Represents U.S. and foreign companies, financial institutions, and individuals in OFAC sanctions and export-control matters, with particular depth in Iran, Russia, and cross-border compliance, and is a widely cited voice on U.S. sanctions policy.
Tyler Cullis is a Principal Attorney at Ferrari & Associates. He advises U.S. and international companies, financial institutions, exporters, insurers, and individuals on economic sanctions, export controls, licensing, compliance, enforcement, and federal investigations.
Mr. Cullis regularly counsels clients on matters before the Office of Foreign Assets Control and the Bureau of Industry and Security. His work includes complex cross-border transactions, internal investigations, compliance program development, specific license applications, voluntary self-disclosures, administrative subpoenas, and enforcement matters.
He has represented individuals and entities seeking removal from OFAC’s Specially Designated Nationals List and BIS-administered restricted-party lists. His matters frequently involve sanctions programs targeting Iran, Russia, and Cuba, as well as overlapping regulatory issues involving financial institutions, exporters, and multinational businesses.
Mr. Cullis is also widely published and frequently cited on U.S. sanctions policy and foreign affairs. His writing has appeared in The New York Times, The Washington Post, CNN, and Foreign Affairs. He has also been quoted by The Wall Street Journal, Financial Times, The Washington Post, and the Associated Press.
Focus Areas
U.S. sanctions and export-control compliance
OFAC and BIS licensing
SDN and restricted-party delisting
Internal investigations and compliance programs
OFAC and BIS enforcement matters
Voluntary self-disclosures
Cross-border transaction counseling
Administrative subpoenas and federal investigations
Experience
Mr. Cullis advises clients across OFAC-administered sanctions programs and in matters before BIS. His practice includes compliance counseling, enforcement defense, licensing, voluntary self-disclosures, internal investigations, export controls, and administrative delisting.
He has advised global financial institutions, multinational corporations, exporters, insurers, and private individuals on complex sanctions and cross-border regulatory matters. His work frequently involves overlapping sanctions authorities, multiple regulators, and transactions requiring careful coordination across legal, compliance, and business teams.
Education
J.D., Boston University School of Law
B.A., The New School
Admissions
- District of Columbia
Tyler Cullis is a Principal Attorney at Ferrari & Associates. He advises U.S. and international companies, financial institutions, exporters, insurers, and individuals on economic sanctions, export controls, licensing, compliance, enforcement, and federal investigations.
Mr. Cullis regularly counsels clients on matters before the Office of Foreign Assets Control and the Bureau of Industry and Security. His work includes complex cross-border transactions, internal investigations, compliance program development, specific license applications, voluntary self-disclosures, administrative subpoenas, and enforcement matters.
He has represented individuals and entities seeking removal from OFAC’s Specially Designated Nationals List and BIS-administered restricted-party lists. His matters frequently involve sanctions programs targeting Iran, Russia, and Cuba, as well as overlapping regulatory issues involving financial institutions, exporters, and multinational businesses.
Mr. Cullis is also widely published and frequently cited on U.S. sanctions policy and foreign affairs. His writing has appeared in The New York Times, The Washington Post, CNN, and Foreign Affairs. He has also been quoted by The Wall Street Journal, Financial Times, The Washington Post, and the Associated Press.
Representative Matters
Russia-Related Delisting
Represented individuals subject to Russia-related sanctions in an administrative delisting matter before OFAC that resulted in removal of their designations.
Multi-Regulator Financial Institution Matter
Assisted in representing a foreign financial institution on sanctions and anti-money laundering compliance in a matter involving OFAC, the Board of Governors of the Federal Reserve System, and the New York Department of Financial Services.
Kingpin Act Delistings
Represented individuals designated under the Kingpin Act in administrative reconsideration matters that resulted in removal from OFAC’s SDN List.
Humanitarian Trade Advisory
Advised a foreign financial institution on sanctions compliance related to humanitarian trade involving Iran.
Terms of Removal Agreement
Helped negotiate a Terms of Removal Agreement for Iranian SDNs that resulted in their removal from OFAC’s SDN List.