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

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

From EMBARGOED! by Miller & Chevalier

April 1, 2026 · 42 min · Season 1 · Episode 97

About this episode

The episode discusses the State Department's role in sanctions, including coordination with OFAC and legal challenges to designations.

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…

People in this episode

Hosts: Tim O'Toole, Collmann Griffin, Melissa Burgess

Guests: Erik Woodhouse, Joshua Kretman

Topics covered

  • Sanctions
  • State Department
  • OFAC
  • Licensing
  • Enforcement
  • Legal Challenges

Keywords

  • Counter Threat Finance
  • Sanctions Attorney
  • Designation
  • Delisting

Mentioned in this episode

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