Overview
Wendy Wysong focuses her practice on regulatory compliance and white-collar defense of international laws, including the Export Administration Regulations (EAR), US sanctions laws and regulations administered by the Office of Foreign Assets Control (OFAC), the International Traffic in Arms Regulations (ITAR), and US anti-boycott laws, as well as the US Foreign Corrupt Practices Act (FCPA). She represents clients throughout the United States and Asia, particularly regarding issues arising from the various US government "blacklists," including the Department of Commerce Entity List, OFAC's Specially Designated Nationals List, the Uyghur Forced Labor Prevention Act (UFLPA) Entity List, and the Department of Defense 1260H List. Much of her work involves helping clients navigate the business challenges faced in their overseas activities, including human rights, anti-corruption, and conflicting foreign sanctions and data security laws, necessitating coordinated legal, diplomatic, political, and communications solutions. 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 "has unrivalled expertise in the investigations and regulatory space. Her experience in the US government and clout in the industry has been extremely valuable in helping us navigate the ever-changing regulatory landscape. She provides invaluable insights into the mindsets and policy directions of regulators, prosecutors and other investigative bodies, and is able to advise us based on the breadth of knowledge and experience over decades of her career."
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
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.
Speaking Engagements
- "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", 11thAsia 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 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
Stepwise Risk Outlook
Sanctions Update: April 28, 2025
April 28, 2025
By: Evan T. Abrams, Meredith Rathbone, Karl Hopkins, Guy Soussan, Alexandra Melia, Darryl Nirenberg, Wendy Wysong, Ali Burney, Quentin Johnson, Elli Zachari, Elliot Letts, Melissa B. Mahle, Anni Coonan, Thomas Goldstein, Zayna Dembinski, Wilson Zhao, Zoey Hong, Hoi Chung Liu, Jonathan Eaton
International Compliance Blog
Weekly Sanctions Update: April 28, 2025
April 28, 2025
By: Evan T. Abrams, Meredith Rathbone, Karl Hopkins, Guy Soussan, Alexandra Melia, Darryl Nirenberg, Wendy Wysong, Ali Burney, Quentin Johnson, Elli Zachari, Elliot Letts, Melissa B. Mahle, Anni Coonan, Thomas Goldstein, Zayna Dembinski, Wilson Zhao, Zoey Hong, Hoi Chung Liu, Jonathan Eaton
Stepwise Risk Outlook
Sanctions Update: April 21, 2025
April 21, 2025
By: Evan T. Abrams, Meredith Rathbone, Karl Hopkins, Guy Soussan, Alexandra Melia, Darryl Nirenberg, Wendy Wysong, Ali Burney, Quentin Johnson, Elli Zachari, Elliot Letts, Melissa B. Mahle, Anni Coonan, Thomas Goldstein, Zayna Dembinski, Wilson Zhao, Zoey Hong, Hoi Chung Liu, Jonathan Eaton
International Compliance Blog
Weekly Sanctions Update: April 21, 2025
April 21, 2025
By: Evan T. Abrams, Meredith Rathbone, Karl Hopkins, Guy Soussan, Alexandra Melia, Darryl Nirenberg, Wendy Wysong, Ali Burney, Quentin Johnson, Elli Zachari, Elliot Letts, Melissa B. Mahle, Anni Coonan, Thomas Goldstein, Zayna Dembinski, Wilson Zhao, Zoey Hong, Hoi Chung Liu, Jonathan Eaton
Stepwise Risk Outlook
Sanctions Update: April 14, 2025
April 14, 2025
By: Evan T. Abrams, Meredith Rathbone, Karl Hopkins, Guy Soussan, Alexandra Melia, Darryl Nirenberg, Wendy Wysong, Ali Burney, Quentin Johnson, Elli Zachari, Elliot Letts, Melissa B. Mahle, Anni Coonan, Thomas Goldstein, Wilson Zhao, Zoey Hong, Isabella Rao, Jonathan Eaton
International Compliance Blog
Weekly Sanctions Update: April 14, 2025
April 14, 2025
By: Evan T. Abrams, Meredith Rathbone, Karl Hopkins, Guy Soussan, Alexandra Melia, Darryl Nirenberg, Wendy Wysong, Ali Burney, Quentin Johnson, Elli Zachari, Elliot Letts, Melissa B. Mahle, Anni Coonan, Thomas Goldstein, Wilson Zhao, Zoey Hong, Isabella Rao, Jonathan Eaton
Stepwise Risk Outlook
Sanctions Update: April 7, 2025
April 7, 2025
By: Evan T. Abrams, Meredith Rathbone, Karl Hopkins, Guy Soussan, Alexandra Melia, Darryl Nirenberg, Wendy Wysong, Ali Burney, Quentin Johnson, Elli Zachari, Elliot Letts, Melissa B. Mahle, Anni Coonan, Thomas Goldstein, Wilson Zhao, Zoey Hong, Jonathan Eaton, Sophia Yang
International Compliance Blog
Weekly Sanctions Update: April 7, 2025
April 7, 2025
By: Evan T. Abrams, Meredith Rathbone, Karl Hopkins, Guy Soussan, Alexandra Melia, Darryl Nirenberg, Wendy Wysong, Ali Burney, Quentin Johnson, Elli Zachari, Elliot Letts, Melissa B. Mahle, Anni Coonan, Thomas Goldstein, Wilson Zhao, Zoey Hong, Jonathan Eaton, Sophia Yang
Stepwise Risk Outlook
US Intelligence’s 2025 Worldwide Threat Assessment; Implications for Businesses
April 2, 2025
By: Melissa B. Mahle
International Compliance Blog
Trump Imposes Novel “Secondary Tariffs” on Countries Importing Venezuelan Oil and Petroleum Products
March 31, 2025
By: Steptoe's Economic Sanctions Practice
Resources
Client Alerts
FCPA/Anti-Corruption Developments: 2022 Year in Review
February 24, 2023
By: Iris E. Bennett
Client Alerts
FCPA/Anti-Corruption Developments: 2021 Year in Review
February 15, 2022
By: Iris E. Bennett, Brigida Benitez, Zoe Osborne, Wendy Wysong, Jingchun (Cherry) Huang, Samantha McCarthy, James M. Purce, Lin Yang, Bo Yue, Wilson Zhao, Joshua Dupre (law clerk), Zhaoxi Zhang (international paralegal)
Client Alerts
China's New Blocking Rules May Impact US Sanctions and Export Control Compliance Strategies for Many
February 10, 2021
By: Edward J. Krauland, Bo Yue
Client Alerts
Singapore Data Protection: Considerations for Data Driven Compliance Activities
February 1, 2021
By: Wendy Wysong, Ali Burney
Client Alerts
The Top Ten Asia-Pacific FCPA Enforcement Actions of 2020
January 27, 2021
By: Wendy Wysong
Client Alerts
FCPA/Anti-Corruption Developments: 2020 Year in Review
January 19, 2021
By: Zoe Osborne, Brigida Benitez, Alexandra Baj, Christopher R. Conte, Alexandra Melia, Ali Burney, Fernando Q. Merino, Wendy Wysong, Jefferson Klocke, Jingchun (Cherry) Huang, Troy Shephard, Lin Yang, Bo Yue, Lucas Caiado (International Regulation & Compliance Intern), Jordan Cannon (Law Clerk), Marcia Pulcherio (International Trainee)
Client Alerts
Sanctions Under the Biden Administration: A Return to 'Smart?'
November 24, 2020
By: Edward J. Krauland, Meredith Rathbone, Wendy Wysong, Jack R. Hayes, Evan T. Abrams, Martin Willner, Jordan Cannon (Law Clerk)
Client Alerts
HKSE Listing Applicants: What You Should Know about Sanctions and Export Controls Due Diligence
October 21, 2020
By: Wendy Wysong, Ali Burney
Client Alerts
White House Memorandum Sets Out Best Practices for Agency Enforcement Actions
October 9, 2020
By: Wendy Wysong, Edward J. Krauland, Ali Burney, Meredith Rathbone
Events
Webinars
Quarterly Investigations & Enforcement Update
April 24, 2025
Speakers: Jason Abel, Akita Adkins, Iris E. Bennett, Christopher R. Conte, Amba M. Datta, Ryan Hayden, Michelle Kallen, Patrick F. Linehan, Michael Campion Miller, Zoe Osborne, Wendy Wysong
Webinars
Quarterly Investigations & Enforcement Update
January 28, 2025
Speakers: Jason Abel, Lee Berger, Christopher R. Conte, Amba M. Datta, Ryan Hayden, Gregory S. McCue, Michael Campion Miller, Zoe Osborne, Wendy Wysong
Seminars & Events
Brussels Symposium and Cocktail Reception
November 12, 2024
Speakers: Ruxandra Cana, Eric C. Emerson, Tyler Evans, Anne-Gabrielle Haie, Robert Klotz, Patrick F. Linehan, Byron Maniatis, Eva Monard, Eléonore Mullier, Daniel A. Mullen, Darryl Nirenberg, Meredith Rathbone, Jeffrey G. Weiss, Charles Whiddington, Wendy Wysong
Webinars
The Steptoe Update: US, EU, and UK Legal Developments Affecting Asian Companies and Public Actors
November 6, 2024
Speakers: Christophe Bondy, Patrick F. Linehan, Zachary Song, Charles Whiddington, Wendy Wysong
Webinars
Quarterly Investigations & Enforcement Update
October 30, 2024
Speakers: Jason Abel, Akita Adkins, Iris E. Bennett, Amba M. Datta, Sandra Hanna, Ryan Hayden, Patrick F. Linehan, Michael Campion Miller, Zoe Osborne, Wendy Wysong
Webinars
Quarterly Investigations & Enforcement Update
July 31, 2024
Speakers: Jason Abel, Iris E. Bennett, Coy Garrison, John J. Kavanagh, Michael Campion Miller, Zoe Osborne, Wendy Wysong
Webinars
Quarterly Investigations & Enforcement Update Webinar
May 1, 2024
Speakers: Jason Abel, Iris E. Bennett, Christopher R. Conte, Amba M. Datta, Patrick F. Linehan, Michael Campion Miller, Zoe Osborne, Wendy Wysong
Webinars
Quarterly Investigations & Enforcement Update Webinar
January 25, 2024
Speakers: Jason Abel, Iris E. Bennett, Lee Berger, Christopher R. Conte, Amba M. Datta, John J. Kavanagh, Michael Campion Miller, Zoe Osborne, Wendy Wysong
Webinars
Investigations & Enforcement Webinar Series
October 19, 2023
Speakers: Andrew C. Adams, Jason Abel, Iris E. Bennett, Christopher R. Conte, Patrick F. Linehan, John J. Kavanagh, Zoe Osborne, Wendy Wysong
Webinars
Investigations & Enforcement Webinar Series
July 27, 2023
Speakers: Jason Abel, Lee Berger, Christopher R. Conte, Amba M. Datta, Patrick F. Linehan, Cáitrín McKiernan, Michael Campion Miller, Zoe Osborne, Wendy Wysong
Noteworthy
- 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 (2019-2024)
- 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, 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.
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
- 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