Wendy Wysong

Wendy L. Wysong is a partner at Steptoe & Johnson. She served previously as a litigation partner with Clifford Chance, offering clients advice and representation on compliance and enforcement under the Foreign Corrupt Practices Act, the Arms Export Control Act, International Traffic in Arms Regulations, Export Administration Regulations, and OFAC Economic Sanctions. She was appointed by the State Department as the ITAR Special Compliance Official for Xe Services (formerly Blackwater) in 2010.

Wendy combines her experience as a former federal prosecutor with the United States Attorney for the District of Columbia for 16 years with her regulatory background as the former Deputy Assistant Secretary for Export Enforcement at the Bureau of Industry and Security, U.S. Department of Commerce. She managed its enforcement program and was involved in the development and implementation of foreign policy through export controls across the administration, including the Departments of Justice, State, Treasury and Homeland Security, as well as the intelligence community.

Wendy received her law degree in 1984 from the University of Virginia School of Law, where she was a member of the University of Virginia Law Review.

anonymous businessman handing bribe in yen from the shadows

Some apparent deficiencies have come to light in Japan’s prosecution of foreign bribery, and the OECD is urging the country to take action to close loopholes and stiffen penalties. Clifford Chance’s Wendy Wysong, Tess Forge and Catherine Ho weigh in. with co-authors Tess Forge and Catherine Ho In June 2019, the Organization for Economic Cooperation and Development (OECD) Working Group on Bribery...

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Hong Kong cityscape at night with lights reflecting in Victoria Harbour

Clifford Chance’s Wendy Wysong and Nick Turner discuss the sanctions risks looming in Hong Kong and what companies operating there can do to protect themselves. with co-author Nick Turner The Financial Action Task Force (FATF) issued its much-anticipated Mutual Evaluation Report (MER) of Hong Kong on September 4, 2019. Among its recommendations, the MER encouraged Hong Kong to closely monitor its exposure...

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handshake in front of power station

Debarment regimes exclude companies from public procurement opportunities following conviction of specified offences. Wendy Wysong, Tim Grave and Madeleine Parker discuss how though the regulation landscape is largely discretionary in the Asia-Pacific, these regimes are only likely to strengthen. with co-authors Tim Grave and Madeleine Parker Countries throughout Asia-Pacific are starting to exclude companies from public procurement opportunities following convictions for corruption, money...

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illustration of china with piggy bank in speech bubble

Wendy Wysong and team discuss a recent U.S. court ruling that reinforces the well-understood rule that non-U.S. banks with branches or correspondent accounts in the U.S. must comply with U.S. government subpoenas regardless of their own country's laws. Under the USA PATRIOT Act, noncompliance risks access to the U.S. financial system. with co-authors Ali Burney and Nick Turner Background On March 18,...

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U.S. and Chinese flags on opposing boxing gloves representing trade war

The government of China recently announced its intentions to publish a list of foreign entities that harm the interests of Chinese companies. Attorneys from Clifford Chance discuss the particulars and how the “unreliable entity list” will have immediate impact to the businesses listed therein. with co-authors Hena Schommer and Nick Turner China's Ministry of Commerce (MOFCOM) introduced a new layer of complexity...

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roll of hundred dollar bills wrapped in barbed wire

The Clifford Chance team covers OFAC’s recently published “Framework for OFAC Compliance Commitments,” with a particular focus on how the guidelines will impact companies based or operating in the Asia-Pacific region. with co-authors Ali Burney and Nick Turner Officials from the U.S. Office of Foreign Assets Control (OFAC) have been teasing for months that they would issue guidelines to help companies comply...

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bumpy road in black and white

The Banking Royal Commission (BRC) focused its attention on Australian banks when investigating misconduct in the financial services industry, but the fallout from the BRC’s recent report will likely be felt much farther afield. Experts from Clifford Chance discuss. with co-authors Lara Gotti, Kirsten Scott, Jenni Hill The Royal Commission into Misconduct in the Banking, Superannuation and Financial Services Industry (the Banking...

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illustration of vladimir putin, nicolas maduro, and donald trump in profile

Clifford Chance’s Wendy Wysong and Nick Turner discuss recent sanctions leveled by the U.S. against Russian and Venezuelan corporations and what the implications are for companies doing business in the Asia-Pacific region. with co-author Nick Turner It appears the Trump administration has decided to embrace economic sanctions as a tactical foreign policy weapon, using the U.S. Office of Foreign Assets Control (OFAC)...

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handcuffs with gavel and stack of bills

Notable Cases, Settlements and Sentencings Wendy Wysong, Nick Turner and Anthony Pan from Clifford Chance discuss last year’s most significant and substantial FCPA enforcement actions from the Asia-Pacific region – some leveled against corporations and some against individuals. with co-authors Nick Turner and Anthony Pan The pace of Foreign Corrupt Practices Act (FCPA) enforcement in Asia-Pacific remained steady in 2018, but not...

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The 2019 TRACE Bribery Risk Matrix Rankings for Asia-Pacific

New Data is Key to Anti-Bribery, Anti-Corruption Efforts TRACE International published an updated Bribery Risk Matrix earlier this month, and the rankings will be hugely informative in corporations’ business dealings across the globe. Clifford Chance’s Wendy Wysong and Nick Turner discuss. with co-author Nick Turner Gut instincts can be good when undertaking an anti-corruption risk assessment on an Asia-Pacific business opportunity. But...

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Malaysian woman in silk factory

Uptick in Companies Taking Steps to Combat This Scourge More and more companies are combating modern slavery. The scourge is a particular problem in the Asia-Pacific region, but the fight is also going strong there. Wendy Wysong and team discuss steps being taken in Asia-Pacific to curb the infringement of human rights. with co-authors Peter Coney, Nick Turner and Amanda Murphy Modern...

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