People

Overview

Jason Wilcox advises U.S. and multinational companies, investors, and financial institutions on export controls, economic sanctions, and other international trade and national security matters.  His practice includes regulatory counseling, transactional due diligence, licensing, compliance risk assessments and program development, internal investigations, and enforcement proceedings.  His clients operate across a broad range of industries, including industrial technology and advanced manufacturing, software and cloud-based services, financial services and digital assets, life sciences, and energy.

Jason counsels clients on the Export Administration Regulations, the International Traffic in Arms Regulations, and sanctions administered by the U.S. Department of the Treasury’s Office of Foreign Assets Control.  His work includes determining the jurisdiction and classification of products, software, and technology; assessing licensing and other authorization requirements; addressing restricted party, end-use, and end-user restrictions; and advising on technology transfers, foreign-person access, and international operations. He also advises clients on export control and sanctions issues arising from acquisitions, investments, joint ventures, commercial relationships, and other cross-border transactions.

Jason’s practice also includes customs and import matters, such as tariff classification, valuation, country of origin, marking, and the application of tariffs and related trade measures.  In addition, he advises investors, buyers, sellers, and U.S. businesses on CFIUS-related risk and filing considerations, prepares declarations and notices, and assists clients with government reviews, mitigation, and post-closing compliance.

When compliance concerns arise, Jason conducts internal investigations and represents clients before BIS, DDTC, OFAC, DOJ, CBP, and other U.S. government agencies.  He assists clients with responding to government inquiries and subpoenas, assessing potential violations, preparing voluntary self-disclosures, seeking regulatory relief, and implementing remedial measures.

In addition to his practice, Jason leads the firm’s participation in the DC Street Law Program and serves on the City of Gaithersburg’s Youth Enrichment Committee.  He was the firm’s 2019 Fellow with the Leadership Council on Legal Diversity and an inaugural recipient of the Baker Botts Excellence in Diversity and Community Engagement Award.

Admissions & Affiliations

  • District of Columbia Bar

Education

  • J.D., Northwestern University School of Law 2010
    cum laude
    Order of the Coif
    Associate Editor, Northwestern University Law Review
  • B.A., Political Science, Duke University 2005
    magna cum laude

Experience

  • Represented multiple parties in a U.S. government investigation concerning the movement of illicit digital assets through a cross-chain exchange protocol involving a North Korean state-sponsored cyberthreat operation.
  • Advised a consortium of financial institutions on Russia-related sanctions issues arising from a capital markets transaction involving a multinational technology services provider.
  • Advised an international financial technology organization on EAR classification and encryption controls for software incorporated into foreign-developed products.
  • Advised energy sector clients on U.S. sanctions affecting prospective operations and investments in Venezuela, including the availability and scope of OFAC authorizations.
  • Advised a defense technology developer on ITAR requirements applicable to international collaboration involving controlled technical data and defense services.
  • Advised an international commodities trader on U.S. sanctions affecting contractual payment obligations involving a designated counterparty.
  • Advised an offshore energy services provider on the application of the EAR to proposed sales of foreign-built equipment incorporating U.S.-origin components for use in China.
  • Advised an international energy trader on U.S. sanctions affecting Russian energy projects and transactions involving designated vessels, including potential implications for non-U.S. commercial parties.
  • Advised a defense systems developer on ITAR licensing, export clearance, and technology control requirements applicable to transfers to Ukraine.
  • Advised an international oil and gas enterprise on U.S. sanctions affecting proposed commodity transactions involving Russian interests, including potential secondary sanctions exposure.
  • Advised an international investor on U.S. primary and secondary sanctions risks associated with investments involving Iran, including U.S.-person participation and restricted party considerations.
  • Represented a cryptocurrency platform in reaching a favorable settlement with OFAC concerning potential violations of multiple U.S. sanctions programs.
  • Obtained favorable resolution of voluntary self-disclosures to BIS and DDTC concerning an aerospace manufacturer’s potential violations of the EAR and ITAR.
  • Obtained favorable resolution of a voluntary self-disclosure to OFAC concerning a technology startup’s potential payments to Russian subcontractors through a sanctioned financial institution.
  • Obtained favorable resolution of a voluntary self-disclosure to BIS concerning a software solutions provider’s potential noncompliance with the conditions of an EAR license exception.
  • Obtained favorable resolution of a voluntary self-disclosure to OFAC concerning an enterprise software provider’s potential provision of products and services to customers in Iran, Syria, Crimea, and the Donetsk and Luhansk regions of Ukraine.
  • Obtained favorable resolution of a voluntary self-disclosure to BIS concerning an oilfield services provider’s potential noncompliance with U.S. antiboycott requirements.
  • Represented a defense equipment provider in responding to DDTC subpoenas concerning exports of ITAR-controlled items to the United Arab Emirates.
  • Represented a blockchain developer in responding to OFAC subpoenas concerning potential activity involving users in sanctioned jurisdictions.
  • Represented a non-U.S. energy company in a successful petition to OFAC for removal from the SDN List.
  • Represented an email management provider in securing CFIUS clearance for its acquisition by a European private equity firm.
  • Represented a European energy business in securing CFIUS clearance for its acquisition of the U.S. operations of a Canadian enterprise.
  • Represented a U.S. aviation services provider in securing CFIUS clearance for its acquisition by a Chinese investor.
  • Advised a multinational food and beverage producer on U.S. sanctions and export control requirements applicable to sales to sanctioned jurisdictions.
  • Procured an OFAC license authorizing a U.S. research institution to collaborate with Iranian institutions and scientists on medical research.