17 episodes

Intelligent talk about international trade for trade geeks and regular people alike, hosted by Miller & Chevalier Members Brian Fleming and Tim O'Toole.

EMBARGOED! Miller & Chevalier

    • Business News
    • 4.7 • 16 Ratings

Intelligent talk about international trade for trade geeks and regular people alike, hosted by Miller & Chevalier Members Brian Fleming and Tim O'Toole.

    We'll See You in Court! Checking In on TikTok, WeChat, ICC, and Commerce Lawsuits | EMBARGOED! Episode 16

    We'll See You in Court! Checking In on TikTok, WeChat, ICC, and Commerce Lawsuits | EMBARGOED! Episode 16

    Brian and Tim drop the gavel to render verdicts on the litigation impacting the TikTok and WeChat bans and a lawsuit challenging the legal bases for the new ICC-related sanctions program. We also discuss OFAC's recent ransomware advisory and give some thoughts on a recent OFAC enforcement action focused on Cuba. Then, in the Lightning Round, we share our initial impressions on brand new U.S. sanctions targeting Iran's financial sector and dissect the outcome of a lawsuit challenging the foundations of the Commerce Department's authority to enforce the export controls framework established by the EAR.*********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, hosted by Miller & Chevalier Members Brian Fleming and Tim O'Toole. 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 for new bi-weekly episodes so you don't miss out!Timestamps:0:10 Introduction and RoadmapThe Rundown 5:38 Quick Check-in on TikTok and WeChat 18:54 Lawsuit Challenging ICC Sanctions 39:36 OFAC and FinCEN Randomware Advisory 53:41 OFAC Settlement with Generali Global1:01:47 Lightning Round 1:02:05 More Sanctions Coming Against Iranian Banks? 1:12:43 FedEx v. BIS1:25:21 Final Thoughts***Stay sanctions free.***

    • 1 hr 27 min
    U.S. v. TikTok and WeChat: Who is Winning? | EMBARGOED! Episode 15

    U.S. v. TikTok and WeChat: Who is Winning? | EMBARGOED! Episode 15

    In the latest episode of EMBARGOED!, Brian and Tim return to China in a big way as they dive headlong into the TikTok and WeChat bans to analyze what transactions are actually prohibited, the status of the various court proceedings seeking to delay the bans, where things stand with CFIUS review of TikTok's "divestiture," and, last but not least, China's countermoves to try to ensure it will have the last word.Next, we turn to Iran and the U.S.'s attempt to unilaterally reimpose U.N. sanctions under the JCPOA more than two years after withdrawing from the deal. Finally, in the Lightning Round, we share a few quick thoughts on recent sanctions aimed at countering foreign interference in U.S. elections and discuss the latest travel-related restrictions on Cuba (Hint: Don't stick rum or cigars in your suitcase before returning to the States unless you have an OFAC license).********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, hosted by Miller & Chevalier Members Brian Fleming and Tim O'Toole. 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 for new bi-weekly episodes so you don't miss out!Timestamps:0:10 Introduction and RoadmapThe Rundown 7:01 More TikTok and WeChat (Commerce rules, state of the "bans," CFIUS and the TikTok "divestiture," China's Unreliable Entities List) 46:17 Iran Snapback1:02:13 Lightning Round 1:02:25 Cyber designations relating to election interference by (GASP!) Russia 1:10:17 CACR amendments to further restrict aspects of Cuba travel1:17:34 Final Thoughts*Stay sanctions free.*

    • 1 hr 19 min
    All Lightning, No China | EMBARGOED! Episode 14

    All Lightning, No China | EMBARGOED! Episode 14

    On this episode of EMBARGOED!, Brian and Tim keep their promise to stay China free (for this week, at least) and change things up to bring you an entire Lightning Round-style episode. With the whole world at our disposal (other than China), we cover the following topics in lightning fashion: the latest U.S. advisory on North Korea, the first U.S. sanctions imposed on the ICC, OFAC's MOU with the State of Delaware, two recent OFAC enforcement actions against an individual and a financial institution, respectively, the latest on Nord Stream 2 and Venezuela, and, finally, a wild card segment featuring our first foray into sanctions trivia.*********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, hosted by Miller & Chevalier Members Brian Fleming and Tim O'Toole. 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 for new bi-weekly episodes so you don't miss out!Timestamps:0:10 Introduction and RoadmapA Full Episode of Lightning Round!4:49 North Korea Advisory 9:27 International Criminal Court Sanctions 17:13 OFAC Memorandum of Understanding with Delaware 21:18 OFAC Settlement (Individual) 25:26 OFAC Settlement (Russia/Ukraine/Deutsche Bank Trust Co. Americas) 30:00 Nord Stream 2 36:44 Latest Venezuela Sanctions 41:20 Wild Card!51:55 Final Thoughts***Stay sanctions free.***

    • 53 min
    If TikTok & WeChat Go Away, Is It Still Safe to Use Tin Cans With String? | EMBARGOED! Episode 13

    If TikTok & WeChat Go Away, Is It Still Safe to Use Tin Cans With String? | EMBARGOED! Episode 13

    EMBARGOED! is back! After a brief, socially-distanced summer vacation, Brian and Tim return to tackle the messy, unprecedented U.S. government actions targeting TikTok and WeChat. Next, we return to one of our favorite topics, Huawei, to analyze the impact of the BIS final rule, which makes another attempt to disrupt the company's supply chain by further expanding the foreign direct product rule. We also discuss the first wave of sanctions targeting Hong Kong and its top officials and ponder whether this was anything more than a symbolic gesture. Plus, in the Lightning Round we share some thoughts on recent Entity List additions targeting, for the first time, activities in the South China Sea, a Xinjiang-related addition to the SDN List causing significant due diligence headaches, and, at long last, the publication of the Advance Notice of Proposed Rulemaking regarding "foundational technologies."*********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, hosted by Miller & Chevalier Members Brian Fleming and Tim O'Toole. 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 for new bi-weekly episodes so you don't miss out!Timestamps:0:10 Introduction and RoadmapThe Rundown 5:36 TikTok and WeChat 30:00 Final BIS Rule re: Huawei and Foreign Direct Product Rule 42:52 First Hong Kong Sanctions51:40 Lightning Round 52:00 BIS Addition of 24 Chinese Companies to the Entity List re: South China Sea 56:56 Xinjiang-related Additions to the SDN List 1:02:00 Commerce (Finally) Issues ANPRM re: Foundational Technologies1:09:00 Final Thoughts***Stay sanctions free.***

    • 1 hr 10 min
    The New Normal(ization) | EMBARGOED! Episode 12

    The New Normal(ization) | EMBARGOED! Episode 12

    On the latest episode of EMBARGOED!, Brian and Tim dissect the continued downward spiral of U.S.-China relations, including the sweeping new Executive Order aimed at "normalizing" U.S. relations with Hong Kong and the latest tit-for-tat sanctions imposed by the U.S. and China, respectively. Next, we cover two notable recent enforcement actions: OFAC's settlement with Amazon and a joint DOJ/OFAC resolution with Essentra FZE relating to North Korea sanctions violations. Finally, in the Lightning Round, we share quick thoughts on recent OFAC designations targeting Nicaragua and some personal reflections on the United States' reliance on human rights as a basis for economic sanctions policies.*********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, hosted by Miller & Chevalier Members Brian Fleming and Tim O'Toole. 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 for new bi-weekly episodes so you don't miss out!Apple Podcasts: https://apple.co/3bDJnmU Spotify: https://spoti.fi/2xAJ9ye Google Play: https://bit.ly/3bAU0Hc Stitcher: https://bit.ly/3awf95i Timestamps:0:10 Introduction and RoadmapThe Rundown4:21 China Round-up22:30 Amazon OFAC Enforcement Action30:51 North Korea Enforcement Action by DOJ/OFAC39:39 Lightning Round: 40:00 Ortega's Inner Circle Targeted by OFAC43:59 A Few Words on Human Rights and the Death Penalty55:45 Final Thoughts***Stay sanctions free.***

    • 56 min
    China Officially Takes Over the Pod (and Hong Kong) | EMBARGOED! Episode 11

    China Officially Takes Over the Pod (and Hong Kong) | EMBARGOED! Episode 11

    On the latest episode of EMBARGOED!, Brian and Tim break down the early days of China's new national security law aimed at Hong Kong and the U.S. response, including the suspension of preferential export control treatment for Hong Kong and new sanctions on the horizon that take aim at financial institutions. Next, we revisit BIS's new military end user/military end use rules and try to decipher the recently issued BIS guidance. Finally, we unpack the somewhat unorthodox multi-agency advisory warning U.S. businesses of supply chain risks relating to forced labor and human rights abuses in the Xinjiang region of China. Plus, the Lightning Round features quick thoughts on continued U.S. efforts to disrupt deepening ties between Venezuela and Iran and what the rest of the world is doing with respect to Huawei.*********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, hosted by Miller & Chevalier Members Brian Fleming and Tim O'Toole. 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 for new bi-weekly episodes so you don't miss out!Apple Podcasts: https://apple.co/3bDJnmUSpotify: https://spoti.fi/2xAJ9yeGoogle Play: https://bit.ly/3bAU0HcStitcher: https://bit.ly/3awf95iTimestamps:0:11 Introduction and Roadmap The Rundown3:49 The Other Shoe Drops for Hong Kong23:19 New BIS FAQs re: Military End Use/User Rules39:01 U.S. Government Advisory re: Xinjiang Supply Chain Risk 49:11 Lightning Round49:37 More Venezuela-Iran Links53:13 What Does the Rest of the World Think of Huawei 59:47 Final Thoughts***Stay sanctions free.***

    • 1 hr

Customer Reviews

4.7 out of 5
16 Ratings

16 Ratings

hockeyguy86 ,

Lightning round! (Pew pew pew)

Awesome show, Brian and Tim are the best and bring incredibly intelligent takes on the topics at hand

Sanctions Practitioner ,

Breezy discussions about export controls and sanctions

Provides a high-level overview of US sanctions and export control developments in a breezy/informal way. But, both speakers are sometimes imprecise in their discussions about legal issues. Brian also has a strange way of mispronouncing the last name of Secretary of State Mike Pompeo.

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