Overview
Jeremy Iloulian is an associate in Kirkland & Ellis LLP’s International Trade and National Security Practice Group in the Washington, D.C., office. Jeremy advises clients globally on complex cross-border transactional, regulatory and investigative matters that touch U.S. national security, foreign investment, and international trade, including:
- Economic sanctions administered by Treasury’s Office of Foreign Assets Control (OFAC);
- Export controls administered by:
- The U.S. Department of Commerce Bureau of Industry and Security, including the Export Administration Regulations (EAR) and the Securing the Information & Communications Technology & Services Supply Chain (ICTS) regulations;
- The U.S. Department of State Directorate of Defense Trade Controls, including the International Traffic in Arms Regulations (ITAR);
- The Nuclear Regulatory Commission (NRC) and the Department of Energy;
- Reviews by the Committee on Foreign Investment in the United States (CFIUS) and CFIUS concerns related to private equity fund formation;
- Anticorruption compliance counseling in matters involving the Foreign Corrupt Practices Act (FCPA);
- Import laws administered by U.S. Customs and Border Protection and other supply chain considerations;
- Anti-boycott regulations; and
- Filings required by the U.S. Department of Commerce Bureau of Economic Analysis (BEA)
Jeremy has advised and counseled U.S.and international clients, such as 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, healthcare, infrastructure, technology, telecommunications and transportation.
Additionally, Jeremy has counseled on, and presented and published research related to, the United Nations Convention on the Law of the Sea (UNCLOS) and maritime law.
Prior to law school, Jeremy worked for a major international law firm on internal conflicts compliance including in relation to economic sanctions administered by OFAC.
Experience
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.
Transactions
- KKR on its $1.4 billion strategic investment in NextEra Energy.
- Thoma Bravo on its $11 billion sale of Ellie Mae.
- Caisse de dépôt et placement du Québec (CDPQ) on its $400 million strategic investment in Allied Universal.
- Calabrio, a portfolio company of KKR, in its acquisition of Teleopti.
- Clearlake Capital Group, L.P. in its acquisition of IXS Holdings, Inc.
- Clearlake Capital Group, L.P. in its acquisition of Pretium Packaging.
- Industrial Growth Partners in its acquisition of Electric Power Systems International (EPS).
- Nordic Capital in its acquisition of ArisGlobal.
- Nordic Capital in its acquisition of Orchid Orthopedic Solutions from Altor Equity Partners.
Strategic Counseling
- Advised private equity sponsors on investments in high-risk markets (e.g. China, Russia).
- Developed summary of exposure to high-risk Chinese entities for telecommunications company.
Government Interactions and Licensing
- Prepared sanctions compliance reports as required by relevant general licenses for U.S. based metals company.
- Drafted and received OFAC specific licenses for 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 compliance policies and procedures for numerous companies and non-profits across a diverse set of industries.
- Conducted training and drafted training modules for company personnel regarding compliance with sanctions, export controls, anti-corruption, and anti-money laundering laws.
Clerk & Government Experience
United Nations Office of Legal Affairs
United States Department of State, Bureau of Oceans, and International Environmental and Scientific Affairs, Office of Science and Technology Cooperation
Prior Experience
Research Assistant, International Maritime Boundaries
Research Assistant, Duke University School of Law
Hogan Lovells LLP
More
Thought Leadership
Academic Journals
Cyber Threats from North Korea and China: Risks and Recommendations, 37 Rev. Banking & Fin. Services 31 (March 2021) (with Mario Mancuso and Sanjay Mullick).
North Korea: Shipping and Supply Chain Risks and Risk Mitigation, 35 Rev. Banking & Fin. Services 37 (March 2019) (with Mario Mancuso and Sanjay Mullick).
From Shark Finning to Shark Fishing: a Strategy for the U.S. & EU to Combat Shark Finning in China & Hong Kong, 27 Duke Envtl. L. & Pol’y F. 345 (2017).
Articles
EO Sets in Motion Ban on Transactions with Chinese App Developers and Owners, Corporate Compliance Insights (January 27, 2021) (with Mario Mancuso, Sanjay Mullick, and Anthony Rapa).
DOE’s China Order May Have Ripple Effects for Bulk Power, Law360 (December 23, 2020) (with Mario Mancuso and Sanjay Mullick).
Foreign Cos. Should Consider Risks of OFAC Iran Sanctions, Law360 (October 22, 2020) (with Abigail Cotterill and Anthony Rapa).
U.S.-China Trade Deal—What It Does and What It Doesn’t, Bloomberg Tax (January 17, 2020) (with Mario Mancuso and Sanjay Mullick).
3 Policy Developments to Watch as US-China Divide Grows, Law360 (October 9, 2019) (with Mario Mancuso and Sanjay Mullick).
What EU Investment Screening Will Mean For Dealmakers, Law360 (March 12, 2019) (with Shawn Cooley, J. Matthew O’Hare, Mario Mancuso, and Anna Schwander).
Client Alerts and Blog Posts
3 Policy Developments to Watch as US-China Divide Grows, Law360 (October 9, 2019) (with Mario Mancuso and Sanjay Mullick).
Commerce Department Issues Interim Rule to Restrict Information and Communications Technology and Services Supply Chain Transactions with “Foreign Adversaries,” Kirkland & Ellis Alert (January 19, 2021) (with Abigail Cotterill, Daniel Gerkin, Lucille Hague, Mario Mancuso, Sanjay Mullick, Anthony Rapa, Ivan Schlager, and Carolyn Schroll).
Trump Administration Comes to a Close Amidst a Flurry of Export Controls and Associated Regulatory Developments, Primarily Targeting China, Kirkland & Ellis Alert (January 13, 2021) (with Michael Casey, Daniel Gerkin, Cori Lable, Mario Mancuso, Sanjay Mullick, Anthony Rapa, and Ivan Schlager).
Executive Order Prohibits Transactions in Securities Issued by Companies Associated with the Chinese Military, Kirkland & Ellis Alert (November 20, 2020) (with Daniel Gerkin, H. Boyd Greene, Mario Mancuso, Sanjay Mullick, Anthony Rapa, Robert Ryland, and Ivan Schlager).
Federal Government Moves to Bar Contractors from Using Certain Chinese Telecommunications and Video Surveillance Services or Equipment, Kirkland & Ellis Alert (July 31, 2020) (with Daniel Gerkin, H. Boyd Greene, Mario Mancuso, Sanjay Mullick, Anthony Rapa, Robert Ryland, and Ivan Schlager).
DOE Requests Information to Secure the Bulk-Power System from “Foreign Adversaries,” Kirkland & Ellis Energy & Infrastructure Blog (July 20, 2020) (with Mario Mancuso, Sanjay Mullick, and Brian Greene).
Trump Administration Moves to Restrict Bulk-Power Systems from “Foreign Adversaries,” Kirkland & Ellis Energy & Infrastructure Blog (May 4, 2020) (with Mario Mancuso and Sanjay Mullick).
The G20: What to Watch, Kirkland & Ellis LLP Alert (June 26, 2019) (with Mario Mancuso, Shawn Cooley, Sanjay Mullick, Anthony Rapa, and Abigail Cotterill).
U.S. Treasury Department Issues New Rule on Mandatory CFIUS Declarations, Kirkland & Ellis LLP Alert (October 12, 2018) (with H. Boyd Greene, Lucille Hague, Mario Mancuso, Sanjay Mullick, Anthony Rapa, H. Boyd Greene, and William Phalen).
Changes in U.S. Cuba, Russia and Iran Sanctions Create Uncertainty for Global Businesses, Kirkland & Ellis LLP Alert (June 21, 2017) (with Lucille Hague, Mario Mancuso, Palmer Quamme, and Joanna Ritcey-Donohue).
Seminars
Presenter, “US Priorities for a Legally Binding Instrument on Marine Biological Diversity of Areas Beyond National Jurisdiction,” Salzburg Cutler Fellows Program (February 23, 2018).
Recognition
Credentials
Admissions & Qualifications
- 2018Illinois
- 2019District of Columbia
Education
- Duke University School of LawJ.D.2018
Editor-in-Chief, Duke Environmental Law & Policy Forum
Zeitgeist Award, Duke Environmental Law and Policy Clinic
Salzburg Cutler Law Fellow, 2018
- The George Washington UniversityB.A., International Affairs & Environmental Studiescum laude2013