Luciano (Lu) Racco advises businesses from startups to large, multi-national companies in the U.S. and around the world on a wide range of international trade regulations, including sanctions and export controls under the Export Administration Regulations (EAR), Foreign Trade Regulations (FTR), International Traffic in Arms Regulations (ITAR), and Office of Foreign Assets Control (OFAC) regulations. Lu also counsels clients engaged in cross-border transactions on Committee on Foreign Investment in the United States (CFIUS) regulations. He has significant experience with anti-boycott laws, import restrictions related to the use of forced labor in supply chains (including related to Withhold Release Orders (WROs) and the Uyghur Forced Labor Prevention Action (UFLPA)), and anti-corruption laws including the Foreign Corrupt Practices Act (FCPA). His clients include companies is a wide array of industries ranging from aerospace and defense, life sciences, technology, manufacturing, software, quantum computing, and financial services, to nonprofits as well as individuals.
Lu provides trade compliance services including transaction-related due diligence, CFIUS filings, export classification determinations, export license applications, sanctions guidance, and assistance with supply chain compliance and challenges. He conducts internal investigations related to potential violations of international trade regulations and drafts voluntary disclosures to government agencies. Lu responds to inquiries and enforcement actions from government agencies and helps clients design and implement international trade compliance policies and procedures.
Lu is a member of the firm’s Tariff Task Force, a multidisciplinary initiative that draws on the firm’s global platform to guide our clients through what comes next in regards to tariffs, including tariff refund matters, tax, litigation, and M&A activity spurred by these global shifts.
Prior to private practice, Lu served as Assistant General Counsel - Global Trade at Raytheon Technologies' Collins Aerospace and Pratt & Whitney divisions. In this role, he led an international trade compliance internal audit program for the 70,000-employee company, developing risk assessments and conducting compliance audits related to sanctions and export control requirements. This in-house experience provides Lu with firsthand knowledge of the challenges companies face when implementing international trade compliance programs and results in practical, business-oriented legal advice.
Lu speaks and writes regularly on international trade matters, and his views on emerging trade issues are frequently sought after by U.S. and international media outlets.
Concentrations
•IEEPA tariff recovery
•Export controls (EAR and ITAR)
•Economic sanctions (OFAC)
•Committee on Foreign Investment in the United States (CFIUS)
•Anti-Bribery/Anti-Corruption compliance (FCPA)
•Internal investigations and responses to government enforcement actions involving alleged trade crimes
•Forced labor compliance and enforcement
•Aerospace and Defense
•Space and Satellite regulatory matters
Recognition & Leadership
Awards & Accolades
•Recipient, Political Asylum / Immigration Project (PAIR), “Outstanding Service Award,” for work securing asylum for Afghan families, 2025
•Listed, JD Supra, “Readers’ Choice Awards,” 2023-2024
•Recipient, Washington Lawyers’ Committee for Civil Rights and Urban Affairs, “Outstanding Achievement Award,” for landmark settlement with the State of Virginia concerning accommodations for deaf inmates in its prisons, 2012
