Episodes
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100th Episode Extravaganza | EMBARGOED! Episode 100
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...
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Sanctions History Trivia | EMBARGOED! Episode 99
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,...
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Emergency Pod: Iran MOU | EMBARGOED! Episode 98
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…
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The Gold Episode | EMBARGOED! Episode 97
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...
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Sanctions and the State Department – Part 2 | EMBARGOED! Episode 96
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...
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Sanctions and the State Department – Part 1 | EMBARGOED! Episode 95
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…
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CFIUS (and Reverse CFIUS) in 2025: A Year in Review | EMBARGOED! Episode 94
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...
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BIS 2025 Year in Review | EMBARGOED! Episode 93
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…
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OFAC 2025 Year in Review | EMBARGOED! Episode 92
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…
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Shipping Compliance with Sanctions Expert Claire O'Neill McCleskey | EMBARGOED! Episode 91
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…
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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...
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South of the Border | EMBARGOED! Episode 89
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...
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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,...
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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...
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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...
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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…
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Mixing It Up with Tornado Cash, Part 2 | EMBARGOED! Episode 84
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...
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Looking Into the Sanctions and Export Controls Crystal Ball | EMBARGOED! Episode 83
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...
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Winding Down Sanctions: A To-Do List When a Program Comes to an End | EMBARGOED! Episode 82
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...
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U.S. and EU Divergence in Trade and Enforcement | EMBARGOED! Episode 81
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:...
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Talking China, Cars, and Tech | EMBARGOED! Episode 80
On this episode of EMBARGOED!, Tim and guests Matt Fogarty (Lead Counsel – Trade & Human Rights, General Motors) and Caroline Watson (Counsel, Miller & Chevalier) talking about the new Information and Communications Technology and Services (ICTS) regulations with a focus on China, cars, and tech....
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ITAR Year in Review | EMBARGOED! Episode 79
Host Tim O'Toole and guests Melissa Burgess (Miller & Chevalier) and Johanna Reeves (Reeves & Dola, LLP) discuss changes to the ITAR that came into effect in 2024, proposed rules that could be finalized in 2025, and the enforcement outlook for the new year. Roadmap: Updates: Addition of Nicaragua...
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Predictions for Trade in 2025: Tariffs and Sanctions Outlook | EMBARGOED! Episode 78
On this episode, host Tim O'Toole and guests Richard Mojica and Laura Deegan of Miller & Chevalier discuss potential tariffs (including IEEPA and China) and sanctions changes (including Venezuela and Iran) in a second Trump term. ******* Thanks to our guests for joining us: Richard Mojica:...
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BIS Enforcement Actions: Everything You've Ever Wanted to Ask a (Former) BIS Special Agent | EMBARGOED Ep. 77
On this week's EMBARGOED!, host Tim O'Toole and Miller & Chevalier's Melissa Burgess, with guest Don Pearce, currently a Senior Advisor with Torres Trade Advisory and a retired BIS Special Agent, discuss the role of BIS Special Agents in enforcement actions, plus updates to BIS enforcement...
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Sanctions on the Ballot | EMBARGOED! Ep. 76
On this episode of EMBARGOED!, host Tim O'Toole and Miller & Chevalier Counsel Laura Deegan discuss how the upcoming U.S. elections could affect sanctions policy. Roadmap: Introduction A new administration is coming - What would a President Harris do? What would a President Trump do? Changes in...
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Back to School | EMBARGOED! Episode 75
Host Tim O'Toole and Miller & Chevalier Senior Associate Melissa Burgess discuss export control considerations for universities, plus new export controls on advanced tech and revisions to the BIS voluntary self-disclosure regulations. Roadmap: Introduction Upcoming speaking, podcasts, and events...
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Lucky 14: The 14th Sanctions Package Against Russia & What it Means on Both Sides of the Atlantic | EMBARGOED! Ep. 74
This week on EMBARGOED!, host Tim O'Toole is joined by BLOMSTEIN's Dr. Florian Wolf and Hanna Sophie Kurtz to discuss the 14th EU sanctions package against Russia and other sanctions topics. Roadmap: Introduction Background to the 14th EU sanctions package against Russia: Why was it necessary?…
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A Deep Dive into CFIUS and Reverse CFIUS | EMBARGOED! Ep. 73
On this episode of EMBARGOED!, host Tim O'Toole is joined by Miller & Chevalier attorneys Caroline Watson and Melissa Burgess to discuss U.S. controls on investment transactions under the CFIUS program and the new reverse CFIUS program, as well as the potential impact of the Supreme Court’s…
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Sanctions Compliance on the High Seas: Shipping, Insurance, Price Caps and the Dark Fleet | EMBARGOED! 72
In this episode of EMBARGOED!, host Tim O'Toole and guests Eric Orsini (Lloyd's List Intelligence), Laura Deegan (Miller & Chevalier), and Manny Levitt (Miller & Chevalier) focus on the shipping industry and sanctions compliance. They talk about shipping, insurance, price caps and have an…
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Demystifying the OFAC Lists: Talking De-listing With Erich Ferrari | EMBARGOED! Episode 71
In this episode of EMBARGOED, host Tim O'Toole and guest Erich Ferrari discuss common questions and issues related to the OFAC delisting process. ******* Thanks to Erich Ferrari for joining us: https://www.ferrariassociatespc.com/our-team/erich-ferrari/ Questions? Contact us at...
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An Update from Update 2024 | EMBARGOED! Episode 70
In this episode, host Tim O'Toole is joined by guest Doug Jacobson as they podcast live from the last day of the 2024 BIS Update Conference. Roadmap: China Russia Semiconductors ICTS Part 744 DDTC Update ******* Thanks to Doug Jacobson for joining us…
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If Sanctions are the New FCPA, are Export Controls the New Sanctions? | EMBARGOED! Episode 69
On this episode of EMBARGOED!, host Tim O'Toole is joined by Miller & Chevalier Senior Associate Melissa Burgess explore the evolving role played by export controls in U.S. sanctions policy, and discuss a few recent developments. Roadmap: "Sanctions are the New FCPA" OFAC’s revised approach to...
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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...
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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...
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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...
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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...
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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...
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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...
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Takeoff: Staying Sanctions Free on the Canadian Side of the Border | EMBARGOED! Episode 62
In this week's episode, Tim and guests John Boscariol (Partner, McCarthy Tetrault) and Stacy Keen (Partner, Pinsent Masons) focus on Canadian sanctions, including the evolution of the Russia sanctions, a comparison of Canadian and U.S. approaches to ownership and control issues, and a look at...
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Russia, Russia, Russia, Russia | EMBARGOED! Episode 61
In the wake of most recent round of sanctions against Russia, host Tim O'Toole and guest Dara Fernandez Perez (General Counsel – Trade Sanctions, EMEAI at Honeywell) discuss the impact of earlier sanctions packages, the challenges and opportunities those sanctions have created for the sanctions...
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The 2023 Sequel to Episode 19: What’s Up with TikTok? | EMBARGOED! Episode 60
Host Tim O'Toole is joined by guest Art Dicker (Senior Counsel with R&P China Lawyers in Shanghai) to discuss the ongoing TikTok legal saga. They'll outline the history of regulation and executive orders regarding TikTok and the proposed legislation addressing it moving forward. Roadmap: History...
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2022: The Year Sanctions Came of Age in Germany? | EMBARGOED! Episode 59
This week, host Tim O'Toole and our guest Roland Stein of the Blomstein law firm in Berlin review trade-related developments in Germany in 2022, particularly with regard to sanctions against Russia. Roadmap: German export controls and sanctions German enforcement agency History of German...
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Price Caps! On Both Sides of the Atlantic | EMBARGOED! Episode 58
Host Tim O'Toole is joined by Stephenson Harwood's Sue Millar to discuss the relatively new price caps on Russian crude oil and the coming price caps on petroleum products in both the U.S. and the U.K. ******* Thanks to our guest, Sue Millar, for joining us:...
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2022: The Good, the Bad, and the Ugly in U.S. Export Controls | EMBARGOED! Episode 57
Happy New Year from EMBARGOED! In this episode, host Tim O'Toole is once again joined by Doug Jacobson from Jacobson Burton Kelley PLLC, this time to go over 2022's major U.S. export controls developments. They'll cover: Global developments BIS June 30, 2022 Administrative Enforcement Memo…
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China Redux: What Could Be Lurking in the Supply Chain? | EMBARGOED! Episode 56
In this episode, Tim is joined by Kate Yin (Fangda Partners) and Miller & Chevalier's Richard Mojica and Virginia Newman to discuss due diligence and other issues arising from the newly implemented Uyghur Forced Labor Prevention Act. The group walks through the basics of the UFLPA, the challenges...
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New Export Controls Related to China and Big Changes to the EAR | EMBARGOED! Episode 55
This week, Tim is joined by Doug Jacobson from Jacobson Burton Kelley PLLC to discuss new export controls related to China that were put out on October 13, 2022. They'll cover: Unverified List and Entity List changes New export controls for certain...
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Emergency Pod: Sanctions Building in Nicaragua | EMBARGOED! Episode 54
On October 24, 2022, President Biden issued an executive order that created infrastructure that could lead to a significant increase in Nicaragua sanctions. In this emergency podcast, Tim is joined by fellow Miller & Chevalier Member Alejandra Montenegro Almonte and Senior Associate Manuel Levitt...
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EU and Dutch Sanctions Enforcement | EMBARGOED! Episode 53
Tim is joined by Van Doorne's Neyah van der Aa for an in-depth discussion of current EU and Dutch sanctions enforcement. They'll touch on the new EU facilitation provision and the new EU limitation on legal services to Russia. In the lightning round, we're back to crypto with Bittrex. Roadmap: EU...
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A Multi-Lateral Approach to Podcasting and Price Caps | EMBARGOED Episode 52
And we're back! Tim and guest Tom Stocker of Pinsent Masons in Edinburgh discuss recent and forthcoming Russia sanctions developments in the U.S. and U.K. Roadmap: Russia sanctions and multilateralism U.K. enforcement post-Brexit generally and how it could/has affected Russia sanctions…
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A Brief Hiatus | EMBARGOED! Episode 51
EMBARGOED! is going on hiatus for August and will be back in September with a new format. In the meantime, check out our back catalog and keep up to date with our trade alerts on millerchevalier.com. ******* Questions? Contact us at [email protected]. EMBARGOED! is not intended and cannot be...
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