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 commodities, including NVIDIA H200 and AMD MI325X chips, to China and Macau, provided that certain requirements are met. Those requirements include, among other things, conducting independent lab testing in the United States of the advanced computing commodities prior to export. Notably, applications for reexports, exports from abroad, and transfers of these same commodities to or within China or Macau remain subject to a presumption of denial.

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

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 more than 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…

Eric Carlson has more than 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 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, 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…

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.

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Photo of Lisa Ann Johnson Lisa Ann Johnson

Lisa Ann Johnson is a senior associate in the International Trade Controls practice group. She regularly advises clients in a wide range of industries on the application of U.S. trade controls, including economic sanctions and export controls laws and regulations. She has experience…

Lisa Ann Johnson is a senior associate in the International Trade Controls practice group. She regularly advises clients in a wide range of industries on the application of U.S. trade controls, including economic sanctions and export controls laws and regulations. She has experience advising on day-to-day trade controls compliance, the development and improvement of compliance programs, and M&A-related risks, as well as supporting licensing and enforcement matters before the U.S. Departments of State, Commerce, and Treasury.

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Photo of Jack Haynie Jack Haynie

Jack Haynie is an associate in the firm’s Washington, DC office and a member of the firm’s International Trade Controls and Trade Policy Practice Groups. Jack advises clients on various international trade-related matters including the application of sanctions and export controls administered by…

Jack Haynie is an associate in the firm’s Washington, DC office and a member of the firm’s International Trade Controls and Trade Policy Practice Groups. Jack advises clients on various international trade-related matters including the application of sanctions and export controls administered by the U.S. Departments of the Treasury, Commerce, and State, as well as recent developments in U.S. trade policy and the enforcement of U.S. customs law and regulations.

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