ACSS NY Chapter: Bridging the Gap between Sanctions & Export Controls

Previously, Howard was a Vice President in the Global Sanctions Compliance Department at MUFG, where he collaborated on sanctions compliance program initiatives and worked on wide-ranging projects, including risk assessments, global product reviews, and consulting on complex transactions. Prior to that, he held anti-financial crime roles at Citibank and AIG, where he provided sanctions and compliance subject-matter expertise to global stakeholders.

Before that, Spieler served in the Bloomberg administration for 10 years, with seven of those years as head of compliance at the New York City Economic Development Corporation, where he helped develop and maintain its risk-based compliance program, which included managing regulatory reporting as well as the ongoing monitoring and assessment of a $30 billion portfolio of public-private real estate transactions.

Between 2016 and June 2023 Howard served on the volunteer board of the ACAMS New York Chapter, with the last five years as as the Chapter Co-Chair. Howard holds a Master’s Degree in Accounting from Kean University, a Master’s Degree in Business Administration (MBA) from St. John’s University, and a Bachelor of Arts with a focus on political science from the University at Albany, State University of New York. Additional information about Howard’s education and professional experience may be found at https://www.linkedin.com/in/howardspieler.

Alice Rojas is a Managing Director and Head of Sanctions Compliance for the Americas at Societe Generale (New York, NY) where she is responsible for managing a team of sanctions compliance professionals working on sanctions investigations, sanctions advisory, and sanctions screening and list management processes. Ms. Rojas also previously worked at Standard Chartered Bank and the Bank of Tokyo-Mitsubishi UFJ leading sanctions teams. In addition, Ms. Rojas served as an Assistant Prosecuting Attorney in Michigan and worked for 10 years in the federal government on sanctions and export control related issues at the Office of Foreign Assets Control (OFAC), the U.S. Department of State/Directorate of Defense Trade Controls (DDTC), and Homeland Security Investigations (HSI). Ms. Rojas holds a BA in Comparative Literature from the University of Michigan, an MA in International Affairs from George Washington University, and a JD from the Georgetown University Law Center.

Eric J. Rudolph’s work focuses on compliance with economic sanctions and U.S. export controls. An attorney by experience and training, Mr. Rudolph has led, managed, and participated in compliance reviews domestically and internationally (North America, Europe, Middle East, Africa, and Asia); internal investigations; economic and trade sanctions, International Traffic in Arms Regulations (ITAR), and Export Administration Regulations (EAR) counseling; jurisdiction and classification analyses; and training efforts. In his practice, Mr. Rudolph focuses on providing practical recommendations concerning risk-based assessment of compliance needs, compliance program design, investigations, audits and reviews, and support of remediation activities.

Additionally, Mr. Rudolph has significant experience working with companies under government-appointed compliance monitors, including serving on a monitor team for a sanctions and export controls case involving criminal and civil settlements with the DOJ, OFAC, and BIS. He has led audit teams for ITAR consent agreements with the Department of State and assisted the sanctions compliance leadership at a major global bank under NYDFS oversight in enhancing its OFAC compliance program.

His experience in sanctions and export controls includes advising clients on compliance with OFAC regulations, reviewing and improving compliance programs, developing screening and due diligence procedures, conducting internal investigations, assisting with voluntary self-disclosures and remedial measures, and advising on sanctions risks in M&A due diligence and integration. He also has expertise in CFIUS matters, leading export classification reviews to determine notice requirements, supporting post-closing compliance, and assisting with mitigation agreement obligations. Beyond sanctions and export controls, Mr. Rudolph has experience in anti-bribery compliance, including policies and procedures, investigations, voluntary disclosures, and remediation, as well as in U.S. Customs matters.

Previously, Mr. Rudolph worked in the export controls and sanctions practice of a Big 4 accounting firm and ran his own firm. He also spent 15 years as in-house counsel, including as General Counsel, advising Boards and executive leadership on compliance. In the trade policy space, he served as a committee liaison to a member of the United States Trade Representative’s Advisory Committee for Trade Policy and Negotiations (ACT

Previously, Howard was a Vice President in the Global Sanctions Compliance Department at MUFG, where he collaborated on sanctions compliance program initiatives and worked on wide-ranging projects, including risk assessments, global product reviews, and consulting on complex transactions. Prior to that, he held anti-financial crime roles at Citibank and AIG, where he provided sanctions and compliance subject-matter expertise to global stakeholders.

Before that, Spieler served in the Bloomberg administration for 10 years, with seven of those years as head of compliance at the New York City Economic Development Corporation, where he helped develop and maintain its risk-based compliance program, which included managing regulatory reporting as well as the ongoing monitoring and assessment of a $30 billion portfolio of public-private real estate transactions.

Between 2016 and June 2023 Howard served on the volunteer board of the ACAMS New York Chapter, with the last five years as as the Chapter Co-Chair. Howard holds a Master’s Degree in Accounting from Kean University, a Master’s Degree in Business Administration (MBA) from St. John’s University, and a Bachelor of Arts with a focus on political science from the University at Albany, State University of New York. Additional information about Howard’s education and professional experience may be found at https://www.linkedin.com/in/howardspieler.

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 and international trade. He focuses on U.S. export controls (Export Administration Regulations [EAR] and International Traffic in Arms Regulations [ITAR]), economic sanctions, supply chain security (ICTS), anti-boycott laws, foreign investment (CFIUS and outbound investment), and various government contract national security restrictions associated with supply chains (Chinese military company analyses) and fundamental research (NSPM-33, foreign talent programs).

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. He provides strategic guidance on managing risks for dealings in high-risk jurisdictions such as Cuba, China, Russia, Venezuela, the Middle East, Southeast Asia, and Africa.

He regularly advocates on behalf of such clients before the Bureau of Industry and Security (BIS), Directorate of Defense Trade Controls, Office of Foreign Assets Control (OFAC), U.S. Department of Justice National Security Division (DOJ NSD), Department of Defense, Bureau of Economic Affairs, Census Bureau, Department of Energy (DOE), and Nuclear Regulatory Commission. Jeremy supports clients in obtaining licenses and advisory opinions, submitting voluntary self-disclosures, and responding to subpoena requests.

Jeremy has supported over 300 mergers, acquisitions, and minority investments by conducting national security, international trade, and bribery and corruption (FCPA) diligence and issuing guidance on credit financing mechanisms.

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), Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES), and its local implementing laws (the Lacey Act).

Alice Rojas is a Managing Director and Head of Sanctions Compliance for the Americas at Societe Generale (New York, NY) where she is responsible for managing a team of sanctions compliance professionals working on sanctions investigations, sanctions advisory, and sanctions screening and list management processes. Ms. Rojas also previously worked at Standard Chartered Bank and the Bank of Tokyo-Mitsubishi UFJ leading sanctions teams. In addition, Ms. Rojas served as an Assistant Prosecuting Attorney in Michigan and worked for 10 years in the federal government on sanctions and export control related issues at the Office of Foreign Assets Control (OFAC), the U.S. Department of State/Directorate of Defense Trade Controls (DDTC), and Homeland Security Investigations (HSI). Ms. Rojas holds a BA in Comparative Literature from the University of Michigan, an MA in International Affairs from George Washington University, and a JD from the Georgetown University Law Center.

Eric J. Rudolph’s work focuses on compliance with economic sanctions and U.S. export controls. An attorney by experience and training, Mr. Rudolph has led, managed, and participated in compliance reviews domestically and internationally (North America, Europe, Middle East, Africa, and Asia); internal investigations; economic and trade sanctions, International Traffic in Arms Regulations (ITAR), and Export Administration Regulations (EAR) counseling; jurisdiction and classification analyses; and training efforts. In his practice, Mr. Rudolph focuses on providing practical recommendations concerning risk-based assessment of compliance needs, compliance program design, investigations, audits and reviews, and support of remediation activities.

Additionally, Mr. Rudolph has significant experience working with companies under government-appointed compliance monitors, including serving on a monitor team for a sanctions and export controls case involving criminal and civil settlements with the DOJ, OFAC, and BIS. He has led audit teams for ITAR consent agreements with the Department of State and assisted the sanctions compliance leadership at a major global bank under NYDFS oversight in enhancing its OFAC compliance program.

His experience in sanctions and export controls includes advising clients on compliance with OFAC regulations, reviewing and improving compliance programs, developing screening and due diligence procedures, conducting internal investigations, assisting with voluntary self-disclosures and remedial measures, and advising on sanctions risks in M&A due diligence and integration. He also has expertise in CFIUS matters, leading export classification reviews to determine notice requirements, supporting post-closing compliance, and assisting with mitigation agreement obligations. Beyond sanctions and export controls, Mr. Rudolph has experience in anti-bribery compliance, including policies and procedures, investigations, voluntary disclosures, and remediation, as well as in U.S. Customs matters.

Previously, Mr. Rudolph worked in the export controls and sanctions practice of a Big 4 accounting firm and ran his own firm. He also spent 15 years as in-house counsel, including as General Counsel, advising Boards and executive leadership on compliance. In the trade policy space, he served as a committee liaison to a member of the United States Trade Representative’s Advisory Committee for Trade Policy and Negotiations (ACT

Previously, Howard was a Vice President in the Global Sanctions Compliance Department at MUFG, where he collaborated on sanctions compliance program initiatives and worked on wide-ranging projects, including risk assessments, global product reviews, and consulting on complex transactions. Prior to that, he held anti-financial crime roles at Citibank and AIG, where he provided sanctions and compliance subject-matter expertise to global stakeholders.

Before that, Spieler served in the Bloomberg administration for 10 years, with seven of those years as head of compliance at the New York City Economic Development Corporation, where he helped develop and maintain its risk-based compliance program, which included managing regulatory reporting as well as the ongoing monitoring and assessment of a $30 billion portfolio of public-private real estate transactions.

Between 2016 and June 2023 Howard served on the volunteer board of the ACAMS New York Chapter, with the last five years as as the Chapter Co-Chair. Howard holds a Master’s Degree in Accounting from Kean University, a Master’s Degree in Business Administration (MBA) from St. John’s University, and a Bachelor of Arts with a focus on political science from the University at Albany, State University of New York. Additional information about Howard’s education and professional experience may be found at https://www.linkedin.com/in/howardspieler.

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 and international trade. He focuses on U.S. export controls (Export Administration Regulations [EAR] and International Traffic in Arms Regulations [ITAR]), economic sanctions, supply chain security (ICTS), anti-boycott laws, foreign investment (CFIUS and outbound investment), and various government contract national security restrictions associated with supply chains (Chinese military company analyses) and fundamental research (NSPM-33, foreign talent programs).

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. He provides strategic guidance on managing risks for dealings in high-risk jurisdictions such as Cuba, China, Russia, Venezuela, the Middle East, Southeast Asia, and Africa.

He regularly advocates on behalf of such clients before the Bureau of Industry and Security (BIS), Directorate of Defense Trade Controls, Office of Foreign Assets Control (OFAC), U.S. Department of Justice National Security Division (DOJ NSD), Department of Defense, Bureau of Economic Affairs, Census Bureau, Department of Energy (DOE), and Nuclear Regulatory Commission. Jeremy supports clients in obtaining licenses and advisory opinions, submitting voluntary self-disclosures, and responding to subpoena requests.

Jeremy has supported over 300 mergers, acquisitions, and minority investments by conducting national security, international trade, and bribery and corruption (FCPA) diligence and issuing guidance on credit financing mechanisms.

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), Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES), and its local implementing laws (the Lacey Act).