EMBARGOED!

Happy 100th Episode! Tim O'Toole is joined by EMBARGOED! co-founder and co-host emeritus Brian Fleming (Steptoe LLP), plus colleagues Melissa Burgess and Collmann Griffin (Miller & Chevalier), for a celebratory recording of the 100th episode of the podcast. In a special edition of the Lightning Round, the team shares thoughts about developments in Iran, Russia, and Cuba sanctions. Along the way, they also revisit a few crystal ball predictions from prior episodes, reveal the EMBARGOED! origin story, and respond to a few AI-generated comments.

Roadmap:

• Lightning Round

• Iran sanctions updates
• Proposed Russia sanctions legislation (Lindsey O. Graham Sanctioning Russia Act of 2026)
• Cuba sanctions updates

• The EMBARGOED! origin story
• Correcting AI comments

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Thanks to our guests for joining us!

Brian Fleming: https://www.steptoe.com/en/lawyers/brian-j-fleming.html

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!

Host Tim O'Toole is joined by colleagues Melissa Burgess and Collmann Griffin (Miller & Chevalier) and guest Rachel Alpert (Jenner & Block) to dive into the history of U.S. economic sanctions. Kicking off the episode, the group tackles a range of trivia questions about predecessors to OFAC, sanctions licensing, sanctions measures dating back to the Revolutionary War, and more. Draft-style, each participant then unpacks favorite and obscure sanctions programs and targets from Southern Rhodesia to unregulated fishing.

Roadmap:

• Update to Episode 98: Two Minutes about Tehran
• Trivia

• OFAC Predecessors
• OFAC FAQ 1
• Where to apply for a specific license
• Precursor to the SDN List
• Why are they called “Specially Designated Nationals”?
• On this date: February 18, 2020
• Definitions of the United States/OFAC's historic jurisdiction
• British comprehensive embargo of the U.S.
• First U.S. countersanctions and first U.S. embargo

• Draft Picks

• Southern Rhodesia and South Africa
• Danzig and Democratic Kampuchea
• Illegal, unreported, and unregulated fishing
• Revolutionary War sanctions

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Thanks to our guests for joining us!

Rachel Alpert: https://www.jenner.com/en/people/rachel-alpert

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!

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

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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!

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?

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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!

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

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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!

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?

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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!

In this episode, Host Tim O'Toole is once again joined by Melissa Burgess, Counsel at Miller & Chevalier. Tim and Melissa discuss the major events and developments in 2025 for the Committee on Foreign Investment in the United States (CFIUS) and the Outbound Investment program that is sometimes referred to as "Reverse CFIUS" (because it involves restrictions on U.S. investment into foreign countries, rather than foreign investment in the U.S.). Tim and Melissa also shared their thoughts on what might be coming in 2026.

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Thanks to our guest for joining us:

Melissa Burgess: 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!

Host Tim O'Toole is joined by guests Melissa Burgess (Counsel at Miller & Chevalier) and Michael Burton (Partner at Jacobsen Burton Kelley) to make their draft picks from a pool of Bureau of Industry and Security (BIS) actions in 2025. Throughout the draft, they dissect each other’s choices, issue some compliments, suggest New Year's resolutions for the agency, and propose a new test for BIS agents. Picks include what BIS didn't do in 2025, the Affiliates Rule, and lifting comprehensive sanctions on Syria.

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Thanks to our guests for joining us:

Michael Burton: https://www.jbktradelaw.com/michael-l-burton

Melissa Burgess: 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!

Happy new year from your friends at EMBARGOED! Tim and Miller & Chevalier's Caroline Watson and Collmann Griffin draft the most significant OFAC events of 2025. The draft is three rounds and picks include sanctions relating to Iran, narco-trafficking, Yemen, Russia, Venezuela, Syria, China, and the International Criminal Court (ICC).

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Thanks to our guests for joining us:

Collmann Griffin: https://www.millerchevalier.com/professional/collmann-griffin

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 episodes so you don't miss out!

On this episode of EMBARGOED!, host Tim O'Toole is joined by Miller & Chevalier's Collmann Griffin and Claire O'Neill McCleskey, former Head of the OFAC Compliance Division, to discuss sanctions compliance in the shipping industry.

Roadmap:

• Typologies

• Iran
• Russia, including Lukoil/Rosneft and price cap
• North Korea

• How can you protect yourself?

• Best commercial screening tools
• Tips for insurers

• Price cap
• EU/U.S. divergence
• Foreign Terrorist Organizations (FTOs)/cartels

• Tips for flag registries
• Are S2S transfers ever okay?

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Thanks to our guests for joining us:

Claire O'Neill McCleskey: https://www.linkedin.com/in/claire-o-neill-mccleskey/

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!

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

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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!

On this episode of EMBARGOED!, host Tim O'Toole is joined by Matteson Ellis (Latin America Practice Lead at Miller & Chevalier) discuss all the sanctions news from Latin America, with a focus on recent developments in Mexico.

Roadmap:

• Introduction, Matt goes to Mexico
• Foreign Terrorist Organizations (FTOs) and LatAm
• Mexico, FTOs, and FinCEN orders
• What's happening on the ground
• The rest of LatAm
• Looking into the crystal ball

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Thanks to Matt Ellis for joining us: https://www.millerchevalier.com/professional/matteson-ellis

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, 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

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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!

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

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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!

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

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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!

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

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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!

Host Tim O'Toole is joined by fellow Miller & Chevalier Member Leah Moushey to unpack the recent conviction of Tornado Cash co-founder Roman Storm for operating an unlicensed money transmitting business, an outcome that surprised many given the jury's deadlock on the more severe money laundering and sanctions charges.

The discussion explores how this case reflects the evolving enforcement landscape at the intersection of crypto, DeFi, and national security. Tim and Leah delve into the broader implications of the verdict including challenges regulators face in applying traditional AML and sanctions frameworks to new technology, including decentralized platforms.

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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 episodes so you don't miss out!

In this episode of EMBARGOED!, host Tim O'Toole and his guest, Miller & Chevalier Counsel Collmann Griffin, make predictions of what's next in sanctions and export controls, including Russia, Iran, Latin America, and AI chips.

Roadmap:

• Intro
• Upcoming Russia sanctions and tariffs
• Likelihood of an Iran deal
• Latin America, Foreign Terrorist Organizations, Mexico, Brazil, and human rights sanctions
• BIS, AI chips, 50% Rule

*******

Thanks to Collmann Griffin for joining us: 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!

On this episode of EMBAROGED!, host Tim O'Toole and his guests, Miller & Chevalier Counsel Melissa Burgess and Collmann Griffin, explore the various ways the U.S. government lifts sanctions programs and corresponding export controls.

Roadmap:

• So you want to lift sanctions: How can you do it? What complexities might be involved?
• A quick tour of history:

• Lifting sanctions under TWEA Section 5(b) in 1917
• Lifting sanctions on China between 1969 and 1980

• Syria sanctions and GL 25
• Eliminating easy sanctions programs: West Bank and Zimbabwe
• Lifting complex sanctions programs: Myanmar/Burma and Sudan; "zombie programs" like Libya
• How to lift restrictions when the sanctions program target is a State Sponsor of Terrorism
• Iraq sanctions programs: I, II, and III

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Thanks to our guests for joining us:

Melissa Burgess: https://www.millerchevalier.com/professional/melissa-burgess

Collmann Griffin: https://www.millerchevalier.com/professional/collmann-griffin

Special thanks to summer associate Chenyang Wang for her assistance in preparing this episode.

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!

This week on EMBARGOED!, host Tim O'Toole is joined by Dr. Tobias Ackermann (BLOMSTEIN) and Caroline Watson (Miller & Chevalier) discuss the growing divergence between the U.S. and EU on key trade issues including economic sanctions on Russia, reciprocal tariffs, and export controls.

Roadmap:

• Increasing disparity between U.S. and EU regulations and policies, regarding Russia

• EU's release of 16th Sanctions Package on Russia in early March
• Changes in approach to Russia from the Biden administration to the Trump administration, including in collaboration with the EU and dialogue with Russia

• U.S.-EU trade war: new U.S. tariffs on the EU and EU countermeasures
• The "bazooka" – the EU's 2023 anti-coercion instrument and whether it could be used in response to U.S. tariffs
• Export controls and how the U.S. is reportedly pulling away from collaboration with the EU on the development of further controls

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Thanks to our guests for joining us:

Dr. Tobias Ackermann: https://www.blomstein.com/en/team/dr-tobias-ackermann

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 episodes so you don't miss out!