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- Home
- Professionals
- Stephen C. Bartenstein
Steve Bartenstein advises companies on the application of international trade controls, including export controls, sanctions, and antiboycott laws and regulations. Mr. Bartenstein also is a litigator with experience representing clients in complex and high-stakes civil litigation, including antitrust matters.
In his international trade controls practice, Mr. Bartenstein counsels clients on U.S. trade controls regulations administered by the State Department, Commerce Department, and Census Bureau; economic sanctions programs administered by the Treasury Department; and compliance with U.S. antiboycott laws and regulations.
He has counseled clients in the defense, energy, pharmaceutical, medical device, and financial services sectors, among others.
- Develops and assists clients with the implementation of compliance initiatives (including policies, procedures, and manuals), and provides international trade controls training.
- Represents companies in internal investigations into international trade controls violations. Capabilities in this area include helping companies prepare and file voluntary disclosures with the Departments of State, Commerce, and Treasury; responding to agency inquiries; and implementing corrective compliance measures in the wake of disclosures.
- Advises companies on preparing and filing export license applications, technical assistance and manufacturing license agreements, commodity jurisdiction and commodity classification ruling requests, and registration with DDTC.
- Counsels clients in the oil & gas and financial services sectors concerning the application of U.S. sanctions against Iran, Russia, and other U.S.-sanctioned countries to their businesses.
- Counsels clients in the pharmaceutical and medical device sectors on the application of U.S. sanctions and humanitarian licensing programs.
- Represents companies in mergers and acquisitions activities, including conducting and responding to trade controls due diligence, and crafting representations and warranties and other contractual provisions related to trade controls compliance.
- Represented a pharmaceutical company in class-action antitrust litigation relating to the settlement of patent infringement litigation under the Hatch-Waxman Act.
Pro Bono
- Outside counsel to humanitarian NGO for U.S. export controls and sanctions matters.
- Represents deaf and hard-of-hearing inmates in Michigan in ADA and constitutional claims.
- Represents a state prison inmate in litigation alleging 8th Amendment violations.
- Represented a DC offender in parole application to the U.S. Parole Commission.
Previous Experience
- Harvard Kennedy School, Belfer Center for Science & International Affairs, Research Assistant for National Security (2009-2010)
- The Atlantic, Editorial Intern (2008)
December 21, 2020, Covington Alert
On December 18, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) released a Final Rule (“the Rule”), effective immediately, adding 77 entities to the BIS Entity List. The majority of these entities are in China, and include, among others, the Semiconductor Manufacturing International Corporation (“SMIC”) and the drone company SZ DJI ...
November 16, 2020, Covington Alert
On Thursday, November 12, 2020, President Trump signed an Executive Order (the “Order”) that, beginning on January 11, 2021, will prohibit U.S. persons from transacting in the publicly traded securities of 31 companies that the Department of Defense has identified as “Communist Chinese military companies.” The requirement for the Department of Defense to create ...
October 14, 2020, Covington Alert
On October 8, 2020, the United States Treasury Department’s Office of Foreign Assets Control (“OFAC”) announced the imposition of comprehensive sanctions against 18 major Iranian banks. As part of the same action, the Treasury Department identified the “financial sector” of the Iranian economy as subject to sanctions under Executive Order No. 13902 (the ...
October 1, 2020
WASHINGTON—Covington has promoted 14 lawyers to its partnership. “Our new partners practice in a wide range of the firm’s key practices and add importantly to our strengths,” said Doug Gibson, Covington’s chair. “This new partner class demonstrates that we continue to build an exceptional pipeline of superbly talented lawyers, across our offices and ...
September 25, 2020
WASHINGTON—Covington represented leading defense contractor Amentum on government contracts and other regulatory matters in its just-announced deal to acquire DynCorp International, a worldwide leader in aviation and logistics support service. Together, the two companies will create one of the largest providers of mission critical support services. The ...
August 8, 2019, Covington Alert
On August 5, 2019, President Trump issued Executive Order 13884 imposing comprehensive sanctions against the Government of Venezuela. Specifically, the Executive Order blocks all property and interests in property of the Government of Venezuela that are in or that come into the United States or the possession or control of a U.S. person.
August 8, 2018, Covington Alert
On August 6, 2018, President Trump issued Executive Order 13846 (the “Executive Order”) that re-imposes -- and to a limited extent broadens the scope of -- certain U.S. secondary sanctions targeting Iran that had been suspended in January 2016 pursuant to the Joint Comprehensive Plan of Action (“JCPOA”) with Iran.
June 15, 2018, Covington Alert
As described in our May 9, 2018, alert, the United States determined on May 8, 2018, to end its participation in the Joint Comprehensive Plan of Action (“JCPOA”) and re-impose sanctions against Iran that had been suspended as part of this 2015 nuclear agreement between the United States, Iran, Germany, France, the UK, and China.
May 15, 2018, Covington Alert
On May 8, 2018, the United States announced the decision to end its participation in the Joint Comprehensive Plan of Action (“JCPOA”) and re-impose sanctions against Iran that had been suspended as part of this 2015 nuclear agreement between the United States, Iran, Germany, France, the UK and China.
May 9, 2018, Covington Alert
On May 8, 2018, President Trump announced his decision to end U.S. participation in the Joint Comprehensive Plan of Action (“JCPOA”) and re-impose sanctions against Iran that had been suspended as part of this 2015 nuclear agreement between the United States, Iran, and certain other governments. This action will have far-reaching effects for both U.S. and ...
May 9, 2018, Covington Alert
On May 8, 2018, President Trump announced his decision to end U.S. participation in the Joint Comprehensive Plan of Action (“JCPOA”) and re-impose sanctions against Iran that had been suspended as part of this 2015 nuclear agreement between the United States, Iran, and certain other governments. This action will have far-reaching effects for both U.S. and ...
November 13, 2017, Covington Alert
On Thursday, November 9, 2017, the U.S. Departments of Treasury and Commerce published regulatory amendments that impose new restrictions on financial, travel, and trade-related transactions with Cuba by persons subject to U.S. jurisdiction.
June 9, 2016, Covington Alert
The U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) yesterday published new Frequently Asked Questions (“FAQs”) that help clarify the scope of certain measures taken by the United States in January to ease its sanctions against Iran in accordance with the Joint Comprehensive Plan of Action (“JCPOA”), the multilateral agreement signed in ...
December 16, 2015, The Review of Securities & Commodities Regulation, Vol. 48, No. 22
June 2, 2015, Inside Energy & Environment
In the wake of the April 2, 2015 announcement that the P5+1 countries (the United States, the United Kingdom, France, Russia, China, and Germany), together with the European Union had reached agreement with Iran on the parameters of a deal in which Iran would curtail its nuclear program in exchange for sanctions relief from the...… Continue Reading
June 2, 2015, Global Policy Watch
In the wake of the April 2, 2015 announcement that the P5+1 countries (the United States, the United Kingdom, France, Russia, China, and Germany), together with the European Union had reached agreement with Iran on the parameters of a deal in which Iran would curtail its nuclear program in exchange for sanctions relief from the...… Continue Reading
June 2, 2015, GlobalPolicyWatch Blog
March 31, 2015
WASHINGTON, DC, March 31, 2015 — The Michigan Department of Corrections (MDOC) unfairly discriminates against and denies equal treatment to prisoners who are deaf or hard of hearing in violation of the Americans with Disabilities Act, the Rehabilitation Act, the Religious Land Use and Institutionalized Persons Act, and the First and Fourteenth Amendments of the ...
August 12, 2014, Covington E-Alert
May 23, 2014, Covington E-Alert
May 12, 2014, Covington E-Alert
- Charles F.C. Ruff Pro Bono Lawyer of the Year (2017)