Sanctions and the State Department – Part 2 EMBARGOED! Episode 96

In this episode, host Tim O'Toole is again joined by colleagues Collmann Griffin and Melissa Burgess (Miller & Chevalier) and special guests Erik Woodhouse (former Deputy Assistant Secretary for Counter Threat Finance and Sanctions in the Bureau of Economic and Business Affairs (EB) at the Department of State) and Joshua Kretman (former Deputy Assistant Secretary (Acting) in EB, who also spent several years as the lead sanctions attorney in the Office of the Legal Adviser at State). In part 2 of their discussion of State's role in sanctions, Erik and Josh address an unanswered question from part 1, then explain the coordination and separation between State and OFAC in licensing and enforcement. The discussion also covers a recent case addressing State’s power to designate and delist, as well as State's role when one of its decisions is challenged in court. Roadmap: Separation between OFAC and State in enforcement State’s general role in sanctions license adjudication Sanctions enforcement versus sanctions implementation Challenging State designations, and the inherent power to delist ******* Thanks to our guest for joining us: Joshua Kretman: Erik Woodhouse: Melissa Burgess: 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.

You can listen to Sanctions and the State Department – Part 2 EMBARGOED! Episode 96 online on Radio and Podcast. Open the player on this page to stream the available audio.

Sanctions and the State Department – Part 2 EMBARGOED! Episode 96 is an episode from EMBARGOED! by Miller & Chevalier.

This episode is 42:15 long.

This episode was published on Apr 1, 2026.

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