On September 29, 2025, the U.S. Commerce Department, Bureau of Industry and Security (“BIS”) issued an interim final rule titled Expansion of End-User Controls to Cover Affiliates of Certain Listed Entities (the “Affiliates Rule”). 

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 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 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 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 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 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 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 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 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 Caroline Garth Caroline Garth

Caroline Garth is an associate in the International Trade Practice Group who regularly advises clients on the application of international trade controls, including economic sanctions and export controls laws and regulations administered by the U.S. Departments of State, Commerce, and Treasury. Caroline has…

Caroline Garth is an associate in the International Trade Practice Group who regularly advises clients on the application of international trade controls, including economic sanctions and export controls laws and regulations administered by the U.S. Departments of State, Commerce, and Treasury. Caroline has experience assisting clients with internal investigations of potential trade controls violations and representing clients in engagements with the U.S. government, including voluntary self-disclosures and enforcement matters. She has also performed trade controls-related due diligence and prepared submissions for regulatory approvals in connection with M&A transactions.

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Photo of Shanelle Van Shanelle Van

Shanelle Van is an associate in the firm’s Washington, DC office. Her practice focuses on the intersection of export controls, sanctions, and white collar defense. She regularly advises clients on the application of international trade controls, including economic sanctions and export controls laws…

Shanelle Van is an associate in the firm’s Washington, DC office. Her practice focuses on the intersection of export controls, sanctions, and white collar defense. She regularly advises clients on the application of international trade controls, including economic sanctions and export controls laws and regulations administered by the U.S. Departments of State, Commerce, and Treasury.

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