Skip to main content

EMBARGOED!: Hitting Reset on E.O. 13959


Brian and Tim kick things off by analyzing the complete do-over called by the Biden administration with respect to E.O. 13959 and contemplate what that means for the future of U.S. person restrictions relating to investments in publicly traded securities of Chinese Military-Industrial Complex Companies. Next, we consider the possible sanctions implications of the new White House directive targeting corruption and check in on the future of the Burma sanctions program in light of the deepening crisis. Finally, in the Lightning Round, we decipher the latest news on JCPOA 2.0, discuss the possible repercussions of Hamas touting its digital currency fundraising efforts, and evaluate recent criticism of the glacial pace of ECRA implementation.

Questions? Contact us at

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: Apple Podcasts | Spotify | Amazon Music | Google Podcasts | Stitcher | YouTube