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.

man and woman shaking hands in office lobby

Mitigating the Risk Posed by Introducers Wendy Wysong and associates at Clifford Chance write on the rise in prominence of “introducers” in Asia-Pacific countries and explain how the use of introducers can expose the organization to corruption risk. The team also discusses several recent cases that have resulted in fines and imprisonment. with co-authors Janice Goh and Feifei Yu Introducers have got...

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shaking hands while accepting under-the-table bribe

Corporate Criminal Liability for Bribery in Asia-Pacific While individual employees and company representatives are responsible for acts of bribery in the majority of cases, the trend in Asia-Pacific countries is toward greater scrutiny of corporations. with co-authors Jenni Hill, Lei Shi, Janice Goh, Tess Forge and Akanksha Bhagat Prosecutors, legislators and regulators in Asia-Pacific are increasingly rejecting the view that companies cannot...

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businessman rejecting bribe

New Developments Across the Region Clifford Chance’s anti-corruption specialists in Asia-Pacific surveyed recent developments in five jurisdictions. Here's what you need to know. with co-authors Kirsten Scott, Lei Shi, Peter Coney and Janice Goh The big picture: Singapore and Australia test drive Deferred Prosecution Agreements (DPAs). Japan and China issue guidance on compliance. And Hong Kong's anti-corruption chief sounds the alarm on...

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businessman's hands in handcuffs

How the Change May Impact Self-Reporting The Australian government is raising fines associated with corporate wrongdoing. The changes will bring the country more in line with penalties levied by U.K. and U.S. regulators, but is it the right move? with contributing authors Jenni Hill, Kirsten Scott and Lara Gotti On April 20, 2018, Australia’s Minister for Revenue and Financial Services announced the...

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Recent moves in Japan towards tougher corporate compliance: Key points to know

In this article, Wendy Wysong, Peter Coney and Tatsuhiko Kamiyama examine three key governance reforms coming from Japanese legislators and what global companies need to know going forward. 'Japan Inc' is now back on the front pages with many Japanese corporations increasingly pursuing significant M&A opportunities internationally given the mature market at home and high levels of cash reserves. The corporate landscape in Japan...

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Oleg Deripaska, owner of United Company RUSAL

A Compliance Challenge On April 6, the U.S. imposed economic sanctions on a number of Russian individuals and entities (specially designated nationals, or SDNs). Wendy Wysong, Nick Turner and Ali Burney offer insights into how these sanctions will impact U.S. and non-U.S. persons and businesses. with co-authors Nick Turner and Ali Burney The most recent U.S. economic sanctions on Russia target 38...

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person accepting bribe in a handshake

Little Movement in Latest Transparency International Rankings Transparency International published its 2017 Corruption Perceptions Index (CPI) on February 21, 2018, showing modest improvements for most countries in Asia-Pacific. Some higher-risk countries, however, continue their downward slide in the overall rankings. We've included the Asia Pacific countries below and the full CPI is available at https://www.transparency.org/news/feature/corruption_perceptions_index_2017. with co-author Nicholas Turner The Big Picture...

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businessman looking confused against digital background

4 Considerations to Mitigate Risk Among the chief concerns of those using blockchain (and its critics) is the lack of transparency. Currently, users can unwittingly violate OFAC sanctions, among other regulations. Clifford Chance’s Wendy Wysong and Ali Burney explore how businesses can guard against the risks inherent in using blockchain technology. with co-author Ali Burney Blockchain, the technology that underpins digital currencies...

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Companies and individuals are increasingly the targets of regulatory investigations in Australia.  Local regulators have long expressed frustration at the disparity between the options available to them when compared to their overseas counterparts. However, recent developments indicate a broadening of the suite of tools available to Australian regulators and the importance for companies to stay abreast of the changes.

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legal paperwork

Multinational companies with operations in China are preparing for the impact of China's new Cyber-security Law, in place now for four months. The Law applies to everyone who operates networks in the PRC, particularly multinational corporations. This could impact their overall IT system set-up and global outsourcing. Also left open to question is how their Chinese offices, particularly in a sensitive sector,...

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