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 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.

Contact:Read more about Stephen RademakerEmail

In introducing the American Security Robotics Act of 2026, Senators Tom Cotton (R-AR) and Chuck Schumer (D-NY) have extended a now familiar congressional playbook into a new and consequential domain:  robotics.  The bill would prohibit executive agencies from procuring or operating unmanned ground vehicle systems (UGVs) manufactured or assembled by “covered foreign entities,” a term that targets companies tied to adversarial nations such as China.

The legislation also reflects early signs of bicameral alignment.  Representative Elise Stefanik (R-NY-21) has introduced companion legislation in the House, signaling that concerns regarding robotics systems manufactured by certain foreign entities are not confined to a single chamber or party.

At one level, the proposal is straightforward.  At another, it reflects a maturing legislative architecture that has evolved across successive National Defense Authorization Acts (NDAAs) and related statutes—an architecture that is increasingly product-specific, attentive to supply chain risk, and focused on issues of data access, operational control, and systemic vulnerability.

Continue Reading The Next Frontier of Supply Chain Security: Congress Trains Its Sights on Robotics

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

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 NDAA

The government is officially closed, and the House of Representatives is in an extended recess, but the Senate keeps working. 

On Wednesday October 22, the Senate Foreign Relations Committee held a business meeting to consider 19 bills and approve two nominations (Joel Rayburn to be Assistant Secretary of State for Near Eastern Affairs and Andrew Veprek to be Assistant Secretary of State for Population, Refugees and Migration).  The bills focused mostly on Russia’s war in Ukraine, and on security concerns relating to China, and generally commanded bipartisan support.  All of the bills were approved, though some were amended.

One of the more consequential bills was the “REPO Implementation Act”, S. 2918, sponsored by Sen. Whitehouse, and co-sponsored by, among others, Foreign Relations Committee Chairman Risch.  This bill seeks to build on last year’s “Rebuilding Economic Prosperity and Opportunity for Ukrainians Act”, or “REPO Act”.  That legislation granted authority to the President to confiscate the approximately $5 billion in immobilized Russian sovereign assets in the United States and provide that money to Ukraine and Ukrainian claimants as compensation for the injuries inflicted on them by the war. 

Continue Reading Senate Foreign Relations Committee Action on Russia and China-related Legislation

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 Package

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

Continue Reading U.S. Department of Commerce Expands End-User Controls to Cover Affiliates of Certain Listed Entities

On 29 September 2025, United Nations (“UN”) nuclear-related sanctions against Iran, which were suspended in 2015, were reimposed following action at the UN Security Council by France, Germany, and the United Kingdom. In parallel, the European Union (“EU”) and United Kingdom (“UK”) also reintroduced autonomous sanctions measures against Iran that…

Continue Reading Reimposition of UN-Mandated Sanctions Against Iran and Additional EU and UK Sanctions

On September 2, 2025, the U.S. Commerce Department, Bureau of Industry and Security (“BIS”) published in the Federal Register a final rule titled Relaxing Export Controls for Syria (the “Syria Export Controls Rule”). The rule eases certain export controls applicable to Syria under the Export Administration Regulations (“EAR”) by adding…

Continue Reading U.S. Commerce Department Eases Export Control Restrictions for Syria

On August 6, President Trump issued an Executive Order (“EO”) (“Addressing Threats to the United States by the Government of the Russian Federation”) invoking his authority under the International Emergency Economic Powers Act (“IEEPA”) to impose a tariff of 25% on most products imported from India, effective August 27, in…

Continue Reading Trump Administration Imposes Secondary Tariffs on India

On January 10, 2025, the U.S. Department of the Treasury and U.S. Department of State intensified sanctions against Russia with new measures targeting Russia’s energy sector. According to the Treasury Department’s press release, these measures are intended “to fulfill the G7 commitment to reduce Russian revenues from energy” and “substantially increase the sanctions risks associated with the Russian oil trade.”

The new U.S. sanctions include a determination by the U.S. Department of the Treasury authorizing the imposition of property-blocking sanctions against any person who is determined by the Treasury Secretary or Secretary of State (in consultation with one another) to operate or have operated in the Russian energy sector, and a determination issued by the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) prohibiting—effective February 27, 2025—the provision of “petroleum services” from the United States or by a U.S. person to any person located in Russia. In addition, OFAC and the U.S. Department of State collectively designated for property-blocking sanctions more than 400 individuals, entities, and vessels from various countries involved in Russia’s energy sector, including two of Russia’s most significant oil producers and exporters—Public Joint Stock Company Gazprom Neft (“Gazprom Neft”) and Surgutneftegas, along with more than two dozen of their subsidiaries. The designations included more than 180 vessels, many of which are part of Russia’s “shadow fleet” of vessels involved in the trade of Russian oil, as well as several Russian energy executives, oil traders, oilfield service providers, and financial and insurance entities associated with Russia’s energy sector. The designations also covered two active Russian liquefied natural gas (“LNG”) projects and a Russian oil project.

On January 15, 2025, the U.S. Department of the Treasury and U.S. Department of State designated or re-designated under additional sanctions authority nearly 250 individuals and entities for property-blocking sanctions, including actors based in China.

OFAC also issued multiple general licenses related to the above designations, including a general license authorizing until February 27, 2025, transactions ordinarily incident and necessary to the wind down of transactions involving Gazprom Neft and Surgutneftegas, their designated subsidiaries, and entities that they own 50 percent or more, directly or indirectly, individually or in the aggregate, subject to certain conditions. In addition, OFAC revoked a general license that had authorized transactions with certain vessels subject to U.S. property-blocking sanctions due to their ownership, and amended two existing general licenses. One of these amended general licenses, General License 8L (which supersedes General License 8K), significantly narrows the scope of permissible energy transactions involving certain blocked financial institutions to include only wind-down transactions until March 12, 2025.

Continue Reading New U.S. and UK Sanctions, Including Related to Russia’s Energy Sector