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Dmitry Bergoltsev

Senior International Trade Specialist I
Senior International Trade Specialist I
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VCard
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Areas of Focus

Overview

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.


Dmitry is also the lead analyst for "Know Your Customer" (KYC) counterparty due diligence. This includes (a) research (using internal and external databases) to identify beneficial ownership, (b) screening of all counterparties against sanctions and other denied party lists, and (c) broader transactional reviews to identify any other potential red flags related to sanctions, AML, corruption, bribery, or other financial crime risks. He is a Licensed Customs Broker (LCB) and Certified Sanctions Specialist (ACSS).
 
Prior to joining Crowell & Moring, Dmitry was a project associate at the Atlantic Council’s Scowcroft Center for Strategy and Security, where he conducted policy analysis on Indo-Pacific trade and security policy issues for the Council’s Indo-Pacific Security Initiative (IPSI). He also served as a graduate intern at the U.S. Department of Commerce’s International Trade Administration (ITA), drafting reports on U.S.–China trade and technology issues and leveraging his Mandarin to interpret PRC government policies and regulatory documents to provide U.S. officials with timely insights.

Career & Education

    • Johns Hopkins University, School of Advanced International Studies (SAIS), M.A., Loe Fellowship for Excellence in China studies, 2021
    • Johns Hopkins University – Nanjing University, Graduate Certificate, Chinese and American studies, 2019
    • Shandong University, M.A., 2019
    • People’s Friendship University of Russia, B.A., 2017
    • Johns Hopkins University, School of Advanced International Studies (SAIS), M.A., Loe Fellowship for Excellence in China studies, 2021
    • Johns Hopkins University – Nanjing University, Graduate Certificate, Chinese and American studies, 2019
    • Shandong University, M.A., 2019
    • People’s Friendship University of Russia, B.A., 2017

    • Russian
    • Mandarin
    • Russian
    • Mandarin

Dmitry's Insights

Client Alert | 8 min read | 10.01.25

BIS Issues “Affiliates Rule” to Dramatically Expand Applicability of Entity and Military End-User Lists

On September 29, 2025, the U.S. Department of Commerce Bureau of Industry and Security (BIS) announced a sweeping Interim Final Rule (IFR), (the “Affiliates Rule”) expanding which entities qualify as Entity List or Military End-User entities, thereby subjecting those entities to elevated export control restrictions under the Export Administration Regulations (EAR). U.S. export restrictions applicable to entities on the Entity List, Military End-User (MEU) List, and Specially Designated Nationals and Blocked Persons (SDN List) now apply to foreign affiliates that are, in the aggregate, owned 50% or more by one or more of the aforementioned entities. An entity that becomes subject to these restrictions because of its ownership structure will be subject to the most restrictive controls that attach to any of its parent entities, regardless of ownership stakes....

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Insights

Client Alert | 8 min read | 10.01.25

BIS Issues “Affiliates Rule” to Dramatically Expand Applicability of Entity and Military End-User Lists

Blog Post | 01.21.25

Parting Shots by Biden Administration in the Form of Sweeping New Russia Sanctions

Blog Post | 01.09.25

OFAC Issues New Syria General License and Updates FAQs

Blog Post | 01.02.25

Commerce Releases ANPRM to Bolster Drone Supply Chain Security

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Practices

Dmitry's Insights

Client Alert | 8 min read | 10.01.25

BIS Issues “Affiliates Rule” to Dramatically Expand Applicability of Entity and Military End-User Lists

On September 29, 2025, the U.S. Department of Commerce Bureau of Industry and Security (BIS) announced a sweeping Interim Final Rule (IFR), (the “Affiliates Rule”) expanding which entities qualify as Entity List or Military End-User entities, thereby subjecting those entities to elevated export control restrictions under the Export Administration Regulations (EAR). U.S. export restrictions applicable to entities on the Entity List, Military End-User (MEU) List, and Specially Designated Nationals and Blocked Persons (SDN List) now apply to foreign affiliates that are, in the aggregate, owned 50% or more by one or more of the aforementioned entities. An entity that becomes subject to these restrictions because of its ownership structure will be subject to the most restrictive controls that attach to any of its parent entities, regardless of ownership stakes....

View All Insights