Anthony Rapa


Anthony 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.

Anthony has been recognized as a leading practitioner by the Legal 500, Who’s Who Legal, and Global Investigations Review. A former member of the Law360 International Trade Editorial Advisory Board, he 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 ("CFIUS").

Anthony 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.

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”).

Mergers and Acquisitions

Anthony has led trade and national security diligence on hundreds of transactions, valued in the tens of billions of dollars total. 

On buy-side deals, this includes advising on sanctions and export control risks related to the target company and its operations, managing risks through terms in the transaction documents, seeking mitigation of compliance issues pre-closing, interfacing with lenders and underwriters, and advising on national security issues that could subject the transaction to CFIUS review. 

On sell-side deals, this includes working to confirm that the company is “exit-ready,” including through identification and remediation of compliance issues, negotiation of transaction documents, and drafting of disclosure schedules.

Internal Investigations

Anthony has led dozens of internal investigations around the world, including complex, large-scale investigations involving collection of data across borders, including in Europe, the Middle East, and Asia. This includes development of investigation work plans, management of data privacy issues, collection and processing of data, interviewing of witnesses, submission of voluntary disclosures to the relevant agencies (OFAC, BIS, DDTC), responding to government requests for information, and negotiation of settlements.

Anthony’s experience includes the closeout of several large-scale enforcement matters without a penalty.

License Requests

Anthony assists clients in obtaining licenses from regulators to engage in activities requiring specific authorization, including OFAC, BIS, and DDTC licenses. This work includes submission of license applications and, as warranted, advocacy before the relevant agency.

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. This has included, for example, ITAR compliance audits for companies in the aerospace and defense industry.

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. This has included, for example, a comprehensive export control assessment for the entire product range of a large manufacturing company.

Information and Communications Technology and Services ("ICTS") Rules

Anthony has provided cutting-edge advice to clients regarding the recently implemented ICTS rules administered by the U.S. Department of Commerce, which figure to evolve into a CFIUS-type regime of particular interest to the technology and telecom industries.

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. This includes development of diligence questionnaires, liaising with suppliers, synthesis of diligence responses, and assessment of human rights and related issues.

Thought Leadership

Anthony actively engages in the marketplace of ideas regarding international trade and national security issues.  He has been quoted by the Associated Press, CNBC, The Wall Street Journal, Compliance Week, Law360, and others, and has contributed articles to publications including Reuters Legal, Bloomberg Law, New York Law Journal, and Law360. He also actively participates in speaking engagements, including webinars organized by Strafford, Federal Publications Seminars, and the Society of Industrial Security Professionals.

Outside the Firm

Born and raised in New York City, Anthony is a proud Yankee fan, an avid chef (particularly of Italian food), and a classic rock devotee. He and his wife live on a farm in Virginia with their corgi-lab mix.


  • Conducted a cross-border sanctions internal investigation for a global logistics provider.
  • Conducted a cross-border sanctions internal investigation for a large French company.
  • Conducted a sanctions internal investigation for a large European manufacturer.
  • Conducted internal investigations for the UK and Italian subsidiaries of a large aerospace and defense company.
  • Conducted internal investigations for a large aerospace and defense company under a consent agreement.
  • Conducted an export controls internal investigation for a U.S. cybersecurity company.
  • Conducted export controls compliance audits in Saudi Arabia and Spain for a large aerospace and defense company.
  • Conducted a comprehensive export controls compliance audit across the three subsidiaries of a U.S. aerospace and defense company.
  • Conducted comprehensive compliance policy review, export control classification exercise, and supply chain review for a large European manufacturer.
  • Conducted a sanctions risk assessment for an Australian mining company.
  • Conducted a sanctions risk assessment for a Norwegian energy company.
  • Advised a semiconductor developer / government contractor with respect to export control and CFIUS issues identified in the course of its sale to a European investor, including an internal investigation of compliance issues, preparation and submission to DDTC of a voluntary disclosure, and review of a CFIUS mitigation agreement, resulting in closeout of DDTC matter without penalty and clearance of transaction by CFIUS.
  • Advised semiconductor foundry / government contractor in acquisition by an investor, conducting comprehensive export control classification assessment of the company’s products and liaising with buyer’s counsel.
  • Advised private equity sponsor on ten-figure acquisition of large cybersecurity company / government contractor, leading international trade due diligence, identifying material compliance issues, negotiating a special indemnity in the purchase agreement, driving remediation of the compliance issues, and taking the transaction through closing and successful closeout of enforcement matter by authorities.
  • Advised private equity sponsor in acquisition of Israeli defense contractor, leading international trade due diligence.
  • Advised private equity sponsor in acquisition of assets of defense contractor, assisting buyer in obtaining an ITAR registration and implementing compliance policies and procedures pursuant to transition services agreement.
  • Advised Japanese electronics company on its entry into U.S. defense business, including with regard to strategic planning, obtaining an ITAR registration, and implementing compliance policies and procedures.
  • Developed sanctions and export control compliance policies for implementation at portfolio companies of large private equity sponsors.
  • Developed a comprehensive sanctions compliance policy for a Singapore-based bank.
  • Conducted export control jurisdiction and classification assessment for aerospace and defense company.
  • Advised aerospace and defense company in preparation and submission of export license requests.

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  • 2021, International Trade, listed in The Legal 500 United States
  • 2018–2020, “Future Leader,” Investigations, listed in Who’s Who Legal
  • 2017, “40 Under 40,” listed in Global Investigations Review



  • District of Columbia
  • England and Wales
  • New York
  • United States Court of Federal Claims


  • Drew University, BA, summa cum laude
  • Seton Hall University School of Law, JD, summa cum laude