between 1969 and 1980

Syria sanctions and GL 25

Eliminating easy sanctions programs: West Bank and Zimbabwe

Lifting complex sanctions programs: Myanmar/Burma and Sudan; "zombie programs" like Libya

How to lift restrictions when the sanctions program target is a State Sponsor of Terrorism

Iraq sanctions programs: I, II, and III

*******

Thanks to our guests for joining us:

Melissa Burgess: https://www.millerchevalier.com/professional/melissa-burgess

Collmann Griffin: https://www.millerchevalier.com/professional/collmann-griffin

Special thanks to summer associate Chenyang Wang for her assistance in preparing this episode.

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. Each episode will feature deep thoughts and hot takes about the latest headline-grabbing developments in this area of the law, as well as some below-the-radar items to keep an eye on. Subscribe wherever you get your podcasts for new episodes so you don't miss out!

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