Represents sanctioned parties in OFAC and State Department delisting matters, licensing, and sanctions-related federal litigation, with particular depth in administrative reconsideration petitions and Administrative Procedure Act legal challenges.
Joseph Diaz is Counsel at Ferrari & Associates. He represents individuals and entities in U.S. economic sanctions matters before the Office of Foreign Assets Control, the U.S. Department of State, and federal courts.
Mr. Diaz handles matters across the sanctions lifecycle, including designation response, requests for stays, administrative reconsideration and delisting petitions, agency questionnaire responses, specific license and unblocking applications, advisory opinions, and Administrative Procedure Act litigation. Clients rely on him when a designation, denial, or licensing obstacle threatens banking access, business operations, reputation, or the ability to transact.
His work combines detailed administrative-record analysis with practical judgment about when to continue through the agency process and when judicial review may be warranted. He has represented former heads of state and senior government officials, international businesspeople, foreign financial institutions, maritime companies and vessel interests, mining and metals businesses, and charitable organizations.
Mr. Diaz regularly works on matters involving the Iran, Russia and Ukraine-related, counterterrorism, counternarcotics, cyber, and Global Magnitsky sanctions programs. His matters often require coordination with OFAC, the State Department, the Department of Justice, financial institutions, and international counterparties.
Focus Areas
SDN delisting and administrative reconsideration before OFAC and the State Department
OFAC licensing, unblocking applications, and specific license requests
Administrative Procedure Act litigation involving designations, denials, and agency delay
Requests for stays of designation and pre-designation submissions
OFAC questionnaires and supplemental submissions
Sanctions investigations, advisory opinions, and counterparty screening
Sanctions-related federal criminal defense support
Experience
Mr. Diaz has spent his legal career at Ferrari & Associates, progressing from Legal Intern to Associate and Counsel. During that time, he has worked on a substantial portfolio of OFAC and State Department matters involving administrative reconsideration, licensing, unblocking, agency questionnaires, advisory opinions, designation stays, investigations, and federal litigation.
Before joining the firm full-time, Mr. Diaz interned with the National Security Law Section of the U.S. Department of Homeland Security and the Transportation Security Administration’s Security Operations team. Those roles provided exposure to the legal and operational framework surrounding U.S. national security matters.
While attending law school, he served on the American University Law Review, worked as a teaching assistant in the Legal Rhetoric program, and volunteered on behalf of Afghan interpreters seeking Special Immigrant Visas.
Education
J.D., American University Washington College of Law
Summa cum laude; ranked fifth in a graduating class of more than 400. Member, American University Law Review. Teaching Assistant, Legal Rhetoric.
B.A., Wake Forest University
Cum laude, Politics and International Affairs.
Admissions
- District of Columbia
- District of Columbia Court of Appeals
- Florida
- Supreme Court of the State of Florida
Joseph Diaz is Counsel at Ferrari & Associates. He represents individuals and entities in U.S. economic sanctions matters before the Office of Foreign Assets Control, the U.S. Department of State, and federal courts.
Mr. Diaz handles matters across the sanctions lifecycle, including designation response, requests for stays, administrative reconsideration and delisting petitions, agency questionnaire responses, specific license and unblocking applications, advisory opinions, and Administrative Procedure Act litigation. Clients rely on him when a designation, denial, or licensing obstacle threatens banking access, business operations, reputation, or the ability to transact.
His work combines detailed administrative-record analysis with practical judgment about when to continue through the agency process and when judicial review may be warranted. He has represented former heads of state and senior government officials, international businesspeople, foreign financial institutions, maritime companies and vessel interests, mining and metals businesses, and charitable organizations.
Mr. Diaz regularly works on matters involving the Iran, Russia and Ukraine-related, counterterrorism, counternarcotics, cyber, and Global Magnitsky sanctions programs. His matters often require coordination with OFAC, the State Department, the Department of Justice, financial institutions, and international counterparties.
Representative Matters
Oleg Deripaska
Contributed to the delisting petition and Administrative Procedure Act challenge brought on behalf of the Russian businessman, including proceedings in the U.S. District Court for the District of Columbia and the U.S. Court of Appeals for the D.C. Circuit in Deripaska v. Mnuchin and Deripaska v. Yellen.
Bahman Group
Worked on the federal court challenge to OFAC’s designation of an Iran-related entity in the U.S. District Court for the District of Columbia in Bahman Group v. Palluconi.
U.S. v. Soltech Industry Co. Ltd. and DES International
Represented Asian corporations accused of violations of U.S. sanctions and export controls targeting Iran.
Alexey Panferov
Contributed to the administrative and litigation strategy that resulted in removal of the client’s State Department sanctions designation following the negotiated resolution of an Administrative Procedure Act challenge in Panferov v. Blinken.
Hanna Elias Khalifeh
Worked on the administrative reconsideration matter that resulted in removal of the client from OFAC’s counterterrorism Specially Designated Nationals List.
Pearl Petrochemical FZE and LPG Tinos I
Advised on OFAC licensing and engagement under General License Q in connection with a blocked vessel and supported related admiralty litigation in the U.S. District Court for the Southern District of Texas.
Zangakani
Supported the defense of an individual in a federal criminal matter involving alleged violations of U.S. sanctions targeting Iran.