Episodi
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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 as a 126.1 country and new DDTC guidance for universitiesDeeper divesExpansion of § 120.54: Activities that are not exports, reexports, retransfers, or temporary importsAUKUS-related changes and new FAQsProposed rules: defense servicesEnforcement: DDTC and BIS approaches in recent years, what does the future look like in the wake of Jarkesy and Loper Bright?*******
Thanks to our guests for joining us:
Melissa Burgess: https://www.millerchevalier.com/professional/melissa-burgess
Johanna Reeves: https://reevesdola.com/about-johanna-e-reeves
Questions? Contact us at [email protected].
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. 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 wherever you get your podcasts for new episodes so you don't miss out!
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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.
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Thanks to our guests for joining us:
Richard Mojica: https://www.millerchevalier.com/professional/richard-mojica
Laura Deegan: https://www.millerchevalier.com/professional/laura-deegan
Questions? Contact us at [email protected].
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. 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 wherever you get your podcasts for new episodes so you don't miss out!
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Episodi mancanti?
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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 policies, recent enforcement actions, and best practices for industry.
Roadmap:
IntroductionThe role of BIS Special Agents in enforcement actions (compared with the roles of other agencies like HSI or OEE personnel involved in reviewing disclosures)How to respond to outreach or a visit from a BIS Special Agent and related tips Providing tips and investigation leads when industry suspects a customer is attempting to divert products: When should industry approach BIS once it identifies red flags? What kind of information is useful?Thoughts about the 2022–present changes to BIS enforcement and voluntary self-disclosure policies, including September 2024 regulatory changesHighlights from the newest Don’t Let This Happen to YouInteresting features or lessons to learn from recent enforcement actions*******
Thanks to our guests for joining us:
Don Pearce: https://torrestradeadvisory.com/team/donald-pearce/
Melissa Burgess: https://www.millerchevalier.com/professional/melissa-burgess
Questions? Contact us at [email protected].
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. 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 wherever you get your podcasts for new episodes so you don't miss out!
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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:
IntroductionA new administration is coming - What would a President Harris do? What would a President Trump do?Changes in Treasury and State appointeesCountry by Country: Iran, Russia, North Korea, Venezuela, Cuba*******
Thanks to Laura Deegan for joining us: https://www.millerchevalier.com/professional/laura-deegan
Questions? Contact us at [email protected].
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. 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 wherever you get your podcasts for new episodes so you don't miss out!
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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:
IntroductionUpcoming speaking, podcasts, and eventsNew BIS export control compliance resources for the academic communityCompliance Note and Compendium of Resources (Aug. 14, 2024)Special issues in a university/research institute environmentBest practices for university export control programsRecent enforcement actionsNew plurilateral approach to controls on advanced tech (Sept. 6, 2024)More tweaks to the BIS voluntary self-disclosure process (Sept. 16, 2024)*******
Thanks to Melissa Burgess for joining us: https://www.millerchevalier.com/professional/melissa-burgess
Questions? Contact us at [email protected].
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. 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 wherever you get your podcasts for new episodes so you don't miss out!
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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:
IntroductionBackground to the 14th EU sanctions package against Russia: Why was it necessary? Why was it delayed? What is its purpose, scope, and applicability? What are details of its legal framework and implementation in EU Member States?Content of the 14th sanctions package (best-effort obligation (Article 8a), prohibition to circumvent restrictive measures (12), No-Russia clause and No-Belarus clause (12g and 12ga), due diligence for export of common high-priority items and impact on companies (12gb), broadened listed goods (3k) and prohibition to provide services (5n)Parallel U.S. sanctions and an update on U.S. sanctions against Russia*******
Thanks to our guests for joining us:
Dr. Florian Wolf: https://www.blomstein.com/en/team/dr-florian-wolf
Hanna Sophie Kurtz: https://www.blomstein.com/en/team/hanna-sophie-kurtz
Questions? Contact us at [email protected].
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. 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 wherever you get your podcasts for new episodes so you don't miss out!
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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 recent decision in SEC v. Jarkesy on enforcement by civil penalties.
Roadmap:
IntroCFIUSOutbound Investment Program (reverse CFIUS)EnforcementPenalties and the impact of Jarkesy*******
Thanks to our guests for joining us:
Caroline Watson: https://www.millerchevalier.com/professional/caroline-j-watson
Melissa Burgess: https://www.millerchevalier.com/professional/melissa-burgess
Questions? Contact us at [email protected].
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. 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 wherever you get your podcasts for new episodes so you don't miss out!
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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 extended discussion of the Dark Fleet.
Road map:
IntroductionsIntroduction to the Price CapAchieving Sanctions GoalsDownstream ConsequencesThe Dark FleetHow does China fit in?Compliance ConsiderationsWhat's on the horizon from OFAC?*******
Thanks to our guests for joining us:
Eric Orsini: https://www.lloydslistintelligence.com/
Laura Deegan: https://www.millerchevalier.com/professional/laura-deegan
Manny Levitt: https://www.millerchevalier.com/professional/manuel-levitt
Questions? Contact us at [email protected].
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. 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 wherever you get your podcasts for new episodes so you don't miss out!
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In this episode of EMBARGOED, host Tim O'Toole and guest Erich Ferrari discuss common questions and issues related to the OFAC delisting process.
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Thanks to Erich Ferrari for joining us: https://www.ferrariassociatespc.com/our-team/erich-ferrari/
Questions? Contact us at [email protected].
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. 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 wherever you get your podcasts for new episodes so you don't miss out!
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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:
ChinaRussiaSemiconductorsICTSPart 744DDTC Update*******
Thanks to Doug Jacobson for joining us: https://www.jbktradelaw.com/douglas-n-jacobson
Questions? Contact us at [email protected].
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. 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 wherever you get your podcasts for new episodes so you don't miss out!
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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 sanctions: 2021 to the presentThe role of BIS and export controls in response to Russia/UkraineSecond anniversary designation announcements (February 23, 2024)Recent subpoenas to maker of semiconductor manufacturing equipmentCommerce’s March 1, 2024, ICTS supply chain ANPRM on “Connected Vehicles”*******
Thanks to Melissa Burgess for joining us: https://www.millerchevalier.com/professional/melissa-burgess
Questions? Contact us at [email protected].
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. 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 wherever you get your podcasts for new episodes so you don't miss out!
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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 trendsNew directive/determinationsSector-wide determinations under E.O. 14024 Section 1(a)(i)Service-related designations under E.O. 14071 Sections 1(a)(ii), 1(b), and 5Import-related restrictions under E.O. 14068 1(a)(i)(B), as amendedImport-related restrictions under E.O. 14068 Sections 1(a)(i)(A) and 1(a)(i)(D)E.O. 14114 (amendment to E.O. 14024 and 14068)Price capIRAN
VENEZUELA
VIRTUAL CURRENCY
COUNTER-TERRORISM SANCTIONS
*******
Thanks to Laura Deegan for joining us: https://www.millerchevalier.com/professional/laura-deegan
Questions? Contact us at [email protected].
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. 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 wherever you get your podcasts for new episodes so you don't miss out!
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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 abroad by U.S. persons, the jurisdictional implications of importing of foreign made defense articles into the U.S., the growing compliance challenges of the deemed export rule, the recently revised Directorate of Defense Trade Controls (DDTC) compliance guidelines and risk matrices, the reorganization of the ITAR, the 10-year anniversary of export control reform (ECR), and the effect ECR has had on the Export Administration Regulations (EAR).
Roadmap:
IntroductionDefense services abroadSubject to the ITAR from coming into the U.S.Deemed export/SpaceXITAR Part 120 rewriteDDTC revised compliance program guidance/risk matrix10-year anniversary of ECRComplexity at the Bureau of Industry and Security (BIS)*******
Thanks to Scott Gearity for joining us: https://www.learnexportcompliance.com/people/scott-gearity/
Questions? Contact us at [email protected].
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. 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 wherever you get your podcasts for new bi-weekly episodes so you don't miss out!
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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 designation brought by Tornado Cash and the subject of cryptocurrency and Office of Foreign Assets Control (OFAC) designations generally.
Roadmap:
IntroductionTornado CashOFAC DesignationStorm and Semenov charged with conspiracy to commit sanctions violationsFinCEN proposes new regulation to enhance transparency in convertible virtual currency mixing and combat terrorist financingHamas virtual currency fundraising and sanctions*******
Thanks to Leah Moushey for joining us: https://www.millerchevalier.com/professional/leah-moushey
Questions? Contact us at [email protected].
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. 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 wherever you get your podcasts for new bi-weekly episodes so you don't miss out!
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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 Venezuela.
Roadmap:
The U.S. government suspended certain sanctions measures in three sectors of the Venezuelan economy: oil and gas, gold, and finance.
Oil and Gas Sector/GL 44Gold Sector/GL 43Financial Sector/GL 3I and GL 9H*******
Thanks to Laura Deegan for joining us: https://www.millerchevalier.com/professional/laura-deegan
Questions? Contact us at [email protected].
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. 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 wherever you get your podcasts for new bi-weekly episodes so you don't miss out!
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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 in the U.S. They'll focus on similarities and differences in U.S. and EU regimes.
Roadmap:
Before 2023 Russia sanctionsRussia sanctions in 2023 have been very differentUnprecedented coordinationKey differences between U.S. and EU Russia sanctionsIssuanceJurisdictionLicensingSeizure/expropriation of assetsRecourse for sanctioned partiesChallenges with divestment from RussiaExport controls*******
Thanks to our guests for joining us:
Dr. Laura Louca: https://www.blomstein.com/en/team.php?p=dr-laura-louca
Caroline Watson: https://www.millerchevalier.com/professional/caroline-j-watson
Questions? Contact us at [email protected].
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. 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 wherever you get your podcasts for new bi-weekly episodes so you don't miss out!
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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 of financial institutions in export controls and sanctions compliance.
Roadmap
First things first: the exact role of banks in sanctions complianceList-based sanctionsEmbargoed countries and internal policiesHumanitarian/non-sanctioned activities involving comprehensively sanctioned countriesEnforcementCircumvention and evasion*******
Thanks to Stéphanie Broekaart for joining us: https://www.linkedin.com/in/st%C3%A9phanie-broekaart-05a2a462/
Questions? Contact us at [email protected].
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. 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 wherever you get your podcasts for new bi-weekly episodes so you don't miss out!
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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 unique compliance challenges.
Roadmap:
50,000 foot primer on Canadian sanctions, including sanctions authority and enforcementSanctions against Russia since Feb. 2022 and how Canadian sanctions have evolvedComparison of ownership and control approaches in the U.S. and CanadaChallenge of ownership and control in the U.S., EU, and CanadaCanadian approach (traditional and new legislation)Compliance challenges*******
Thanks to our guests for joining us:
John Boscariol: https://www.mccarthy.ca/en/people/john-boscariol
Stacy Keen: https://www.pinsentmasons.com/people/stacy-keen
Questions? Contact us at [email protected].
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. 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 wherever you get your podcasts for new bi-weekly episodes so you don't miss out!
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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 compliance and legal communities, and the particulars of the latest sanctions on both sides of the Atlantic.
Roadmap:
Overview of Russia sanctions since February 2022 in the EU, U.K., and U.S.New EU and U.K. sanctionsU.S. sanctions/export controlsE.O. 14024: Authority to designate companies operating in Architecture, Engineering, Construction, Manufacturing, and TransportationE.O. 14071: Prohibition on architecture and engineering servicesOver 300 designations by OFAC/State, focusing on sanctions evasion, tech imports, and energy and extractive revenue, including Polyus (subject to wind-down GL)BIS Export ControlsFinCEN-BIS Joint Alert*******
Thanks to Dara Fernandez Perez for joining us: https://www.linkedin.com/in/dara-fernandez-perez-2ab9a912/
Questions? Contact us at [email protected].
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. 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 wherever you get your podcasts for new bi-weekly episodes so you don't miss out!
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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:
HistoryCommerce Department executive order under IEEPACFIUS (music.ly acquisition)Supply Chain Notice of Rulemaking and EO (under IEEPA)ProposalsProposed legislation that would undo result of litigation by amending IEEPAProposed legislation that would focus on data privacy concerns*******
Thanks to our guest, Art Dicker, for joining us: https://www.rplawyers.com/lawyer/art-dicker/
Questions? Contact us at [email protected].
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. 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 wherever you get your podcasts for new bi-weekly episodes so you don't miss out!
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