Wendy Wysong

Partner

Hong Kong

+852 3729 1804

Washington, DC

+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

"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 12th Annual 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

News & Publications

Publications

May 2022

By: Edward J. Krauland, Meredith Rathbone, Wendy Wysong, David M. Stetson, Jack R. Hayes, Peter Jeydel, Martin Willner, Jordan Cannon, Ryan Pereira

Client Alerts

Transparency International's CPI and the TRACE Bribery Risk Matrix

March 29, 2022

By: Wendy Wysong, Ali Burney, Nicholas Turner

Publications

March 2022

By: Wendy Wysong, Nicholas Turner, Wilson (Di) Zhao

Press Releases

February 22, 2022

Publications

Regulation Asia

February 2, 2022

By: Nicholas Turner, Edward J. Krauland, Alexandra Baj, Wendy Wysong, David M. Stetson, Meredith Rathbone

Publications

WorldECR

February 2022

By: Wilson (Di) Zhao, Wendy Wysong, Ali Burney, Nicholas Turner

Media Mentions

January 28, 2022

Press Releases

January 13, 2022

Press Releases

January 13, 2022

Client Alerts

January 10, 2022

By: Wendy Wysong

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Resources

Client Alerts

February 15, 2022

By: Iris E. Bennett, Lucinda A. Low, Elizabeth Arkell, Rachel B. Peck, Brigida Benitez, Zoe Osborne, Wendy Wysong, Jordan Cannon, Jingchun (Cherry) Huang, Jessica D. Maneval, Samantha McCarthy, James M. Purce, Meihui (May) Xiao, Lin Yang, Bo Yue, Wilson (Di) Zhao, Joshua Dupre (law clerk), Zhaoxi Zhang (international paralegal)

Client Alerts

February 23, 2021

By: Wendy Wysong, Ali Burney, Nicholas Turner

Client Alerts

February 10, 2021

By: Edward J. Krauland, Bo Yue

Client Alerts

February 1, 2021

By: Lucinda A. Low, Wendy Wysong, Ali Burney

Client Alerts

January 27, 2021

By: Wendy Wysong

Client Alerts

January 19, 2021

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

Client Alerts

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)

Client Alerts

October 21, 2020

By: Wendy Wysong, Ali Burney, Nicholas Turner

Client Alerts

October 9, 2020

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

Client Alerts

September 9, 2020

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

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Events

Webinars

Quarterly Investigations Update

April 21, 2022

Speakers: Iris E. Bennett, Christopher R. Conte, Stacie R. Hartman, Paul R. Hurst, Lucinda A. Low, Alexandra Melia, Michael Campion Miller, Wendy Wysong, Rachel B. Peck

Webinars

March 24, 2022

Speakers: Lucinda A. Low, Wendy Wysong, Bo Yue

Webinars

Quarterly Investigations Update

January 27, 2022

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

Webinars

Quarterly Investigations Update

October 28, 2021

Speakers: Christopher R. Conte, Erica Gerson, Stacie R. Hartman, Paul R. Hurst, Lucinda A. Low, Michael Campion Miller, Zoe Osborne, Wendy Wysong

Webinars

Quarterly Investigations Update

July 21, 2021

Speakers: Jason Abel, Elizabeth H. Baird, Christopher R. Conte, Stacie R. Hartman, Patrick F. Linehan, Lucinda A. Low, Michael Campion Miller, Zoe Osborne, David M. Stetson, Wendy Wysong

Webinars

Quarterly Investigations Update

May 12, 2021

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

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

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Noteworthy

Chambers Asia-Pacific, Band 1, Corporate Investigations/Anti-Corruption: China (2019-2022)
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 (2019-2021)
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