On March 23, 2026, the Federal Communications Commission (FCC) updated its Covered List—a list of communications equipment and services deemed to pose an unacceptable risk to U.S. national security or the safety and security of U.S. persons—to include consumer-grade routers produced in a foreign country, absent an exemption granted by the U.S. Departments of War (DoW) or Homeland Security (DHS). This designation effectively prohibits the import of all consumer routers that are not produced in the United States.

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Tags: China, FCC
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Photo of Caroline Brown Caroline Brown

Caroline E. Brown is a partner in Crowell & Moring’s Washington, D.C. office and a member of the firm’s White Collar & Regulatory Enforcement and International Trade groups and the steering committee of the firm’s National Security Practice. She provides strategic advice to…

Caroline E. Brown is a partner in Crowell & Moring’s Washington, D.C. office and a member of the firm’s White Collar & Regulatory Enforcement and International Trade groups and the steering committee of the firm’s National Security Practice. She provides strategic advice to clients on national security matters, including anti-money laundering (AML) and economic sanctions compliance and enforcement challenges, investigations, and cross border transactions, including review by the Committee on Foreign Investment in the United States (CFIUS) and the Committee on Foreign Investment in the U.S. Telecommunications Services Sector (Team Telecom).

Caroline brings over a decade of experience as a national security attorney at the U.S. Departments of Justice and the Treasury. At the U.S. Department of Justice’s National Security Division, she worked on counterespionage, cybersecurity, and counterterrorism matters and investigations, and gained unique insight into issues surrounding data privacy and cybersecurity. In that role, she also sat on both CFIUS and Team Telecom and made recommendations to DOJ senior leadership regarding whether to mitigate, block, or allow transactions under review by those interagency committees. She also negotiated, drafted, and reviewed mitigation agreements, monitored companies’ compliance with those agreements, and coordinated and supervised investigations of breaches of those agreements.

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Rajeev Raghavan

Rajeev Raghavan is a former special counsel to the Director of the Federal Bureau of Investigation (FBI) and federal prosecutor who guides clients through high-stakes cybersecurity and privacy incidents, government investigations and enforcement actions, sensitive national security matters, and litigation.

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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 Sibilla Grenon Sibilla Grenon

Sibilla Grenon is an associate in Crowell & Moring’s International Trade Group.

Before joining Crowell, Sibilla clerked for the Honorable Timothy M. Reif of the Court of International Trade, where she assisted Judge Reif in cases related to antidumping and countervailing duties, customs,

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Sibilla Grenon is an associate in Crowell & Moring’s International Trade Group.

Before joining Crowell, Sibilla clerked for the Honorable Timothy M. Reif of the Court of International Trade, where she assisted Judge Reif in cases related to antidumping and countervailing duties, customs, and matters arising from the Court’s residual jurisdiction. Sibilla also assisted Judge Reif in the adjudication of cases before the Southern District of New York, notably in areas of trade secret and copyright law. Prior to her clerkship, Sibilla was an associate in the litigation group of a law firm where she represented clients on compliance issues concerning privacy and data security for large corporations in accordance with state, federal, and international privacy regulations (GDPR, CCPA, CPRA, TCPA, BIPA, and GLBA) and employment matters.

Sibilla is a Rising Leader with the Aspen Strategy Group, a program that cultivates the next generation of rising leaders in national security and foreign policy.

As a law student, Sibilla served as the articles editor for the Georgetown Journal of International Law, a fellow at the Institute of International Economic Law, and was a member of Georgetown’s francophone moot court team of the Concours d’Arbitrage International de Paris.

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Photo of Rachel Richman Rachel Richman

With a focus on White Collar and Regulatory Enforcement and International Trade, Rachel Richman assists clients—from startups to large corporations—in navigating government investigations and regulatory challenges.

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