Regulatory and Compliance


Josephine Aiello LeBeau is a partner in Wilson Sonsini Goodrich & Rosati's Washington, D.C., office, counseling domestic and foreign companies on issues related to compliance and enforcement of U.S. export control regulations and economic sanctions.

Josephine advises clients in a wide range of technology industries and assists them in obtaining necessary government approvals related to the export or transfer of their products, software, technology, and services. She works extensively with companies in determining which regulations may affect their transactions and has substantial expertise in commercial and dual-use controls promulgated under the Export Administration Regulations, military-specific controls administered under the International Traffic in Arms Regulations, and economic sanctions programs implemented by the Office of Foreign Assets Control. Josephine assists U.S. companies that employ foreign nationals in obtaining deemed export licenses and also prepares classification and encryption technical review requests. She regularly provides advice related to technical assistance, manufacturing license, and distribution agreements.

Josephine also counsels clients on potential export control liabilities stemming from cross-border technology transfers, joint venture projects, and mergers and acquisitions. She works closely with companies in designing and implementing internal compliance programs, conducting internal investigations and compliance assessments, training employees on regulatory compliance issues, preparing voluntary disclosures, and settling enforcement actions with U.S. government agencies.

Josephine frequently speaks on export control and trade sanctions issues and has chaired several conferences focusing on international technology transfers. Prior to joining Wilson Sonsini Goodrich & Rosati, Josephine was a partner at Miller & Chevalier in Washington, D.C.

  • J.D., Harvard Law School, 1995
    Articles Editor, Harvard Journal of Law & Technology; Technical Editor, Harvard Journal on Legislation
  • B.A., Political Science, and B.S., Computer Science, Tulane University, 1992
    Summa Cum Laude, Phi Beta Kappa
  • Selected for inclusion in the 2017 edition of Washington DC Super Lawyers
  • Recognized as the "Best in Export Control Regulation - USA" in the 2016 Legal Awards by Acquisition International
  • Selected for inclusion in the 2013 Women in Business Law Expert Guide
  • Honored as a "BTI Client Service All-Star" for 2013
  • Named among the country's top international trade attorneys in the 2010-2019 editions of Chambers USA: America's Leading Lawyers for Business
  • Recognized in the International Trade: Export Controls & Economic Sanctions category of the 2012-2019 editions of Chambers Global: The World's Leading Lawyers for Business
  • "Life Sciences & Export Compliance: Avoid the Pitfalls and Take Advantage of Unique Exemptions and Policies," WSGR event, Boston, July 19, 2018
  • "Avoiding Sanctions Risks: How to Navigate OFAC Rules for Web Based Interactions, Cloud Computing, and Shared Networks," ACI's 10th Annual Advanced Forum on Economic Sanctions Enforcement and Compliance, Washington, D.C., April 24, 2017
  • "'Technical Data' and the 'Specially Designed' Rule: Group Exercises on How to Apply These Complicated Definitions to Challenging, Real-Life Dilemmas," ACI's Ninth National Export Controls Forum on International Technology Transfers, Cloud Computing and Deemed Exports, Washington, D.C., October 18, 2016
  • "Wassenaar: How New Proposals, 2015 Controls, and Countries' Adoption of Note 4 and OAM Affect Your Global Encryption Compliance Strategy," ACI Global Encryption, Cloud & Cybersecurity Controls Conference, San Francisco, March 30, 2016
  • Panelist, "Understanding Disclosure: Best Practice," IBC Global Trade Controls & Compliance Conference, London, November 20, 2015
  • "Intangible Exports, Cloud Computing, and Export Controls," IBC Global Trade Controls and Compliance Conference, London, November 19, 2014
  • Roundtable Speaker with Olga King, "Lessons Learned from the Esterline, Intevac and Meggitt Cases: How to Manage a Government Investigation, Mitigate Exposure and Restore Confidence," Eighth National Export Controls Forum on International Technology Transfers and Deemed Export Compliance, San Francisco, California, September 16, 2014
  • "Understanding the Problems of Intangible Exports Including 'Cloud Computing' and Data Transfer," Global Trade Controls and Compliance 26th Annual Conference, London, November 2013
  • "Commodity Jurisdiction Determinations: Proven Strategies for Drafting an Effective Request and How to Interpret a DDTC Determination," The ITAR Summit, Washington, D.C., June 24-25, 2013
  • Co-chair and Speaker, "International Technology Transfers and Deemed Export Compliance: How to Control IT Access and the Flow of Technical Data, and Minimize the Risk of Intangible Export Controls Violations in Defense Services, Cloud Computing and Outsourcing," American Conference Institute's Seventh National Export Controls Forum, San Francisco, California, January 28-29, 2013
  • Speaker, "The Export Control Dimension of 'Cloud Computing' and Other Intangible Exports," 25th Annual Global Trade Controls Conference, London, November 13-14, 2012
  • "Cloud Computing within Export Controls Limits: Collaborating within Security, Privacy, and Encryption Restrictions," American Conference Institute's 15th National Forum on Global Export Controls Compliance, Washington, D.C., May 23-24, 2012
  • Co-chair and Speaker, "Monitoring Technology Transfers in the Context of M&A Transactions: How to Incorporate Effective Safeguards into the Due Diligence, Deal Structure, and Post-Closing Implementation," American Conference Institute's 6th National Forum on International Tech Transfers and Deemed Export Compliance, Washington, D.C., September 26-27, 2011
  • "When to Self-Classify or Seek Government Review Under US Encryption Rules: Determining Jurisdiction and Overcoming Complex Classification Challenges," American Conference Institute's 2nd Advanced Summit on Complying with Global Encryption Controls, San Francisco, California, April 12-13, 2011
  • "Getting EAR Jurisdiction Right: How to Classify Under the CCL, ECCNs, de minimis Rule and More," American Conference Institute's EAR Boot Camp, Dallas, Texas, January 26-27, 2011
  • "Securing BIS License Approvals: How to Prepare Successful License Applications and Use Key EAR Exceptions," American Conference Institute's EAR Boot Camp, Dallas, Texas, January 26-27, 2011
  • "Implementing a Global Encryption Compliance Strategy: Identifying 'Ancillary Cryptography' and Obtaining U.S. and Foreign Approvals," American Conference Institute's 13th National Forum on Export Controls, Washington, D.C., May 19, 2010
  • Co-chair and Speaker, "Protecting Intangibles in Tech Support and R&D Offshoring Ventures," American Conference Institute's 5th National Forum on Complying with Export Controls on International Technology Transfers, San Francisco, California, September 23-24, 2009
  • "When & How to Conduct an Effective ITAR Internal Investigation," American Conference Institute's 4th Forum on ITAR Compliance," Washington, D.C., July 22, 2009
  • Lead Panelist and Moderator, "Implementing a Global Export Controls Compliance Program," American Conference Institute's 12th National Forum on Export Controls Global Compliance Strategies, Washington, D.C., May 19-20, 2009
  • "Due Diligence: What to Do if Your Good Work Uncovers a Potential Export Controls or Sanctions Violation," American Conference Institute's 11th National Forum on Export Controls, Washington, D.C., May 28, 2008
  • "Preparing Government Submissions and Using License Exceptions for Exports and Reexports to China," American Conference Institute's 2nd National International Forum on China Trade Compliance, San Francisco, California, October 16-17, 2007
  • "The Ultimate Benchmarking Opportunity: The Export Control Document Swap," American Conference Institute's 10th National Forum on Export Controls, Washington, D.C., May 17, 2007
  • "Implementing and Policing an Internal Technology Compliance Program" and "How to Obtain Deemed Export Licenses, TAAs, and MLAs: A Complete Guide," American Conference Institute's Third National Forum on Complying with Export Controls on International Technology Transfers, San Francisco, California, January 24, 2007
  • "The Magic of ITAR Licensing: Preparing DSP-5s, TAAs, and MLAs That Will Impress DTC's Toughest Licensing and Agreements Officers," National Forum on ITAR Compliance, Washington, D.C., June 22, 2006
  • "Export Controls," International Corporate Compliance Forum, Plano, Texas, January 19, 2006
  • "Meeting the Requirements of the Deemed Export Rule: Key Compliance Challenges and How to Overcome Them" and "Successfully Obtaining Deemed Export Licenses, TAAs, and MLAs: A Complete Guide," American Conference Institute's Forum on Ensuring Compliance with Export Controls on International Technology Transfers, Washington, D.C., June 27-28, 2005, and San Francisco, January 26-27, 2005
  • "Do's and Don'ts in Export Classification and Licensing: Techniques for Export Managers," Eighth National Forum on Export Controls, Washington, D.C., April 29, 2005
  • "The Complete Guide to Listening under EAR, ITAR, and OFAC: The Magic Is Back," Seventh National Export Controls and Global Trade Compliance Conference, Washington, D.C., April 21, 2004
  • "U.S. Export and Re-export Legislation: The Long Arm of U.S. Law," EuroLegal's Conference on Export Controls, London, March 16, 2004
  • Bar of the District of Columbia
  • Virginia State Bar