Wilson Zhao

Associate

Hong Kong

+852 2241 2574

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Areas of Work

Export Controls, Economic Sanctions, Customs, National Security & Cross-Border Transactions

Languages

Mandarin

Overview

Wilson Zhao focuses his practice on regulatory compliance and cross-border investigations involving sanctions, import/export controls, and anti-bribery laws. He has experience assisting clients in a variety of sectors handling internal and external investigations, conducting risk assessments, filing voluntary self-disclosures, and navigating the legal changes arising from various US sanctions and export control lists. Utilizing his in-house and governmental experience, he is able to help clients conduct cross-border investigations and develop practical compliance programs, particularly when facing conflicting obligations in the Asia-Pacific region.

Wilson also advises clients on various national security-related investment controls, including Committee on Foreign Investment in the United States (CFIUS) and information and communications technology services (ICTS) rules.

Prior to joining Steptoe, Wilson served as trade compliance counsel and legal advisor for Alibaba. He began his practice as an associate at a leading Chinese law firm; he also worked as a senior customs officer in Zhoushan, China for more than four years.

New York
Chinese National Bar (non-practicing)
Registered Foreign Lawyer, Hong Kong

LL.M., New York University School of Law, 2020
B.L., China University of Political Science and Law, 2011

Areas of Work

Representative Matters

Provide ongoing legal and compliance advice concerning the application of US sanctions and export controls to the global operations of a Chinese state-owned telecommunications company.
Representing Chinese companies in the biotechnology, information technology, chemicals, and digital solutions industries in their effort to be removed from the US sanctions and export control lists, and to prevent additional listings by other agencies.
Representation of a major international social media company on all matters related to international sanctions, including sanctions against Russia.
Advise one of the largest SOEs on matters related to international sanctions, including US sanctions against Russia, Iran, and Venezuela.
Representation of Chinese companies in the biotechnology, information technology, 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.
Representation of an Asia-based global oil and gas trading company in relation to a multi-agency sanctions-related investigation by DOJ, Homeland Security Investigations (HSI), and the FBI.
Advise the investment teams of Mainland and Hong Kong subsidiaries of major investment banks on IPO transactions where the issuer was either subject to US sanctions or export controls or had business dealings with such entities.

News & Publications

Stepwise Risk Outlook

February 9, 2026

By: Evan T. Abrams, Meredith Rathbone, Karl Hopkins, Alexandra Melia, Wendy Wysong, Ali Burney, Quentin Johnson, Elliot Letts, Melissa B. Mahle, Anni Coonan, Thomas Goldstein, Zayna Dembinski, Wilson Zhao, Zoey Hong, Sophia Yang, Jonathan Eaton, Carter Spahn, Chris Dantes

International Compliance Blog

February 9, 2026

Stepwise Risk Outlook

February 2, 2026

By: Evan T. Abrams, Meredith Rathbone, Karl Hopkins, Guy Soussan, Alexandra Melia, Wendy Wysong, Ali Burney, Quentin Johnson, Elliot Letts, Algirdas Semeta, Melissa B. Mahle, Anni Coonan, Thomas Goldstein, Zayna Dembinski, Wilson Zhao, Zoey Hong, Hoi Chung Liu, Jonathan Eaton

International Compliance Blog

February 2, 2026

Stepwise Risk Outlook

January 26, 2026

International Compliance Blog

January 26, 2026

Stepwise Risk Outlook

January 21, 2026

International Compliance Blog

January 21, 2026

Stepwise Risk Outlook

January 12, 2026

By: Evan T. Abrams, Meredith Rathbone, Karl Hopkins, Alexandra Melia, Wendy Wysong, Ali Burney, Quentin Johnson, Elliot Letts, Algirdas Semeta, Melissa B. Mahle, Anni Coonan, Thomas Goldstein, Zayna Dembinski, Wilson Zhao, Zoey Hong, Hoi Chung Liu, Jonathan Eaton

International Compliance Blog

January 12, 2026

View All

Resources

Client Alerts

February 15, 2022

By: Iris E. Bennett, Brigida Benitez, Zoe Osborne, Wendy Wysong, Samantha McCarthy, James M. Purce, Lin Yang, Bo Yue, Wilson Zhao, Joshua Dupre (law clerk), Zhaoxi Zhang (international paralegal)

Wilson Zhao

Associate

Overview

Areas of Work

Representative Matters

News & Publications

Resources

Events