On July 28, 2026, the Federal Communications Commission (FCC) updated its Covered List — established through the Secure and Trusted Communications Networks Act — to include foreign-produced connected power inverters and advanced robotic devices, following an executive branch national security determination that they “pose unacceptable risks to the national security of the United States or the safety and security of United States persons.” Equipment on the Covered List is ineligible for FCC equipment authorization, effectively prohibiting the import, sale, or marketing of those products without an exception or approval.

A few weeks later, on August 20, the FCC issued a new public notice and updates to its Frequently Asked Questions (FAQ) that modifies its Covered List entry for foreign-produced power inverters, following a second National Security Determination from the U.S. Department of War (DoW), and updates its guidance on foreign-produced advanced robotic devices.

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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.

Photo of Rajeev Raghavan 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.

Photo of Dmitry Bergoltsev Dmitry Bergoltsev

Dmitry Bergoltsev is a Senior International Trade Specialist I in Crowell & Moring’s Washington, D.C., office. With professional fluency in Russian and Mandarin, Dmitry bridges language and cultural barriers, offering valuable insights for clients navigating complex global trade and regulatory matters. He works…

Dmitry Bergoltsev is a Senior International Trade Specialist I in Crowell & Moring’s Washington, D.C., office. With professional fluency in Russian and Mandarin, Dmitry bridges language and cultural barriers, offering valuable insights for clients navigating complex global trade and regulatory matters. He works closely with attorneys to develop practical solutions for clients facing challenges before the Office of Foreign Assets Control (OFAC), U.S. Customs and Border Protection (CBP), the Bureau of Industry and Security (BIS), and other federal agencies. Dmitry’s key areas of focus include advising clients on sanctions and export controls compliance, U.S. import and export regulations, and supply chain due diligence, with particular attention to the geopolitical and regulatory risks our clients face when operating across global markets.