Wendy Wysong

Economic Sanctions and Export Controls

• We successfully advised a Chinese company on its removal from the BIS Entity List after it was included based on allegations of forced labor, which we successfully rebutted, marking the first removal from that list in over two years.
• Conducted a global audit of Airbus' commercial and defense-related businesses as part of a monitorship requirement imposed on the company in connection with a consent agreement with the US Department of State, Directorate of Defense Trade Controls to settle allegations of export control violations under the International Traffic in Arms Regulations (ITAR).
• Representing Chinese companies in the biotechnology, information technology, chemicals, radio technology, and digital solutions industries before BIS, OFAC, DOJ, and other government agencies in their effort to be removed from the BIS Entity List and to prevent additional listings by other agencies
• Represents clients on all aspects of delisting from and compliance with the BIS Entity List, Federal Communications (FCC) List, National Defense Authorization Act (NDAA), Military End Use and End User List, non-SDN CMIC List, including impact of restrictions on listed entities’ U.S. and foreign subsidiaries, affiliates, and global operations and supply chain.
• Represented Chinese telecommunications company ZTE Corporation in a five-year 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.
• Appointed as a special compliance monitor by both the US Department of Justice and the US Department of State.

FCPA/Anti-Corruption

• We are collaborating with the Foundation for International Human Rights Reporting Standards (FIHRRST) in Indonesia, on joint projects for Indonesian clients involving anti-corruption, anti-money laundering, business and human rights, environmental, social, and governance (ESG), and sustainability.  
• Led an internal investigation on three continents, and represented global company based in France before the US Department of Justice and Securities and Exchange Commission (SEC), successfully concluded with no penalty.
• 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.

• "Strategic Responses for Chinese Enterprises Amid Technology Blockades and Restrictions," 4th Compliance Management & Practice Conference, Infotrans, Shanghai, China, June 20, 2025
• "Crossroad of Compliance: Sanctions and the US-China Trade Relationship," Dow Jones Risk & Compliance, June 5, 2025
• "Strengthening Compliance & Risk Management in Indonesia," Steptoe and Moores Rowland Indonesia, Jakarta, Indonesia, April 24, 2025
• "The New Compliance Risks and Realities in China: A Closer Look at the Intricacies of the Data Security, Encryption, Cloud and Cyber Landscapes," ACI's 15th Advance Forum on Global Encryption, AI, Cloud & Cyber Export Controls, American Conference Institute, San Francisco, CA, March 26, 2025
• "Trade Remedies and Sanctions," 8^th IBA Asia Pacific Regional Forum Biennial Conference, International Bar Association, Hong Kong, February 21, 2025
• "US Treasury’s Final Rule on US Outbound Investments and Defense Department's Chinese Military Companies List," Asia Securities Industry & Financial Markets Association (ASIFMA) Webinar, January 21, 2025
• "Anti-Bribery & Corruption: 2024 APAC Region Update," Anti-Bribery & Corruption: 2024 APAC Region Update Webinar, TRACE International, December 11, 2024
• "The Impact of Current Geopolitical Developments on Trade Policy," Brussels Symposium, Steptoe, November 12, 2024  
• "Managing Export Control Evasion Risks," ACAMS: The Assembly APAC, Hong Kong, April 23, 2024
• "Round-Table: The Possible Impact of the New US Outbound Investment Review Regulations on Chinese High-Tech Companies," Infotech 3rd Compliance and Management Practice Conference, Shanghai, April 17, 2024
• "Anti-Corruption Issues When Doing Business in Asia Pacific," Practicing Law Institute Foreign Corrupt Practices Act and International Anti-Corruption Developments Conference 2024, New York, April 10, 2024
• "Recent Trends and Investigations in FCPA Enforcement", 11^thAsia Anti-Corruption Compliance Summit 2023, November 16, 2023
• "The Development of International Cooperation in Corruption Investigations," IBA Annual Conference, November 1, 2022
• "Managing Compliance in the Current Environment," Alix Partners, April 6, 2022
• "BIS Entity List Removal Strategy," Enterprise Compliance Management and Practice Conference, Shanghai, March 11, 2022
• "Interpretation of US Trade and Control Policies from the Perspective of Chinese Enterprises," 4th Global Export Control (China) Summit hosted by Ficient Global, March 24, 2022
• "How Companies are Implementing China's New Data Security and Export Control Laws: The Finer Points of Navigating Grey Areas Affecting Data Transfers, Classification," ACI's 12^thAnnual Forum on Global Encryption, Cloud & Cyber Export Controls, March 30, 2022
• Co-Chair, GIR Live: Hong Kong 2021, December 8, 2021
• "Navigating the Challenges of Trade Compliance and Export Control in Asia Pacific," Dow Jones Risk & Compliance Webinar, September 15, 2021
• Managing Regulatory and Enforcement Risks: Preparing for the Impact of COVID-19, The Legal Week's Dispute Resolution Forum, June 16, 2021
• "US Tech Export Controls, Sanctions Against Chinese Entities in 2020," China Law & Practice podcast, January 7, 2021
• Co-Chair, GIR Live: Hong Kong 2020, December 7, 2020
• "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

• IFLR1000, "Leading Lawyer – Highly Regarded," Hong Kong SAR (2024-2025)
• Women's White Collar Defense Association, Laurie A. Miller Leadership Award for the Advancement of Women in White Collar Defense (2024)
• Chambers Greater China, Band 1, Corporate Investigations/ Anti-Corruption: China (International Firms) (2015-2024) (formerly Chambers Asia-Pacific)
• Chambers Greater China, Band 2, International Trade/WTO (International Firms) (2024)
• Chambers Global, Band 1, Corporate Investigations/Anti-Corruption: China (2019-2024)
• Chambers Global, International Trade: Export Controls & Economic Sanctions, US (2019-2024)
• Chambers USA, International Trade: Export Controls & Economic Sanctions, Nationwide (2019-2025)
• Who's Who Legal, Investigations, Top Practitioner (2024)
• Who's Who Legal, Investigations, Global Elite Thought Leader (2019-2023)
• Who's Who Legal, Government Investigations Review, Thought Leader (2019)
• Who's Who Legal, Investigations (2019-2022)
• Who's Who Legal, Business Crime Defence - Corporates (2022)
• Who's Who Legal, Business Crime Defence, Mainland China & Hong Kong SAR Thought Leader (2022)
• 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, International Trade: Export Controls & Economic Sanctions (2025)
• 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 Individual, Regulatory: Anti-Corruption and Compliance, Hong Kong (2018-2025)
• Expert Guides, White Collar Crime (2019-2020)
• China Business Law Journal, A-List Visionary (2022, 2024-2025)
• 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.

• 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)

• Hong Kong Country Representative of TRACE International
• 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