Luciano Racco

Counsel, Co-Chair, Trade Sanctions & Export Controls Practice - Washington, D.C.

Lu Racco

Contact Information

Luciano Racco is the co-chair of Foley Hoag’s Trade Sanctions & Export Controls practice. He advises clients 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.  He also routinely counsels clients on the Committee on Foreign Investment in the United States (CFIUS) regulations, anti-boycott laws, Withhold Release Orders (WROs), and anti-corruption laws including the Foreign Corrupt Practices Act (FCPA). 

Luciano provides clients with a variety of trade compliance services, such as: transaction-related due diligence; counseling on, and the preparation of, filings to CFIUS; determining the export classifications of products; advising on and preparing export license applications; providing advice and counsel on a wide range of sanctions questions; complying with, and challenging WROs and findings of forced labor by Customs and Border Protection (CBP); delivering compliance training; and helping clients design and implement tailored international trade compliance policies and procedures. In addition, Luciano has conducted hundreds of internal investigations related to potential violations of international trade compliance regulations and has extensive experience drafting voluntary disclosures to relevant agencies. He has significant experience responding to inquiries and enforcement actions from government agencies.

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  • Vanderbilt University Law School, J.D., 2008
  • College of the Holy Cross, B.A., Economics and History, with college honors, Phi Beta Kappa, 2004


English, Italian

Representative Experience

  • Secured CFIUS clearance for a quantum computing software company in connection with funding obtained from a group of foreign investors
  • Representing manufacturer in petitioning CBP to modify WRO
  • Conducted comprehensive export classification review for leading software and services company
  • Led trade compliance due diligence for multiple Fortune 500 companies in connection with strategic acquisitions
  • Core member of investigation team in one of the largest FCPA investigations in U.S. history

Professional Experience

  • Raytheon Technologies (Collins Aerospace and Pratt & Whitney divisions), Assistant General Counsel – Global Trade
  • Led international trade compliance internal audit program for 70,000-employee company
  • Helped guide United Technologies Corporation through its Consent Agreement with the Department of State for export controls violations as both outside and in-house counsel


  • Outstanding Achievement Award from Washington Lawyers’ Committee for Civil Rights and Urban Affairs for landmark settlement with the State of Virginia concerning accommodations for deaf inmates in its prisons


  • American Bar Association
  • Connecticut Bar Association
  • District of Columbia Bar Association
  • Holy Cross Lawyers Association – Board of Directors
  • Society for International Affairs
  • The Q. Walter Peabody Foundation - President, Chairman of the Board of Directors
  • Speaker, Tech GC Roundtable, “What Every Startup Needs to Know about Export Controls,” February 24, 2022 
  • Panelist, Massachusetts Export Center’s Export Expo, “Human Rights Issues in Your Supply Chain: Compliance Risks from Withhold Release Orders and the Uyghur Forced Labor Prevention Act,” January 27, 2022
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Bar Admissions

  • Connecticut
  • District of Columbia
  • New York