EMBARGOED‪!‬ Miller & Chevalier

In this episode of EMBARGOED, host Tim O'Toole and guest Erich Ferrari discuss common questions and issues related to the OFAC delisting process.
*******
Thanks to Erich Ferrari for joining us: https://www.ferrariassociatespc.com/our-team/erich-ferrari/ 
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. 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!

In this episode, host Tim O'Toole is joined by guest Doug Jacobson as they podcast live from the last day of the 2024 BIS Update Conference.
Roadmap:
China
Russia
Semiconductors
ICTS
Part 744
DDTC Update
*******
Thanks to Doug Jacobson for joining us: https://www.jbktradelaw.com/douglas-n-jacobson 
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. 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!

On this episode of EMBARGOED!, host Tim O'Toole is joined by Miller & Chevalier Senior Associate Melissa Burgess explore the evolving role played by export controls in U.S. sanctions policy, and discuss a few recent developments.
Roadmap:
"Sanctions are the New FCPA"
OFAC’s revised approach to sanctions: 2021 to the present
The role of BIS and export controls in response to Russia/Ukraine
Second anniversary designation announcements (February 23, 2024)
Recent subpoenas to maker of semiconductor manufacturing equipment
Commerce’s March 1, 2024, ICTS supply chain ANPRM on “Connected Vehicles”
*******
Thanks to Melissa Burgess for joining us: https://www.millerchevalier.com/professional/melissa-burgess 
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. 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!

In this episode of EMBAROGED!, host Tim O'Toole and his guest, fellow Miller & Chevalier attorney Laura Deegan, recap sanctions developments in 2023, focusing on developments in U.S. sanctions against Russia, Iran, Venezuela, and virtual currency companies.
Roadmap:
RUSSIA
Sanctions designation trends
New directive/determinations
Sector-wide determinations under E.O. 14024 Section 1(a)(i)
Service-related designations under E.O. 14071 Sections 1(a)(ii), 1(b), and 5
Import-related restrictions under E.O. 14068 1(a)(i)(B), as amended
Import-related restrictions under E.O. 14068 Sections 1(a)(i)(A) and 1(a)(i)(D)

E.O. 14114 (amendment to E.O. 14024 and 14068)
Price cap
IRAN
VENEZUELA
VIRTUAL CURRENCY
COUNTER-TERRORISM SANCTIONS
*******
Thanks to Laura Deegan for joining us: https://www.millerchevalier.com/professional/laura-deegan
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. 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!

In this episode, host Tim O'Toole and guest Scott Gearity, President of the Export Compliance Training Institute (ECTI), talk in-depth about the International Traffic in Arms Regulations (ITAR). They discuss the growing importance of the regulations related to the provision of defense services abroad by U.S. persons, the jurisdictional implications of importing of foreign made defense articles into the U.S., the growing compliance challenges of the deemed export rule, the recently revised Directorate of Defense Trade Controls (DDTC) compliance guidelines and risk matrices, the reorganization of the ITAR, the 10-year anniversary of export control reform (ECR), and the effect ECR has had on the Export Administration Regulations (EAR). 
Roadmap:
Introduction
Defense services abroad
Subject to the ITAR from coming into the U.S.
Deemed export/SpaceX
ITAR Part 120 rewrite
DDTC revised compliance program guidance/risk matrix
10-year anniversary of ECR
Complexity at the Bureau of Industry and Security (BIS)
*******
Thanks to Scott Gearity for joining us: https://www.learnexportcompliance.com/people/scott-gearity/ 
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. 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!

On this episode of EMBARGOED!, host Tim O'Toole and guest Leah Moushey (Counsel, Miller & Chevalier) return to the subject of cryptocurrency mixers, specifically in the context of Tornado Cash and recent agency guidance.  Their discussion looks at the recent federal ruling in a challenge to its designation brought by Tornado Cash and the subject of cryptocurrency and Office of Foreign Assets Control (OFAC) designations generally.
Roadmap:
Introduction
Tornado Cash
OFAC Designation
Storm and Semenov charged with conspiracy to commit sanctions violations

FinCEN proposes new regulation to enhance transparency in convertible virtual currency mixing and combat terrorist financing
Hamas virtual currency fundraising and sanctions
*******
Thanks to Leah Moushey for joining us: https://www.millerchevalier.com/professional/leah-moushey 
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. 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!