About SanctionLaw

Over the past two decades, when confronted with threats to its national security, the United States has increasingly turned to economic sanctions as a primary response. As the role of sanctions in the U.S. policy toolkit has grown, so too has the compliance demands on U.S. businesses, lawyers, and even individual citizens.

Compliance with U.S. sanctions regulations has never been easy. As the 2001 Final Report of the Judicial Review Commission on Foreign Assets Control attests, “Members of the legal and business communities who regularly deal with OFAC expressed frustration regarding perceived barriers to effective and efficient compliance with the sanctions programs that OFAC administers.” While some progress has been made, the number of sanctions programs has multiplied in both number and complexity.

Sanction Law was created in December 2008 by Sanction Law Founding Editor Erich Ferrari in order to analyze the legal and policy considerations of this powerful foreign policy tool.

Sanction Law’s mission is to provide a practical, easy to use resource that will assist both expert practitioners and newcomers alike in navigating the world of U.S. economic sanctions.

About the Authors

Erich Ferrari

Erich Ferrari

Founder

As the Founder and Principal of Ferrari & Associates, P.C., Mr. Ferrari represents U.S. and foreign corporations, financial institutions, exporters, insurers, as well as private individuals in trade compliance, regulatory licensing matters, and federal investigations and prosecutions. He frequently represents clients before the United States Department of the Treasury’s Office of Foreign Assets Control (OFAC), the United States Department of Commerce’s Bureau of Industry and Security (BIS), and in federal courts around the country. With over 12 years of experience in national security law, exports control, and U.S. economic sanctions, he counsels across industry sectors representing parties in a wide range of matters from ensuring compliance to defending against federal prosecutions and pursuing federal appeals.

Mr. Ferrari’s representations before OFAC frequently involve investigations concerning violations of the Iranian Transactions and Sanctions Regulations, the Cuban Assets Control Regulations, and the Counter Narcotics Trafficking Sanctions Regulations. As part of these representations, he has worked to have names removed from OFAC’s Specially Designated Nationals and Blocked Persons List (SDN List), and OFAC administrative subpoenas issued during the course of an OFAC investigation, procure OFAC specific licenses to engage in transactions prohibited by OFAC, draft OFAC voluntary self-disclosures, develop and implement OFAC compliance programs for international import-export companies, and provide general counseling on OFAC related matters.

Tyler Cullis

Tyler Cullis

Contributing Author

Mr. Cullis is an Associate Attorney at Ferrari & Associates, P.C. where he is engaged in the practice of U.S. economic sanctions, including trade compliance, regulatory licensing matters, and federal investigations and prosecutions. Mr. Cullis has extensive experience counseling clients on matters falling under the purview of the United States Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the U.S. Department of Commerce’s Bureau of Industry and Security (BIS). He has provided counsel to U.S. and foreign parties on complex cross-border transactions and compliance with U.S. economic sanctions; conducted corporate internal investigations and developed sanctions compliance policies; and submitted license applications and voluntary self-disclosures to OFAC. Mr. Cullis has advised global financial institutions, multi-national corporations, U.S. and foreign exporters and insurers, as well as private individuals regarding U.S. sanctions matters, including matters involving Russia, Iran, and Cuba.

Mr. Cullis has also assisted U.S. parties responding to OFAC administrative subpoenas in the course of federal investigations related to potential sanctions violations and has provided representation to individuals and entities whose names have been identified on OFAC’s Specially Designated Nationals and Blocked Persons List (SDN List) or BIS-administered lists.