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Significant Cases and Outcomes

Ferrari & Associates not only represents clients in high-profile or significant cases, it achieves results in those cases. It is often hard to guess how OFAC will react to certain submissions or arguments. Further, it can be difficult to predict whether results can be achieved in matters pending before OFAC, given that they often rely on policies, guidance, and information that is not publicly available. Nevertheless, over the years, the OFAC lawyers at Ferrari & Associates have been able to successfully represent their clients before OFAC based on their understanding of OFAC’s procedures, policies, and legal interpretations. This success can take many forms ranging from obtaining additional information to allow a designated party to understand the true reasons behind their designation to helping a bank or multinational corporation institute a sanctions compliance program. While there is always a level of uncertainty when dealing with OFAC, the cases noted below show that our firm has a track record of success in dealing with OFAC and achieving results for our clients.

Multi-National Oil & Gas Company

Ferrari & Associates represented a U.S.-headquartered multinational oil and gas company in an OFAC enforcement investigation into apparent violations of the Iran and Ukraine-/Russia-related sanctions programs. That investigation was successfully resolved through the issuance of a warning letter.

Multi-National Law and Intellectual Property Firm

Representation of a global law and intellectual property firm with offices in multiple embargoed jurisdictions. The representation involved our successful re-establishment of the client’s banking relationships with U.S. financial institutions and the augmentation of its sanctions compliance policies and procedures to ensure maintenance of those re-established relationships.

Financial Services Firm

Provided advice and counseling to a UK-based financial institution with respect to dealings in Government of Venezuela debt in order to ensure compliance with U.S. sanctions. Advice was relied upon to engage in the transactions in full compliance with U.S. law.

Global Financial Institution

Represented the U.S. branch of a major global financial institution in preparing a voluntary self-disclosure to OFAC concerning apparent violations of the Iran sanctions program. OFAC issued a cautionary (warning) letter in that matter and took no further actions against the bank.

European Ship Owner

Provided advice and counseling to a European ship owner with respect to their designation under the Venezuela sanctions program, as well as that of their ship and the charterer of that ship. The client followed our advice and was able to successfully delist themselves and their ship.

Multi-National Spirits Retailer

Ferrari & Associates represented a multi-national alcohol distributor in the investigation of numerous transfers blocked by U.S. financial institutions, in the preparation of license applications to OFAC to unblock those transfers, and in requesting guidance from OFAC as to whether, by operation of U.S. law, OFAC deemed the client to be blocked. OFAC returned guidance that the client was not blocked and issued licenses unblocking all blocked funds transfers.

African Financial Institution

Representation of an African financial institution before OFAC. The bank had been publicly accused of engaging in sanctionable activity. We successfully represented the bank by gathering, assessing, and submitting exculpatory information to OFAC rebutting those allegations and helped install policies, procedures, and other remedial steps to ensure that the bank was not sanctioned.

Audio Equipment Manufacturer

Represented a major U.S. audio equipment manufacturer in an OFAC enforcement matter arising from a subpoena issued by OFAC. Successfully obtained a cautionary (warning) letter in that matter.

Multi-National Medical Equipment Manufacturer

Long term representation of a multinational medical equipment manufacturer with respect to U.S. sanctions and export control compliance and licensing matters. Have successfully obtained numerous OFAC and BIS licenses on their behalf, thereby ensuring their ability to sell to certain embargoed jurisdictions.