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 spearheading the launch of Steptoe's Hong Kong office.
Ranked as a top-tier practitioner by Chambers in its Asia Pacific and Global guides, Wendy has been noted by the editors for her "deep experience in matters related to economic sanctions, handling both enforcement and compliance." 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.
- 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
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Appointed as a special compliance monitor by both the US Department of Justice and the US Department of State.
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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.
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Provided advice and representation as DHL's external export controls compliance counsel.
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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).
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Conducted internal investigation of bribery allegations by the AIC in China for a US-based global healthcare company.
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Conducted three internal FCPA investigations for a global insurance brokerage firm in China and Africa.
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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.
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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
- "The Enforcement Environment: Perspectives from the Practitioners," Practising Law Institute's Coping with US Export Controls and Sanctions 2019, December 13, 2019
- 36th International Conference on Foreign Corrupt Practices Act, American Conference Institute, December 5, 2019
- Women, Influence & Power in Law Executive Leadership Forum, Corporate Counsel, Washington, DC, October 3, 2018
News & Publications
Publications
Has the Road to Settlement Gotten Bumpier?
Corporate Compliance Insights
March 2019
By: Wendy Wysong
Resources
International Law Advisory
DOJ Adds Incentives for Disclosure in Updated Export Control and Sanctions Enforcement Policy
January 13, 2020
By: M. Jeffrey Beatrice, Wendy Wysong, Ali Burney, Hena Schommer, Jillian Norton
Noteworthy
- Chambers Asia-Pacific, Band 1, Corporate Investigations/Anti-Corruption (International Firms) – China
- Chambers Global, Band 1, Corporate Investigations/Anti-Corruption (International Firms) – China
- Chambers USA, International Trade: Export Controls & Economic Sanctions, Nationwide
- Benchmark Litigation, Dispute Resolution Star, White-Collar Crime (2018)
- Global Investigations Review,"Women in Investigations: One Hundred Investigation Specialists from Around the World" (2015)
- 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