Immediate-past chief counsel to the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC).
Led the legal development of OFAC’s Russia-related sanctions program in the wake of Russia’s full-scale invasion of Ukraine.
Helps to lead Akin’s top-tier, multijurisdictional economic sanctions practice, including as related to Russia, China, and other jurisdictions worldwide.
Extensive global sanctions and export controls experience, including in the emerging areas of fintech and virtual currency.
More than 18 years of legal experience, both in government and private practice.

Jason counsels exporters and multinational companies, including financial institutions, on an array of U.S. regulatory compliance and enforcement matters at the intersection of international trade and national security. Jason has a global practice across sanctions, export controls, national security, and investigations amid a rapidly evolving geopolitical environment.

In particular, Jason advises financial services, technology, software, fintech, virtual currency, aerospace and defense, e-commerce, semiconductor, telecommunications, energy, mining, agribusiness, and other companies on navigating the increasingly complex legal regimes of economic sanctions and export controls. He helps to lead Akin’s top-tier, multijurisdictional economic sanctions practice.

Jason is the immediate-past chief counsel of 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 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 another 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. In the wake of Russia’s full-scale invasion of Ukraine, Jason led the legal development of OFAC’s Russia-related sanctions program. Jason also oversaw the legal advice for the issuance of more than a dozen new sanctions-related executive orders, directives, and determinations.

Further, Jason played a major role in OFAC’s response to humanitarian and political crises in Venezuela and Afghanistan, regulating investment in China’s defense industrial base, and combatting emerging cyber threats, narcotics trafficking, and atrocities in Ethiopia and Burma.

Jason 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, Jason is experienced in helping companies develop policies and procedures, due diligence protocols, and training programs aimed at minimizing 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.

Representative Work

Strategic Compliance Counseling, Risk Assessments, and Licensing

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 Japanese multinational conglomerate company on navigating the U.S. secondary sanctions risks applicable to its global sales and operations.
Counseling a South Korean multinational energy company on compliance with U.S. sanctions applicable to a multi-billion-dollar project, including requests to OFAC for specific licenses and interpretive guidance critical to the company’s ongoing operation of the project.
Represented a U.S.-based technology company in successfully securing a so-called Russian “exit tax” specific license from OFAC as part of the company’s efforts to divest its Russian subsidiary and exit the Russian market.
Counseling a multinational fintech company on compliance with U.S. sanctions applicable to Russia, Iran, and Cuba.

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.
Performed a U.S. sanctions and export controls risk assessment, and providing day-to-day compliance advice, for a multibillion-dollar Software as a Service company with global sales and operations.
Counseled 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.
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 OFAC sanctions arising from the U.S. 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 a 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 anticorruption 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.

List may include matters worked on prior to joining Akin.

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.
Performed a U.S. sanctions and export controls risk assessment, and providing day-to-day compliance advice, for a multibillion-dollar Software as a Service company with global sales and operations.
Counseled 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.
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 OFAC sanctions arising from the U.S. 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 a 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 anticorruption 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.

List may include matters worked on prior to joining Akin.

Education
J.D., Notre Dame Law School, magna cum laude, 2005
M.Phil., University of Cambridge, 2000
A.B., Davidson College, magna cum laude, 1999

Bar Admissions
District of Columbia

Recognitions

The Legal 500 US, International Trade: Customs, Export Controls and Economic Sanctions, 2024.
U.S. Department of the Treasury, Exceptional Service Award, Presented by the Treasury Secretary for Exceptional Service as Chief Counsel to the Office of Foreign Assets Control, 2023.
Japan Ministry of Economy, Trade & Industry and Japan Ministry of Foreign Affairs, Invited Observer of 23rd Asian Export Control Seminar, Tokyo, Japan, 2016.

Affiliations and Public Service

Department of the Treasury, Office of the Chief Counsel (Foreign Assets Control): Chief Counsel, 2020 – 2022.
Department of the Treasury, 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.
American Bar Association, Export Controls/Economic Sanctions Committee: Vice Chair, 2019 - 2020; Steering Group Member, 2018 - 2020; and Member, 2006 – 2020; 2023 - present.

Speeches and Publications

Panelist, “OFAC’s Expectations for IP Blocking and Geofencing,” American Conference Institute (ACI) 18th Annual Flagship Conference on Economic Sanctions Enforcement and Compliance, Washington, D.C., April 30, 2024.
Panelist, “The Role of Corporate Compliance in Protecting National Security,” Compliance Week National, Washington, DC, April 3, 2024.
Presenter, “Proactive: Strategies to Anticipate and Reduce Risk,” PLI's Investing, Trading, and Doing Deals in a Dynamic World 2024: Sticks and Carrots; Risks and Opportunities, New York, NY, February 8, 2024.
Panelist, “Emerging Trends in Sanctions and Export Enforcement: Takeaways for Responding to Enforcement Actions, and Informal Regulator Outreach,” American Conference Institute (ACI) New York Forum on Economic Sanctions, New York, NY, December 12, 2023.
Presenter, “Export Controls and Sanctions,” 2023 WITA Academy Virtual Intensive Trade Seminar, Online, October 2, 2023.
Presenter, “Sanctions and Export Controls: Ensuring Compliance,” One Trust Webinar, June 29, 2023.
Presenter, “Crafting and Expanding OFAC's Russia-Related Sanctions,” CFT Roundtable Series, Washington Institute, Washington, DC, June 5, 2023.
Presenter, “Sanctions/Kleptocracy Panel,” NYC Bar White Collar Crime Institute, New York, NY, May 24, 2023.
Presenter, “Sanctions: The #1 Foreign Policy Tool,” SIFMA Anti-Money Laundering & Financial Crimes Conference, New York, NY, May 23, 2023.
Presenter, “Hot Topics in Sanctions,” 2023 Spring Virtual Advanced Conference - Global Trade Technology Controls in a New Era of Great Power Competition, Society for International Affairs, Online, May 8, 2023.
Presenter, “New Risks in Sanctions,” Wall Street Journal Risk & Compliance Forum - Managing Risk Doesn't Have to Be Risky, The Wall Street Journal, Online, May 8, 2023.
Presenter, “Deep Dive on Russia Sanctions,” National Council on International Trade Development, Washington, DC, March 8, 2023.
US to Weigh Venezuela Vote Transparency on Future Sanctions, Bloomberg, July 29, 2024.
Maduro Faces Reckoning as Venezuelans Head to Polls, Energy Intelligence, July 25, 2024.
Practitioner Profile – Jason Prince: ‘Sanctions are having a significant impact,’ The Export Practitioner, July / August 2024, Vol. 38, No. 7 / 8.
Foreign Aid Package Comes with New Sanctions Risks for Companies, The Wall Street Journal, April 25, 2024.
Firms Pursue Venezuela Deals Despite Sanctions Snapback, Energy Intelligence, April 23, 2024.
New Rule Amps Up Reporting Burden for Banks, Law360, May 8, 2024.
US Fires Secondary Sanctions Warning to Trade Banks, Global Trade Review, June 14, 2024.
Crypto And Cooperation: Trends In OFAC Enforcement to Continue In 2024, Global Investigations Review, January 26, 2024.
How Hamas’ Attack May Further Complicate Sanctions Risk, Law360, October 19, 2023.
U.S. Could Sanction More Hamas Front Companies, Former OFAC Official Says, Export Compliance Daily, October 17, 2023.
U.S. Slaps Sanctions on Turkey And UAE-Based Shippers Over Oil Cap Breaches, Global Trade Review, October 10, 2023.
U.S. Takes Russia Sanctions Showdown to Sea, Law360, October 10, 2023.
U.S. Authorities Seize Iranian Oil Traded In Violation Of Sanctions, Global Investigations Review, September 12, 2023.
Many VCs May Be Underestimating The Full Impact Of Outbound Rule, Foreign Investment Watch, September 10, 2023.
“Go Home And Get Nothing”: Western Companies Grapple With Russian Exit Taxes, Global Reinvestigations Review, August 11, 2023.
U.S. Warns Banks Over Wagner Group Gold Risks, Global Trade Review, July 5, 2023.
Sanctions Lawyers Describe Difficult OFAC Delisting Process, Global Investigation Review, May 25, 2023.