Kimberly A. Strosnider

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 ...

December 8, 2020

WASHINGTON—Covington is assisting Veritas Capital and its portfolio company Peraton with their pending acquisition of the federal IT and mission support services business of Northrop Grumman for $3.4 billion. The transaction is expected to close in the first half of 2021. Peraton is a trusted provider of highly differentiated space, intelligence, cyber, defense, ...

November 19, 2020, 6th Annual Forum on Global Economic Sanctions for Canadian Operations

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 30, 2020

WASHINGTON—Covington represented GovernmentCIO, LLC, a leading provider of high-end technology and digital solutions to the Federal Health IT Services market, in its sale to Welsh, Carson, Anderson & Stowe. GovCIO is a rapidly growing provider of advanced technology solutions and digital services to the federal government. In the 10 years since its founding, ...

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 ...

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 ...

September 22, 2020, Covington Alert

On September 15, 2020, the Department of the Treasury, as chair of the Committee on Foreign Investment in the United States (“CFIUS”), published in the Federal Register a final rule (the “Final Rule”) amending the requirement to file with CFIUS certain transactions involving U.S. businesses that produce, design, test, manufacture, fabricate, or develop one or ...

September 21, 2020, Covington Alert

On September 19, 2020, China’s Ministry of Commerce ("MOFCOM") issued regulations that provide new details on the government’s plans for an “Unreliable Entity List” first proposed in May 2019.

August 20, 2020, Covington Alert

On August 17, 2020, the Commerce Department’s Bureau of Industry and Security (“BIS”) released a Final Rule (the “August 17 Final Rule”) significantly expanding U.S. export controls restrictions on certain non-U.S. items reexported, exported from abroad, or transferred (in-country) in transactions involving Huawei or its affiliates designated on the BIS Entity ...

July 16, 2020, Covington Alert

In our client alert of May 29, 2020, we reported on the initial U.S. government reaction to the announced intention of China’s legislature, the National People’s Congress (“NPC”), to unilaterally impose national security legislation on Hong Kong. As expected, on June 30, the NPC unanimously adopted the “Law of the People’s Republic of China on Safeguarding ...

June 27, 2020

WASHINGTON—Covington represented Piramal Enterprises Limited (PEL) in the sale of a 20% stake in Piramal Pharma Limited (Piramal Pharma), a wholly owned subsidiary of PEL that will contain its pharmaceutical businesses, to CA Clover Intermediate II Investments, an affiliated entity of CAP V Mauritius Limited, an investment fund managed and advised by affiliated ...

May 21, 2020, Covington Alert

In an effort to curtail access by China’s Huawei Technologies Co., Ltd. to products made using U.S. semiconductor software and technology, the Commerce Department’s Bureau of Industry and Security (“BIS”) on May 15, 2020, released an Interim Final Rule expanding and extending U.S. export controls jurisdiction to certain non-U.S. items when destined for Huawei or ...

May 21, 2020, Covington Alert

On May 21, 2020, the Department of the Treasury, as chair of the Committee on Foreign Investment in the United States (“CFIUS”), published in the Federal Register a proposed rule (the “Proposed Rule”) that would amend the requirements to file with CFIUS certain transactions involving U.S. businesses that produce, design, test, manufacture, fabricate, or develop ...

April 29, 2020, Covington Alert

On April 28, 2020, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) published two final rules and one proposed rule to modify certain license exceptions and definitions in the Export Administration Regulations (“EAR”) (15 CFR Parts 730 – 774), based on concern that sensitive products and technologies were being diverted to military uses ...

March 23, 2020

NEW YORK—The American Lawyer has named Covington lawyers Sergio Urías and Laura Torre as “Dealmakers of the Year.” The annual feature highlights “the most impressive and significant matters that deal lawyers worked on in 2019.” Shareholders of Covington’s client Prisma Medios de Pago, Argentina’s largest payment processing company, were mandated by the antitrust ...

January 17, 2020

WASHINGTON—Covington represented Piramal Enterprises Limited in itsdefinitive agreement to sell Decision Resources Group to Clarivate Analytics plc, in a deal valued at $950 million. The $950 million purchase price includes $900 million in cash and approximately $50 million in Clarivate ordinary shares to be issued following the one-year anniversary of ...

January 15, 2020, Covington Alert

On January 10, 2020, President Trump issued a new Executive Order (“January 10 Executive Order”) that provides authority for the imposition of sanctions with respect to certain additional sectors of Iran’s economy, including Iran’s construction, mining, manufacturing, and textiles sectors. The January 10 Executive Order introduces both property-blocking ...

December 17, 2019, Covington Alert

On Friday, December 13, Principal Deputy Attorney General David Burns of the Justice Department’s (“DOJ’s” or “the Department’s”) National Security Division (“NSD”), announced a new DOJ policy for business organizations that voluntarily disclose potential criminal violations of the U.S. export controls and sanctions laws to NSD’s Counterintelligence and Export ...

October 10, 2019, Covington Alert

On October 9, the U.S. Department of Commerce issued a Final Rule adding 20 Chinese government entities and eight Chinese private sector entities (“Listed Entities”) to the Entity List maintained by the Commerce Department’s Bureau of Industry and Security (“BIS”).

August 28, 2019, Covington Alert

On August 23, 2019, President Donald J. Trump tweeted: "Our great American companies are hereby ordered to immediately start looking for an alternative to China, including bringing . . . your companies HOME and making your products in the USA."

August 20, 2019, Covington Alert

On August 19, 2019, the Commerce Department’s Bureau of Industry and Security (“BIS”) issued a Final Rule adding 46 non-U.S. affiliates of Huawei Technologies Co., Ltd. (“Huawei”) to the Entity List and extended, through November 18, 2019, a revised Temporary General License (“TGL”) authorizing certain transactions with Huawei and listed Huawei entities.

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.

July 22, 2019

NEW YORK—Covington advised Bayer in a definitive agreement to sell the Dr. Scholl’s™ business to Yellow Wood Partners for a purchase price of $585 million. Bayer is a global enterprise with core competencies in the life science fields of health care and nutrition. Its products and services are designed to benefit people by supporting efforts to overcome the ...

May 23, 2019

WASHINGTON—Covington is representing Alion Science and Technology Corporation in a recently announced deal to sell its Naval Systems Business Unit to Serco Inc. for $225 million. The sale, subject to certain regulatory approvals, is expected to close in the second half of 2019. Headquartered in McLean, VA, Alion delivers advanced engineering, IT and, operational ...

May 17, 2019, Covington Alert

The U.S. Department of Commerce yesterday issued a Final Rule adding Huawei Technologies Co., Ltd. (“Huawei”) and 68 non-U.S. Huawei affiliates to the Entity List maintained by the Commerce Department’s Bureau of Industry and Security (“BIS”). While the rule will not be published in the Federal Register until May 21, it was effective immediately upon release ...

May 13, 2019

NEW YORK—Covington advised Bayer in a definitive agreement to sell its Coppertone™ business to Beiersdorf AG, a provider of skin care products, for $550 million. Bayer is a global enterprise with core competencies in the life science fields of health care and nutrition. Its products and services are designed to benefit people by supporting efforts to overcome ...

April 25, 2019, Covington Alert

The Trump Administration has announced multiple U.S. sanctions measures over the past several weeks, further tightening the sanctions on Iran and imposing additional measures on Venezuela and its allies, Cuba and Nicaragua.

April 3, 2019, Covington Alert

In February 2019, the U.S. Department of Justice (“DOJ”) announced a settlement with Honda Aircraft Company LLC regarding claims that Honda Aircraft violated the Immigration and Nationality Act (“INA”) by discriminating against non-U.S. citizens in an attempt to comply with requirements of the International Traffic in Arms Regulations (“ITAR”) and the Export ...

January 29, 2019, Covington Alert

January 22, 2019

NEW YORK—Covington advised Prisma Medios de Pago, Argentina’s leading payments company, in the sale of a controlling stake to Advent International. Prisma’s existing shareholders will retain a 49% stake in the company. The transaction values 100 percent of Prisma at $1.42 billion.   Prisma is an Argentinian company established in 2014 through the merger of Visa ...

November 20, 2018, Covington Alert

On November 19, 2018, the U.S. Commerce Department’s Bureau of Industry and Security (“BIS”) released an Advance Notice of Proposed Rulemaking (“ANPRM”) requesting public comment on the criteria to identify emerging technologies essential to U.S. national security. The comments will inform the interagency process that was authorized under the Export Control ...

November 6, 2018, Covington Alert

The Trump Administration yesterday completed the reimposition of sanctions against Iran that previously were suspended as part of the 2015 multilateral nuclear agreement, known as the Joint Comprehensive Plan of Action (“JCPOA”).

August 30, 2018, Covington Alert

On August 27, 2018, the Department of State imposed sanctions against Russia pursuant to the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991 (CBW Act) in response to Russia’s use of a chemical nerve agent against a UK citizen.

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.

July 30, 2018, Covington Alert

On July 23, the final text of the Export Control Reform Act of 2018 (“ECRA”) was released as part of the Conference Report to accompany the National Defense Authorization Act (“NDAA”) for fiscal year 2019. The NDAA is a must-pass piece of legislation that authorizes funding for the Department of Defense, and we expect it to be enacted and signed within the next ...

July 2, 2018, Covington Alert

In furtherance of President Trump’s May 8, 2018 announcement that the United States is withdrawing from the Joint Comprehensive Plan of Action (“JCPOA”) (discussed in our recent alert), on June 27 the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced several changes to the U.S. sanctions against 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 16, 2018, Covington Alert

We are writing to report on the current status of the Foreign Investment Risk Review Modernization Act (“FIRRMA”), legislation to reform the Committee on Foreign Investment in the United States (“CFIUS” or the “Committee”). FIRRMA, a bill introduced by Senator John Cornyn (R-TX) in the Senate and Congressman Robert Pittenger (R-NC) in the House, seeks to ...

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 ...

May 8, 2018, Covington Alert

It has been publicly reported that the Trump Administration is considering invoking the International Emergency Economic Powers Act (IEEPA) to further regulate—and in certain areas potentially preclude—Chinese direct investment in the United States, beyond the authorities exercised by the Committee on Foreign Investment in the United States (CFIUS). The prospect ...

April 20, 2018, Covington Alert

On April 15, 2018, the U.S. Department of Commerce, Bureau of Industry and Security (“BIS”) lifted its suspension of a denial order against two companies, Zhongxing Telecommunications Equipment Corporation of Shenzhen, China (“ZTE Corporation”) and ZTE Kangxun Telecommunications Ltd. of Hi-New Shenzhen, China (“ZTE Kangxun,” and together with ZTE Corporation, ...

April 6, 2018, Covington Alert

On April 6, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced expanded sanctions against Russian entities and individuals, targeting a number of Russian oligarchs in the energy, banking, and other sectors and companies they own or control, as well as 17 senior Russian government officials.

March 8, 2018, Covington Alert

On February 15, 2018, House Foreign Affairs Committee Chairman Ed Royce (R-CA) introduced bipartisan legislation—the Export Control Reform Act of 2018 (“ECRA”)⸺to modernize U.S. export control regulation of commercial and dual-use items.

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.

November 9, 2017, Global Policy Watch

During the past two weeks, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) and the U.S. Department of State have taken a number of steps toward implementing aspects of the Countering America’s Adversaries Through Sanctions Act (“CAATSA”), a major piece of sanctions legislation passed by the U.S. Congress in July and...… Continue ...

November 8, 2017, Covington Alert

During the past two weeks, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) and the U.S. Department of State have taken a number of steps toward implementing aspects of the Countering America’s Adversaries Through Sanctions Act (“CAATSA”), a major piece of sanctions legislation passed by the U.S. Congress in July and signed by ...

October 17, 2017, Global Policy Watch

Administration Also Revises Russia Sanctions, Terminates Most Sudan Sanctions On October 13, President Trump announced that he would no longer certify to Congress that the suspension of U.S. sanctions against Iran pursuant to the Joint Comprehensive Plan of Action (“JCPOA”) is “appropriate and proportionate” to the steps that Iran has taken to terminate its ...

October 17, 2017, Covington Alert

On October 13, President Trump announced that he would no longer certify to Congress that the suspension of U.S. sanctions against Iran pursuant to the Joint Comprehensive Plan of Action (“JCPOA”) is “appropriate and proportionate” to the steps that Iran has taken to terminate its illicit nuclear program. The President’s much-anticipated announcement does not ...

September 22, 2017, Covington Alert

President Trump has issued an Executive Order (“the Order”), effective September 21, 2017, imposing additional sanctions on persons doing business in certain sectors of the North Korean economy or engaging in certain trade or financial activities involving North Korea. President Trump issued the Order in response to North Korea’s recent intercontinental ...

August 29, 2017, Covington Alert

Last week, President Trump issued an Executive Order imposing new economic sanctions on the Venezuelan government in response to President Nicolás Maduro’s increasingly authoritarian actions. The new sanctions expand the U.S. restrictions against Venezuela, which previously were comprised of sanctions against a few key individuals, but they do not amount to a ...

July 28, 2017, Covington Alert

Congress has passed and sent to President Trump, for his signature or veto, a bill that would impose significant new sanctions against Russia, Iran, and North Korea. The legislation—the Countering America’s Adversaries Through Sanctions Act—enjoys broad bipartisan support, having passed the U.S. House of Representatives on July 25 by a vote of 419-3, and the ...

June 19, 2017, Covington Alert

On Friday, June 16, 2017, President Donald J. Trump announced a tightening of the United States’ long-standing Cuba embargo, rolling back some of the easing implemented during the Obama Administration and described in our prior client alerts. The Trump Administration’s approach is outlined in a National Security Presidential Memorandum, but the full scope of ...

May 2017, The Export Compliance Manager's Handbook

January 13, 2017, Covington Alert

In response to “positive actions” taken by the Government of Sudan over the past six months, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced today an amendment to the Sudanese Sanctions Regulations (“SSR,” 31 C.F.R. Part 538) that effectively suspends virtually all of the U.S. sanctions against Sudan by authorizing ...

January 13, 2017, Covington Alert

Over the past few months, the agencies responsible for criminal and civil enforcement of U.S. export control and economic sanctions laws have implemented a number of important changes in their enforcement practices. In October 2016, the U.S. Department of Justice (“DOJ”), National Security Division (“NSD”) published guidance on voluntary self-disclosures of ...

October 17, 2016, Covington Alert

Effective today, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) has amended the Cuban Assets Control Regulations (“CACR”) and the U.S. Commerce department’s Bureau of Industry and Security (“BIS”) has amended the Export Administration Regulations (“EAR”) to expand permissible dealings involving Cuba, further easing the longstanding U.S. ...

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 ...

April 14, 2016, Covington Conference Call

March 9, 2016, Practicing Law Institute Webinar

January 29, 2016, Panel Presentation to the University of Pennsylvania Law School, 2015-2016 LALSA Conference

January 28, 2016, ABA Section of International Law, 2015 U.S. Export Controls Year in Review

January 28, 2016, Covington Alert

January 19, 2016, Global Policy Watch

On January 16, 2016, the United States and the European Union (“EU”) significantly eased their sanctions against Iran, following verification by the International Atomic Energy Agency (“IAEA”) that Iran had carried out its commitments under the Joint Comprehensive Plan of Action (“JCPOA”), the multilateral agreement signed in mid-July 2015 in which Iran agreed ...

January 17, 2016, Covington Alert

December 16, 2015, The Review of Securities & Commodities Regulation, Vol. 48, No. 22

September 21, 2015, Covington Alert

September 11, 2015, Presentation to the International Compliance Professionals Association, Houston, Texas

July 30, 2015, ACI’s Economic Sanctions West Coast Forum, San Diego, California

July 15, 2015, Covington Alert

6/12/2015, Covington Alert

May 1, 2015, Spring Meeting, ABA Section of International Law, Washington, DC

April 28, 2015, Money Laundering Bulletin

April 8, 2015, Webinar Presentation to the Alaska Bar Association

January 8, 2015, Global Policy Watch

President Obama’s announcement that the United States is “changing its relationship with the people of Cuba” has been welcomed by many in the business community, who continue to await regulatory amendments that will implement the new policy.  (For background on the President’s announcement, please see our client alert of December 17, 2014 and our audio...… ...

2010-2015, Practicing Law Institute Webinar

December 24, 2014, Covington E-Alert

December 17, 2014, Covington E-Alert

December 17, 2014, Covington E-Alert

October 16, 2014, WorldECR Forum 2014, London

September 22, 2014, Covington E-Alert

September 13, 2014, Covington E-Alert

September 11, 2014, Momentum Webinar

August 15, 2014, Covington E-Alert

August 12, 2014, Covington E-Alert

July 31, 2014, Global Policy Watch

On July 29, the EU and United States took coordinated steps to expand sanctions targeting the Russian financial services, energy, and defense sectors, including restrictions on energy-related exports to Russia.  The EU also took steps to limit certain types of trade and investment in Crimea, while both the EU and United States identified additional parties...… ...

July 23, 2014, Covington E-Alert

July 18, 2014, Global Policy Watch

On July 16, 2014, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) imposed an additional wave of sanctions against Russian entities in the financial, energy, and defense sectors.  OFAC established a new Sectoral Sanctions Identifications List (the “SSI List”), which identifies two Russian financial institutions and two Russian energy ...

July 17, 2014, Covington E-Alert

July 10, 2014, Covington E-Alert

June 23, 2014, Covington E-Alert

May 23, 2014, Covington E-Alert

May 12, 2014, Covington E-Alert

April 28, 2014, Covington E-Alert

April 15, 2014, Covington E-Alert

March 21, 2014, Covington E-Alert

March 18, 2014, Covington E-Alert

March 6, 2014, Covington E-Alert

March 5, 2014, Covington E-Alert & Advisory

January 22, 2014, Covington E-Alert

October 31, 2013, Forum on Protecting Threatened Wildlife in Africa with Technology, co-hosted by The Richardson Center for Global Engagement, World Wildlife Fund, and African Parks, Washington, DC

October 16, 2013, Fall Meeting, ABA Section of International Law, London

6/26/2013

WASHINGTON, DC, June 26, 2013 — Covington & Burling is pleased to announce that partner Kimberly Strosnider has been named co-chair of the Aerospace and Defense Industries Committee of the American Bar Association’s Section of International Law for the 2013-14 term. “It is exciting and a great honor to become co-chair,” said Ms. Strosnider, who has served as a ...

April 2013, Spring Meeting, ABA Section of International Law

2013, The Year in Review: An Annual Survey of International Legal Developments

April 2012, WorldECR

November 2011, 24th Annual Global Trade Controls Conference, London

March 2011, 2011 International Trade Update, Georgetown University Law Center

March 15, 2010

WASHINGTON, DC, March 15, 2010 — CVG, Incorporated (“CVG”) has announced its merger with Integral Systems, Inc. in a deal valued at $34.675 million. Covington & Burling LLP advised CVG on the transaction. CVG and its subsidiary, Avtec systems, Inc., based in Chantilly, Virginia, provide secure satellite-based communication solutions to government and commercial ...

10/1/2009

WASHINGTON, DC, October 1, 2009 — Covington & Burling LLP today announced that ten of its lawyers have been elected to the firm’s partnership effective today. The new partners practice in the corporate, litigation, and regulatory fields. The ten new partners and their practices are as follows:  Marney Cheek (International) represents companies and trade ...

2009, 22 The Air & Space Lawyer 3

January 17, 2007

NEW YORK, NY, January 17, 2007 — Evraz Group S.A. announced that it successfully completed its tender offer for Oregon Steel Mills, Inc. (NYSE: OS) common stock for $63.25 per share, with approximately 91.5% of the outstanding shares of common stock of Oregon Steel Mills tendered into the offer. The tender offer was the first step of the previously announced ...

2002, 39 Am. Crim. L. Rev. 101