Brian and Tim kick off this episode by digging in to the implications of the newly announced U.S. sanctions targeting the Nord Stream 2 project and why they may amount to an admission of defeat. Next, we check in on the seemingly imminent JCPOA 2.0, the latest court challenge to the CCMC List, and a recent report issued pursuant to the Hong Kong Autonomy Act. Finally, in the Lightning Round, we consider OFAC’s ransomware guidance following recent high profile attacks and share our initial thoughts on the possible fallout from the diversion of a Ryanair flight by Belarus to arrest an opposition journalist.

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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.

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!

Timestamps: 0:10 Introduction and Roadmap

The Rundown 4:50 PEESA Sanctions and Nord Stream 2 19:00 Inching Toward JCPOA 2.0 26:18 Xiaomi Updates and Another CCMC Lawsuit 34:21 Recent Hong Kong Autonomy Act Report

45:10 Lightning Round 45:24 Colonial Pipeline Attack and Ransomware Epidemic 58:03 Belarus and Ryanair

1:06:24 Final Thoughts

***Stay sanctions free.***