Jason E. Prince

Partner

Overview

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 immediate-past 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 35 sanctions programs. 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 U.S. Department of Commerce, Bureau of Industry and Security’s (BIS) Export Administration Regulations (EAR), and the U.S. Department of State, Directorate of Defense Trade Controls’ International Traffic in Arms Regulations (ITAR). 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 Economy Minister.

Career & Education

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    • Department of the Treasury
      Office of the Chief Counsel (Foreign Assets Control): Chief Counsel, 2020 – 2022
      Office of the Assistant General Counsel for Enforcement and Intelligence: Attorney-Advisor, 2020
    • Department of the Treasury
      Office of the Chief Counsel (Foreign Assets Control): Chief Counsel, 2020 – 2022
      Office of the Assistant General Counsel for Enforcement and Intelligence: Attorney-Advisor, 2020
    • Deputy Press Secretary, Office of Nobuteru Ishihara, Member of the Japanese House of Representatives and Japan’s former Economy Minister, 2001 – 2002
    • Deputy Press Secretary, Office of Nobuteru Ishihara, Member of the Japanese House of Representatives and Japan’s former Economy Minister, 2001 – 2002
    • Davidson College, A.B., magna cum laude, Phi Beta Kappa
    • University of Cambridge, M.Phil.
    • University of Notre Dame Law School, J.D., magna cum laude, editor-in-chief, Notre Dame Law Review, Summer International Law Program, London, England
    • Davidson College, A.B., magna cum laude, Phi Beta Kappa
    • University of Cambridge, M.Phil.
    • University of Notre Dame Law School, J.D., magna cum laude, editor-in-chief, Notre Dame Law Review, Summer International Law Program, London, England
    • District of Columbia
    • District of Columbia
    • Law Clerk, Judge Susan H. Black, U.S. Court of Appeals for the Eleventh Circuit, 2005
    • Law Clerk, Judge Susan H. Black, U.S. Court of Appeals for the Eleventh Circuit, 2005
  • Professional Activities and Memberships

    • American Bar Association, Export Controls/Economic Sanctions Committee: Vice Chair, 2019-2020; Steering Group Member, 2018 – 2020; and Member, 2006 – 2020 
    • Invited Observer, 23rd Asian Export Control Seminar, Co-Hosted by the Japan Ministry of Economy, Trade & Industry and the Japan Ministry of Foreign Affairs, February 2016, Tokyo, Japan 
    • "Definitions, Terms & Acronyms Handbook for Defense Trade" Task Force, Member, 2017 
    • American Bar Association, Anti-Corruption Committee: Member, 2006 – 2020

    Professional Activities and Memberships

    • American Bar Association, Export Controls/Economic Sanctions Committee: Vice Chair, 2019-2020; Steering Group Member, 2018 – 2020; and Member, 2006 – 2020 
    • Invited Observer, 23rd Asian Export Control Seminar, Co-Hosted by the Japan Ministry of Economy, Trade & Industry and the Japan Ministry of Foreign Affairs, February 2016, Tokyo, Japan 
    • "Definitions, Terms & Acronyms Handbook for Defense Trade" Task Force, Member, 2017 
    • American Bar Association, Anti-Corruption Committee: Member, 2006 – 2020

Representative Matters

Compliance Counseling and Risk Assessments

  • Counseling a Fortune 200 technology company on the complex sanctions compliance issues related to its exit from the Russian market, including obtaining multiple expedited specific licenses from OFAC.
  • Counseling a U.S.-based money transmitter on compliance with OFAC sanctions in relation to its domestic and international money transfers on behalf of customers.
  • Performing a U.S. sanctions and export controls risk assessment, and providing day-to-day compliance advice, for a multi-billion-dollar Software as a Service company with global sales and operations.
  • Counseling 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.
  • Counseling a Fortune 500 Europe-based e-commerce company on various U.S. sanctions and national security legal issues arising from its global sales and operations.
  • Counseled a Fortune 100 heavy equipment manufacturer on various OFAC sanctions, ITAR, EAR, and FCPA compliance matters arising from its global sales.
  • 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.
  • 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.
  • 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.

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.  
  • Representing and advising a Fortune 500 technology company with respect to its voluntary self-disclosure to OFAC of apparent sanctions violations stemming from a European subsidiary’s sales.
  • Representing 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.
  • 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.
  • Advised a Singapore-based multinational electronics manufacturer on its voluntary self-disclosure to OFAC of apparent sanctions violations spanning multiple jurisdictions.
  • Advised a Japan-based multinational electronics manufacturer on its voluntary self-disclosure to OFAC of apparent sanctions violations arising from its global supply chain.
  • 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.
  • Defended a nuclear reactor safety technology company in responding to a U.S. Department of Energy, National Nuclear Security Administration’s cease-and-desist letter and request for information in relation to compliance with Part 810 export controls.
  • Conducted a Fortune 500 multinational technology company's internal investigation into alleged kickbacks involving customers in multiple Asian countries.

Recognition

  • Exceptional Service Award, Presented by the Secretary of the U.S. Department of the Treasury for exceptional service as Chief Counsel to the Office of Foreign Assets Control, 2023
  • Acritas Star Lawyer, 2018 – 2019
  • The Henry Luce Foundation, Luce Scholar, Tokyo, Japan, 2001 – 2002
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