EMBARGOED!

Miller & Chevalier

Intelligent talk about international trade for trade geeks and regular people alike, hosted by Miller & Chevalier.

  1. 1 dag geleden

    Emergency Pod: Iran MOU | EMBARGOED! Episode 98

    In this emergency episode, host Tim O'Toole is joined again by colleague Melissa Burgess (Miller & Chevalier) to discuss sanctions aspects of the June 17, 2026, Islamabad Memorandum of Understanding (MOU) between the U.S. and Iran and legal considerations impacting the lifting of sanctions against the Islamic Republic of Iran. The episode reviews paragraphs 7 and 10 of the MOU before taking a brief tour through the nearly 50-year history of sanctions on Iran and some of the key sanctions authorities. They discuss a sampling of reporting, waiver, and certification considerations, examine General License X, and share thoughts on some of the more difficult potential sanctions delistings. Roadmap: Paragraphs 7 and 10 of the MOU Where do the Iran sanctions come from? Carter EO, Clinton EO, IEEPA, Iran Sanctions Act INARA and CISADA: certifications, waivers, and statutory sunset considerations General License X Hardest delistings ******** Thanks to Melissa 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!

    52 min.
  2. 17 jun

    The Gold Episode | EMBARGOED! Episode 97

    In this episode, host Tim O'Toole is joined by special guests Brad Brooks-Rubin (Arktouros) and Dr. David Soud (I.R. Consilium), as well as colleagues Collmann Griffin and Melissa Burgess (Miller & Chevalier), to discuss the many connections between gold and sanctions. The episode begins by exploring gold as a natural resource, the gold supply chain, and the difficulties of tracing gold. We also examine gold as a payment mechanism throughout history, and gold's function in foreign exchange transactions. Along the way, the episode dives into restrictions on gold in sanctions programs from the early days of the Trading with the Enemy Act through current Russia and Venezuela sanctions, cartel involvement in the gold supply chain, and use of gold as a hedge against sanctions. Roadmap: Gold 101 What are the risks related to Venezuela gold, despite the recent sanctions lifting in that sector? What are the connections between gold and cartels? How did Russia seek to use gold as part of its countersanctions strategy?  How did the United States respond? What is the connection between gold and conflict, for example in the DRC and Sudan?  How can sanctions counter this?   ******** Thanks to our guests for joining us! Brad Brooks-Rubin: https://www.arktouros.co/team/bbr Dr. David Soud: https://irconsilium.com/david-soud/  Melissa Burgess: https://www.millerchevalier.com/professional/melissa-burgess Collmann Griffin: https://www.millerchevalier.com/professional/collmann-griffin  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!

    1 u 6 m
  3. 1 apr

    Sanctions and the State Department – Part 2 | EMBARGOED! Episode 96

    In this episode, host Tim O'Toole is again joined by colleagues Collmann Griffin and Melissa Burgess (Miller & Chevalier) and special guests Erik Woodhouse (former Deputy Assistant Secretary for Counter Threat Finance and Sanctions in the Bureau of Economic and Business Affairs (EB) at the Department of State) and Joshua Kretman (former Deputy Assistant Secretary (Acting) in EB, who also spent several years as the lead sanctions attorney in the Office of the Legal Adviser at State). In part 2 of their discussion of State's role in sanctions, Erik and Josh address an unanswered question from part 1, then explain the coordination and separation between State and OFAC in licensing and enforcement. The discussion also covers a recent case addressing State’s power to designate and delist, as well as State's role when one of its decisions is challenged in court.   Roadmap: Separation between OFAC and State in enforcement State’s general role in sanctions license adjudication Sanctions enforcement versus sanctions implementation Challenging State designations, and the inherent power to delist ******* Thanks to our guest for joining us: Joshua Kretman: https://www.dentons.com/en/joshua-kretman  Erik Woodhouse: https://www.crowell.com/en/professionals/erik-woodhouse  Melissa Burgess: https://www.millerchevalier.com/professional/melissa-burgess Collmann Griffin: https://www.millerchevalier.com/professional/collmann-griffin  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!

    42 min.
  4. 16 mrt

    Sanctions and the State Department – Part 1 | EMBARGOED! Episode 95

    In this episode, host Tim O’Toole is joined by colleagues Collmann Griffin and Melissa Burgess (Miller & Chevalier), and special guests Erik Woodhouse (former Deputy Assistant Secretary for Counter Threat Finance and Sanctions in the Bureau of Economic and Business Affairs (EB) at the Department of State) and Joshua Kretman (former Deputy Assistant Secretary (Acting) in EB, who also spent several years as the lead sanctions attorney in the Office of the Legal Adviser at State). In part 1 of this discussion, Erik and Josh explain the structure and various players working on sanctions within State, walk through the process of creating a new sanctions program, and discuss State's role in sanctions targeting. Roadmap: Introductions and former positions at State Background on the State Department What role does State play in sanctions? Are there issues where State would want to hear from clients? What kinds of issues would you consider raising with State Venezuela: What role do you think State will play/is playing in this space? ******* Thanks to our guest for joining us: Joshua Kretman: https://www.dentons.com/en/joshua-kretman  Erik Woodhouse: https://www.crowell.com/en/professionals/erik-woodhouse  Melissa Burgess: https://www.millerchevalier.com/professional/melissa-burgess Collmann Griffin: https://www.millerchevalier.com/professional/collmann-griffin  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!

    46 min.

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Intelligent talk about international trade for trade geeks and regular people alike, hosted by Miller & Chevalier.

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