Jason Prince

Jason Prince represents and counsels exporters and multinational companies, including financial institutions, on an array of complex international trade compliance and enforcement matters. Jason has helped financial services, aerospace and defense, technology, semiconductor, telecommunications, energy, mining, agribusiness, and other companies to navigate sanctions, export controls, and various other complicated U.S. regulatory regimes applicable to international business and national security. Jason is the former chief counsel to the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC), where he oversaw the legal design of new sanctions measures and led the legal review of all major enforcement, compliance, licensing, regulatory, and litigation actions across all of OFAC’s more than 40 sanctions programs. Prior to the chief counsel role at Treasury, he served as an attorney‐advisor in the Office of the Assistant General Counsel for Enforcement and Intelligence, where he advised the under secretary who sits over OFAC and its anti‐money laundering (AML) counterpart, the Financial Crimes Enforcement Network (FinCEN). Before becoming a senior U.S. government official, Jason was the co-chair of the sanctions and export controls practice group at a large U.S. law firm.

As OFAC’s chief counsel, Jason gained in-depth experience leading OFAC’s implementation and enforcement of sanctions programs against nations such as Russia, Iran, Syria, North Korea, Cuba, and Venezuela, and thousands of designated individuals and entities deemed to threaten the national security, foreign policy, or economy of the United States. He focuses his practice on helping clients to comply with complex, evolving legal restrictions governing international trade and investment, as well as internal investigations, compliance program reviews, voluntary self‐disclosures, and enforcement actions involving OFAC’s sanctions regulations, the International Traffic in Arms Regulations (ITAR), the Export Administration Regulations (EAR), the National Nuclear Security Administration’s (NNSA) export controls (Part 810), the Committee on Foreign Investment in the United States (CFIUS), the Bank Secrecy Act (BSA) and AML regulations, and the Foreign Corrupt Practices Act (FCPA). Additionally, he is experienced in helping companies to develop policies and procedures, due diligence protocols, and training programs aimed at minimizing such compliance risks. In the sanctions arena, Jason has experience with preparing OFAC license applications and interpretive guidance requests, as well as voluntary self-disclosures of potential violations, and meeting with OFAC officials to advocate on behalf of clients in relation to such submissions.

Jason’s experience also includes serving as a law clerk to Judge Susan H. Black of the U.S. Court of Appeals for the Eleventh Circuit, as well as a deputy press secretary to Nobuteru Ishihara, a former Japanese House of Representatives Member and Japan’s former Economy Minister.

Recognition

• Acritas Star Lawyer, 2018 – 2019
• The Henry Luce Foundation, Luce Scholar, Tokyo, Japan, 2001 – 2002
  

Affiliations

Representative Matters

Compliance Counseling and Risk Assessments

• Counseled a Fortune 100 heavy equipment manufacturer on various OFAC sanctions, ITAR, EAR, and FCPA compliance matters arising from its global sales.
• Counseled one of the world's 10 largest international defense trade companies on an array of ITAR, EAR, and OFAC sanctions compliance matters arising from its foreign military sales and direct commercial sales around the globe.
• Advised a European-based multinational automotive company on compliance with the OFAC sanctions arising from the United States' withdrawal from the Joint Comprehensive Plan of Action with respect to Iran's nuclear program.
• Advised a European-based global frozen food supply chain company on certain U.S. trade sanctions considerations arising from its provision of services to a Canada-based global food company's U.S. subsidiary.
• Conducted an EAR compliance review for an emerging growth counter-UAS technology company as part of the due diligence associated with a private equity investment; prepared a Commodity Jurisdiction request for the company's counter-UAS system.
• Counseled an emerging growth counter-UAS technology company on the ITAR and EAR compliance and national security issues arising from its foreign commercial and military sales, including preparation of ITAR export authorization applications.
• Developed a global sanctions and anti-corruption compliance program for a U.S.-based publicly traded mining company with operations in Canada and sales to the Pacific Rim.
• Conducted a compliance program gap analysis for a U.S.-based publicly traded mining company with sales in multiple Asian countries, focusing primarily on trade sanctions and anti-corruption compliance matters.
• Drafted an FCPA compliance policy for a U.S.-based multinational agribusiness company, developed training for the company's employees in China, and counseled the company on minimizing FCPA compliance risks arising from its joint venture in India.

Internal Investigations and Enforcement

• As Chief Counsel to OFAC, advised on the legal theories underpinning numerous OFAC enforcement actions and evaluated outside counsel’s advocacy on behalf of target companies with reference to OFAC’s Economic Sanctions Enforcement Guidelines.  
• Represented a Fortune 100 heavy equipment manufacturer in internally investigating and preparing a voluntary self-disclosure to OFAC regarding apparent violations of the Iran sanctions program, which resulted in a no-action letter from OFAC.
• Represented one of the world's 10 largest international defense trade companies in handling multiple internal investigations and voluntary disclosures to DDTC regarding potential ITAR violations.
• Conducted an internal investigation and prepared voluntary disclosures to DDTC and BIS regarding potential ITAR and EAR violations arising from a counter-UAS technology company’s sales in Europe, Asia, and the Middle East.
• Assisted with successfully securing the de-listing of over forty individuals and entities in the financial services industry that OFAC placed on its Specially Designated Nationals and Blocked Persons (SDN) List.
• Defended a nuclear reactor safety technology company in responding to an NNSA cease-and-desist letter and request for information in relation to compliance with Part 810.
• Conducted a Fortune 500 multinational technology company's internal investigation into alleged kickbacks involving customers in multiple Asian countries.
• Directed the internal investigation of a U.S.-based medical device manufacturer's alleged FCPA violations arising from the conduct of a third-party sales agent in South America.