Enforcement-palooza 2.0! | EMBARGOED! Episode 29


May 13 2021 • 1 hr 22 mins

We are long overdue for a deep dive on the latest enforcement actions, so we’re covering the DOJ-led joint resolution with SAP, OFAC settlements with MoneyGram and Alliance Steel, DDTC’s consent agreement with Honeywell, and, last but not least, Luokung Technology’s successful court challenge to its CCMC listing.  Then, in the Lightning Round, we check in on JCPOA 2.0, the U.S. approach to Venezuela and Cuba, and the winding down of an important general license for Belarus.


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, 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 Rundown 4:27 SAP NPA and OFAC Settlement 21:38 MoneyGram OFAC Settlement 28:28 Alliance Steel OFAC Settlement 33:25 Honeywell DDTC Settlement 40:46 Luokung Takes Another Bite Out of the CCMC List

58:00 Lightning Round 58:12 JCPOA 2.0 1:11:26 Signals on Venezuela and Cuba 1:16:43 Belarus GL 2H

1:20:52 Final Thoughts

***Stay sanctions free.***