Jonathan C. Poling

Partner - Akin Gump

Jonathan C. Poling is a partner in Akin Gump’s international trade practice with significant experience handling complex export control and trade-related civil and criminal matters involving a wide array of industries. He is a former federal prosecutor with the U.S. Department of Justice (DOJ) National Security Division’s Counterespionage Section.

Practice & Background

Mr. Poling represents clients nationally and internationally in a variety of matters, including white collar criminal cases, administrative enforcement matters, trade-related due diligence, integration issues in mergers and acquisitions, internal investigations, audits, temporary denial orders (TDOs), entity list designations, export control and sanctions cases, and addressing corporate compliance issues. His practice also covers anti-money laundering and fraud investigations involving international trade and trade finance, including investigations involving potential violations of the International Emergency Economic Powers Act, the Trading with the Enemy Act and the Arms Export Control Act. He has also handled substantial and high-profile investigations and prosecutions of non-U.S. companies and financial institutions for trade violations.

During his time with the DOJ, Mr. Poling handled a number of cases, including a matter that resulted in the first arrests and prosecution of employees of a European freight forwarding company for violations of U.S. export control laws and one of the largest sanctions cases in U.S. history. He also received multiple commendations and awards for excellence while at DOJ.

Mr. Poling worked with the DOJ’s National Export Coordinator and interacted with the licensing agencies and civil enforcement authorities on numerous international trade and trade finance matters. He worked extensively in training both U.S. and non-U.S. law enforcement agencies on export control enforcement efforts, and previously served on the DOJ’s Foreign Investment Review Staff, which serves on the Committee on Foreign Investment in the United States (CFIUS) review process.

Representative Matters

  • Defended a large multinational manufacturer in response to a subpoena from the U.S. Department of Commerce’s Office of Export Enforcement (OEE)
  • Represented a U.S. technology company in a cross-border internal investigation relating to the theft of intellectual property
  • Represented a large financial institution regarding an investigation for alleged violations of regulations administered by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC)
  • Represented a defense contractor in administrative proceedings and a consent agreement pending before the Directorate of Defense Trade Controls (DDTC) at the U.S. Department of State for alleged violations of the International Traffic in Arms Regulations (ITAR)
  • Provided trade and sanctions advice to a logistics and management company relating to integration of an acquired company
  • Drafted the export control and sanctions policy for a global supply chain company
  • Defended an industrial supplier in an investigation by the U.S. Department of Commerce’s OEE
  • Represented a company as part of an industry outreach by U.S. law enforcement to its offices.

Public Service

  • Prosecutor, U.S. Department of Justice, National Security Division, Counterespionage Section
  • Committee on Foreign Investment in the United States, as a member of the DOJ Foreign Investment Review Staff.

Awards and Accolades

  • Award for Excellence from the U.S. Department of Commerce, Office of Export Enforcement, 2010
  • Special Commendation Award from the Assistant Attorney General for the National Security Division, 2009
  • Award for Excellence from the National Security Division, 2008, 2009 and 2010.