This week, host Tim O'Toole chats with Damien Spleeters (Conflict Armament Research) and return guest Collmann Griffin (Miller & Chevalier) about how bad actors use sophisticated evasion tactics to circumvent U.S. export controls and sanctions to obtain components America's adversaries need for missiles, drones, and other weapons systems.

Roadmap:

• Background on Conflict Armament Research (CAR), particularly CAR's work in Ukraine
• Western components that end up in Russian, Iranian, North Korean, and other weapons systems and how this overlaps with the BIS Common High Priority List (CHPL)
• A walkthrough of how an item makes its way from a U.S.-owned fabricator to a foreign weapons system
• Screening/due diligence steps recommended for manufacturers and distributors of high-priority items

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Thanks to our guests for joining us:

Damien Spleeters: https://www.linkedin.com/in/damienspleeters/

Collmann Griffin: https://www.millerchevalier.com/professional/collmann-griffin

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. 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!

On this episode of EMBARGOED!, host Tim O'Toole is joined by Matteson Ellis (Latin America Practice Lead at Miller & Chevalier) discuss all the sanctions news from Latin America, with a focus on recent developments in Mexico.

Roadmap:

• Introduction, Matt goes to Mexico
• Foreign Terrorist Organizations (FTOs) and LatAm
• Mexico, FTOs, and FinCEN orders
• What's happening on the ground
• The rest of LatAm
• Looking into the crystal ball

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Thanks to Matt Ellis for joining us: https://www.millerchevalier.com/professional/matteson-ellis

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. 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!

On this episode of EMBARGOED!, host Tim O'Toole, Miller & Chevalier Counsel Melissa Burgess and Collmann Griffin, and guest Chris Chamberlain of Morrison & Foerster continue their discussion of AI chip-related export controls, musing about Infrastructure-as-a-Service (IaaS) considerations, semiconductor manufacturing equipment (SME), and the much-anticipated BIS release of a 50 Percent Rule for the Entity List.

Roadmap:

• May 13, 2025, BIS Policy Statement on training AI models
• Controls on SME and balancing foreign policy, national security, and other reasons for control under the EAR
• Not reasons for control: Economic and other factors BIS does not consider determinative when assessing controls
• Pros and cons of BIS having an OFAC-style 50 Percent Rule for the Entity List

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Thanks to our guests for joining us:

Chris Chamberlain: https://www.mofo.com/people/chris-chamberlain

Melissa Burgess: https://www.millerchevalier.com/professional/melissa-burgess

Collmann Griffin: https://www.millerchevalier.com/professional/collmann-griffin

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. 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!