Team

Charlie Lyons

Counsel

• LinkedIn Profile
• lyons@falawpc.com
• 202-280-6370

Charlie Lyons is Counsel at Ferrari & Associates, where he represents companies and individuals in complex matters involving economic sanctions administered by the United States Department of the Treasury’s Office of Foreign Assets Control (OFAC). His practice focuses on sanctions issues related to key programs, including those targeting Russia, Iran, Venezuela, Cuba, cyber-related threats, as well as the Global Magnitsky sanctions and other human rights and corruption authorities.

Charlie advises clients on all aspects of sanctions compliance and risk, including the treatment of designated parties on OFAC’s Specially Designated Nationals and Blocked Persons (SDN) List, the process for unblocking assets, and the use of specific licenses to authorize activities that are otherwise prohibited. His experience includes counseling on primary and secondary sanctions, conducting internal investigations, voluntary self-disclosures, and developing and implementing sanctions compliance programs, policies, and procedures for clients with global operations.

Beyond compliance counseling, Charlie regularly represents clients before OFAC in enforcement, licensing, and delisting matters, as well as in related litigation under the U.S. Constitution and the Administrative Procedure Act. He has authored articles on sanctions developments for Law360 and Bloomberg Law, including analysis of U.S. sanctions policy toward Syria and the sanctions risks facing agricultural importers amid heightened enforcement.

Representative Matters

• Defended a U.S.-based technology company in an OFAC enforcement proceeding related to Cuba sanctions, obtaining a cautionary letter instead of civil monetary penalties.
• Secured the removal of individuals and entities from OFAC’s SDN List across various sanctions programs, including the Global Magnitsky and Russia sanctions programs.
• Obtained specific licenses across Russia, Iran‑related, and cyber‑related sanctions programs to unblock and maintain accounts, investments, real estate, and maritime assets in compliance with OFAC requirements.
• Developed and executed strategies for clients sanctioned by OFAC and the United States Department of State to pursue delisting and relief from related restrictions in administrative proceedings and federal litigation.

Compliance, Licensing, and Advisory Work

• Advising technology, financial, energy, and maritime clients on sanctions compliance for global operations, including policies, screening procedures, and internal controls.
• Preparing specific license applications and requests for interpretive guidance to facilitate transactions involving sanctioned jurisdictions, state‑owned enterprises, and designated parties.
• Conducting internal investigations, voluntary self‑disclosures, and counseling on primary and secondary sanctions risks in connection with proposed transactions and counterparties.
• Advising on sanctions screening, transaction monitoring, and post‑designation asset management, including the handling of blocked or restricted accounts and property.