U.S. Sanctions: Regulatory Developments

Mr. Rapa leads Blank Rome’s National Security team. A dual U.S./UK-qualified practitioner with on-the-ground experience spanning four continents, he counsels companies and private equity sponsors regarding cross-border trade, operations, investments, and geopolitical strategic planning. A former member of the Law360 International Trade Editorial Advisory Board, Mr. Rapa is a trusted advisor to clients on matters involving economic sanctions, export controls, and investment screening involving the Committee on Foreign Investment in the United States. He has advised clients across a broad range of industries, including aerospace and defense, manufacturing, automotive, aviation and aviation-adjacent, technology/software, semiconductors, telecommunications, maritime, financial, shipping, freight forwarding and logistics, and energy.

Mr. Mullick has a broad range of experience providing counsel on export controls administered by the Department of Commerce Bureau of Industry and Security (BIS) under the Export Administration Regulations (EAR); the Department of State Directorate of Defense Trade Controls (DDTC) under the International Traffic in Arms Regulations (ITAR); and the Department of Energy’s rules on nuclear exports, as well as economic sanctions administered by the Department of the Treasury Office of Foreign Assets Control (OFAC). He also advises on compliance and enforcement matters concerning the Bureau of Customs and Border Protection (CBP) and foreign trade zones (FTZ). He advises companies, sponsors and investors on export controls and sanctions risk assessment in conjunction with investments, offerings and mergers and acquisitions.

Ms. Cotterill provides legal advice to companies, financial institutions, and private equity sponsors on the regulatory and other risks of operating or investing across international borders. She focuses her practice on international trade and anticorruption compliance and investigations. She has broad experience on matters involving the economic sanctions administered by the U.S. Department of the Treasury Office of Foreign Assets Control (OFAC); the export controls administered under the Export Administration Regulations (EAR) of the U.S. Department of Commerce Bureau of Industry and Security (BIS) and the International Traffic in Arms Regulations (ITAR) of the U.S. Department of State Directorate of Defense Trade Controls (DDTC); and anticorruption compliance counseling in matters involving the Foreign Corrupt Practices Act.