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EMBARGOED!

EMBARGOED! Episode 49: Don’t Worry, We Haven’t Forgotten About China

In a refreshing change of pace, Brian and Tim spend time on one of their favorite non-Russia topics, China. First, they discuss President Biden’s pledge to defend Taiwan from a PRC invasion and what it means (if anything). Next, they discuss the state of China’s imports to Russia following the invasion of Ukraine and the growing debate over various proposals in the U.S. to create a “reverse CFIUS” process to review outbound investment to China and other countries of concern. Finally, Brian and Tim cover two new U.S. government advisories focused on North Korean IT workers and Sudan, respectively.

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EMBARGOED! is not intended and cannot be relied on as legal advice; the content only reflects the thoughts and opinions of its hosts.
***Stay sanctions free.***

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EMBARGOED!

EMBARGOED! Episode 48: OFAC’s Victory Day Present for Putin & Sanctions Are the New FCPA

Brian and Tim kick things off by briefly covering OFAC’s issuance, on the eve of Victory Day, of two determinations aimed at disrupting Russia’s use of accounting, trust and corporate formation, and management consulting services. Next, they discuss recent public comments by the Deputy Attorney General proclaiming that, as a DOJ enforcement priority, sanctions are the new FCPA. We also check in on what China has been up to lately (with respect to Russia) and share a few thoughts on the recently issued Ukraine-/Russia-Related Sanctions Regulations. Finally, in the Lightning Round, they briefly cover the unsealing of indictments against Virgil Griffith’s alleged co-conspirators and debate what it could mean that Nicaragua’s ruling family has reportedly reached out to the U.S. seeking sanctions relief.

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EMBARGOED! is not intended and cannot be relied on as legal advice; the content only reflects the thoughts and opinions of its hosts.
***Stay sanctions free.***

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EMBARGOED!

EMBARGOED! Episode 47: The Evolving U.S. Response to Russia’s Invasion of Ukraine

After a brief break, Brian and Tim are back to catch up on all things Russia, including the biggest compliance challenges thus far, the recent U.S. ban on “new investment,” and where things could be headed in the coming months. Next, they head to SDNY to discuss a notable recent sentencing in a North Korea sanctions case. Finally, in the Lightning Round, Brian and Tim debate the role and impact of sanctions-like bans in the world of international sports.

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EMBARGOED! is not intended and cannot be relied on as legal advice; the content only reflects the thoughts and opinions of its hosts.
***Stay sanctions free.***

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EMBARGOED!

EMBARGOED! Episode 46: Addressing the Russia Conundrum

With escalating U.S. and international sanctions and export controls further isolating Russia, and no end in sight to the conflict in Ukraine, Brian and Tim share their thoughts on surprising developments thus far, as well as the regulatory and practical challenges faced by companies whether they are seeking to wind down operations in Russia or stick it out. They also provide a brief recap of the most significant actions of the past few weeks and ponder what could be coming next. Finally, in the Lightning Round, Brian and Tim cover the latest on JCPOA 2.0 and reports that a deal is within reach.

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EMBARGOED! is not intended and cannot be relied on as legal advice; the content only reflects the thoughts and opinions of its hosts.
***Stay sanctions free.***

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EMBARGOED!

EMBARGOED! Episode 45: Russia Invades Ukraine and Triggers the Biggest Week in Economic Sanctions History

After a tumultuous and historic week, Brian and Tim gather themselves to discuss the U.S. (and global) response to Russia’s invasion of Ukraine. They start by diving in to the broad, coordinated economic sanctions aimed at debilitating Russia’s financial sector and Putin’s inner circle, debate how well the new measures will work, and contemplate what could be coming next. They next turn to the significant expansion of export controls implicating Russia and discuss the likely impact. Finally, in the Lightning Round, Brian and Tim bid farewell to DOJ’s China Initiative and read between the lines to decipher DOJ’s ongoing priorities.

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EMBARGOED! is not intended and cannot be relied on as legal advice; the content only reflects the thoughts and opinions of its hosts.
***Stay sanctions free.***

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EMBARGOED!

EMBARGOED! Episode 44: Afghanistan in the Spotlight (while Iran, Russia, and China Lurk Offstage)

Brian and Tim discuss the new E.O. aimed at resolving the question of what to do with Da Afghanistan Bank’s assets in the U.S. and debate whether it will work as intended. Next, they place bets on whether it’s too late for JCPOA 2.0 to happen and discuss how far the U.S. may be prepared to go to impose costs on China if it disregards the (possible) “crushing” sanctions that could be imposed upon Russia. Finally, Brian and Tim stick with China to briefly cover the recently unsealed trade secret theft charges against Hytera Communications and an atypical CFIUS review initiated by a U.S. company unhappy with its Chinese investors.

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EMBARGOED! is not intended and cannot be relied on as legal advice; the content only reflects the thoughts and opinions of its hosts.
***Stay sanctions free.***

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EMBARGOED!

EMBARGOED! Episode 43: Russia and Iran and China, Oh My!

This week on EMBARGOED!, Brian and Tim cover three of their favorite topics: Russia, Iran, and China. First, they discuss the latest U.S. threat to deploy Huawei-style foreign direct product rule restrictions on exports to Russia. Next, they consider whether it is truly now or never for JCPOA 2.0 and, then, contemplate the future of DOJ’s China Initiative in the wake of a high-profile dismissal. Finally, in the Lightning Round, Brian and Tim go below deck to provide some perspective on recent developments in a Helms-Burton lawsuit targeting major players in the cruise industry and share some quick thoughts on the new U.S. government advisory regarding Burma (Myanmar).

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EMBARGOED! is not intended and cannot be relied on as legal advice; the content only reflects the thoughts and opinions of its hosts.
***Stay sanctions free.***

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EMBARGOED!

EMBARGOED! Episode 42: Russia-stravaganza!

Brian and Tim kick off 2022 by diving deep on Russia and the crisis brewing at Ukraine’s border. They discuss the “punishing” sanctions that could be coming if Russia invades Ukraine, Nord Stream 2 (of course), and what companies should be doing right now to prepare for the worst and mitigate risk. In the Lightning Round, Brian and Tim share quick thoughts on the Uyghur Forced Labor Prevention Act, new Commerce Department appointments, and OFAC’s recent enforcement action against Airbnb Payments.

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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.
***Stay sanctions free.***

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EMBARGOED!

EMBARGOED! Episode 41: Top 10 Stories of 2021

In the year’s final episode, Brian and Tim run through a Lightning Round-style discussion of the top economic sanctions and export controls stories of 2021. In no particular order, they discuss: the U.S. hitting the policy reset button, successful court challenges, China!, the slow death of JCPOA 2.0, virtual currency and ransomware, Russia’s reemergence, turbulent times yield lots of new sanctions programs and policies, Huawei’s CFO gets a DPA, all quiet in the Americas, and a renewed focus on anti-corruption, democracy, and human rights. See you in 2022! Stay sanctions free!

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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.
***Stay sanctions free.***

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EMBARGOED!

EMBARGOED! Episode 40: Fresh New Topics and Old Favorites

Before turning to some old favorites, Brian and Tim cover some fresh new topics, including the first designations under, and tailored aims of, the new Ethiopia-related sanctions program and the Cambodia Business Advisory on High-Risk Investments and Interactions. Next, they discuss recent actions to combat Iran’s attempts to interfere in the 2020 U.S. presidential election and Russia’s latest provocations with respect to Ukraine and Europe’s energy supply. Finally, in the Lightning Round, Brian and Tim briefly consider a possible U.S. diplomatic boycott of the Beijing Olympics and the end of OFAC’s Burundi sanctions program.

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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.
***Stay sanctions free.***