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EMBARGOED!: If Sanctions are the New FCPA, are Export Controls the New Sanctions?


On this episode of EMBARGOED!, host Tim O'Toole is joined by Miller & Chevalier Senior Associate Melissa Burgess to explore the evolving role played by export controls in U.S. sanctions policy and discuss a few recent developments.


  • "Sanctions are the New FCPA"
  • OFAC’s revised approach to sanctions: 2021 to the present
  • The role of BIS and export controls in response to Russia/Ukraine
  • Second anniversary designation announcements (February 23, 2024)
  • Recent subpoenas to maker of semiconductor manufacturing equipment
  • Commerce’s March 1, 2024, ICTS supply chain ANPRM on “Connected Vehicles”


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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. 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!