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 DHL's external export controls compliance counsel.
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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 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
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"The Enforcement Environment: Perspectives from the Practitioners," Practising Law Institute's Coping with US Export Controls and Sanctions 2019, December 13, 2019
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"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
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Women, Influence & Power in Law Executive Leadership Forum, Corporate Counsel, Washington, DC, October 3, 2018
News & Publications
Press Releases
Steptoe Receives 19 Practice, 56 Individual Mentions in Chambers USA 2020
April 23, 2020
Press Releases
Steptoe Receives 13 Practice, 29 Individual Mentions in Chambers Global 2020
February 13, 2020
Publications
The BIS Entity List: The US Government's 'New' Foreign Policy Stick
The Review of Banking & Financial Services
February 2020
By: Wendy Wysong, Ali Burney, Hena Schommer, Nicholas Turner, Anthony Pan
Publications
Has the Road to Settlement Gotten Bumpier?
Corporate Compliance Insights
March 2019
By: Wendy Wysong
Resources
International Law Advisory
BIS Expands Entity List Jurisdiction Covering Huawei and Affiliates
May 22, 2020
By: Meredith Rathbone, Wendy Wysong, Jack R. Hayes, Hena Schommer, Peter Jeydel
International Law Advisory
Trump Administration Pursues Restrictions to Secure US Electricity Grid
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)
International Law Advisory
Commerce Issues Long-Awaited Export Control Rules for China, Russia, and Venezuela
April 30, 2020
By: Edward J. Krauland, Brian Egan, Wendy Wysong, Meredith Rathbone, Alexandra Baj, Hena Schommer, Nicholas Turner, Jack R. Hayes, Peter Jeydel
International Law Advisory
US and EU Sanctions Policies on Humanitarian Exports and COVID-19 Relief
April 6, 2020
By: Wendy Wysong, Ali Burney, Edward J. Krauland, Meredith Rathbone, Guy Soussan, Hena Schommer, Nicholas Turner, Jack R. Hayes, Peter Ibrahim, Stefan Tsakanakis, Eléonore Colin
International Law Advisory
Four Things We Learned from OFAC's Recent SDN Designations
March 5, 2020
By: Wendy Wysong, Ali Burney, Nicholas Turner, Hena Schommer
International Law Advisory
Holding Steady: Improvements Offset by Declines in 2019 Asia Pacific Corruption Rankings
February 11, 2020
By: Wendy Wysong, Ali Burney, Susan Munro, Richard J. Battaglia, Hena Schommer, Nicholas Turner, Anthony Pan
International Law Advisory
The Asia Pacific Top Ten FCPA Enforcement Actions of 2019
February 3, 2020
By: Wendy Wysong, Richard J. Battaglia, Susan Munro, Ali Burney, Hena Schommer, Nicholas Turner, Anthony Pan
International Law Advisory
FCPA/Anti-Corruption Developments: 2019 Year in Review
January 21, 2020
By: Lucinda A. Low, Brittany Prelogar, Brigida Benitez, Wendy Wysong, Zoe Osborne, Steven J. Barber, Alexandra Melia, Susan Munro, Richard J. Battaglia, Ali Burney, Fernando Q. Merino, Rachel B. Peck, Nicholas Turner, Hena Schommer, Alexandra Baj, Jessica Piquet Megaw, Elizabeth Arkell, Jefferson Klocke, Yasmin Almeida, Yas Froemel, Veronica Ganzitti, Chris Han, Peter Ibrahim, Jessica D. Maneval, Lia Metreveli, Jillian Norton, Anthony Pan, Alexandrea Rahill, Ayushi Sharma, Troy Shephard, A. Cherie Tremaine, Stefan Tsakanakis, Meihui (May) Xiao, Lin Yang, Bo Yue
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, Nicholas Turner, Jillian Norton
Events
On Demand
April 17, 2020
Speakers: Brian Egan, Wendy Wysong, Hena Schommer
Webinars
Ask the Lawyers: Update on US Sanctions Risks for Non-US Companies
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)
- 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