On the final EMBARGOED! episode of 2020, Brian and Tim present their Top 10 sanctions and export controls stories of the year (in Lightning Round fashion). There are no winners and losers here, but the list includes: Huawei, sanctions targeting China, expanded MEUser/MEUse restrictions, the maximum pressure campaign against Iran, TikTok and WeChat EOs, disappearing Russia, U.S. v. Sadr, ExxonMobil v. OFAC, efforts to undercut the so-called Troika of Tyranny, and the state of OFAC enforcement.

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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.

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!


0:10 Introduction and Roadmap

The Top 10 Sanctions and Export Controls Stories of 2020
5:50 Huawei (FPDP Rule and CFO Meng Wanzhou)
9:05 Sanctions targeted at China (Hong Kong/Uyghurs, statutes/EOs)
14:10 Military End User/Military End Use restrictions
19:30 Has Iran pressure been maxed out?
25:04 TikTok/WeChat EOs
29:57 Disappearing Russia (will it be back on the radar in 2021?)
35:50 Throwing out the Sadr conviction in SDNY
44:15 ExxonMobil v. OFAC (“fair notice” for all!)
53:12 Continued focus on the “Troika of Tyranny” (Venezuela, Cuba, Nicaragua)
57:23 OFAC enforcement (or lack thereof)
1:03:53 Honorable mentions

1:08:45 Final Thoughts