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

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Thanks to our guest for joining us:

Joshua Kretman: https://www.dentons.com/en/joshua-kretman

Erik Woodhouse: https://www.crowell.com/en/professionals/erik-woodhouse

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

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