In this session, hosts and International Trade Practice Leaders Nicole Simonian and Dj Wolff talk with Crowell lawyers Jeremy Iloulian and Laurel Saito about the significant new sanctions and export control authorities included in the recently enacted National Security Supplemental fiscal package. While this legislation is best known for providing U.S. foreign aid commitments for Ukraine, Israel, and Taiwan, it also contains critical trade related provisions that (i) expand the statute of limitations for U.S. sanctions violations; (ii) give the President new authorities to coordinate sanction efforts with the US and UK; (iii) expand sanctions and export controls on Iran (with some targeting Chinese financial institutions); and (iv) provide for new sanctions authorities targeting terror groups.

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Photo of Nicole Simonian Nicole Simonian

Nicole Janigian Simonian is the co-chair of the firm’s International Trade practice and International Employment and Global Mobility Lead, with a focus on the firm’s Asia practice. A partner in the firm’s Los Angeles office, she is also a director of the firm’s…

Nicole Janigian Simonian is the co-chair of the firm’s International Trade practice and International Employment and Global Mobility Lead, with a focus on the firm’s Asia practice. A partner in the firm’s Los Angeles office, she is also a director of the firm’s China office in Shanghai. Nicole’s practice covers a range of international compliance and regulatory issues, including cross border transactions, international trade, global mobility and employment, and global supply chains.

Nicole is a member of the firm’s COVID‐19 Working Group, focusing on advising employers on compliance with U.S. and international initiatives affecting private employers and providing guidance on how to navigate the myriad of regulatory complexities companies are confronted with on a global basis.

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Photo of Dj Wolff Dj Wolff

David (Dj) Wolff is the co-chair of Crowell & Moring’s International Trade Group and a director with C&M International, the firm’s trade policy affiliate.

At Crowell & Moring, he serves on the steering committee for the International Trade Group, where his practice focuses

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David (Dj) Wolff is the co-chair of Crowell & Moring’s International Trade Group and a director with C&M International, the firm’s trade policy affiliate.

At Crowell & Moring, he serves on the steering committee for the International Trade Group, where his practice focuses on all aspects of compliance with U.S. economic sanctions, including day-to-day compliance guidance, developing compliance programs, responding to government inquiries, conducting internal investigations, and representation during civil and criminal enforcement proceedings. Dj works regularly with non-U.S. clients, both in Europe and Asia, to evaluate the jurisdictional reach of U.S. sanction authorities to their global operations, identify and manage the potential conflict of laws that can result from that reach, as well as to support client’s design, implementation, and evaluation of a corresponding risk-based sanctions compliance program. Dj also regularly leads teams in diligence efforts on trade and related regulatory areas on behalf of his U.S. and non-U.S. clients in the M&A arena, having successfully closed more than 30 deals with an aggregate valuation of several billion dollars over the last 18 months.

Dj is ranked by Chambers USA in International Trade: Export Controls & Economic Sanctions. He has previously been recognized by Law360 as a Rising Star in International Trade (2020), by The National Law Journal as a “DC Rising Star” (2019), by Who’s Who Legal: Investigations as a “Future Leader” (2018 and 2019), Acritas Star as an Acritas Stars Independently Rated Lawyers (2019), by Global Investigations Review as one of the “40 under 40” in Investigations internationally (2017), and WorldECR as one of the five finalists for the WorldECR Young Practitioner of the Year award (2016).

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Photo of Jeremy Iloulian Jeremy Iloulian

Recognized as a “Rising Star” in International Trade by Super Lawyers, Jeremy Iloulian advises clients globally on complex cross-border regulatory, compliance, investigative, and transactional matters and policy developments that touch U.S. national security, international trade, and foreign investment, including those relating to

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Recognized as a “Rising Star” in International Trade by Super Lawyers, Jeremy Iloulian advises clients globally on complex cross-border regulatory, compliance, investigative, 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 (EAR and ITAR), economic sanctions, anti-boycott laws, the Committee on Foreign Investment in the United States (CFIUS), and various national security controls on fundamental research and supply chains.

Jeremy has extensive experience counseling U.S. and non-U.S. clients, including public and private companies, private equity sponsors, and nonprofits spanning a multitude of industries, including aerospace and defense, energy, entertainment, fashion, food and beverage, health care, infrastructure, technology, telecommunications, and transportation. He provides strategic guidance on managing risks for dealings in high-risk jurisdictions such as China, Russia, Venezuela, and the Middle East, among other countries and regions. 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 Nuclear Regulatory Commission (NRC).

Additionally, Jeremy has previously counseled on, presented on, and published research related to international environmental law, specifically the United Nations Convention on the Law of the Sea (UNCLOS) and Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES).

Prior to and during law school, Jeremy interned at multiple government agencies, including the United Nations, the U.S. State Department, and the Iraqi Embassy in Washington, D.C.

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Photo of Laurel Saito Laurel Saito
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