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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 export and reexport controls; (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 (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, medicine; medical devices, agricultural commodities, and humanitarian donations.  The firm has significant experience with the U.S. embargo against Cuba.  For example, the firm has assisted clients with such matters as preparing service provider license applications, seeking changes in the transportation limitations (including airport designations), obtaining various authorizations for U.S. athletes to participate in international competitions in Cuba, obtaining overflight waivers for charter flights transporting prominent passengers, and defending enforcement and civil penalty matters before OFAC and DOC.   The firm, moreover, provides advice to clients on export and foreign asset control compliance programs.


Practice Area Members - Export & Foreign Asset Control

Malcolm L. Benge

Lonnie Anne Pera

Rachel B. Trinder

Selected Export & Foreign Asset Control Publications

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

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