On October 22, 2025, the U.S. government imposed property-blocking sanctions on Russia’s two largest oil companies, Open Joint Stock Company Rosneft Oil Company (“Rosneft”) and Lukoil OAO (“Lukoil”), by designating these entities, as well as 34 Russia-based Rosneft and Lukoil subsidiaries, to the List of Specially Designated Nationals and Blocked Persons (“SDN List”) maintained by the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”). These are the first Russia-related sanctions imposed by the current Trump Administration (other than the “secondary tariff” announced with respect to India in August 2025, which we covered in a prior alert), and mark a significant escalation in the Administration’s approach towards Russia sanctions.

Click here to read the full alert on cov.com.

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Photo of Peter Flanagan Peter Flanagan

Peter Flanagan counsels clients on a broad range of compliance requirements affecting international trade and investment. These include most notably export controls, economic sanctions constraints, defense trade limitations, and the implications of related non-U.S. requirements. He also has experience in financial services regulation. …

Peter Flanagan counsels clients on a broad range of compliance requirements affecting international trade and investment. These include most notably export controls, economic sanctions constraints, defense trade limitations, and the implications of related non-U.S. requirements. He also has experience in financial services regulation.

Peter has advised leading companies in the oil and gas sector, pharmaceutical and medical technology companies, defense contractors, manufacturing entities, financial institutions and private equity firms, software and high-technology concerns, and university-affiliated laboratories. Consistently ranked as a top-tier practitioner, Peter has deep experience in assisting multinational clients with complex compliance, enforcement, and licensing matters before the key U.S. trade controls agencies, including the U.S. Departments of Treasury, Commerce, and State.

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Photo of Kimberly Strosnider Kimberly Strosnider

Co-chair of the firm’s International Trade Controls Practice Group, Kim Strosnider has more than 20 years’ experience advising companies on the application of international trade controls, including export controls, economic sanctions, and antiboycott laws and regulations.

Kim counsels clients across a range of…

Co-chair of the firm’s International Trade Controls Practice Group, Kim Strosnider has more than 20 years’ experience advising companies on the application of international trade controls, including export controls, economic sanctions, and antiboycott laws and regulations.

Kim counsels clients across a range of industries on trade controls matters, including resolving complex compliance, enforcement, licensing, and jurisdiction/classification issues. She regularly advocates for clients before the key trade controls agencies, including the U.S. Departments of State, Commerce, and Treasury.

Kim has led numerous internal investigations for clients on trade controls matters and has helped companies design and implement compliance programs. She also frequently advises on trade control issues in mergers, acquisitions, and divestitures.

Among the areas in which Kim counsels clients are compliance with the International Traffic in Arms Regulations (ITAR), Export Administration Regulations (EAR), economic sanctions programs administered by the Treasury Department’s Office of Foreign Assets Control (OFAC), and antiboycott programs administered by the Commerce and Treasury Departments. She has particular experience in advising on the complex and changing U.S. trade controls applicable to China and Russia.

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Photo of David Lorello David Lorello

David Lorello is a partner in the firm’s London office and serves as a vice chair of the firm’s International Trade Controls Practice Group. David advises clients concerning a range of international regulatory, white collar, and commercial matters under both European and U.S.

David Lorello is a partner in the firm’s London office and serves as a vice chair of the firm’s International Trade Controls Practice Group. David advises clients concerning a range of international regulatory, white collar, and commercial matters under both European and U.S. laws. 

David is recognized in the leading peer review publications for his work on trade controls and anti-corruption compliance and investigations matters, with Chambers Global describing David as a “compliance authority” in those areas. He appeared as an expert commentator at the UK Parliament’s Select Committee’s inquiry into UK Arms Exports. David, alongside other experts, spoke about the potential impact of the UK’s withdrawal from the EU on strategic export controls and sanctions policies.

Anti-Corruption Compliance and Investigations

David regularly assists clients in investigating anti-corruption compliance issues arising under the U.S. Foreign Corrupt Practices Act (FCPA), the UK Bribery Act and other related U.S., UK, and European anti-bribery and anti-money laundering laws. David has particular experience in managing corporate investigations and developing anti-corruption compliance programs for companies operating in Europe, including coordinating advice concerning parallel risks under U.S. and European anti-corruption laws, advising clients concerning European criminal enforcement and debarment risks, and ensuring compliance with European data protection and workplace laws in the course of investigations and compliance matters.

David also regularly represents clients before the World Bank, and other international financial institutions, in debarment proceedings concerning allegations of corrupt practices in connection with contracts financed by those institutions. In addition, David advises clients concerning the commercial liability risks arising from corrupt practices, including private rights of action that may arise for parties that suffer losses as a result of corrupt practices.

Export Controls and Economic Sanctions

David regularly represents clients before the major agencies responsible for export controls and economic sanctions laws and regulations, both in the United States and European Union. He has assisted clients in export and sanctions licensing and compliance issues with regard to a variety of industries and products, including encryption and other computer technologies, satellites, oil and gas products, military items, and other goods and technology controlled for export due to national security reasons. David has extensive experience assisting clients in developing effective export compliance strategies, including preparing export license requests, voluntary self-disclosures and intra-company agreements as well as policies necessary to ensure export controls and economic sanctions compliance.

David has particular experience in assisting clients in economic sanctions matters relating to the financial services industry. He has represented financial services clients in various matters before U.S. and EU Member State regulators, and he has worked with financial services clients in developing tailored internal controls focused on economic sanctions compliance.

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Photo of Stephen Bartenstein Stephen Bartenstein

Steve Bartenstein advises companies on the application of international trade controls, including export controls, sanctions, and antiboycott laws and regulations.

In his international trade controls practice, Steve counsels clients on U.S. exports controls regulations administered by the Commerce Department and State Department; economic…

Steve Bartenstein advises companies on the application of international trade controls, including export controls, sanctions, and antiboycott laws and regulations.

In his international trade controls practice, Steve counsels clients on U.S. exports controls regulations administered by the Commerce Department and State Department; economic sanctions programs administered by the Treasury Department; and compliance with U.S. antiboycott laws and regulations. He has particular experience helping companies navigate complex compliance and licensing matters relating to software, technology, and advanced computing export controls, as well as the defense trade controls in the International Traffic in Arms Regulations (ITAR). Steve also regularly advises on trade controls enforcement matters, and has helped international companies of all sizes develop or enhance their internal trade controls compliance programs and perform related risk assessments.

Steve has counseled leading U.S. and non-U.S. companies in the technology, pharmaceutical, medical device, defense and aerospace, and energy sectors, among others.

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Photo of Eric Carlson Eric Carlson

Eric Carlson has nearly two decades of experience advising clients operating in China and other jurisdictions in Asia on compliance and investigations matters, particularly in the areas of export controls/sanctions and fraud/corruption/FCPA.

Having lived in China for more than a decade, Eric has…

Eric Carlson has nearly two decades of experience advising clients operating in China and other jurisdictions in Asia on compliance and investigations matters, particularly in the areas of export controls/sanctions and fraud/corruption/FCPA.

Having lived in China for more than a decade, Eric has deep experience leading highly sensitive investigations in China and other jurisdictions in Asia, including investigations presenting complex legal, political, and reputational risks in the areas of export controls/sanctions, anti-corruption/FCPA, fraud, and accounting irregularities. He has assisted numerous clients in responding to subpoenas and inquiries from government agencies in the United States, China, and other jurisdictions, and navigating cross-border data transfer restrictions during internal and government investigations. Eric speaks Mandarin and Cantonese and has led more than four hundred witness interviews in Chinese in 24 provinces in China, and conducted dozens of trainings in Chinese. He is a Certified Fraud Examiner.

Eric also counsels clients on the compliance risks of proposed transactions, conducts compliance due diligence as part of mergers, acquisitions, and joint ventures, assists companies in updating and strengthening their internal compliance programs and tailoring them to the unique features of Asian markets, and developing and presenting tailored compliance training in Chinese and English. Eric has advised scores of companies and organizations representing nearly every major industry.

Eric is a regular speaker and author on China-related export controls/sanctions and anti-corruption/fraud issues. He has been quoted in publications such as 

The Wall Street Journal

, 

The Economist, The Financial Times, Global Investigations Review, Compliance Week, FCPA Report, The Corporate Treasurer, Commercial Dispute Resolution, China Business Law Journal, 

and 

Economy and Nation Weekly

and

was a contributing editor to the

 FCPA Blog.

 

Chambers notes that Eric has “much more than just a conversational grasp of the language, but the ability to conduct interviews on specific subject matter details and get to the root of the issues.” Chambers further notes that “his language skills are very impressive” and that he provides “great advice that is grounded in reality,” adding: “They know the industry and their advice is very risk-based and balanced.” One client noted to Chambers: “They have strong regional coverage both in terms of footprint as well as language skills. If I have a compliance investigation in region with a tight timeframe, I know they can get it done. They take a more realistic approach to scoping investigations.” Other clients noted to Chambers that Eric is “really brilliant” and “an expert in this field.” According to one client surveyed by Chambers, “he is particularly adept at ‘right sizing’ the scope of an investigation to get at the key issues without incurring unnecessary operational or financial burden. He is also incredibly responsive to client communications.”

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Photo of Peter Lichtenbaum Peter Lichtenbaum

Peter Lichtenbaum advises clients on a broad array of international regulatory compliance and trade matters, including export controls, economic sanctions, national security reviews of foreign investments, anti-corruption laws, market access, and international trade disputes. He has specialized experience in the aerospace and defense…

Peter Lichtenbaum advises clients on a broad array of international regulatory compliance and trade matters, including export controls, economic sanctions, national security reviews of foreign investments, anti-corruption laws, market access, and international trade disputes. He has specialized experience in the aerospace and defense industries.

Peter is ranked in Band 1 for Export Controls & Sanctions in Chambers USA (2019), which reports that he is “one of those rare lawyers who thinks through all the options moving forward.” Chambers describes him as a “go-to lawyer for those with export controls and sanctions issues.”

Peter has recently helped several companies establish, review or enhance their compliance programs. He is advising major technology companies regarding the impact of recent and ongoing export control developments on their businesses. He has worked with many leading aerospace and defense companies on internal investigations and disclosures related to trade controls and China. He also advises many of these companies on export control reform and defense trade policy issues, including international agreements on the regulation of defense trade. He has extensive experience with the trade controls issues that arise in the U.S. system for national security review of foreign investment, helping companies to identify issues and mitigate government concerns.

Peter served as Vice President for Regulatory Compliance and International Policy at BAE Systems, Inc., the U.S. subsidiary of one of the world’s largest defense contractors. He was responsible for a broad array of regulatory compliance and policy issues. He participated in BAE Systems’ development of innovative standards of internal governance in order for the company to be recognized as a global leader in ethical business conduct.

Previously, Peter held senior positions in the Department of Commerce, one of three key agencies responsible for administering U.S. trade controls. From October 2003 through February 2006, he served as the Assistant Secretary of Commerce for Export Administration, responsible for developing BIS policies regarding export controls imposed for national security, foreign policy, nonproliferation, and other reasons. Peter chaired the inter-agency Advisory Committee on Export Policy, and managed BIS’s participation in multilateral export control regimes. He represented the Department of Commerce in many sensitive matters reviewed by the Committee on Foreign Investment in the United States (CFIUS). Peter served for several months as Acting Under Secretary of Commerce for Industry and Security and as Acting Deputy Under Secretary of Commerce for International Trade.

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Photo of Eric Sandberg-Zakian Eric Sandberg-Zakian

Eric Sandberg-Zakian is the chair of Covington’s Trade Controls Enforcement Practice Group. He represents clients in criminal cases, civil enforcement actions, and internal investigations involving sanctions, export controls, and other national security laws.

Eric has represented leading global companies in some of the…

Eric Sandberg-Zakian is the chair of Covington’s Trade Controls Enforcement Practice Group. He represents clients in criminal cases, civil enforcement actions, and internal investigations involving sanctions, export controls, and other national security laws.

Eric has represented leading global companies in some of the country’s most high-profile and complex trade controls cases in recent history. He specializes in defending clients in parallel investigations by multiple agencies, and has handled matters involving the Treasury, Commerce, State, Defense, and Homeland Security Departments, the Securities and Exchange Commission, the Special Inspector General for Afghanistan Reconstruction, the Department of Justice’s National Security and Criminal Divisions, and U.S. Attorney’s Offices across the country.

Eric also has extensive experience making voluntary disclosures to civil trade controls regulators in matters that could give rise to criminal prosecution, and he routinely helps companies enhance their compliance programs, conduct risk assessments, and navigate forward-looking compliance challenges, especially in the fields of economic sanctions and export controls. Eric has worked with clients in the aerospace, defense, technology, oil and gas, pharmaceutical, manufacturing, semiconductor, not-for-profit, consulting, travel, and financial sectors.

Eric maintains an active pro bono practice, and has helped pro bono clients with matters before the Department of Veterans Affairs, Congress, the Supreme Court, and federal appellate and district courts. Most notably, he served as lead counsel in a high-profile wrongful conviction case, overturning a double-murder conviction and freeing an innocent man who was serving a life sentence in Kentucky state prison.

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Photo of Joshua Williams Joshua Williams

Josh Williams helps clients assess and manage the impact of U.S. economic sanctions and export controls on their global operations. He has deep expertise in the economic sanctions laws and regulations administered and enforced by the U.S. Treasury Department and State Department, and…

Josh Williams helps clients assess and manage the impact of U.S. economic sanctions and export controls on their global operations. He has deep expertise in the economic sanctions laws and regulations administered and enforced by the U.S. Treasury Department and State Department, and in the export control laws and regulations administered and enforced by the U.S. Commerce Department, State Department, and Census Bureau.

Josh advises leading U.S. and non-U.S. companies across a range of industries, including companies operating in the energy, financial services, pharmaceutical, technology, aerospace and defense, telecommunications, consulting, and consumer products sectors.

Josh regularly assists clients with complex trade controls compliance, enforcement, licensing, and transactional matters. He also has significant experience leading trade controls risk assessments and counseling companies seeking to develop or strengthen their compliance programs.

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Photo of Corinne Goldstein Corinne Goldstein

Corinne Goldstein has decades of experience advising clients on the application to their worldwide operations of U.S. economic sanctions, export controls, and antiboycott programs.

She has particular expertise advising on the primary and secondary sanctions programs administered by the U.S. Treasury Department’s Office…

Corinne Goldstein has decades of experience advising clients on the application to their worldwide operations of U.S. economic sanctions, export controls, and antiboycott programs.

She has particular expertise advising on the primary and secondary sanctions programs administered by the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC). Her clients include leading U.S. and non-U.S. companies in the oil and gas, financial services, pharmaceutical, general manufacturing, and other sectors that must navigate these sanctions regimes in their day-to-day businesses. Because of her deep expertise, Corinne is able to provide thoughtful and practical advice to difficult questions these industries face.

In her work with multinational companies, Corinne regularly:

Advises clients on novel and complex interpretive issues relating to the application of new and existing U.S. sanctions regimes,
Prepares corporate trade controls policies and procedures,
Develops trade controls compliance and training programs,
Secures U.S. government licenses,
Conducts internal investigations of potential violations of applicable regulations, and
Represents clients in enforcement proceedings.

Corinne has been consistently ranked by Chambers Global and Chambers USA, as well as Legal 500, as a knowledgeable leader in the fields of economic sanctions and export controls who is “responsive,” “has her fingers on the pulse of the government,” and provides extremely practical advice in these areas. The BTI Consulting Group also named Corinne to its 2020 “Client Service All-Stars” list, which recognizes “attorneys who stand above all the others in delivering the absolute best in client service.”

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Photo of Stephen Rademaker Stephen Rademaker

With wide-ranging experience working on national security issues in the White House, the State Department, and the U.S. Senate and House of Representatives, Stephen Rademaker helps clients navigate international policy, sanctions, and CFIUS challenges.

Among his accomplishments in public service, Stephen had lead…

With wide-ranging experience working on national security issues in the White House, the State Department, and the U.S. Senate and House of Representatives, Stephen Rademaker helps clients navigate international policy, sanctions, and CFIUS challenges.

Among his accomplishments in public service, Stephen had lead responsibility, as a U.S. House staffer, for drafting the legislation that created the U.S. Department of Homeland Security. Serving as an Assistant Secretary of State from 2002 through 2006, he headed at various times three bureaus of the State Department, including the Bureau of Arms Control and the Bureau of International Security and Nonproliferation. He directed the Proliferation Security Initiative, as well as nonproliferation policy toward Iran and North Korea, and led strategic dialogues with Russia, China, India, and Pakistan. He also headed U.S. delegations to numerous international conferences, including the 2005 Review Conference of the Parties to the Treaty on the Nonproliferation of Nuclear Weapons.

Stephen concluded his government career on Capitol Hill in 2007, serving as Senior Counsel and Policy Director for National Security Affairs for then-Senate Majority Leader Bill Frist (R-TN). In this role, he helped manage all aspects of the legislative process relating to foreign policy, defense, intelligence and national security. He earlier served as Chief Counsel for the House Select Committee on Homeland Security of the U.S. House of Representatives and as Deputy Staff Director and Chief Counsel of the House Committee on International Relations.

During President George H. W. Bush’s administration, Stephen served as General Counsel of the Peace Corps, Associate Counsel to the President in the Office of White House Counsel, and as Deputy Legal Adviser to the National Security Council. After leaving government in 2007, he continued to serve as the U.S. representative on the United Nations Secretary-General’s Advisory Board on Disarmament Matters, and he was subsequently appointed by House Republican Leader John Boehner (R-OH) to the U.S. Commission on the Prevention of Weapons of Mass Destruction Proliferation and Terrorism.

In addition to his practice at Covington, Stephen is an adjunct assistant professor at Georgetown University, where he teaches a course on Sanctions in U.S. Foreign Policy in the Security Studies Program of the School of Foreign Service.

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Photo of Adam Szubin Adam Szubin

Adam Szubin leverages his extensive experience in U.S. government and private practice to advise leading global companies and financial institutions facing an increasingly dynamic and uncertain national security regulatory landscape.

Adam previously led the U.S. Department of the Treasury’s Office of Terrorism and…

Adam Szubin leverages his extensive experience in U.S. government and private practice to advise leading global companies and financial institutions facing an increasingly dynamic and uncertain national security regulatory landscape.

Adam previously led the U.S. Department of the Treasury’s Office of Terrorism and Financial Intelligence and served for nearly a decade as the Director of Treasury’s Office of Foreign Assets Control (OFAC). His practice focuses on advisory and enforcement matters involving U.S. national security, with a particular emphasis on economic sanctions, export controls, money laundering, and investment security matters.

Adam’s distinguished 13 year tenure at the U.S. Department of the Treasury spanned the presidential administrations of George W. Bush, Barack Obama, and Donald Trump. As the Acting Under Secretary for Terrorism and Financial Intelligence, Adam led the Treasury Department’s policy, enforcement, regulatory, and intelligence functions aimed at combating foreign adversaries, international terrorist organizations, proliferators of weapons of mass destruction, narcotics traffickers, and others posing threats to U.S. national security and economic interests.

He also advised the Treasury Secretary and National Security Council on a wide range of economic and national security issues, including matters before the Committee on Foreign Investment in the United States (CFIUS). As OFAC Director, he led the Treasury Department’s administration and enforcement of U.S. economic and trade sanctions.

Earlier in his career, Adam served in the Department of Justice (DOJ) as Counsel to the Deputy Attorney General and worked as a trial attorney in DOJ’s Civil Division.

In addition to his work in private practice, Adam is a professor of practice at Johns Hopkins University’s School of Advanced International Studies.

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Photo of Alan Estevez Alan Estevez

Alan Estevez draws on 30+ years of service in senior roles in the U.S. Departments of Commerce and Defense to provide strategic advice to clients on cross-border investment and national security matters, including reviews conducted by the Committee on Foreign Investment in the…

Alan Estevez draws on 30+ years of service in senior roles in the U.S. Departments of Commerce and Defense to provide strategic advice to clients on cross-border investment and national security matters, including reviews conducted by the Committee on Foreign Investment in the United States (CFIUS), and international trade controls.

A non-lawyer, Alan joined the firm after serving as Under Secretary of Commerce for Industry and Security. In that role, he led the Bureau of Industry and Security (BIS) and oversaw U.S. government efforts to protect U.S. and allied technology from being acquired and used against the national security and foreign policy of the United States.

Prior to his role at the U.S. Department of Commerce, Alan was a national security strategy and logistics executive at Deloitte where he led acquisition, contracting, and logistics support for multiple complex operations and worked with a range of clients to help innovate and transform their own capabilities.

Previously, Alan held a number of senior roles at the U.S. Department of Defense (DoD) during a distinguished 36-year career, including as Principal Deputy Under Secretary of Defense for Acquisition, Technology & Logistics. In that role, he oversaw more than 40,000 people, a $20 billion budget, and an annual equipment and services contract spend of $300 billion. Alan also served as DoD’s representative to CFIUS.

Earlier in his tenure at DoD, Alan was the first career federal official ever to hold the Senate confirmed position of Assistant Secretary of Defense for Logistics and Materiel Readiness. In that role, he provided world-class military logistics support to the men and women of the United States Armed Forces and managed a budget of over $170 billion in logistics operations. Alan also previously served as the Principal Deputy Assistant Secretary of Defense for Logistics and Material Readiness.

Alan has been repeatedly honored throughout his career, earning, among numerous other plaudits, three DoD Distinguished Public Service Medals, two Presidential Rank Awards (Meritorious and Distinguished Executive), and the National Security Service to America Medal. Alan was presented with the National Defense Industrial Association Logistician Emeritus Award and the National Defense Transportation Association Distinguished Government Service Award.

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Photo of Seth Atkisson Seth Atkisson

Seth Atkisson advises clients on all aspects of U.S. trade controls, including economic sanctions and dual-use and defense export controls, as well as business transactions before the Committee on Foreign Investment in the United States (CFIUS).

Seth represents clients before a number of…

Seth Atkisson advises clients on all aspects of U.S. trade controls, including economic sanctions and dual-use and defense export controls, as well as business transactions before the Committee on Foreign Investment in the United States (CFIUS).

Seth represents clients before a number of U.S. governmental bodies, including the Department of Justice, the Treasury Department’s Office of Foreign Assets Control (OFAC), the Commerce Department’s Bureau of Industry and Security (BIS), and the Department of State’s Directorate of Defense Trade Controls (DDTC).

In addition to his work before the government, Seth advises clients on the design and implementation of trade controls compliance programs and has performed trade controls-related due diligence in connection with many mergers, acquisitions, and capital markets transactions.

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Photo of Blake Hulnick Blake Hulnick

Blake Hulnick focuses his practice on advisory and enforcement matters involving U.S. national security, including economic sanctions and export controls administered by the Departments of Treasury, Commerce, and State, and the outbound investment security regime administered by the Treasury Department.

Blake rejoined the…

Blake Hulnick focuses his practice on advisory and enforcement matters involving U.S. national security, including economic sanctions and export controls administered by the Departments of Treasury, Commerce, and State, and the outbound investment security regime administered by the Treasury Department.

Blake rejoined the firm after serving in the Department of the Treasury, where he was an Attorney-Advisor in the Office of Chief Counsel for Foreign Assets Control (OFAC) and a Senior Advisor to the General Counsel. In the Office of Chief Counsel, Blake advised OFAC on all legal issues relating to the administration of U.S. economic sanctions. Most recently, he was counsel to the Iran and Russia sanctions programs, in addition to advising on other programs and cross-programmatic matters. He supported the full range of OFAC activities, including enforcement, targeting/designations, removal petitions, licensing, regulations, and the NSC policy process, and coordinated closely with the Department of Justice on litigation matters, including numerous litigated challenges to sanctions designations.

Blake also served as Senior Advisor to Treasury’s General Counsel on national security matters including all OFAC, Financial Crimes Enforcement Network (FinCEN), and Committee on Foreign Investment in the United States (CFIUS) matters. In this role, he advised Treasury’s General Counsel and other top agency officials on novel sanctions matters involving Russia, anti-money-laundering rulemaking, congressional oversight of Treasury’s national security functions, cross-agency enforcement matters, and the creation of the first outbound investment regulations and program. He was given the Meritorious Service Award by Secretary Janet Yellen for his work in this capacity.

At Covington, Blake leverages his experience in government and private practice to help clients navigate the U.S. sanctions and export controls landscape. He advises a wide range of U.S. and non-U.S. companies on U.S. sanctions administered by OFAC . He also advises clients on the export controls administered by the State Department’s Directorate of Defense Trade Controls and the Commerce Department’s Bureau of Industry and Security, and the outbound investment security program administered by the Department of the Treasury. In each of these areas, Blake’s work ranges from providing guidance, assessing newly announced rules, seeking advisory opinions or licenses, and conducting corporate due diligence to assisting clients with voluntary disclosures and enforcement matters.

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Photo of Emanuel Ghebregergis Emanuel Ghebregergis

Emanuel Ghebregergis advises clients on international trade controls, white collar, and Business and Human Rights (BHR) matters under both European and German laws. His trade controls practice has included advising clients in a wide variety of industries on UN, EU and German sanctions…

Emanuel Ghebregergis advises clients on international trade controls, white collar, and Business and Human Rights (BHR) matters under both European and German laws. His trade controls practice has included advising clients in a wide variety of industries on UN, EU and German sanctions and export controls matters. Emanuel has also advised clients on a range of compliance issues and has also been involved in the review and assessment of trade controls compliance programs.

Emanuel’s BHR practice focuses on advising organizations across industry sectors on national and international standards for human rights and environmental due diligence in their supply chains. He has particular expertise advising clients on the new German Human Rights and Environmental Supply Chain Due Diligence Law.

Prior to joining Covington, Emanuel worked for the United Nations Office for Coordination of Humanitarian Affairs, where he dealt with human rights law as well as humanitarian law questions in response to complex emergencies.

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Photo of Edwin Djabatey Edwin Djabatey

Edwin Djabatey is an associate in the London office. He advises on regulatory and compliance issues within, and at the intersection of, the firm’s financial services, technology, media, trade controls and white collar practices.

Reflecting an increasing trend in regulators looking beyond industry…

Edwin Djabatey is an associate in the London office. He advises on regulatory and compliance issues within, and at the intersection of, the firm’s financial services, technology, media, trade controls and white collar practices.

Reflecting an increasing trend in regulators looking beyond industry remits, Edwin acts on multi-disciplinary and cross-sectoral regulatory compliance matters. For example, he has advised global technology companies on operational resilience requirements imposed by financial services regulators.

Edwin has assisted clients on compliance matters and internal investigations – for instance, in the white collar context, concerning issues such as bribery, corruption, anti-money laundering, and fraud, and in the financial services context, concerning culture, conduct, and whistleblowing. He provides clients in the pharmaceutical, technology and energy industries with UK and EU sanctions and export controls advice. He also has experience advising clients in the technology and media industries on regulatory matters.

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Photo of Mark Clifford Mark Clifford

Mark Clifford helps clients navigate their most complex and sensitive U.S. sanctions and export controls compliance and enforcement matters. He regularly represents clients before the key U.S. trade controls regulators, including the U.S. Departments of State, Treasury, Commerce, and the U.S. Census Bureau.…

Mark Clifford helps clients navigate their most complex and sensitive U.S. sanctions and export controls compliance and enforcement matters. He regularly represents clients before the key U.S. trade controls regulators, including the U.S. Departments of State, Treasury, Commerce, and the U.S. Census Bureau.

Mark provides strategic counsel to U.S. and non-U.S. companies in the energy, aerospace and defense, life sciences, financial services, telecommunications, technology, and consumer goods sectors, among others. He has extensive experience managing internal and external risk assessments, guiding clients in establishing or enhancing their trade controls compliance programs, advising on transactional due diligence, and obtaining sanctions and export control licenses from U.S. regulators.

Mark also leverages his skills as a former litigator to effectively represent clients in voluntary disclosures and enforcement actions involving alleged civil and/or criminal violations of economic sanctions and export control laws and regulations. He has helped clients successfully resolve enforcement matters before every major U.S. trade controls enforcement agency and the U.S. Department of Justice.

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