Reading the Sanctions Tea Leaves | EMBARGOED! Episode 3

In this episode, hosts Brian Fleming and Tim O'Toole summon all of their prognostication powers to take a closer look at the Halkbank case, the future of U.S. sanctions against Iran, Venezuela, and North Korea, and the latest OFAC enforcement action. Plus: The Lightning Round features more Huawei (of course) and deep thoughts on the meaning of rejection (at least as defined, or not, by OFAC). Questions? Contact us at [email protected]. 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: 0:12 Introduction The Rundown 2:09 Developments in Halkbank case in New York and related Iran signals (General License 8, release of Iranian prisoner in Germany, etc.) 23:31 Venezuela OFAC developments 33:18 North Korea cyber sanctions developments at OFAC 39:45 OFAC settlement involving Société Internationale de Télécommunications Aéronautiques (SITA) 47:48 Lightning Round 48:12 Latest on Huawei 53:58 OFAC Guidance on recent amendment to Reporting, Procedures, and Penalties Regulations (Part 501) 59:50 Final Thoughts