Erich Ferrari

As the Founder and Principal Attorney of Ferrari & Associates, Mr. Ferrari represents U.S. and foreign corporations, financial institutions, exporters, insurers, as well as private individuals in trade compliance, regulatory licensing matters, and federal investigations and prosecutions. He frequently represents clients before the United States Department of the Treasury’s Office of Foreign Assets Control (OFAC), the United States Department of Commerce’s Bureau of Industry and Security (BIS), and in federal courts around the country. With over 13 years of experience in national security law, exports control, and U.S. economic sanctions, he counsels across industry sectors representing parties in a wide range of matters from ensuring compliance to defending against federal prosecutions and pursuing federal appeals.

Mr. Ferrari’s representations before OFAC frequently involve matters involving the Iran, Ukraine-/Russia-related, Democratic Republic of the Congo, Counter-Terrorism, and the Counter Narcotics sanctions programs. As part of these representations, he has worked to have names removed from OFAC’s Specially Designated Nationals and Blocked Persons List (SDN List), respond to OFAC administrative subpoenas issued during the course of an OFAC investigation, procure OFAC specific licenses to engage in transactions prohibited by OFAC, draft OFAC voluntary self-disclosures, develop and implement OFAC compliance programs for financial institutions and multi-national companies, and provide general counseling on OFAC related matters to a variety of client.

Mr. Ferrari has served as lead trial counsel on a number of complex federal criminal matters. He is a seasoned litigator that has obtained mistrials and acquittals for his clients in various matters including prosecutions for smuggling, and International Emergency Economic Powers Act (IEEPA) based export control charges. He has also successfully handled mail and wire fraud cases, tax fraud cases, money laundering cases, espionage cases, economic sanctions criminal cases, and federal criminal appeals. These representations have occurred in various courts across the United States and involved both U.S. and international clientele. 

Mr. Ferrari’s litigation experience includes numerous lawsuits against OFAC arising from blocking both of assets, as well as those targeting parties under various sanctions authorities. In addition, he has extensive experience representing parties in federal criminal prosecutions, including those involving export control and sanctions violations. He has also represented clients in other litigation including, for instance, federal civil forfeiture proceedings.

Mr. Ferrari actively writes on OFAC-administered trade sanctions on his blog at sanctionlaw.com as well as for publication. In addition, he is often called upon by media outlets to speak on U.S. trade sanctions issues and has been interviewed on OFAC-related issues by CNN, The New York Times, The Washington, Post, Forbes Magazine, and the Wall Street Journal.

Representative Matters

• U.S. v. Zarrab: Represented Turkish businessman in one of the largest criminal prosecutions for violations of U.S. sanctions targeting Iran to ever be charged. 
• U.S. v. Zangakani: Represented UAE-based businessman in both criminal and civil prosecutions brought under the International Emergency Economic Powers Act and federal money laundering statutes in a sanctions evasion scheme.
• DRC-Government Officials: Represented numerous current and former government officials of the Democratic Republic of the Congo in challenges to their sanctions designations both in the administrative delisting process administered by the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”), as well as in court challenges to those designations brought against OFAC.
• U.S. v. Soltech Industry Co. Ltd, and DES International: Represented two Asian corporations alleged to have engaged in violations of U.S. sanctions and export controls targeting Iran.
• Mammut Industrial Group and Related Parties: Represented Major Iranian Corporation and four derivative designees in removal of their sanctions designations under Executive Order 13882 through both OFAC’s administrative delisting process, as well as in court challenges brought against OFAC. Have thus far removed three of the five designees targeted under that action.