Blake Hulnick focuses his practice on advisory and enforcement matters involving U.S. national security, including economic sanctions and export controls administered by the Departments of Treasury, Commerce, and State, and the outbound investment security regime administered by the Treasury Department.
Blake rejoined the firm after serving in the Department of the Treasury, where he was an Attorney-Advisor in the Office of Chief Counsel for Foreign Assets Control (OFAC) and a Senior Advisor to the General Counsel. In the Office of Chief Counsel, Blake advised OFAC on all legal issues relating to the administration of U.S. economic sanctions. Most recently, he was counsel to the Iran and Russia sanctions programs, in addition to advising on other programs and cross-programmic matters. He supported the full range of OFAC activities, including enforcement, targeting/designations, removal petitions, licensing, regulations, and the NSC policy process, and coordinated closely with the Department of Justice on litigation matters, including numerous litigated challenges to sanctions designations.
Blake also served as Senior Advisor to Treasury’s General Counsel on national security matters including all OFAC, Financial Crimes Enforcement Network (FinCEN), and Committee on Foreign Investment in the United States (CFIUS) matters. In this role, he advised Treasury’s General Counsel and other top agency officials on novel sanctions matters involving Russia, anti-money-laundering rulemaking, congressional oversight of Treasury’s national security functions, cross-agency enforcement matters, and the creation of the first outbound investment regulations and program. He was given the Meritorious Service Award by Secretary Janet Yellen for his work in this capacity.
At Covington, Blake leverages his experience in government and private practice to help clients navigate the U.S. sanctions and export controls landscape. He advises a wide range of U.S. and non-U.S. companies on U.S. sanctions administered by OFAC . He also advises clients on the export controls administered by the State Department’s Directorate of Defense Trade Controls and the Commerce Department’s Bureau of Industry and Security, and the outbound investment security program administered by the Department of the Treasury. In each of these areas, Blake’s work ranges from providing guidance, assessing newly announced rules, seeking advisory opinions or licenses, and conducting corporate due diligence to assisting clients with voluntary disclosures and enforcement matters.
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