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.
• Provided monthly guidance to a top Japanese conglomerate on evolving challenges between the United States, China, Iran, Myanmar, and Russia.  
• Drafted strategic considerations for a PE firm’s potential minority investments into an entity on the 1260H List.

Internal Investigations

Jeremy is proud to note that none of the internal investigations and voluntary self-disclosures that he has supported have resulted in any clients being penalized by OFAC, BIS, or DDTC. Some examples:

• 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.
• Represented an Iceland-based maritime company for an internal investigation and voluntary self-disclosure to BIS for Russia-related risks, including application of the Russia foreign direct product rule, with investigation touchpoints in the United States, Europe, the Middle East, and Asia.

Transactions

Jeremy has counseled on international trade and national security considerations for over 350 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 U.S. private equity firm on its $640 million acquisition of a chemical provider with touchpoints in China, LATAM, Europe, and Africa.
• 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 Indian entity, whereby a pre-existing minority investor was a U.S. sanctioned Russian person.

Regulatory Counseling

• Drafted guidance on U.S. foreign direct product rule (FDPR) and de minimis export analyses for a Chinese subsidiary of a publicly traded Japanese company. 
• 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 establishing new manufacturing facilities in Mexico and Brazil, and U.S. export restrictions.
• 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.
• Advised a Moldovan financial institution on compliance with U.S. sanctions on Russia and navigating relevant general licenses.

Government Licensing/Advocacy

• Represented a U.S. academic institution in front of the Select Committee on China, including preparing subpoena responses for export control and malign foreign talent program risk exposure and supporting the implementation of compliance measures, ultimately resulting in public praise from the Select Committee on China.
• 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.
• Frequently conducts and provides training and 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 structures for non-U.S. persons employed at facilities in the United States.

• Super Lawyers: Illinois Rising Stars for 2024–2026, International