Chi Zhang

/ Associate
Chi Zhang

Advises U.S. and international clients on OFAC sanctions, export controls, and trade compliance, drawing on prior in-house experience in compliance, due diligence, and financial crime matters while supporting the firm’s business development across Asia, particularly China.

Chi Zhang is an Associate Attorney at Ferrari & Associates. He advises U.S. and international clients on economic sanctions administered by the Office of Foreign Assets Control, export controls, anti-money laundering compliance, and cross-border trade matters.

Mr. Zhang handles OFAC delisting petitions, questionnaire and request-for-information responses, specific license applications, asset-unblocking requests, pre-designation submissions, and legal analysis involving international transactions. His work includes Russia-related sanctions matters and representation of clients in Asia, with particular focus on China.

Before joining Ferrari & Associates, Mr. Zhang held financial crime, compliance, research, and in-house legal roles at Morgan Stanley, Dow Jones, and a technology company in China. He speaks English and Mandarin Chinese.

Focus Areas

OFAC sanctions counseling and risk assessments

SDN delisting and designation challenges

Specific license and unblocking applications

Export controls under the Export Administration Regulations

Sanctions and trade compliance programs

Due diligence and internal investigations

Anti-money laundering and financial crime compliance

Cross-border matters involving Asia and China

Experience

Mr. Zhang advises clients across OFAC sanctions programs, with significant experience in Russia-related matters. His work spans delisting petitions, questionnaire and RFI responses, specific license applications, asset unblocking, investment licensing, legal opinions, pre-designation submissions, and sanctions compliance program development.

Before joining Ferrari & Associates, he served as a Global Financial Crime Manager at Morgan Stanley and as a researcher at Dow Jones. He also worked as in-house counsel for a technology company in China, advising on sanctions, export controls, and anti-corruption compliance.

Mr. Zhang holds the Certified Anti-Money Laundering Specialist, Certified Global Sanctions Specialist, and Certified Financial Crime Specialist credentials.

Education

LL.M., George Mason University Antonin Scalia Law School

J.M., Tsinghua University School of Law
International Arbitration and Dispute Resolution

B.A., Sun Yat-sen University School of International Studies

Admissions

  • District of Columbia
  • People’s Republic of China

Chi Zhang is an Associate Attorney at Ferrari & Associates. He advises U.S. and international clients on economic sanctions administered by the Office of Foreign Assets Control, export controls, anti-money laundering compliance, and cross-border trade matters.

Mr. Zhang handles OFAC delisting petitions, questionnaire and request-for-information responses, specific license applications, asset-unblocking requests, pre-designation submissions, and legal analysis involving international transactions. His work includes Russia-related sanctions matters and representation of clients in Asia, with particular focus on China.

Before joining Ferrari & Associates, Mr. Zhang held financial crime, compliance, research, and in-house legal roles at Morgan Stanley, Dow Jones, and a technology company in China. He speaks English and Mandarin Chinese.

Representative Matters

Russian Sanctions Delisting

Represented sanctioned Russian individuals in OFAC delisting proceedings and related specific license applications involving otherwise restricted transactions.

Southeast Asian Company and Individual

Represented a Southeast Asian company and an associated individual in OFAC delisting matters and a related federal criminal investigation.

Hong Kong Licensing and Unblocking

Represented Hong Kong-based companies in specific license applications and requests to unblock funds connected to blocked payments.

Foreign Financial Institutions

Advised financial institutions on U.S. sanctions and export-control exposure and risk-based decision-making under their internal compliance frameworks.

Nonprofit Compliance Program

Advised a nongovernmental organization on developing and maintaining a sanctions compliance program, including policies, procedures, and continuing risk controls.

Export-Control Counseling

Counseled clients on Export Administration Regulations requirements involving Russia, Syria, controlled items, and proposed cross-border transactions.