Meredith Rathbone

Meredith Rathbone

Meredith Rathbone focuses on export controls and economic sanctions, and has assisted clients in the energy, manufacturing, telecommunications, information security, banking, insurance, pharmaceutical, and service industries, among many others, in navigating the requirements of the Export Administration Regulations (EAR), International Traffic in Arms Regulations (ITAR) and US sanctions regulations administered by the Office of Foreign Assets Control (OFAC) and US Department of State.  She regularly assists companies in developing compliance policies, conducting internal investigations, performing training, and conducting due diligence in M&A transactions.  She has represented individuals and companies facing civil and criminal investigations in this area, and has also represented clients in their efforts to be removed from OFAC’s list of Specially Designated Nationals (SDNs).  She is a frequent writer and speaker on export controls and sanctions topics.  She is the co-chair of the American Bar Association’s Export Controls and Economic Sanctions Committee, and also serves on the Sanctions Subcommittee of the State Department’s Advisory Committee on International Economic Policy.

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President Trump Reissues Iran Sanctions Waivers, but Warns That Concerns over JCPOA Must Be Addressed

On January 12, President Trump announced that he was reissuing statutory waivers necessary to continue certain sanctions relief pursuant to the Joint Comprehensive Plan of Action (“JCPOA” or Iran nuclear deal), but stated that this was the last time he would reissue such waivers unless his concerns over the agreement were addressed.  On the same … Continue Reading

UK MPs Seek to Designate Iran’s Islamic Revolutionary Guard Corps a Terrorist Organisation

In light of the recent protests in Iran, a UK press report has recently drawn attention to a motion – known as Early Day Motion 483 – filed in October by a Conservative Party MP to designate Iran’s Islamic Revolutionary Guard Corps (“IRGC”) as a terrorist organisation. The motion calls upon the UK Government to … Continue Reading

WorldECR Publishes Article on Coping with US Secondary Sanctions

Steptoe partners Meredith Rathbone and Brian Egan authored an article on US secondary sanctions published in WorldECR’s special report, “The Global Agenda.” The article discusses how US secondary sanctions seek to target and restrict the activities of non-US persons and explains how best to deal with those sanctions. More information is available here.… Continue Reading

Groundbreaking Russia Sanctions Bill Introduced in the Senate

A bipartisan group of US Senators introduced a bill on January 11, 2017 – the Countering Russian Hostilities Act of 2017 – that would impose unprecedented sanctions on Russia and persons and entities conducting certain types of business involving Russia.  This bill would codify into law most of the existing sanctions targeting Russia, making it … Continue Reading

New DOJ Guidance Could be a Game Changer for Export Controls and Sanctions Enforcement

Steptoe’s Meredith Rathbone and Peter Jeydel co-authored an article in Risk & Compliance, “New DOJ Guidance Could be a Game Changer for Export Controls and Sanctions Enforcement.”  The article was published in the January-March issue and centers on how the US Department of Justice’s guidance may cause difficulties and new risks for industries. For more … Continue Reading

DDTC and BIS Publish Long-Awaited Final Rules for Category XII: Night Vision and Cameras

On October 12, 2016, the State Department’s Directorate of Defense Trade Controls (DDTC) and the Commerce Department’s Bureau of Industry and Security (BIS) published companion final rules to amend Category XII of the United States Munitions List (USML) and move some less sensitive items to the Commerce Control List (CCL).  The final rules will become … Continue Reading

UN Tightens the Screws on North Korea with Additional Trade and Banking Sanctions

On November 30, 2016, UN Security Council Resolution (UNSCR) 2321 was adopted, pushing the limits on how far international economic sanctions can go in isolating the North Korean regime without entirely collapsing the country’s economy.  The resolution also lays out a handful of additional legal restrictions that will be pertinent for US and international stakeholders … Continue Reading

U.S. Removes Restrictions on Government-to-Government Assistance for Myanmar

As we discussed in a previous post, the United States terminated its economic sanctions program targeting Myanmar (which the U.S. Government still calls “Burma”) on October 7, 2016.  Building upon the normalization of relations that led to the lifting of sanctions, the U.S. Government has determined that the circumstances now allow for a resumption of … Continue Reading

US Lifts All Economic and Financial Sanctions on Myanmar (Burma), But Risks Remain

Following up on our previous post, on October 7, 2016, President Obama issued an Executive Order (which we will refer to as the New EO), lifting all US economic and financial sanctions on Myanmar.  This order follows a September 14, 2016 announcement on which we previously advised.  The Department of the Treasury’s Office of Foreign … Continue Reading

How the 2016 Election Will Impact Public Policy Developments

Sunday’s presidential town hall debate was the second of three opportunities for candidates Donald Trump and Hillary Clinton to make their case to the American electorate.  In addition to the discussion of personal and character issues, the candidates touched on a range of policy issues, including tax policy, financial services, energy, and international trade.  The … Continue Reading

BIS Removes Vestiges of Cuba’s State Sponsor of Terrorism Designation from the EAR, with Little Practical Impact

On July 22nd, the Department of Commerce’s Bureau of Industry and Security (BIS) revised the Export Administration Regulations (EAR) to implement the Secretary of State’s May 29, 2015 rescission of Cuba’s designation as a State Sponsor of Terrorism.  While Cuba’s removal from this list is a notable symbolic action, and provides some benefit to non-US … Continue Reading
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