Wendy Wysong

Practice Areas

White Collar Defense | Independent & Internal Investigations | Regulatory Compliance & Enforcement | Export Controls & Economic Sanctions | National Security | FCPA/Anticorruption

Career

For over a dozen years, Wendy Wysong has focused her practice in Hong Kong 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’s Bureau of Industry & Security (BIS), Entity List, OFAC's Specially Designated Nationals List and non-SDN Chinese Military-Industrial Complex Companies (CMIC) List, and the Department of Defense Chinese Military Companies (CMC) List. Wendy is the managing partner of Steptoe's Hong Kong office and global co-leader of the Investigation and White Collar Practice Group.

As a former Assistant US Attorney in Washington and Deputy Assistant Secretary for Export Enforcement in the Department of Wendy offers clients a unique combination of experience and insight as both a prosecutor and regulator before courts and agencies. She was named as one of the "Top 100 Women in Investigations" by Global Investigations Review who also named her one of 25 sanctions lawyers to have on speed dial.

Professional Memberships

-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

Work Highlights

ECONOMIC SANCTIONS AND EXPORT CONTROLS

-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

-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.