On January 13, 2026, the U.S. Commerce Department, Bureau of Industry and Security (“BIS”) issued a final rule, titled Revision to License Review Policy for Advanced Computing Commodities (the “BIS Rule”), that implements a more favorable license application review policy for exports from the United States of certain advanced computing
Continue Reading U.S. Commerce Department Revises License Review Policy for Exports of Certain Advanced Computing Commodities to China and Macau
Blake Hulnick
Blake Hulnick focuses his practice on advisory and enforcement matters involving U.S. national security, with a particular focus on U.S. economic sanctions and export controls.
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. Among other assignments, he served as counsel to OFAC’s Iran and Russia sanctions programs, supporting the full range of OFAC activities, including enforcement, targeting, delisting, licensing, and the policy development process.
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. He advised Treasury’s General Counsel and other top agency officials on novel sanctions matters involving Russia/Ukraine, anti-money-laundering rulemaking and enforcement, congressional oversight of Treasury’s national security functions, cross-agency enforcement matters, and the creation of the first outbound investment security regulations. He was given the Meritorious Service Award by Secretary Janet Yellen for his work in this capacity.
At Covington, Blake leverages his experience in private practice and all three branches of the federal government to help clients navigate the intersection of U.S. national security law and international trade. His advisory and enforcement practices encompass economic sanctions, defense and dual-use export controls, and the outbound investment security program.
New Sanctions Authorities in the FY 2026 NDAA
After passing the House the preceding week, the National Defense Authorization Act for Fiscal Year 2026 (FY 2026 NDAA) passed the Senate on December 17 by a vote of 77-20 and was signed into law by President Trump the following day. As is frequently the case, this annual “must pass”…
Continue Reading New Sanctions Authorities in the FY 2026 NDAAU.S. and UK Sanctions Target Russia’s Two Largest Oil Companies; EU Issues Significant New Russia and Belarus Sanctions Package
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…
Continue Reading U.S. and UK Sanctions Target Russia’s Two Largest Oil Companies; EU Issues Significant New Russia and Belarus Sanctions PackagePresident Trump Issues Executive Order Prohibiting Transactions Involving Publicly Traded Securities of “Communist Chinese Military Companies”
On Thursday, November 12, 2020, President Trump signed an Executive Order (the “Order”) that, beginning on January 11, 2021, will prohibit U.S. persons from transacting in the publicly traded securities of 31 companies that the Department of Defense has identified as “Communist Chinese military companies.” The requirement for the Department…
Continue Reading President Trump Issues Executive Order Prohibiting Transactions Involving Publicly Traded Securities of “Communist Chinese Military Companies”