Jonathan M. Epstein is a partner in Holland & Knight's Washington, D.C., office where he focuses his practice on international trade and aviation law. Mr. Epstein's trade practice includes advising clients in the aerospace, electronics, agrochemical, biochemical and other high-technology industries on export, import and related trade issues. His aviation practice focuses on representing clients before the Federal Aviation Administration (FAA) and the Department of Transportation (DOT), and assisting clients in corporate jet transactions and structuring of corporate aircraft operations to comply with FAA regulations.
In the area of International Trade Law, Mr. Epstein has for many years represented clients on regulatory matters before various government agencies including:
assisting clients in the defense/aerospace industry with registration, drafting of licenses, technical assistance agreements, voluntary disclosures, and compliance programs under the International Traffic Arms Regulations (ITAR) and in liaising with the State Department Directorate of Defense Trade Controls (DDTC)
representing telecommunications, agrochemical, electronics, and biochemical companies before the Department of Commerce Bureau of Industry and Security (BIS) on a wide range of commercial exports issues including licensing, classification, encryption reviews, investigations, civil penalty cases, and compliance issues under the Export Administration Regulations (EAR)
advising clients on the scope and application of U.S. economic embargoes administered by the Office of Foreign Assets Control (OFAC), including extraterritorial application of U.S. embargoes to non-U.S. companies
assisting clients in Customs and import matters including classification, valuation, penalty cases, protests, and country of origin determinations
guiding clients through regulatory hurdles common in cross-border acquisitions, such as Exxon-Florio filings before the Committee on Foreign Investment of the United States (CFIUS), transfer authorizations required by other government agencies relating to radio licenses and air carrier authorizations, and negotiating and putting in place mitigation measures acceptable to the Department of Defense to mitigate Foreign Ownership, Control, or Influence (FOCI)
In support of Holland & Knight's large aviation practice, Mr. Epstein has developed considerable experience in a wide range of regulatory and commercial matters related to the aviation/aerospace industry, including:
advising clients in structuring of private/corporate aircraft operations to comply with FAR 91.501, including negotiating and drafting aircraft leases, time sharing, interchange, and charter management agreements
assisting clients in purchasing and selling corporate aircraft and fractional share purchases and resale
representing clients before the Federal Aviation Administration (FAA) in HAZMAT and Suspect Unapproved Parts investigations and civil penalty proceedings; and airport issues including FAA "no hazard" determinations for towers and for construction proximate to airports
assisting commercial aviation clients in proceedings before the Department of Transportation (DOT) including civil penalty proceedings and foreign air carrier exemption, code-sharing, and commuter air carrier authorization proceedings
Mr. Epstein's background also includes experience in telecommunications law (primarily on satellite and spectrum allocation issues), liability and policy issues relating to commercial use of the Global Positioning System, and aviation related tort and contracts litigation.
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