Rachel Bogin

Associate | She/Her/Hers

Overview

Rachel Bogin is an associate in the International Trade and White Collar and Regulatory Enforcement practices in Crowell & Moring’s Washington, D.C. office. Rachel is experienced in analyzing global sanctions and export control regimes to provide compliance guidance, examining domestic import regulations, and providing client representation in government investigations.

Career & Education

    • Department of Commerce
      Law Clerk, Commercial Law Development Program, 2023
    • Securities and Exchange Commission
      Law Clerk, Division of Enforcement, FCPA Unit, 2022
    • New York
      Law Clerk, Medicaid Fraud Control Unit, Office of the New York Attorney General, 2022
    • Department of Commerce
      Law Clerk, Commercial Law Development Program, 2023
    • Securities and Exchange Commission
      Law Clerk, Division of Enforcement, FCPA Unit, 2022
    • New York
      Law Clerk, Medicaid Fraud Control Unit, Office of the New York Attorney General, 2022
  • Jacob Burns Community Legal Clinics, Criminal Defense and Justice Clinic, 2024

    Jacob Burns Community Legal Clinics, Criminal Defense and Justice Clinic, 2024

    • The George Washington University, J.D., 2024
    • Tulane University, B.S., cum laude, in legal studies in business, minor in art history, 2020
    • The George Washington University, J.D., 2024
    • Tulane University, B.S., cum laude, in legal studies in business, minor in art history, 2020
    • District of Columbia
    • District of Columbia
    • Russian
    • Hebrew
    • Russian
    • Hebrew

Rachel'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....

Rachel'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....