Jeremy Iloulian

Jeremy Iloulian is an associate in Crowell & Moring’s Chicago office and is a member of the International Trade Group. Jeremy advises clients globally on complex cross-border investigative, regulatory, compliance, 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, economic sanctions, anti-boycott laws, and the Committee on Foreign Investment in the United States (CFIUS).

Jeremy has extensive experience counseling U.S. and international clients, including public and private companies, private equity sponsors, and nonprofits that span across a multitude of industries, including aerospace and defense, energy, entertainment, fashion, food and beverage, health care, infrastructure, technology, telecommunications, and transportation. 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 the Nuclear Regulatory Commission (NRC).

Additionally, Jeremy has previously counseled on, presented, and published research related to the United Nations Convention on the Law of the Sea (UNCLOS) and maritime law.

Before joining Crowell & Moring, Jeremy worked in Chicago and Washington, D.C. as an associate in the international trade and national security practice of a law firm.

During and prior to law school, Jeremy interned at multiple internationally focused governmental agencies, including the United Nations Office of Legal Affairs, U.S. Department of State, and the Embassy of Iraq in Washington, D.C.

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 $1.4 billion strategic investment in an electric services company.
• Advised a U.S. private equity firm on its $11 billion sale of a mortgage technology 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 portfolio company of a U.S. private equity firm in its acquisition of a software company.
• 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.

Government Licensing

• Prepared sanctions compliance reports as required by relevant general licenses for U.S.-based metals company.
• Drafted and received OFAC specific licenses for a 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.