Admissions
- New York
- Washington, DC
- U.S. District Court for the Eastern District of New York
Education
- Georgetown University Law School, J.D., 1994
- University of California, Berkeley, M.S., Structural Engineering, 1987
- University of California, Santa Barbara, B.S., Mechanical Engineering, 1984
Languages
- Farsi
Overview
Mr. Hoghooghi joined BCR more than ten years ago and has been the firm’s Managing Partner since January 2023. His practice is primarily focused on U.S. economic sanctions. His extensive experience on matters relating to U.S. economic sanctions have included representation of numerous clients in the U.S. and abroad, providing them with advice and counsel about compliance with the ever-changing and complex array of U.S. primary and secondary sanctions on Afghanistan (Taliban), Iran, Russia, Syria, Venezuela, Yemen (Ansarullah) and other countries, as well as other U.S. sanctions programs (i.e., Global Magnitsky). He has represented clients with respect to SDN delistings and licensing matters, including for the release of blocked funds or other properties, and in connection with voluntary disclosures, investigations, and civil/criminal enforcement actions before the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) and the U.S. Department of Justice (DOJ).
Having practiced law for about thirty years, Mr. Hoghooghi has also represented clients on a wide range of domestic and international commercial and corporate matters. He has acted as counsel to Fortune 500 companies and small to medium size businesses in connection with the acquisition or sale of business entities or commercial assets, as well as the structuring and development of projects including major domestic and international infrastructure and power projects. He has also represented borrowers and lenders in connection with the financing of projects by commercial banks and export credit agencies.
Mr. Hoghooghi was a founding Board Member and the first President of the Iranian American
Bar Association for five years, beginning in 2000.
Practice Focus
- Economic Sanctions (OFAC), including licensing & compliance, delistings, civil and criminal enforcement actions
- Corporate & Transactional
Representative U.S. Economic Sanctions Experience
- Representing ten individual clients facing extradition to the U.S. and/or criminal prosecution in U.S. courts for alleged violations of U.S. sanctions
- Representing four clients with respect to their OFAC petitions for removal from the SDN List
- Advising clients concerning the potential application of U.S. secondary sanctions relating to the Nordstream and Turkstream gas pipeline projects
- Advising export credit agencies of two major Asian countries with respect to the potential application of U.S. secondary sanctions
- Submission of U.S. sanctions expert statement before a German court in a dispute involving a prominent European bank and a major insurance company
- Representing clients, including a major international law firm, in significant international court cases or arbitration matters involving U.S. sanctions issues
- Representing a European company with respect to an OFAC license application to unblock significant funds & ensuing civil forfeiture proceedings initiated by the DOJ
- Representing an Asian company in connection with criminal proceedings initiated by the DOJ involving alleged violations of U.S. sanctions on North Korea
- Representing clients to provide advice and counsel regarding the Oil Price Cap Policy directed at Russia and trading in Russian oil
- Providing sanctions compliance advice to U.S. clients with respect to the distribution and marketing of an award-winning Iranian film in the U.S. and with respect to an OFAC license for the shooting and production of a movie in Iran
- Providing compliance advice to a number of U.S. or European clients engaged in humanitarian exports to Iran or charitable activities in Iran, Afghanistan, or Yemen