Overview
Wilson (Di) Zhao focuses his practice on sanctions, import/export controls, and anti-bribery compliance and investigations . He has experience assisting clients in a variety of sectors, ranging from e-commerce, manufacturing, banking, and insurance. Utilizing his in-house and PRC governmental experience, he is able to help clients design and implement practical compliance programs, particularly when facing conflicting obligations. 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, the leading Chinese e-commerce company. He began his practice at a leading Chinese law firm as an associate. 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.
- 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
Media Mentions
Nikkei Asia Quotes Wilson Zhao in Article About DoD’s Chinese Military Companies List
February 9, 2024
International Compliance Blog
The Top Ten Asia-Pacific FCPA Enforcement Actions of 2023
January 12, 2024
By: Wendy Wysong, Wilson Zhao, Zoey Hong
International Compliance Blog
December 29, 2023
By: Ali Burney, Wendy Wysong, David M. Stetson, Zoey Hong, Wilson Zhao
International Compliance Blog
Biden Administration Announces New Outbound Investment Regime Targeting China
August 11, 2023
By: Evan T. Abrams, Wilson Zhao, Ali Burney, Wendy Wysong, Jack R. Hayes, David M. Stetson, Brian J. Fleming, Bo Yue, Meredith Rathbone, Edward J. Krauland, Alexandra Baj
International Compliance Blog
Commerce, Treasury, and Justice Issue Joint Compliance Note on Voluntary Self-Disclosure
July 31, 2023
By: Wilson Zhao, Wendy Wysong, Ali Burney, Jack R. Hayes, David M. Stetson, Brian J. Fleming, Edward J. Krauland, Bo Yue
Publications
New Sanctions Authority for Theft of Us Trade Secrets by Foreign Persons
WorldECR
February 2023
By: Ali Burney, Wilson Zhao, David M. Stetson, Darryl Nirenberg, Zoey Hong
Client Alerts
The Top Ten Asia-Pacific FCPA Enforcement Actions of 2022
January 18, 2023
By: Wendy Wysong, Wilson Zhao, Zoey Hong, Zhaoxi Zhang
Publications
OFAC Publishes Determination and Guidance on Implementing the Price Cap Policy for Russian Crude Oil
WorldECR
December 2022 – January 2023
By: Wendy Wysong, Ali Burney, David M. Stetson, Edward J. Krauland, Bo Yue, Wilson Zhao, Zoey Hong
International Compliance Blog
Price Cap Coalition Selects Level for Cap on Price of Seaborne Russian-Origin Crude Oil
December 13, 2022
By: Ali Burney, David M. Stetson, Wendy Wysong, Darryl Nirenberg, Wilson Zhao, Zoey Hong
International Compliance Blog
November 29, 2022
By: Wendy Wysong, Ali Burney, Bo Yue, Wilson Zhao, David M. Stetson, Edward J. Krauland, Zoey Hong
Resources
Client Alerts
FCPA/Anti-Corruption Developments: 2021 Year in Review
February 15, 2022
By: Iris E. Bennett, Lucinda A. Low, Rachel B. Peck, 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)
Events
Seminars & Events
Global Trade and Enforcement Symposium in Hong Kong
June 1, 2023
Speakers: Renato Antonini, Yongqing Bao, Brigida Benitez, Brian G. Burke, Ali Burney, Henry Cao, John Caracappa, Boyd Cloern, Robyn C. Crowther, Brian J. Fleming, Coy Garrison, Stacie R. Hartman, Zoey Hong, Stanley C. Kuo, Amy J. Lentz, Michelle L. Levin, Patrick F. Linehan, Lucinda A. Low, Jamie Lucia, Alexandra Melia, Cáitrín McKiernan, Eva Monard, Darryl Nirenberg, Gwendolyn Prothro Renigar, Angus Rodger, Guy Soussan, David M. Stetson, Grace Wang, Philip R. West, Charles Whiddington, Wendy Wysong, Lin Yang, Bo Yue, Wilson Zhao