In issuing the Affiliates Rule with immediate effect, the U.S. Department of Commerce Bureau of Industry and Security (BIS) drastically expanded the number of entities subject to the BIS’ most restrictive export tools by applying the same trade prohibitions to any entities that are owned, directly or indirectly, 50 percent or more by one or more entities listed on BIS’ Entity List, Military End-User (MEU) List, or certain SDN entities.

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Tags: BIS, Export controls
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Photo of Scott Wise Scott Wise

Scott Wise is a partner in Crowell’s Denver office and a member of the firm’s International Trade Group. His practice focuses on export controls, economic sanctions, and outbound investment issues across industries, with an emphasis on emerging technologies and the technology industry.

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Scott Wise is a partner in Crowell’s Denver office and a member of the firm’s International Trade Group. His practice focuses on export controls, economic sanctions, and outbound investment issues across industries, with an emphasis on emerging technologies and the technology industry.

Working with established and start-up tech companies, Scott helps clients to develop unique compliance programs that are responsive to the full range of regulations governing the exports of goods and services. He also trains and counsels clients on compliance with relevant export control regulations such as the International Traffic in Arms Regulations (ITAR) and the Export Administration Regulations (EAR). In addition to technology companies, Scott advises companies in the aerospace and aviation, automotive, chemical, defense, electronics, energy, engineering, financial and insurance, manufacturing, professional services, security, and transportation industries, among others.

Prior to joining Crowell, Scott was the Assistant General Counsel for Global Trade at a multinational technology company where he led a consolidated team focusing on export controls, economic sanctions, and outbound investment. He was the lead export controls and economic sanctions attorney for key business groups ranging from emerging technologies, such as artificial intelligence and quantum computing, to aerospace and defense contracts, and to commercial software and gaming. In that role, Scott developed the company’s compliance approach to new regulations governing the export of various  new technologies, including AI, integrated circuits and chips, and quantum computing, which involved coordination between senior government officials and business leaders. Scott also has prior law firm experience in the international trade practice area.

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Photo of Jeremy Iloulian Jeremy Iloulian

Recognized as a “Rising Star” in International Trade by Super Lawyers, Jeremy Iloulian advises clients globally on complex cross-border regulatory, compliance, investigative, and transactional matters and policy developments that touch U.S. national security, international trade, and foreign investment, including those relating to

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Recognized as a “Rising Star” in International Trade by Super Lawyers, Jeremy Iloulian advises clients globally on complex cross-border regulatory, compliance, investigative, and transactional matters and policy developments that touch U.S. national security, international trade, and foreign investment, including those relating to U.S. export controls (EAR and ITAR), economic sanctions, anti-boycott laws, the Committee on Foreign Investment in the United States (CFIUS), and various national security controls on fundamental research and supply chains.

Jeremy has extensive experience counseling U.S. and non-U.S. clients, including public and private companies, private equity sponsors, and nonprofits spanning a multitude of industries, including aerospace and defense, energy, entertainment, fashion, food and beverage, health care, infrastructure, technology, telecommunications, and transportation. He provides strategic guidance on managing risks for dealings in high-risk jurisdictions such as China, Russia, Venezuela, and the Middle East, among other countries and regions. He regularly advocates on behalf of such clients before the U.S. Bureau of Industry and Security (BIS), Directorate of Defense Trade Controls (DDTC), Office of Foreign Assets Control (OFAC), Bureau of Economic Affairs (BEA), Census Bureau, Department of Energy, and Nuclear Regulatory Commission (NRC).

Additionally, Jeremy has previously counseled on, presented on, and published research related to international environmental law, specifically the United Nations Convention on the Law of the Sea (UNCLOS) and Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES).

Prior to and during law school, Jeremy interned at multiple government agencies, including the United Nations, the U.S. State Department, and the Iraqi Embassy in Washington, D.C.

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Photo of Chandler Leonard Chandler Leonard

Chandler S. Leonard is an associate in Crowell & Moring’s Washington, D.C. office and a member of the firm’s International Trade Group. Chandler’s practice focuses on export controls and economic sanctions issues, including voluntary disclosures and enforcement matters before the Departments of Commerce…

Chandler S. Leonard is an associate in Crowell & Moring’s Washington, D.C. office and a member of the firm’s International Trade Group. Chandler’s practice focuses on export controls and economic sanctions issues, including voluntary disclosures and enforcement matters before the Departments of Commerce, State, and Treasury. Chandler has experience analyzing and advising U.S. and non-U.S. companies with respect to proposed transfers of U.S. origin technology, software, hardware, and services. She has performed jurisdictional and classification analyses under the ITAR and EAR, including drafting Commodity Jurisdiction requests and CJ Reconsideration requests. She assists in developing and/or reviewing U.S. export and sanctions compliance programs, including risk assessments. Chandler also has experience training a wide variety of audiences, both U.S. and foreign, on compliance with U.S. export control and sanctions requirements.

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Photo of Jackie Schaeffer Jackie Schaeffer

Jackie Schaeffer is an associate in Crowell & Moring’s New York office and a member of the firm’s International Trade Group. Jackie focuses her practice on global compliance, regulatory enforcement, investigations, and transactional matters at the intersection of U.S. national security and international

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Jackie Schaeffer is an associate in Crowell & Moring’s New York office and a member of the firm’s International Trade Group. Jackie focuses her practice on global compliance, regulatory enforcement, investigations, and transactional matters at the intersection of U.S. national security and international trade, including economic sanctions, anti-money laundering (AML), export controls, and the Committee on Foreign Investment in the United States (CFIUS).

Jackie received her J.D. from Stanford Law School where she was a Franke Fellow in Global Business Law.  She received her LLM in EU and International Business Law from The University of Vienna School of Law. During law school, she worked at the Estonian Foreign Ministry, clerked for the Honorable Chief Justice of the Supreme Court of the Republic of Rwanda, and worked with the United Nations Independent Commission of Inquiry on Ukraine.

Prior to law school, Jackie was a Coro Fellow in Public Affairs in San Francisco.

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Photo of Rachel Bogin Rachel Bogin

Rachel Bogin is an associate in the International Trade and White Collar and Regulatory Enforcement practices in Crowell & Moring’s Washington, D.C. office. Rachel is experienced in analyzing global sanctions and export control regimes to provide compliance guidance, examining domestic import regulations, and…

Rachel Bogin is an associate in the International Trade and White Collar and Regulatory Enforcement practices in Crowell & Moring’s Washington, D.C. office. Rachel is experienced in analyzing global sanctions and export control regimes to provide compliance guidance, examining domestic import regulations, and providing client representation in government investigations.

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Photo of Dmitry Bergoltsev Dmitry Bergoltsev

Dmitry Bergoltsev is a senior international trade analyst in Crowell & Moring’s Washington, D.C. office. He provides practice support to the International Trade Group on import regulatory matters pending before the Office of the U.S. Trade Representative (USTR) and U.S. Customs and Border

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Dmitry Bergoltsev is a senior international trade analyst in Crowell & Moring’s Washington, D.C. office. He provides practice support to the International Trade Group on import regulatory matters pending before the Office of the U.S. Trade Representative (USTR) and U.S. Customs and Border Protection (CBP). He works closely with attorneys developing courses of action for clients impacted by investigations under Section 301 of the Trade Act of 1974 and Section 232 of the Trade Expansion Act of 1962. He also supports unfair trade investigations, including antidumping (AD) and countervailing duty (CVD) investigations, sunset reviews, and changed circumstance reviews before the Department of Commerce and the International Trade Commission (ITC).

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