69 episodes

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

EMBARGOED‪!‬ Miller & Chevalier

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    • 4.8 • 27 Ratings

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

    2023 Year in Review: The Good, the Bad, and the Ugly in U.S. Sanctions | EMBARGOED! Ep. 68

    2023 Year in Review: The Good, the Bad, and the Ugly in U.S. Sanctions | EMBARGOED! Ep. 68

    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!

    • 51 min
    The ITAR Episode (for the Real Trade Nerds) | EMBARGOED! Episode 67

    The ITAR Episode (for the Real Trade Nerds) | EMBARGOED! Episode 67

    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!

    • 1 hr 3 min
    Blowing in the Wind: The Tornado Cash Designation, Mixers, and Federal Litigation | EMBARGOED! Ep. 66

    Blowing in the Wind: The Tornado Cash Designation, Mixers, and Federal Litigation | EMBARGOED! Ep. 66

    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!

    • 45 min
    Changes in Venezuela: Emergency Pod! | EMBARGOED! Ep. 65

    Changes in Venezuela: Emergency Pod! | EMBARGOED! Ep. 65

    Tim and this week's guest, Miller & Chevalier Counsel Laura Deegan, talk about big recent changes to Venezuela sanctions, including a discussion of what happened, how long its expected to last, and what companies can do to better understand and comply with the changed sanctioned regime in Venezuela.
    Roadmap:
    The U.S. government suspended certain sanctions measures in three sectors of the Venezuelan economy: oil and gas, gold, and finance.  
    Oil and Gas Sector/GL 44
    Gold Sector/GL 43
    Financial Sector/GL 3I and GL 9H
    *******
    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 bi-weekly episodes so you don't miss out!

    • 30 min
    Why Can’t We Be Friends? The Growth of Multi-Lateral Coordination in U.S. Sanctions Policy Toward Russia | EMBARGOED! Ep. 64

    Why Can’t We Be Friends? The Growth of Multi-Lateral Coordination in U.S. Sanctions Policy Toward Russia | EMBARGOED! Ep. 64

    This week on EMBARGOED! host Tim O'Toole is joined by guests Dr. Laura Louca of Blomstein and Caroline Watson of Miller & Chevalier to talk about how EU and U.S. sanctions have evolved in the past 18 months in a time of growing sanctions infrastructure in Europe and growing coordination of policy in the U.S.  They'll focus on similarities and differences in U.S. and EU regimes.
    Roadmap:
    Before 2023 Russia sanctions
    Russia sanctions in 2023 have been very different
    Unprecedented coordination
    Key differences between U.S. and EU Russia sanctions
    Issuance
    Jurisdiction
    Licensing
    Seizure/expropriation of assets
    Recourse for sanctioned parties
    Challenges with divestment from Russia
    Export controls


    *******
    Thanks to our guests for joining us:
    Dr. Laura Louca: https://www.blomstein.com/en/team.php?p=dr-laura-louca
    Caroline Watson: https://www.millerchevalier.com/professional/caroline-j-watson
    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!
     

    • 1 hr 12 min
    Taking It to the Banks: The Role of Financial Institutions in Sanctions Compliance | EMBARGOED!

    Taking It to the Banks: The Role of Financial Institutions in Sanctions Compliance | EMBARGOED!

    This week, in light of the expanding multi-lateral sanctions against Russia and the focus on financial institutions as the front lines of sanctions compliance, host Tim O'Toole and guest Stéphanie Broekaart (Magara Sanctions and Export Controls Compliance Counseling) take a close look at the role of financial institutions in export controls and sanctions compliance.   
    Roadmap
    First things first: the exact role of banks in sanctions compliance
    List-based sanctions
    Embargoed countries and internal policies
    Humanitarian/non-sanctioned activities involving comprehensively sanctioned countries
    Enforcement
    Circumvention and evasion
    *******
    Thanks to Stéphanie Broekaart for joining us: https://www.linkedin.com/in/st%C3%A9phanie-broekaart-05a2a462/ 
    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!

    • 53 min

Customer Reviews

4.8 out of 5
27 Ratings

27 Ratings

Amiloooo ,

One of the best sanctions podcast out there

There are several sanctions/export control sanctions podcasts. This one is one of my favorite ones.

tff6;5;!!#\}*~ ,

Great podcast

Thank you for helping crystallize complex topics in an ever-changing compliance landscape.

Vigrdsafhvds ,

A podcast for the workday!

As a newbie export control practitioner and long time podcast enthusiast, the intersection of export control knowledge and updates in a podcast is so relevant to me! Easy to follow and enjoyable to listen. A definite work-day listening requirement.

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