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Jeremy Iloulian

Counsel | He/Him/His
Counsel | He/Him/His
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Areas of Focus

Overview

Recognized as a “Rising Star” in International Trade by Super Lawyers, Jeremy Iloulian advises clients globally on complex cross-border regulatory, compliance, investigative, and transactional matters and policy developments that touch U.S. national security, international trade, and foreign investment, including those relating to U.S. export controls (EAR and ITAR), economic sanctions, anti-boycott laws, the Committee on Foreign Investment in the United States (CFIUS), and various national security controls on fundamental research and supply chains.

Jeremy has extensive experience counseling U.S. and non-U.S. clients, including public and private companies, private equity sponsors, and nonprofits spanning a multitude of industries, including aerospace and defense, energy, entertainment, fashion, food and beverage, health care, infrastructure, technology, telecommunications, and transportation. He provides strategic guidance on managing risks for dealings in high-risk jurisdictions such as China, Russia, Venezuela, and the Middle East, among other countries and regions. He regularly advocates on behalf of such clients before the U.S. Bureau of Industry and Security (BIS), Directorate of Defense Trade Controls (DDTC), Office of Foreign Assets Control (OFAC), Bureau of Economic Affairs (BEA), Census Bureau, Department of Energy, and Nuclear Regulatory Commission (NRC).

Additionally, Jeremy has previously counseled on, presented on, and published research related to international environmental law, specifically the United Nations Convention on the Law of the Sea (UNCLOS) and Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES).

Prior to and during law school, Jeremy interned at multiple government agencies, including the United Nations, the U.S. State Department, and the Iraqi Embassy in Washington, D.C.

Career & Education

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    • United Nations
      Legal Intern, Office of Legal Affairs, Division for Ocean Affairs and Law of the Sea, Summer 2016
    • Department of State
      Intern, Office of Science and Technology Cooperation, Spring 2013
    • Embassy of Iraq
      Intern, American Administration Outreach, Summer 2011
    • United Nations
      Legal Intern, Office of Legal Affairs, Division for Ocean Affairs and Law of the Sea, Summer 2016
    • Department of State
      Intern, Office of Science and Technology Cooperation, Spring 2013
    • Embassy of Iraq
      Intern, American Administration Outreach, Summer 2011

    • The George Washington University, B.A., cum Laude, International Affairs & Environmental Studies, 2013
    • Duke University School of Law, J.D., 2018
    • The George Washington University, B.A., cum Laude, International Affairs & Environmental Studies, 2013
    • Duke University School of Law, J.D., 2018

    • Illinois
    • District of Columbia
    • Illinois
    • District of Columbia

Jeremy's Insights

Client Alert | 7 min read | 11.08.24

New BIS Guidance Continues Trend of Enhanced EAR Compliance Expectations for Financial Institutions

The U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued new guidance (“BIS Guidance”) for financial institutions (“FIs”) on October 9, 2024, recommending that FIs undertake specific compliance practices to minimize their risk of violating General Prohibition (“GP”) 10 of BIS’s Export Administration Regulations (“EAR”).  GP 10 prohibits any person (U.S. or otherwise) from selling, transferring, exporting, reexporting, financing, ordering, buying, removing, concealing, storing, using, loaning, disposing of, transporting, forwarding, or otherwise servicing an item “subject to the EAR” with knowledge that that item was, or will be, exported, reexported, or transferred in violation of the EAR.  Knowledge in this context goes beyond actual knowledge, and can be inferred from circumstances surrounding a transaction; in other words, a “known or should have known” standard.  Although BIS has published several joint alerts with FinCEN encouraging financial institutions to look for potential red flags of evasion of export controls, this guidance goes further in establishing specific export compliance best practices for financial institutions and suggests that financial institutions that finance or otherwise service prohibited exports risk liability under the EAR....

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Representative Matters

Internal Investigations

  • Lead associate on a sanctions and export control internal investigation for a U.S.-based media company with investigation touchpoints in the United States, Europe, the Middle East, Africa, and Latin America.
  • Lead associate on a sanctions internal investigation responding to U.S. government subpoenas for a U.S.-based technology company with investigation touchpoints in the United States, Europe, Asia, and Australia.
  • Lead associate on an export controls and sanctions internal investigation for a U.S.-based technology company with investigation touchpoints in the United States, Europe, the Middle East, Asia, and Australia.
  • Lead associate on a sanctions internal investigation for a U.S.-based freight forwarder with investigation touchpoints in the United States, Europe, the Middle East, Asia, and Latin America.

Transactions

  • 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.

Strategic Counseling

  • Advised private equity firms on investments in, and exposure to, high-risk markets (e.g. China, Russia).
  • Developed summary of exposure to high-risk Chinese entities for telecommunications company and risk of enforcement of the Information and Communications Technology and Services (ICTS) supply chain regulations.
  • Counseled U.S. manufacturer on exports of manufacturing base to Mexico and Brazil.
  • Created framework for contracting firm to build out operations in Saudi Arabia and associated risks.

Government Licensing/Advocacy

  • Successful advocated to the U.S. Department of Defense on behalf of a U.S.-based weapons manufacturer that the components utilized of Chinese origin did not violate provisions of the DFARs.
  • Regularly assisted companies to apply for and receive U.S. export and sanctions licenses. Some 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, and OFAC specific licenses for an Iranian non-profit to receive donations.

Development of Compliance Infrastructure

  • Developed, enhanced, and implemented sanctions, export controls (EAR and ITAR), anti-corruption, 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.

Jeremy's Insights

Client Alert | 7 min read | 11.08.24

New BIS Guidance Continues Trend of Enhanced EAR Compliance Expectations for Financial Institutions

The U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued new guidance (“BIS Guidance”) for financial institutions (“FIs”) on October 9, 2024, recommending that FIs undertake specific compliance practices to minimize their risk of violating General Prohibition (“GP”) 10 of BIS’s Export Administration Regulations (“EAR”).  GP 10 prohibits any person (U.S. or otherwise) from selling, transferring, exporting, reexporting, financing, ordering, buying, removing, concealing, storing, using, loaning, disposing of, transporting, forwarding, or otherwise servicing an item “subject to the EAR” with knowledge that that item was, or will be, exported, reexported, or transferred in violation of the EAR.  Knowledge in this context goes beyond actual knowledge, and can be inferred from circumstances surrounding a transaction; in other words, a “known or should have known” standard.  Although BIS has published several joint alerts with FinCEN encouraging financial institutions to look for potential red flags of evasion of export controls, this guidance goes further in establishing specific export compliance best practices for financial institutions and suggests that financial institutions that finance or otherwise service prohibited exports risk liability under the EAR....

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Recognition

  • Super Lawyers: Rising Stars for 2024, International

Jeremy's Insights

Client Alert | 7 min read | 11.08.24

New BIS Guidance Continues Trend of Enhanced EAR Compliance Expectations for Financial Institutions

The U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued new guidance (“BIS Guidance”) for financial institutions (“FIs”) on October 9, 2024, recommending that FIs undertake specific compliance practices to minimize their risk of violating General Prohibition (“GP”) 10 of BIS’s Export Administration Regulations (“EAR”).  GP 10 prohibits any person (U.S. or otherwise) from selling, transferring, exporting, reexporting, financing, ordering, buying, removing, concealing, storing, using, loaning, disposing of, transporting, forwarding, or otherwise servicing an item “subject to the EAR” with knowledge that that item was, or will be, exported, reexported, or transferred in violation of the EAR.  Knowledge in this context goes beyond actual knowledge, and can be inferred from circumstances surrounding a transaction; in other words, a “known or should have known” standard.  Although BIS has published several joint alerts with FinCEN encouraging financial institutions to look for potential red flags of evasion of export controls, this guidance goes further in establishing specific export compliance best practices for financial institutions and suggests that financial institutions that finance or otherwise service prohibited exports risk liability under the EAR....

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Insights

Client Alert | 7 min read | 11.08.24

New BIS Guidance Continues Trend of Enhanced EAR Compliance Expectations for Financial Institutions

Blog Post | 09.18.24

BIS Amends Voluntary Self-Disclosure Process and Penalty Guidelines and Adds First-Ever Chief of Corporate Enforcement

Blog Post | 09.12.24

OFAC Extends Recordkeeping Requirements from 5 to 10 Years Through Interim Final Rule

Blog Post | 08.16.24

DDTC Publishes Amendments to the ITAR Definition of Activities That Are Not Exports, Reexports, Retransfers, or Temporary Imports
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Practices

Industries

Jeremy's Insights

Client Alert | 7 min read | 11.08.24

New BIS Guidance Continues Trend of Enhanced EAR Compliance Expectations for Financial Institutions

The U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued new guidance (“BIS Guidance”) for financial institutions (“FIs”) on October 9, 2024, recommending that FIs undertake specific compliance practices to minimize their risk of violating General Prohibition (“GP”) 10 of BIS’s Export Administration Regulations (“EAR”).  GP 10 prohibits any person (U.S. or otherwise) from selling, transferring, exporting, reexporting, financing, ordering, buying, removing, concealing, storing, using, loaning, disposing of, transporting, forwarding, or otherwise servicing an item “subject to the EAR” with knowledge that that item was, or will be, exported, reexported, or transferred in violation of the EAR.  Knowledge in this context goes beyond actual knowledge, and can be inferred from circumstances surrounding a transaction; in other words, a “known or should have known” standard.  Although BIS has published several joint alerts with FinCEN encouraging financial institutions to look for potential red flags of evasion of export controls, this guidance goes further in establishing specific export compliance best practices for financial institutions and suggests that financial institutions that finance or otherwise service prohibited exports risk liability under the EAR....

View All Insights