EMBARGOED!

Miller & Chevalier

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

  1. NOV 26

    Sanctions & Export Control Evasion with Conflict Armament Research's Damien Spleeters | EMBARGOED! Episode 90

    This week, host Tim O'Toole chats with Damien Spleeters (Conflict Armament Research) and return guest Collmann Griffin (Miller & Chevalier) about how bad actors use sophisticated evasion tactics to circumvent U.S. export controls and sanctions to obtain components America's adversaries need for missiles, drones, and other weapons systems. Roadmap: Background on Conflict Armament Research (CAR), particularly CAR's work in Ukraine Western components that end up in Russian, Iranian, North Korean, and other weapons systems and how this overlaps with the BIS Common High Priority List (CHPL) A walkthrough of how an item makes its way from a U.S.-owned fabricator to a foreign weapons system Screening/due diligence steps recommended for manufacturers and distributors of high-priority items ******* Thanks to our guests for joining us:  Damien Spleeters: https://www.linkedin.com/in/damienspleeters/ 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!

    35 min
  2. NOV 7

    Semiconductor Export Controls (Part 2): AI, SME, and the BIS 50% Rule | EMBARGOED! Episode 88

    On this episode of EMBARGOED!, host Tim O'Toole, Miller & Chevalier Counsel Melissa Burgess and Collmann Griffin, and guest Chris Chamberlain of Morrison & Foerster continue their discussion of AI chip-related export controls, musing about Infrastructure-as-a-Service (IaaS) considerations, semiconductor manufacturing equipment (SME), and the much-anticipated BIS release of a 50 Percent Rule for the Entity List. Roadmap: May 13, 2025, BIS Policy Statement on training AI models Controls on SME and balancing foreign policy, national security, and other reasons for control under the EAR Not reasons for control: Economic and other factors BIS does not consider determinative when assessing controls Pros and cons of BIS having an OFAC-style 50 Percent Rule for the Entity List ******* Thanks to our guests for joining us: Chris Chamberlain: https://www.mofo.com/people/chris-chamberlain  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!

    1h 5m
  3. OCT 30

    Semiconductor Export Controls (Part 1): AI Chips and the "Secret Entity List" | EMBARGOED! Episode 87

    On this episode of EMBARGOED!, host Tim O'Toole is joined by Miller & Chevalier Counsel Melissa Burgess and Collmann Griffin, and guest Chris Chamberlain of Morrison & Foerster to review the evolution of export controls on AI chips from October 2022 to the present. The discussion explores the variety of tools BIS has employed as it wrestles with tailoring controls, the value of BIS "is informed" letters, and chip diversion. Roadmap: The October 7 IFR and a brief tour of subsequent changes through May 2025 Identifying a problem versus tailoring controls: Troubleshooting how to restrict access to the most advanced compute resources and the tools necessary to manufacture them Assessing the benefits to both BIS and industry of "is informed" letters Predictions for the next iteration of the AI Diffusion Rule A diversion into the problem of diversion: Red flags and tactics identified in the wild ******* Thanks to our guests for joining us: Chris Chamberlain: https://www.mofo.com/people/chris-chamberlain  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!

    1h 4m
  4. OCT 16

    EU Sanctions for American Lawyers | Episode 86

    Host Tim O'Toole discusses the latest EU sanctions on Russia with returning guests Collmann Griffin (Miller & Chevalier) and Dr. Tobias Ackermann (BLOMSTEIN). They focus on EU sanctions on Russia imposed that may be stricter than or conflict with their U.S. counterparts. Roadmap: Logistics of the sanctions Imports and purchase - aluminum and Russian petroleum Software Finance and crypto "Best efforts" - EU operators that own or control non-EU entities, including U.S. companies with EU-based subsidiaries, are required to use “best efforts” to ensure that those entities do not undermine EU sanctions against Russia and Belarus "No Russia" and "No Belarus" clauses Future measures ******* Thanks to our guests for joining us: Collmann Griffin: https://www.millerchevalier.com/professional/collmann-griffin  Dr. Tobias Ackermann: https://www.blomstein.com/en/team/dr-tobias-ackermann  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!

    58 min
  5. OCT 2

    Die Kunst Des Erfolgs: Navigating Foreign Investment Deals Through U.S., EU, and German Regulators | EMBARGOED! Episode 85

    On this episode of EMBARGOED! Host Tim O'Toole is joined by guests Melissa Burgess (Miller & Chevalier) and Dr. Tobias Ackerman (BLOMSTEIN) to compare and contrast the foreign investment review regimes in the EU and Germany with the CFIUS process in the U.S. Roadmap: Brief introduction to Germany's FDI regime and the EU regime A quick history of CFIUS Exploration of the types of transactions subject to review and mandatory versus voluntary filing triggers Summaries of the different filing and assessment processes Review of recent and pending FDI developments in the U.S. and EU, including the America First Investment Policy ******* Thanks to our guests for joining us: Melissa Burgess: https://www.millerchevalier.com/professional/melissa-burgess Dr. Tobias Ackermann: https://www.blomstein.com/en/team/dr-tobias-ackermann  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
4.8
out of 5
27 Ratings

About

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

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