这名高管虽所在银行早已被制裁，自己却仍对被点名感到震惊。此人既无明显政治关系，也不特别富有，且与军方无关，还正准备离职。经同事建议后，他联络了华盛顿律师Erich Ferrari；Ferrari自2009年创办Ferrari & Associates以来，专门协助个人与企业从美国制裁名单中移除，并已帮助超过100名个人和实体解除制裁。
美国制裁已成为一个数十亿美元产业。据Center for a New American Security称，去年财政部又把1,764名个人和实体加入SDN名单；如今还有制裁会议、行业组织与年度奖项。Ferrari也因此受益，并多次起诉OFAC，超过50次把财政部告上法庭。他辩称，这是对政府权力的必要制衡；批评者则指责他在帮助涉入杀戮、酷刑和战争罪的人逃避惩罚。
In spring 2022, a Russian bank executive learned from a US Treasury press release that life was about to get much harder. In response to Vladimir Putin’s invasion of Ukraine, the US imposed another round of sanctions on Russia, aiming to weaken its economy and deprive its war machine of funds. The latest tranche hit the executive, dozens of other financial-industry figures, three state-run TV stations, and a rifle maker.
Although the bank itself had already been sanctioned, the executive was shocked to be personally listed. With no clear political ties, no military work, and a recent plan to resign, the person sought help and was told to contact Erich Ferrari. Since founding Ferrari & Associates in 2009, Ferrari has built a practice devoted to getting people and companies removed from US sanctions lists, and he says his firm has delisted more than 100 individuals and entities.
US sanctions have become a multibillion-dollar industry. The Treasury added 1,764 individuals and entities to the SDN list last year, and sanctions conferences, trade groups, and awards now exist around the field. Ferrari has also sued OFAC more than 50 times, portraying litigation as a check on government power, while critics accuse him of helping alleged killers, torturers, and war criminals avoid punishment.