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 and co-chair of the firm's Investigations and White-Collar Defense group.

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

Successfully represented a Singapore based commodity trader in front of DOJ and FBI relating to allegations of violations of US sanctions and anti-money laundering laws. As a result of the representation, DOJ issued a declination letter and the client did not have to pay a monetary penalty despite the fact that the initial allegations by DOJ and FBI suggested more than USD 200 million in suspect transactions over a five-year period.
Represented an Asia based refiner in relation to an inquiry from the State Department relating to a suspected shipment of Iranian crude oil. Following our submissions on behalf of the client, the State Department concluded its inquiry without any further action against our client.
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

"US Tech Export Controls, Sanctions Against Chinese Entities in 2020," China Law & Practice podcast, January 7, 2021
"Taking Stock of US Relations Post-Election: The View from DC and Hong Kong," AmCham Webinar, November 9, 2020
"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

Media Mentions

March 17, 2021

Media Mentions

March 15, 2021

Press Releases

February 18, 2021

Media Mentions

February 11, 2021

Media Mentions

January 19, 2021

Publications

Asian Legal Business

January 7, 2021

By: Richard J. Battaglia, Wendy Wysong, Susan Munro, Lin Yang, Anthony Pan

Media Mentions

January 6, 2021

Press Releases

December 17, 2020

Media Mentions

November 4, 2020

Press Releases

October 23, 2020

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Resources

International Law Advisory

February 23, 2021

By: Wendy Wysong, Richard J. Battaglia, Ali Burney, Susan Munro, Nicholas Turner, Anthony Pan

International Law Advisory

February 10, 2021

By: Edward J. Krauland, Bo Yue

International Law Advisory

February 1, 2021

By: Lucinda A. Low, Wendy Wysong, Ali Burney, Wan Yi Ho

International Law Advisory

January 27, 2021

By: Wendy Wysong, Anthony Pan

International Law Advisory

January 19, 2021

By: Lucinda A. Low, Zoe Osborne, Brigida Benitez, Alexandra Baj, Christopher R. Conte, Alexandra Melia, Susan Munro, Richard J. Battaglia, Ali Burney, Fernando Q. Merino, Wendy Wysong, Rachel B. Peck, Nicholas Turner, Elizabeth Arkell, Yas Froemel, Veronica Ganzitti, Wan Yi Ho, Jingchun (Cherry) Huang, Nicholas Kimbrell, Jessica D. Maneval, Lia Metreveli, Anthony Pan, Troy Shephard, Jennifer Shulkin, A. Cherie Tremaine, Stefan Tsakanakis, Lin Yang, Bo Yue, Lucas Caiado (International Regulation & Compliance Intern), Jordan Cannon (Law Clerk), Marcia Pulcherio (International Trainee)

International Law Advisory

November 24, 2020

By: Edward J. Krauland, Meredith Rathbone, Wendy Wysong, Jack R. Hayes, Nicholas Turner, Peter Jeydel, Evan T. Abrams, Martin Willner, Nicholas Kimbrell, Jordan Cannon (Law Clerk)

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

International Law Advisory

August 25, 2020

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

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Events

Webinars

Quarterly Investigations Update

February 25, 2021

Speakers: Jason Abel, Christopher R. Conte, Paul R. Hurst, Patrick F. Linehan, Lucinda A. Low, Michael Campion Miller, Zoe Osborne, Wendy Wysong

Webinars

February 10, 2021

Speakers: Lucinda A. Low, Wendy Wysong

Webinars

January 28, 2021

Speakers: Brian M. Heberlig, Wendy Wysong, Nicholas Turner

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, 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: 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, Wendy Wysong

On Demand

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

April 17, 2020

Speakers: Brian Egan, Wendy Wysong

Webinars

February 20, 2020

Speakers: Wendy Wysong, Ali Burney, Nicholas Turner

Noteworthy

Chambers Asia-Pacific, Band 1, Corporate Investigations/Anti-Corruption: China (2019-2021)
Chambers Global, Band 1, Corporate Investigations/Anti-Corruption: China (2019-2021)
Chambers Global, International Trade: Export Controls & Economic Sanctions, US (2019-2021)
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 (2018-2021)
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