Jeremy Iloulian

Strategic Guidance and Crisis Situations

• Provided weekly guidance to a top 10 U.S. private equity firm on investments in, and exposure to, high-risk markets (e.g. China, Russia).
• Developed and implemented an assessment of a U.S. private equity firm’s portfolio companies for compliance with U.S. trade and national security laws.
• Fashioned an export-compliant Russia-exit strategy for an EU-based financial institution.
• Advised a South Korean technology company on ongoing operations and support in Russia.

Internal Investigations

• Represented a U.S. government contractor for an internal investigation and voluntary self-disclosure to BIS and NSD regarding exports to China, Russia, and other locations in Europe, as well as the Middle East and Asia, with investigation touchpoints in the United States, Europe, Southeast Asia, and East Asia.
• Represented a Southeast Asia-based technology company for an internal investigation and voluntary self-disclosure to OFAC regarding transactions involving Cuba and Iran, with investigation touchpoints in the United States, South Asia, Southeast Asia, Latin America, and the Middle East.
• Represented a U.S. academic institution for an internal investigation and voluntary self-disclosure to BIS and DOE regarding potential exports to export-restricted parties and potential implications of foreign talent program requirements.
• Represented a UK-based and U.S.-owned media company for an internal investigation and voluntary self-disclosure to OFAC and BIS regarding sales to Cuba and Iran, with investigation touchpoints in the United States, Europe, the Middle East, Africa, and Latin America.
• Represented a U.S.-based technology company for responding to OFAC subpoenas regarding provision of services and technology to U.S. sanctioned persons, with investigation touchpoints in the United States, Europe, Asia, and Australia.
• Represented a U.S.-based technology company for an internal investigation and voluntary self-disclosure to BIS regarding transactions involving export-restricted parties with investigation touchpoints in the United States, Europe, the Middle East, Asia, and Australia.
• Represented a U.S.-based freight forwarder for an internal investigation and voluntary self-disclosure to OFAC with investigation touchpoints in the United States, Europe, the Middle East, Asia, and Latin America.

Transactions

Jeremy has counseled on international trade and national security considerations for over 300 mergers, acquisitions, and minority investments, and hundreds of credit financing arrangements. Examples include:

• Advised a U.S. private equity firm on its $11 billion sale of a mortgage technology company.
• Advised a U.S. private equity firm on its $1.4 billion strategic investment in an electric services company.
• Advised a Canadian pension fund company on its $400 million strategic investment in a U.S. provider of security systems and services.
• Advised a U.S. aerospace company on its $675 million de-SPAC processes.
• Advised a U.S. strategic investor in acquiring a minority investment of an entity, whereby another minority investment was a U.S. sanctioned person.

Regulatory Counseling

• Developed summary of exposure to high-risk Chinese entities for a telecommunications company and risk of enforcement of the Information and Communications Technology and Services (ICTS) supply chain regulations.
• Counseled a U.S. manufacturer on exports of manufacturing base to Mexico and Brazil.
• Created framework for a U.S. contracting firm to build out operations in Saudi Arabia and the associated EAR, ITAR, and government contracting risks.
• Drafted a memorandum for an EU-based financial institution, and summarized risks and potential mechanisms to achieve compliance with U.S. export controls and BIS expectations.

Government Licensing/Advocacy

• Successfully advocated to the U.S. Department of Defense on behalf of a U.S. defense contractor that the components utilized of Chinese origin did not violate provisions of the DFARs.
• Regularly assists companies in applying for and receiving U.S. export and sanctions licenses. Recent examples include: BIS export licenses for the export of medical products to 700+ parties in Russia, BIS export license for the export of machinery to Russia, OFAC specific licenses for an Iranian non-profit to receive donations, and OFAC specific licenses to winddown operations with a sanctioned Chinese party.

Development of Compliance Infrastructure

• Developed, enhanced, and implemented sanctions, export controls (EAR and ITAR), anti-corruption (FCPA), and anti-money laundering (AML) compliance policies and procedures for numerous companies and nonprofits across a diverse set of industries.
• Conducted training and drafted training modules for company personnel regarding compliance with sanctions, export controls, anti-corruption, and AML laws.
• Analyzed potential export control risks (EAR and ITAR) and develop specific compliance structured for non-U.S. persons employed at facilities in the United States.

• Super Lawyers: Illinois Rising Stars for 2024 and 2025, International