Brian Egan

Photo of Brian Egan

Brian Egan advises on a number of international legal issues that affect US and foreign clients, including economic sanctions, export controls, and anti-money laundering programs; national security trade and investment reviews; international arbitration and other cross-border disputes; international cybersecurity and data privacy; and issues of public international law. He has worked in various senior legal positions for the US government, giving him keen insight into domestic and international legal matters that influence US government national security and foreign relations policies and programs. Before joining Steptoe, Brian served as the Legal Adviser to the US Department of State, the Legal Adviser to the National Security Council, Deputy White House Counsel, and Assistant General Counsel for Enforcement and Intelligence with the US Department of the Treasury. Brian has regularly appeared in public fora to speak on international legal issues, including testifying before Congress, public speaking engagements, and panel presentations.

Read Brian's full bio.

Latest Articles

As a first step to implementing the wide-ranging Foreign Investment Risk Review Modernization Act of 2018 (FIRRMA) that was enacted in August 2018, the U.S. Department of the Treasury on October 10, 2018 issued an interim rule to launch a “pilot program” to expand the jurisdiction of the Committee on Foreign Investment in the United States (CFIUS) to review certain “critical technology” transactions.  Treasury also issued temporary regulations that make limited changes to…
On October 3, 2018, the International Court of Justice (“ICJ” or the “Court”), the principal judicial organ of the United Nations, issued an Order ruling partly in favor of Iran on Iran’s request for provisional measures against the US for its May 8, 2018 withdrawal from the Joint Comprehensive Plan of Action (“JCPOA”) and re-imposition of sanctions on August 6, 2018. On July 16, 2018, Iran instituted proceedings against the US with regard to…
On September 25, 2018, OFAC added six individuals, three entities, and an aircraft to the SDN list (link to press release here).  These designations appear to be motivated by a continued effort to pressure the Maduro government to change its policies.  The press release notes that, “By the end of 2018, hyperinflation in Venezuela is projected to reach over one million percent.  Three million Venezuelans will have departed Venezuela for neighboring nations to escape…
On September 20, 2018, the State Department announced sanctions on China’s Equipment Development Department (EDD) (formerly known as the General Armaments Department (GAD)) and its director, Li Shangfu, for engaging in significant transactions with Russia’s Rosoboronexport for the delivery to China of Su-35 combat aircraft in 2017 and equipment for S-400 surface-to-air missile systems in 2018. The EDD is part of the Chinese State Council’s Central Military Commission and plays a key role in the…
After months of hearings and other deliberations, Congress passed, and President Trump signed into law on August 13, 2018, the Foreign Investment Risk Review Modernization Act of 2018 (FIRRMA). FIRRMA marks the first update to the Committee on Foreign Investment in the United States (CFIUS) in over a decade and will considerably expand the jurisdiction of the Committee and make other important changes to its rules. A text of the final version of FIRRMA (Sections…
On August 8, 2018, the US State Department announced that it would be imposing new sanctions on Russia pursuant to the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991 (CBW Act).  The new sanctions are in response to a determination by the US government that the Russian government was behind the recent use of a nerve agent in the United Kingdom against two UK citizens.  The CBW Act requires the imposition of…
President Trump issued an Executive Order today re-imposing and, in some cases, expanding sanctions on Iran that had been lifted under the 2016 nuclear deal (the “JCPOA”), as today marked the end of the first “wind-down” period of 90 days following the President’s May 8 announcement that the US would no longer honor its sanctions commitments under the JCPOA.  Some of the re-imposed sanctions will be effective tomorrow, August 7; others will come back into…
Earlier this week, negotiators from the House and Senate reached agreement on what will very likely be the final text of the Foreign Investment Risk Review Modernization Act (FIRRMA), which will be part of the National Defense Authorization Act for Fiscal Year 2019 (NDAA). FIRRMA seeks to overhaul the Committee on Foreign Investment in the United States (CFIUS) by expanding the scope of the committee’s jurisdiction and closing certain “loopholes,” among other revisions.  A text…
Since President Trump’s announcement, on May 8, that the United States would withdrawal from the Joint Comprehensive Plan of Action (“JCPOA”) and re-impose previously lifted sanctions against Iran, the remaining JCPOA signatories have been scrambling to save the agreement. On June 4, officials from the UK, Germany, France, and the EU sent a letter to Secretary of State Mike Pompeo and Secretary of the Treasury Steven Mnuchin seeking a number of exemptions to US…