Jonathan Epstein
Practices: Communications | Aviation | Aviation Regulation | Business Aviation | Satellite and Space Technology | China Practice | Cuba Action Team | International and Cross Border Transactions | International Trade | Anti-Money Laundering | Customs and Products Importation | Industrial Security | Trade Litigation | U.S. Antiboycott Laws | U.S. Export Control and Sanctions Laws | Cybersecurity and Privacy | Transportation of Hazardous Materials | Corporate Services | Financial Services | Maritime Regulatory, Government and Security | Risk and Crisis Management | Korea Practice Client
Sectors: Transportation & Infrastructure | Technology & Telecommunications Jonathan M. Epstein is a partner in the Washington, D.C. office of Holland & Knight. His aviation practice focuses on assisting clients in business aircraft transactions and the related structuring of business aircraft operations. He also represents commuter and charter air carriers on regulatory matters before the Federal Aviation Administration (“FAA”) and the Department of Transportation (“DOT”).
Mr. Epstein’s commercial and regulatory experience includes:
• Representing individuals and companies in the purchase and sale of business aircraft, and advising clients on how to structure aircraft transactions for tax planning purposes, loan documentation, and FAA regulatory compliance
• Advising clients in structuring of private and corporate aircraft operations, including negotiating and drafting leases, charter management, joint ownership, time sharing, interchange, and pilot services agreements
• Advising clients on fractional share purchases and resale
• Representing clients before FAA in HAZMAT and Suspect Unapproved Parts investigations and civil penalty proceedings; and airport issues
• Representing charter air carries on “operational control” issues before the FAA, and in restructuring charter management arrangements to comply with FAA requirements, including OPSPEC A008
• Representing commercial aviation clients in proceedings before DOT including civil penalty proceedings and foreign air carrier exemption, citizenship reviews, code-sharing, and commuter air carrier authorization proceedings
• Supporting air carriers and aerospace manufacturing companies involved in mergers and acquisitions with regulatory filings, aviation specific due diligence, and corporate structuring issues
• Advising clients ranging from individual purchasers to large aerospace companies on U.S. Customs tariff and importation requirements, and on export issues ranging from licensing exports of aircraft under the International traffic in Arms Regulations (ITAR), to advising airlines on issues relating to U.S. embargoes
• Advising unmanned aerial vehicle manufacturers in meeting civil registration requirements and on radio spectrum/frequency issues, both domestically and abroad Mr. Epstein’s background also includes experience in international trade law, 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.
Honors & Awards
• Chambers High Net Worth guide, Private Aircraft: Global-wide, 2017
• Georgetown Journal of Legal Ethics, Editor-in-Chief
Memberships
• United States Navy, Line Officer
• National Business Aviation Association, Regulatory Issues Advisory Group
Publications
• Corporate Compliance Answer Book, Export Controls Chapter, Practising Law Institute, 2018 Edition • U.S. Government Issues Guidance on Expanded Russia Sanctions, Holland & Knight Alert, November 9, 2017
• ExxonMobil Fined $2 Million for Ukraine/Russia Sanctions Violations, Holland & Knight Alert, July 31, 2017
• Trump Administration Sanctions Iran in Response to Missile Test, Holland & Knight Alert, February 7, 2017
• Corporate Compliance Answer Book, Export Controls Chapter, Practising Law Institute, 2017 Edition
• Reestablishment of Scheduled Air Service Between the United States and Cuba:
What Is the Impact on Aircraft Finance?, Holland & Knight Aviation Law Blog, February 17, 2016
• Implementation Day: Iran Sanctions Relief Officially Takes Effect, Holland & Knight Alert, January 19, 2016
• Implementation of Iran Accord Potentially Big News for the Commercial Aviation Industry, Holland & Knight Aviation Law Blog, January 19, 2016
• Corporate Compliance Answer Book, Export Controls Chapter, Practising Law Institute, 2016 Edition
• What Does the Iran Accord Mean for the Commercial Aviation Industry?, Holland & Knight Aviation Law Blog, August 18, 2015
• Implications of the Iran Accord for the Maritime Industry, Holland & Knight Alert, July 22, 2015
• Impact of Iran Accord on International Business, Holland & Knight Alert, July 15, 2015
• Are Your Portfolio Aircraft Flying to Havana?, Holland & Knight Aviation Law Blog, July 1, 2015
• Cuba Travel Resources: Restrictions on Flying to Cuba Still Largely Intact, Co-Author, National
Business Aviation Association (NBAA) Guidance, February 13, 2015
• What Will Be the Impact of Relaxed U.S.-Cuba Restrictions?, Inter-American Dialogue Financial Services Advisor, January 23, 2015
• U.S. Imposes Further Sanctions on Russia and the Crimea Region, Holland & Knight Alert, December 24, 2014
• U.S. Begins Easing Cuba Embargo: New Opportunities and Challenges, Holland & Knight Alert, December 23, 2014
• Corporate Compliance Answer Book, Export Controls Chapter, Practising Law Institute, 2015 Edition
• Fifth Round of Sanctions Target Certain Russian Banks, Energy Companies and Arms Manufacturers, Holland & Knight Alert, July 17, 2014
• Coping with Rapidly Expanding U.S. Sanctions on Russia, Holland & Knight Alert, May 13, 2014
• Crisis in Ukraine: U.S. Imposes Additional Sanctions Targeting President Putin’s Inner Circle, Holland & Knight Alert, March 24, 2014
• Crisis in Ukraine: U.S. Imposes Targeted Sanctions, Holland & Knight Alert, March 6, 2014
• Economic Sanctions in Iran: Coping with the Changing Landscape, Co-Author, Ethisphere Magazine, March 2014
• Temporary Easing of Sanctions on Iran to Go Into Effect Jan. 20, 2014, Holland & Knight Alert, January 14, 2014
• Corporate Compliance Answer Book, Export Controls Chapter, Practising Law Institute, 2014 Edition
• Initial Export Control Reforms Take Effect: Is Your Company Ready?, Compliance Alliance Update, October 2013
• Placing Your Aircraft with an Aircraft Charter-Management Company, Holland & Knight Alert, September 30, 2013
• Major Changes to U.S. Export Laws Go into Effect October 15, 2013: Is Your Company Ready?, Holland & Knight Alert, August 2, 2013
• Expanded U.S. Sanctions on Iran Effective July 1, 2013, Holland & Knight Alert, June 6, 2013
• The View From Above: How Export Control Reform Will Impact Aviation, WorldECR, March 2013
• How Will the Aviation Industry Be Affected by Export Control Reforms?, February 25, 2013
• Iran Sanctions Update, Holland & Knight Alert, January 16, 2013
• Corporate Compliance Answer Book, Export Controls Chapter, Practising Law Institute, 2013 Edition
• Iran Sanctions: U.S. Bans Foreign Subsidiaries of U.S. Companies from Doing Business with Iran, Holland & Knight Alert, October 11, 2012
• Iran Sanctions: U.S. Significantly Expands Sanctions Against Iran Considerably Limiting Trade in Petroleum Products to and from Iran, Holland & Knight Alert, August 16, 2012
• Further Round of U.S. Sanctions on Iran Likely if Diplomatic Talks Do Not Succeed, Holland & Knight Alert, May 29, 2012
• Corporate Compliance Answer Book, Export Controls Chapter, Practising Law Institute, 2012 Edition
• New U.S. Law Targets Foreign Financial Institutions Involved in Significant Financial Transactions With Iran, Holland & Knight Alert, January 5, 2012
• U.S. Tightens Sanctions on Iran: Targets Petroleum/Petrochemical Trade and Financial Sector With Further Extraterritorial Sanctions, Holland & Knight Alert, November 30, 2011
• Recent Iran Sanctions Act Designations Target Maritime Industry, Holland & Knight Alert, June 3, 2011
• United States Imposes Sanctions on Qadhafi Family and the Libyan Government and Its Entities, Holland & Knight Alert, March 1, 2011
• Expansion of Travel Opportunities to Cuba, Holland & Knight Alert, February 9, 2011
• OFAC Issues Regulations Implementing Recent Iran Sanctions Legislation, Holland & Knight Alert, August 18, 2010
• Game-Change Alert: FAA Proposes Enhanced Oversight Over Foreign Aircraft Operators, CoAuthor, Airline Fleet Management, July 2010
• Corporate Compliance Answer Book, Export Controls Chapter, Practising Law Institute, 2010 Edition
• Developments in HAZMAT Regulations: Shipping Lithium Batteries by Air, Holland & Knight Newsletter, May 2010
• New Rules Regarding Telecommunications Service to Cuba, Holland & Knight Alert, December 1, 2009
• The U.S. Dual-Track Strategy of Economic Sanctions and Engagement with Iran: Recent Developments and Potential Impact on Foreign Businesses, ABA Section of International Law: International Trade Committee Newsletter, November 25, 2009
• The U.S. Dual-Track Strategy of Economic Sanctions and Engagement With Iran: Recent Developments and Potential Impact on Foreign Businesses, Holland & Knight Alert, November 3, 2009
• Optimizing Structures for Business Aircraft Ownership and Operations, Holland & Knight Newsletter, October 2009
• Cuba: New Regulations Implementing Presidential Policy, Holland & Knight Alert, September 11, 2009
• Buying and Operating Business Aircraft in the Current Economic Environment, Holland & Knight Newsletter, June 2009
• Required Security Programs for Large Private Aircraft, Holland & Knight Newsletter, February 2009
• Corporate Compliance Answer Book, Export Controls Chapter, Practising Law Institute, 2009 Edition
• International Aviation Transactions: Compliance With U.S. Export and Embargo Restrictions, Holland & Knight Newsletter, November 2008
• Export Controls 2007 in Review: Practical Advice for Updating Your Export Compliance Program, Holland & Knight Alert, January 24, 2008
• Use of Private Aircraft by Members of Congress and Federal Candidates Under New Ethics Reforms, Holland & Knight Newsletter, December 2007
• Exporting Commercial Goods And Technology To China Under The New Military End-Use Restrictions, The Metropolitan Corporate Counsel, December 1, 2007
• New Restrictions on Exports of Aircraft and Other Products to China Under New “Military Catch-All” Regulations, Holland & Knight Newsletter, August 31, 2007
• The New China “Military Catch-All” Regulations: End-Use Restrictions on Certain Commercial Exports to China, Holland & Knight Alert, June 28, 2007
• Department of Transportation Proposal Regarding Charter Operations, Holland & Knight Newsletter, February 2007
• FAA Implementing New Policy on Operational Control for Charter Operators, Holland & Knight Newsletter, February 2007
• Trends in U.S. Export Control Policy – How Do They Affect Your Company?, Holland & Knight Alert, January 8, 2007
• The China “Military Catch-All” Rule: The U.S. Department of Commerce Proposal to Impose New Restrictions on Exports to China, Holland & Knight Alert, October 30, 2006
• Update on FAA Policy Regarding “Operational Control” in Charter Management Arrangements, Holland & Knight Newsletter, October 13, 2006
• Export Controls Update: Practical Advice For Updating Your Export Compliance Program, Holland & Knight Alert, February 3, 2006
• National Security Issues in Cross-Border Mergers, Acquisitions, & Joint Ventures, June 2, 2004
• Weathering U.S. Customs Focused Assessment, Metropolitan Corporate Counsel, May 2004
• National Security Issues in Cross Border Acquisitions & Joint Ventures, Metropolitan Corporate Counsel, May 2004
• Weathering a U.S. Customs Focused Assessment, February 1, 2004
• Complying with U.S. Embargo and PATRIOT Act Requirements: A Practical Approach for U.S. Company Compliance, February 1, 2004
• Contact a Holland & Knight Trade Lawyer, November 13, 2001
• Exporting Commercial Satellite Technology: Coping in the Current Regulatory Environment, October 1, 2001
• FCC Audit of Radio Licenses Held by Many Industries and Municipal Agencies, Holland & Knight Alert, September 5, 2001
• Driver Distraction And The Use Of Wireless Phones And Other In-vehicle Technologies, Holland & Knight Newsletter, December 5, 2000
• Information Security: New Encryption Rules Give U.S. Companies Opportunity to Compete, Metropolitan Corporate Counsel, May 2000
Speaking Engagements
• Tracking Controlled Data, TCP Integration, and Access by Third-Parties and End-Users, American Conference Institute’s 9th National Export Controls Forum on Technology Transfers, Cloud Computing & Deemed Exports, October 19, 2016
• Iranian Sanction: How the Lifting of Sanctions Has Impacted Shipping and International Trade, Ince & Co London Seminar, May 24, 2016
• Iran Sanctions Update, Thomson Reuters Complimentary Webcast, March 2, 2016
• ABA Forum on Air & Space Law’s 2015 Aviation Finance Conference, Flight Operations to Cuba: New Opportunities, New Challenges, December 3, 2015
• National Business Aviation Association’s 2015 Convention, November 17-19, 2015
• Doing Business in Sanctions “No Man’s” Land, Thomson Reuters Complimentary Webcast, October 8, 2015
• Chief Pilots Roundtable, National Business Aviation Association, October 7, 2015
• ABA Aircraft Financing Subcommittee 2015 Spring Meeting, The Thawing of U.S./Cuba Relations and the Impact on U.S. Commercial, Business and General Aviation, April 16-17, 2015
• U.S. Policy Shift on Cuba: Three-Month Assessment, Inter-American Dialogue Program, March 23, 2015
• Cuba Sanctions Update, Massachusetts Export Center Webinar, March 12, 2015
• Focus on EXPORT: Exporting Off-Lease Equipment to the Global Marketplace, Equipment Lease Finance Association (ELFA), Equipment Management & Convention, February 22-24, 2015
• ABA Forum on Air & Space Law’s 2014 Aviation Finance Conference, Moderator, US/EU Sanctions on Russia - Managing Sanctions Risk in Aviation Financing, December 4, 2014
• Avoiding Export Control & Economic Sanctions Missteps, ABA TIPS Aviation & Space Law Committee Meeting, October 22-23, 2014
• Russian Sanctions Trade War: Global Sanctions Against Russia Lead to Russian Retaliatory Sanctions, Thomson Reuters Webcast, October 15, 2014
• Navigating the Rocks and Shoals of Economic Sanctions, 2014 Pacific Admiralty Seminar, October 9-10, 2014
• Developing an Integrated Global Trade Compliance Program, Massachusetts Export Center Webinar, October 3, 2014
• Protecting EAR and ITAR-Controlled Technical Data Overseas, and Complying with the Deemed Export and ITAR Dual/Third Country National Rules, American Conference Institute 17th National Forum on Global Export Control Compliance, June 12-13, 2014
• Russian Sanctions: What the U.S. and OFAC Directives Mean for Global Companies, Ethisphere Webinar, June 11, 2014
• Export Controls in Science Collaboration, Department of Energy Contractor Attorneys’ Association Conference, May 29-30, 2014
• Latest International Insurance Regulatory Developments, Private Placement Life Insurance (PPLI) & Annuities (PPVA), May 20, 2014
• Coping With Rapid Changes in Economic Sanctions, 2014 INTERTANKO Conference, May 9, 2014
• Classification and Jurisdictional Determinations for ITAR-Controlled Products, Momentum ITAR Summit, January 27-28, 2014
• Easing of Sanctions on Iran: New Opportunities and Risks for the Aviation Industry, Aviation Maintenance Magazine (AVM) Summit, January 21-22, 2014
• ABA Aviation Finance Conference, Export Control – What Should the Aviation Industry Know?, December 5, 2013
• What You Should Know About U.S. Export and Embargo Laws (and How They Are Changing), Aviation Maintenance Magazine (AVM) Summit, November 21-22, 2013
• How to Structure “Charter-Management” Arrangements to Comply with FAA Requirements, National Business Aviation Association Convention, October 22-24, 2013
• American Conference Institute ITAR Boot Camp, October 8, 2013
• 2013 Latin America/US M&A Trends, Trade and Regulation Forum, Speaker, Trade Issues: US and LATAM Perspectives, June 20-21, 2013
• Practical Advice on Export and Embargo Laws in Cross-Border Aircraft Transactions, 20th Annual Aircraft Transaction Forum, March 5, 2013
• Technology Control Plans, International Technology Transfers & Deemed Export Compliance, American Conference Institute, San Francisco, CA, January 28, 2013
• Complying with U.S. Economic Sanctions, Export Controls and Anti-Corruption Laws in Aircraft Transactions and Flight Operations, National Business Aviation Association’s 65th Annual Meeting & Convention, October 31, 2012
• Roundtable with the Departments of State and Treasury on Implementation of the Latest Sanctions on Iran, Moderator, Washington Foreign Law Society, American Society of International Law, ABA Section of International Law, September 28, 2012
• Connecticut Maritime Association Annual Shipping Conference and Exhibition, March 19-21, 2012
• American Conference Institute ITAR Boot Camp, February 18-29, 2012
• How to Avoid Running Aground on U.S. Sanctions, Holland & Knight CLE Seminar, February 17, 2012
• American Conference Institute Advanced ITAR Compliance Conference, “Determining Eligibility for U.S. Government, Technical Data, Temporary Import and Canadian Exemptions: Weighing the Risks of Exemption Misuse against Applying for a License”, July 14, 2011
• Issues for the Shipping Community, Gard (North America) Inc., New York, NY, September 30, 2010
• Export Licensing Under ITAR, June 23, 2010
• Export Logistics and Regulatory Compliance Certificate Series, Massachusetts Export Center, November 7, 2008
• ITAR Bootcamp: A Hands-On Workshop for Compliance, Massachusetts Export Center and Massachusetts Alliance for International Business Seminar, June 12, 2008
Education
• Georgetown University Law Center, J.D., cum laude
• Hamilton College, B.A., magna cum laude
Bar Admissions
• District of Columbia
• Maryland
• Virginia
