Blank Rome LLP

International Trade - Customs, Export Controls And Economic Sanctions

Anthony Rapa is co-chair of Blank Rome’s International Trade practice group. A dual U.S./UK-qualified practitioner, he counsels companies, private equity sponsors, and financial institutions regarding cross-border trade, operations, and investments, drawing from on-the-ground experience spanning four continents.

Anthony is a trusted adviser to clients on matters involving economic sanctions, export controls, and investment screening involving the Committee on Foreign Investment in the United States (“CFIUS”). Global Investigations Review and Who’s Who Legal have recognized him as a leading practitioner, and he is a former member of the Law360 International Trade Editorial Advisory Board.

Anthony has advised clients across a broad range of industries, including aerospace and defense, manufacturing, automotive, aviation and aviation-adjacent, technology/software, semiconductors, emerging technologies, telecommunications, financial, freight forwarding and logistics, and energy.

Economic Sanctions

Anthony advises on the full range of issues arising under economic sanctions regulations administered by the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”), including sanctions regarding Russia, China, Iran, Cuba, and Venezuela, among others.

Export Controls

Anthony advises on all aspects of export controls, including dual-use export controls administered by the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) under the Export Administration Regulations (“EAR”), and military export controls administered by the U.S. Department of State’s Directorate of Defense Trade Controls (“DDTC”) under the International Traffic in Arms Regulations (“ITAR”).

Foreign Investment Review / CFIUS

Anthony advises clients on CFIUS requirements in the context of foreign investment in U.S. businesses and real estate. This includes advice regarding the extent of CFIUS jurisdiction, the intersection of the CFIUS rules and export controls, whether a CFIUS filing is required or warranted under the circumstances, and the preparation and submission of CFIUS filings.

Mergers and Acquisitions

Anthony has led trade and national security diligence on hundreds of transactions, valued in the tens of billions of dollars total. This includes advising on sanctions and export control risks related to the target company and its operations, negotiating transaction documents, interfacing with lenders and underwriters, and advising on CFIUS issues.

Internal Investigations

Anthony has led dozens of internal investigations around the world, including in Europe, the Middle East, and Asia. This includes preparation and submission of voluntary disclosures to the relevant agencies (OFAC, BIS, DDTC), responding to government requests for information, and negotiation of settlements.

License Requests

Anthony assists clients in obtaining licenses from regulators to engage in activities requiring specific authorization, including OFAC, BIS, and DDTC licenses.

Counseling Regarding Transactions/Operational Matters

Anthony advises clients on day-to-day counseling matters, covering all sanctions and export control issues that may arise for a company in the ordinary course of business. This includes advice regarding potential acceptance of new orders, shipments, entry into new markets, and counterparty due diligence.

Development of Compliance Programs

Anthony advises clients across many industries in the implementation of trade compliance programs, including the development of policies and procedures, and related training.

Compliance Audits

Anthony has led compliance audits for companies seeking to evaluate their trade compliance functions, including through transaction testing, gap analysis, and domestic and international site visits.

Export Control Classification

Anthony assists clients in classifying their products (hardware and software) against relevant export control lists under the EAR and ITAR, including through self-classification and, as warranted, submission of classification requests to regulators.

Information and Communications Technology and Services (“ICTS”) Rules

Anthony has advised clients regarding the ICTS rules administered by the U.S. Department of Commerce.

Supply Chain Diligence

Anthony assists clients in conducting supply chain diligence and is familiar with compliance issues presented under the Uyghur Forced Labor Prevention Act.

For Anthony's full biography, please visit  Anthony Rapa | Blank Rome LLP