As Counsel at Ferri & Associates, P.C., Mr. Cullis 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-disclosure to OFAC. Mr. Cullis has advised global financial institutions, multinational 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.
Mr. Cullis has written extensively on U.S. sanctions-related matters, and his writings have been published in The New York Times, the Washington Post, CNN, Foreign Affairs, amongst others. Mr. Cullis is also a frequent contributor to major U.S. and foreign news publications and has been cited for his expertise on U.S. trade sanctions in the Wall Street Journal, the Financial Times, the Washington Post, the Associated Press, and others. Mr. Cullis also writes regularly for the U.S. economic sanctions blog, Sanction Law.
Representative Matters
- Represented Tier I Kingpins in administrative delisting matters before OFAC that led to the rescission of their designations;
- Assisted in the representation of a foreign financial institution regarding U.S. sanctions and AML compliance in matter pending before OFAC, Board of Governors of Federal Reserve Bank, and New York Department of Financial Services;
- Drafted specific license applications to OFAC that led to OFAC authorizing provision of certain educational and related marketing services to a U.S.-embargoed jurisdiction;
- Provided compliance advisory work to foreign financial institution seeking to facilitate humanitarian trade with Iran;
- Successfully represented a U.S. shipping company in an enforcement matter before the United States Department of Commerce’s Bureau of Industry and Security regarding potential violations of the EAR;
- Facilitated entry into a Terms of Removal Agreement on behalf of Iranian SDNs that achieved their removal from OFAC’s SDN List