Wendy Wysong

Partner

Hong Kong

+852 3729 1804

Washington

+1 202 429 8092

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Areas of Work

FCPA/Anti-Corruption, Economic Sanctions, Export Controls, Anti-Boycott

Overview

Wendy Wysong focuses her practice on regulatory compliance and white-collar defense of international laws, including the US Foreign Corrupt Practices Act (FCPA), International Traffic in Arms Regulations (ITAR), Export Administration Regulations (EAR), US sanctions laws and regulations administered by the Office of Foreign Assets Control (OFAC), and US anti-boycott laws, as well as government fraud and public corruption. She represents clients throughout the United States and Asia in the logistics, defense, aerospace, healthcare, telecommunications, gaming, consumer goods, and energy sectors. Wendy is the managing partner of Steptoe's Hong Kong office.

Ranked as a Band 1 practitioner by Chambers in its Asia Pacific and Global guides, clients report that Wendy is "at the top of her game technically" and "brilliant at bringing to bear a global picture of how regulators react." One insider noted that "she is the most experienced white-collar export lawyer that I know." Additionally, Global Investigations Review named her as one of the 100 remarkable women operating in the field of investigations around the world.

Her notable experience includes leading an international team that represented a Chinese telecommunications company charged with violating US export controls and sanctions, and securing the first ever "Temporary General License" enabling the company to stay in business during the multi-agency investigation.

As a former Assistant US Attorney in Washington and Deputy Assistant Secretary for Export Enforcement in the Department of Commerce's Bureau of Industry & Security (BIS), Wendy offers clients a unique combination of experience and insight as both a prosecutor and regulator before courts and agencies.

Registered Foreign Lawyer, Hong Kong
District of Columbia
Virginia

Hon. Stanley S. Harris, US District Court, District of Columbia, 1984-1985

J.D., University of Virginia School of Law, 1984, Virginia Law Review
B.A., University of Nebraska, 1981

Areas of Work

Representative Matters

Provides advice and representation as external export controls compliance counsel to multinational freight forwarding and logistics companies.
Appointed as a special ITAR compliance monitor by both the US Department of Justice and the US Department of State.
Represented Chinese telecommunications company ZTE Corporation in a five-year export controls and economic sanctions investigation by the US Departments of Justice, Commerce's Bureau of Industry & Security (BIS), and Treasury's Office of Foreign Assets Control (OFAC) from investigation to settlement. Secured the first ever Temporary General License (TGL), enabling ZTE to stay in business during the multi-agency investigation.
Provided compliance advice, conducting anti-corruption risk assessment on global operations, undertaking an internal investigation on three continents, and representing global company based in France before the US Department of Justice and Securities and Exchange Commission (SEC).
Conducted internal investigation of bribery allegations by the AIC in China for a US-based global healthcare company.
Conducted three internal FCPA investigations for a global insurance brokerage firm in China and Africa.
Conducted a global anti-corruption risk assessment review for a multinational beverage company, involving 13 countries throughout Asia. Following the risk assessments, developed global anti-corruption policies with tailored local policies that reflected particular risks faced in each country and incorporated local law.
Led the on-site investigative team on an internal investigation of a multinational company involving possible bribes paid in connection with undervalued imports in various countries in Africa and Asia.

Speaking Engagements

"Asia Legal Business," Hong Kong Anti-Corruption & Compliance Forum, October 28, 2020
"Asia Legal Business," Hong Kong In-House Legal Summit 2020, October 28, 2020
"US-China Trade Controls," American Conference Institute, August 13, 2020
"The Enforcement Environment: Perspectives from the Practitioners," Practising Law Institute's Coping with US Export Controls and Sanctions 2019, December 13, 2019
"Compliance Drill: Re-Thinking Contingency Planning and Compliance Amid More Overlapping, Unpredictable Exposure: ABC, Fraud, AML, Trade, Sanctions and Geopolitics," ACI's 36th International Conference on the FCPA, Oxon Hill, MD, December 5, 2019
Women, Influence & Power in Law Executive Leadership Forum, Corporate Counsel, Washington, DC, October 3, 2018

News & Publications

Press Releases

October 23, 2020

Media Mentions

October 15, 2020

Publications

Global Investigations Review

2020

By: Nicholas Turner, Wendy Wysong, Ali Burney

Press Releases

September 21, 2020

Media Mentions

September 17, 2020

Media Mentions

August 14, 2020

Media Mentions

August 11, 2020

Media Mentions

July 27, 2020

Media Mentions

July 24, 2020

Publications

Hong Kong Lawyer

July 2020

By: Wendy Wysong, Susan Munro, Ali Burney, Nicholas Turner

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Resources

International Law Advisory

October 21, 2020

By: Wendy Wysong, Ali Burney, Nicholas Turner, Wan Yi Ho

International Law Advisory

October 9, 2020

By: Wendy Wysong, Brian Egan, Edward J. Krauland, Ali Burney, Meredith Rathbone, Nicholas Turner

International Law Advisory

September 9, 2020

By: Brittany Prelogar, Meredith Rathbone, Gregory S. McCue, Wendy Wysong, Ali Burney, Nicholas Turner, Nicholas Kimbrell

International Law Advisory

August 25, 2020

By: Alexandra Baj, M. Jeffrey Beatrice, Ali Burney, Brian Egan, Eric C. Emerson, Edward J. Krauland, Michelle L. Levin, Patrick F. Linehan, Meredith Rathbone, Wendy Wysong, Elizabeth (Liz) Laskey LaRocca, Hena Schommer, Nicholas Turner, Dana J. Delott, Anthony Pan, Zachary Simmons, Martin Willner, Jacob Nelson (International Trade Assistant)

International Law Advisory

August 4, 2020

By: Lucinda A. Low, Wendy Wysong, Meredith Rathbone, Ali Burney, Nicholas Turner

International Law Advisory

July 20, 2020

By: Lucinda A. Low, Brittany Prelogar, Christopher R. Conte, John P. Rupp, Brigida Benitez, Wendy Wysong, Ali Burney, Jefferson Klocke, Yasmin Almeida, Anthony Pan, Wan Yi Ho

International Law Advisory

July 15, 2020

By: Wendy Wysong, Ali Burney, Darryl Nirenberg, Brian Egan, Nicholas Turner

International Law Advisory

June 1, 2020

By: Ali Burney, Brian Egan, Eric C. Emerson, Edward J. Krauland, Darryl Nirenberg, Susan Munro, Wendy Wysong, Nicholas Turner

International Law Advisory

May 22, 2020

By: Meredith Rathbone, Wendy Wysong, Jack R. Hayes, Hena Schommer, Peter Jeydel

International Law Advisory

May 11, 2020

By: Brian Egan, Jeffrey G. Weiss, Daniel A. Mullen, Wendy Wysong, Ali Burney, Ying Huang, Nicholas Turner, Zachary Simmons, Jacob Nelson (International Trade Assistant)

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Events

Webinars

Quarterly Investigations Update

October 27, 2020

Speakers: James D. Barnette, Christopher R. Conte, Paul R. Hurst, Patrick F. Linehan, Lucinda A. Low, Michael Campion Miller, Brittany Prelogar, Wendy Wysong

Webinars

How companies are handling ever-tightening US export controls and sanctions focused on China

October 7, 2020

Speaker: Wendy Wysong

Webinars

August 4, 2020

Speakers: M. Jeffrey Beatrice, Michelle L. Levin, Wendy Wysong

Webinars

Midyear Update

July 16, 2020

Speakers: James D. Barnette, Christopher R. Conte, Paul R. Hurst, Patrick F. Linehan, Lucinda A. Low, Michael Campion Miller, Brittany Prelogar, Wendy Wysong

On Demand

National Security and Foreign Investments into the United States Post-COVID-19

April 17, 2020

Speakers: Brian Egan, Wendy Wysong, Hena Schommer

Webinars

February 20, 2020

Speakers: Wendy Wysong, Ali Burney, Nicholas Turner

Noteworthy

Chambers Asia-Pacific, Band 1, Corporate Investigations/Anti-Corruption: China (2019-2020)
Chambers Global, Band 1, Corporate Investigations/Anti-Corruption: China (2019-2020)
Chambers Global, International Trade: Export Controls & Economic Sanctions, US (2019-2020)
Chambers USA, International Trade: Export Controls & Economic Sanctions, Nationwide (2019-2020)
Who's Who Legal, Investigations, Global Elite Thought Leader (2019-2020)
Who's Who Legal, Government Investigations Review, Thought Leader (2019)
Global Investigations Review, 25 Most Respected Sanctions Lawyers in Washington (2019)
Global Investigations Review, "Women in Investigations: One Hundred Investigation Specialists from Around the World" (2015)
Benchmark Litigation, Dispute Resolution Star, White-Collar Crime (2019-2020)
Benchmark Litigation, Top 100 Women in Litigation, Asia-Pacific (2020)
Legal 500 US, Dispute Resolution: International Trade (2019)
Legal 500 US, Dispute Resolution: Corporate Investigations and White-Collar Criminal Defense (2019)
Legal 500 Asia Pacific, Leading Lawyer, Regulatory: Anti-Corruption and Compliance, Hong Kong (2018-2020)
Expert Guides, White Collar Crime (2019-2020)
While serving as Assistant US Attorney in DC, received the Attorney General's Director's Award for Superior Achievement as an AUSA 1996 and was named Senior Litigation Counsel in 2003.

Previous Employment

Deputy Assistant Secretary for Export Enforcement, Bureau of Industry & Security (BIS), Department of Commerce (2004-2007)
Acting Assistant Secretary for Export Enforcement, Bureau of Industry & Security (BIS), Department of Commerce (2004-2005)
Assistant US Attorney, District of Columbia (1989-2004)

Professional Affiliations

Hong Kong Country Representative of TRACE International
Co-Chair, ABA Transnational Crimes, White-Collar Crime Committee
Steering Committee, ABA Export Controls & Economic Sanctions Committee
International Association of Independent Compliance Monitors
Leadership and Executive Committee, Vice Chair for West Coast/Pacific, Hong Kong Chapter Leader, Women's White-Collar Defense Association