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EMBARGOED!: OFAC's Victory Day Present for Putin & Sanctions Are the New FCPA


Brian and Tim kick things off by briefly covering OFAC's issuance, on the eve of Victory Day, of two determinations aimed at disrupting Russia’s use of accounting, trust and corporate formation, and management consulting services. Next, they discuss recent public comments by the Deputy Attorney General proclaiming that, as a DOJ enforcement priority, sanctions are the new FCPA. We also check in on what China has been up to lately (with respect to Russia) and share a few thoughts on the recently issued Ukraine-/Russia-Related Sanctions Regulations. Finally, in the Lightning Round, they briefly cover the unsealing of indictments against Virgil Griffith's alleged co-conspirators and debate what it could mean that Nicaragua’s ruling family has reportedly reached out to the U.S. seeking sanctions relief.

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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, hosted by Miller & Chevalier. 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