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Export & Foreign Asset Control


The firm regularly advises clients on export control and foreign asset control matters, including, but not limited to: (i) the scope of permitted exports and aircraft operations to countries that are subject to U.S. sanctions; (ii) the scope of permitted transactions involving countries and entities that may be subject to foreign asset controls; (iii) applications for specific licenses from the Office of Foreign Assets Control ("OFAC") authorizing a variety of transactions with or involving sanctioned countries (such as Cuba, Iran, Sudan, and Syria) and sanctioned targets (including Specially Designated Nationals); and (iv) applications for U.S. Department of Commerce ("DOC") licenses that authorize the exportation or reexportation of such U.S. commodities as aircraft and aircraft parts, medicines; medical devices, agricultural commodities, and humanitarian donations.  The firm has significant experience with U.S. sanctions against Cuba.  For example, the firm has assisted clients with such matters as preparing license applications, seeking changes in transportation restrictions (including airport designations), obtaining various authorizations for U.S. athletes to participate in international competitions in Cuba, and obtaining overflight waivers for charter flights transporting prominent passengers.  The firm, moreover, assists clients in developing compliance programs, training employees, and defending enforcement actions.



Practice Area Members - Export & Foreign Asset Control

Malcolm L. Benge

Lonnie Anne Pera

Selected Export & Foreign Asset Control Publications

U.S. Restrictions on Overflights and Air Transportation Services - Lonnie A. Pera, 2016.

U.S. Air Transportation Restrictions & Sanctions - Lonnie Anne Pera, 2012

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