Anne E. Seymour

Anne E. Seymour

Of Counsel

Anne Seymour is Of Counsel in Wilson Sonsini Goodrich & Rosati's Washington, D.C., office, where she focuses on issues related to compliance and enforcement of U.S. export control regulations and economic sanctions and U.S. import regulations.

Anne counsels foreign and domestic clients across technology industries on all aspects of international trade, including export controls, economic sanctions, and import issues. This work includes providing advice on potential export and import considerations stemming from cross-border technology transfers, joint venture projects, mergers and acquisitions, foreign investment, foreign distributor agreements, and delivery (both physical and virtual) of products and services.

Anne works closely with companies to determine which regulations may affect their transactions; obtain necessary government approvals related to the import, export, or transfer of their products, software, technology, and services; design and implement internal compliance programs; conduct compliance assessments; train employees on regulatory compliance issues; and, when necessary, prepare voluntary disclosures.

Anne is an expert 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. She assists clients as new regulatory challenges arise, including adapting to new sanctions regimes, classification of “critical technologies” as they may apply to CFIUS analyses, and obtaining of “deemed export” licenses for clients that employ H-1B visa holders in export-controlled areas.

Experience

Education

J.D., The George Washington University Law SchoolWith High Honors; Articles Editor, The George Washington Law Review
B.A., Spanish/Latin American Studies, American University

Honors

Recognized in the "International Trade: Export Controls and Economic Sanctions" category of the 2017-2020 and 2023 editions of Chambers USA: America's Leading Lawyers for Business, with commentators praising her as "very knowledgeable and very responsive"

Admissions

Bar of the District of Columbia
State Bar of Maryland

Credentials

Education

J.D., The George Washington University Law SchoolWith High Honors; Articles Editor, The George Washington Law Review
B.A., Spanish/Latin American Studies, American University

Honors

Recognized in the "International Trade: Export Controls and Economic Sanctions" category of the 2017-2020 and 2023 editions of Chambers USA: America's Leading Lawyers for Business, with commentators praising her as "very knowledgeable and very responsive"

Admissions

Bar of the District of Columbia
State Bar of Maryland

Select Publications

Co-author with M. Casey, J. Hartwig, S. Heifetz, and T. Jenkins, “Crypto Exchange Agrees to Pay More Than $362,000 to Settle Alleged Sanctions Violations,” Wilson Sonsini Advisory, December 14, 2022
Co-author with J. Aiello LeBeau and B. Poellot, "BIS Implements New Semiconductor- and Supercomputer-related Export Controls and End-Use Controls ," Wilson Sonsini Alert, October 13, 2022
Co-author with J. Aiello LeBeau and K. Millard, "New Russia Sanctions Imposed as Ukraine War Continues: Expansion of Controls on EAR99 Items and Military End-Uses," Wilson Sonsini Alert, September 19, 2022
Co-author with J. Aiello LeBeau and K. Millard, "Russia Sanctions Update: Intellectual Property General License and a Prohibition on the Provision of Some Services," Wilson Sonsini Alert, May 11, 2022
Co-author with J. Aiello LeBeau and K. Millard, "New U.S. Sanctions on Russian Banks and Elites, Expanded Export Controls, and Other Updates," Wilson Sonsini Alert, April 11, 2022
Co-author with L. Johnson and L. Lieto, "Companies Face Impact of U.S. Government Sanctions and Russian Government Directive on Russian and Eurasian Patents," Wilson Sonsini Alert, March 14, 2022
Co-author with J. Aiello LeBeau and K. McDonough, "License Exception ENC Severely Limited for Exports to Russia and Belarus, Belarus Targeted by Biden’s Third Tranche of Controls, OFAC Clarifies Earlier Restrictions in Russia-Ukraine Crisis," Wilson Sonsini Alert, March 3, 2022
Co-author with J. Aiello LeBeau, M. Casey, J. Hartwig, and K. McDonough, "Biden Administration Implements Significant BIS Controls and Imposes Second Tranche of OFAC Sanctions in Russia-Ukraine Crisis," Wilson Sonsini Alert, February 25, 2022
Co-author with J. Aiello LeBeau, J. Hartwig, and K. McDonough, "Biden Administration Authorizes New Sanctions on Regions of Ukraine," Wilson Sonsini Alert, February 23, 2022
Co-author with J. Aiello LeBeau, "Intrusion Preclusion: BIS Issues Long-Awaited Controls on Cybersecurity Items, Creates New License Exception," Privacy & Cybersecurity Law Report, February-March, 2022
Co-author with J. Aiello LeBeau and J. Hartwig, "U.S. State Department Proposes ITAR Revisions to Remove Prior Citizenship Status Considerations," Wilson Sonsini Alert, February 4, 2022
Co-author with J. Aiello LeBeau, M. Casey, J. Hartwig, and S. Heifetz, "CJEU Publishes Judgment Interpreting the EU's Blocking Regulation," Wilson Sonsini Alert, February 3, 2022
Co-author with J. Aiello LeBeau, M. Casey, and K. McDonough, "2021 U.S. Sanctions Year in Review," Wilson Sonsini Alert, January 13, 2022
Co-author with J. Aiello LeBeau, J. Hartwig, and K. McDonough, "Know Your Customer: OFAC, BIS Penalize Companies for Sales of 'EAR99' Items and Services to Prohibited Parties Through Distributors," Wilson Sonsini Alert, September 21, 2021
Co-author with J. Aiello LeBeau, J. Hartwig, and K. McDonough, “Electronics Testing Company Penalized $6.6 Million for Unauthorized Software Exports,” Wilson Sonsini Alert, August 19, 2021
Co-author with J. Aiello LeBeau, “President Biden Issues Executive Order Amending Restrictions on Chinese Military and Surveillance Companies,” Wilson Sonsini Alert, June 11, 2021
Co-author with J. Aiello LeBeau and M. Mannino, “Take Two: Another Executive Order Addresses U.S. Personal Data Concerns by Prohibiting Business with Companies that Develop or Control Eight Specified Applications with Connections to China,” Wilson Sonsini Alert, January 6, 2021
Co-author with J. Aiello LeBeau and M. Mannino, “U.S. Government Authorization Now Required for Certain Business with SMIC and Over 70 Additional Entities in China," Wilson Sonsini Alert, December 19, 2020
Co-author with J. Aiello LeBeau, J. Gruenspecht, S. Heifetz, and M. Mannino, “As the App World Turns: Halt on Implementation of Commerce Prohibitions Regarding TikTok and WeChat,” Wilson Sonsini Alert, September 21, 2020
Co-author with J. Aiello LeBeau, J. Gruenspecht, and M. Mannino, “U.S. Department of Commerce Publishes Transactions with ByteDance and Tencent That are Prohibited Due to National Security Concerns Raised by TikTok and WeChat,” Wilson Sonsini Alert, September 18, 2020
Co-author with J. Aiello LeBeau, J. Davey, and M. Mannino, “Expansion of U.S. Export Controls on Huawei-Designed or Produced Items,” Wilson Sonsini Alert, May 29, 2020
Co-author with J. Aiello LeBeau, J. Davey, and M. Mannino, “License Requirements and U.S. Government Visibility into Exports to China, Russia, and Venezuela Will Increase, but Countries Remain Open for U.S Business,” Wilson Sonsini Alert, May 1, 2020
Co-author with J. Aiello LeBeau and M. Mannino, “Artificial Intelligence Software Controlled for Export, Including to Foreign National Employees,” Wilson Sonsini Alert, January 10, 2020
Co-author with J. Aiello LeBeau and M. Mannino, “License to Be Required for Exports, Reexports, and Transfers of U.S.-Origin Items to 28 Additional Chinese Entities,” WSGR Alert, October 8, 2019
Co-author with J. Aiello LeBeau and M. Mannino, “Export Control Update: 46 Huawei Affiliates Added; License Extended,” WSGR Alert, August 21, 2019
Co-author with J. Aiello LeBeau and M. Mannino, “License Required for Exports and Other Items Sent to Huawei and Affiliates,” WSGR Alert, May 17, 2019
Co-author with J. Aiello LeBeau, J. Gruenspecht, S. Heifetz, and M. Mannino, “Emerging Technologies to Be Controlled for Export: Comments Due December 19, 2018,” WSGR Alert, November 19, 2018
Co-author, "ZTE Update: Denial of Export Privileges Suspended," WSGR Alert, July 17, 2018
Co-author, "ZTE Update: Order Signed, but Denial of Export Privileges Still Is in Effect," WSGR Alert, June 11, 2018
Co-author, "Denial of Export Privileges Against ZTE Corporation to Be Lifted Once Order Is Signed," WSGR Alert, June 7, 2018
Co-author, "Reminder: Mandatory Foreign Direct Investment Reports for U.S. Entities Due May 31, 2018," WSGR Alert, May 8, 2018
Co-author, "ZTE Corporation Sanctioned Again—Prohibitions on Transactions Involving U.S.-Origin Items Effective Immediately," WSGR Alert, April 18, 2018
Co-author, "Forms Issued for U.S. Mandatory Foreign Direct Investment Reporting," WSGR Alert, March 9, 2018
Co-author, "Mandatory Reporting for U.S. Entities in 2018 Regarding Foreign Direct Investment," WSGR Alert, December 4, 2017
Co-author with J. Aiello LeBeau, M. Labriola, and M. Mannino, "OFAC Due Diligence in Securities Offerings," Lexis Practice Advisor, November 16, 2017
Co-author, "Additional Documentation Requirements Take Effect for Exports and Reexports of U.S. Items to and from Hong Kong," WSGR Alert, April 19, 2017
Co-author, "Continuation of ZTE General License Until February 27, 2017," WSGR Alert, November 21, 2016
Co-author, "U.S. Further Eases Embargo on Cuba," WSGR Alert, October 17, 2016
Co-author, "BIS Modifies Rules Governing the Export of Information Security Items Under the Export Administration Regulations; Updates to Cuba Regulations Coming Next Week," WSGR Alert, October 14, 2016
Co-author, "Second Continuation of General License for Exports, Reexports, and Transfers to ZTE," WSGR Alert, August 18, 2016
Co-author, "Continuation of General License for Exports, Reexports, and Transfers to ZTE," WSGR Alert, June 28, 2016
Co-author, "Department of Commerce to Ease License Requirement for Exports, Reexports, and Transfers to ZTE as of March 24, 2016," WSGR Alert, March 22, 2016
Co-author, "License Required for All Exports, Reexports, and Transfers to ZTE Corporation as of March 8, 2016," WSGR Alert, March 7, 2016
Co-author, "Iran Not Open for U.S. Business: U.S. Trade Embargo Remains in Place; Nuclear Sanctions Lifted," WSGR Alert, January 19, 2016
Co-author, "Proposed Rule to Subject Certain Cybersecurity Items to Greater Export Restrictions," WSGR Alert, July 9, 2015
Co-author, "U.S. Companies with Foreign Subsidiary or Affiliate Granted One-Month Extension to File Mandatory Forms," WSGR Alert, June 1, 2015
Co-author, "Restrictions Eased for Communications-Related Items Exported to Sudan," WSGR Alert, March 24, 2015
Co-author, "Reporting Requirements for U.S. Companies Regarding Direct Investment," WSGR Alert, March 18, 2015
Co-author, "U.S. Relaxes the Half-Century-Old Embargo on Cuba," WSGR Alert, January 16, 2015
Co-author, "Increasing Russian Sanctions Target Financial and Energy Sectors," WSGR Alert, July 21, 2014
Co-author, "More Restrictions on Business with Russia," WSGR Alert, May 1, 2014
Co-author, "U.S. Expands Sanctions on Russia in Light of Crisis in Ukraine," WSGR Alert, March 26, 2014

Insights

Select Publications

Co-author with M. Casey, J. Hartwig, S. Heifetz, and T. Jenkins, “Crypto Exchange Agrees to Pay More Than $362,000 to Settle Alleged Sanctions Violations,” Wilson Sonsini Advisory, December 14, 2022
Co-author with J. Aiello LeBeau and B. Poellot, "BIS Implements New Semiconductor- and Supercomputer-related Export Controls and End-Use Controls ," Wilson Sonsini Alert, October 13, 2022
Co-author with J. Aiello LeBeau and K. Millard, "New Russia Sanctions Imposed as Ukraine War Continues: Expansion of Controls on EAR99 Items and Military End-Uses," Wilson Sonsini Alert, September 19, 2022
Co-author with J. Aiello LeBeau and K. Millard, "Russia Sanctions Update: Intellectual Property General License and a Prohibition on the Provision of Some Services," Wilson Sonsini Alert, May 11, 2022
Co-author with J. Aiello LeBeau and K. Millard, "New U.S. Sanctions on Russian Banks and Elites, Expanded Export Controls, and Other Updates," Wilson Sonsini Alert, April 11, 2022
Co-author with L. Johnson and L. Lieto, "Companies Face Impact of U.S. Government Sanctions and Russian Government Directive on Russian and Eurasian Patents," Wilson Sonsini Alert, March 14, 2022
Co-author with J. Aiello LeBeau and K. McDonough, "License Exception ENC Severely Limited for Exports to Russia and Belarus, Belarus Targeted by Biden’s Third Tranche of Controls, OFAC Clarifies Earlier Restrictions in Russia-Ukraine Crisis," Wilson Sonsini Alert, March 3, 2022
Co-author with J. Aiello LeBeau, M. Casey, J. Hartwig, and K. McDonough, "Biden Administration Implements Significant BIS Controls and Imposes Second Tranche of OFAC Sanctions in Russia-Ukraine Crisis," Wilson Sonsini Alert, February 25, 2022
Co-author with J. Aiello LeBeau, J. Hartwig, and K. McDonough, "Biden Administration Authorizes New Sanctions on Regions of Ukraine," Wilson Sonsini Alert, February 23, 2022
Co-author with J. Aiello LeBeau, "Intrusion Preclusion: BIS Issues Long-Awaited Controls on Cybersecurity Items, Creates New License Exception," Privacy & Cybersecurity Law Report, February-March, 2022
Co-author with J. Aiello LeBeau and J. Hartwig, "U.S. State Department Proposes ITAR Revisions to Remove Prior Citizenship Status Considerations," Wilson Sonsini Alert, February 4, 2022
Co-author with J. Aiello LeBeau, M. Casey, J. Hartwig, and S. Heifetz, "CJEU Publishes Judgment Interpreting the EU's Blocking Regulation," Wilson Sonsini Alert, February 3, 2022
Co-author with J. Aiello LeBeau, M. Casey, and K. McDonough, "2021 U.S. Sanctions Year in Review," Wilson Sonsini Alert, January 13, 2022
Co-author with J. Aiello LeBeau, J. Hartwig, and K. McDonough, "Know Your Customer: OFAC, BIS Penalize Companies for Sales of 'EAR99' Items and Services to Prohibited Parties Through Distributors," Wilson Sonsini Alert, September 21, 2021
Co-author with J. Aiello LeBeau, J. Hartwig, and K. McDonough, “Electronics Testing Company Penalized $6.6 Million for Unauthorized Software Exports,” Wilson Sonsini Alert, August 19, 2021
Co-author with J. Aiello LeBeau, “President Biden Issues Executive Order Amending Restrictions on Chinese Military and Surveillance Companies,” Wilson Sonsini Alert, June 11, 2021
Co-author with J. Aiello LeBeau and M. Mannino, “Take Two: Another Executive Order Addresses U.S. Personal Data Concerns by Prohibiting Business with Companies that Develop or Control Eight Specified Applications with Connections to China,” Wilson Sonsini Alert, January 6, 2021
Co-author with J. Aiello LeBeau and M. Mannino, “U.S. Government Authorization Now Required for Certain Business with SMIC and Over 70 Additional Entities in China," Wilson Sonsini Alert, December 19, 2020
Co-author with J. Aiello LeBeau, J. Gruenspecht, S. Heifetz, and M. Mannino, “As the App World Turns: Halt on Implementation of Commerce Prohibitions Regarding TikTok and WeChat,” Wilson Sonsini Alert, September 21, 2020
Co-author with J. Aiello LeBeau, J. Gruenspecht, and M. Mannino, “U.S. Department of Commerce Publishes Transactions with ByteDance and Tencent That are Prohibited Due to National Security Concerns Raised by TikTok and WeChat,” Wilson Sonsini Alert, September 18, 2020
Co-author with J. Aiello LeBeau, J. Davey, and M. Mannino, “Expansion of U.S. Export Controls on Huawei-Designed or Produced Items,” Wilson Sonsini Alert, May 29, 2020
Co-author with J. Aiello LeBeau, J. Davey, and M. Mannino, “License Requirements and U.S. Government Visibility into Exports to China, Russia, and Venezuela Will Increase, but Countries Remain Open for U.S Business,” Wilson Sonsini Alert, May 1, 2020
Co-author with J. Aiello LeBeau and M. Mannino, “Artificial Intelligence Software Controlled for Export, Including to Foreign National Employees,” Wilson Sonsini Alert, January 10, 2020
Co-author with J. Aiello LeBeau and M. Mannino, “License to Be Required for Exports, Reexports, and Transfers of U.S.-Origin Items to 28 Additional Chinese Entities,” WSGR Alert, October 8, 2019
Co-author with J. Aiello LeBeau and M. Mannino, “Export Control Update: 46 Huawei Affiliates Added; License Extended,” WSGR Alert, August 21, 2019
Co-author with J. Aiello LeBeau and M. Mannino, “License Required for Exports and Other Items Sent to Huawei and Affiliates,” WSGR Alert, May 17, 2019
Co-author with J. Aiello LeBeau, J. Gruenspecht, S. Heifetz, and M. Mannino, “Emerging Technologies to Be Controlled for Export: Comments Due December 19, 2018,” WSGR Alert, November 19, 2018
Co-author, "ZTE Update: Denial of Export Privileges Suspended," WSGR Alert, July 17, 2018
Co-author, "ZTE Update: Order Signed, but Denial of Export Privileges Still Is in Effect," WSGR Alert, June 11, 2018
Co-author, "Denial of Export Privileges Against ZTE Corporation to Be Lifted Once Order Is Signed," WSGR Alert, June 7, 2018
Co-author, "Reminder: Mandatory Foreign Direct Investment Reports for U.S. Entities Due May 31, 2018," WSGR Alert, May 8, 2018
Co-author, "ZTE Corporation Sanctioned Again—Prohibitions on Transactions Involving U.S.-Origin Items Effective Immediately," WSGR Alert, April 18, 2018
Co-author, "Forms Issued for U.S. Mandatory Foreign Direct Investment Reporting," WSGR Alert, March 9, 2018
Co-author, "Mandatory Reporting for U.S. Entities in 2018 Regarding Foreign Direct Investment," WSGR Alert, December 4, 2017
Co-author with J. Aiello LeBeau, M. Labriola, and M. Mannino, "OFAC Due Diligence in Securities Offerings," Lexis Practice Advisor, November 16, 2017
Co-author, "Additional Documentation Requirements Take Effect for Exports and Reexports of U.S. Items to and from Hong Kong," WSGR Alert, April 19, 2017
Co-author, "Continuation of ZTE General License Until February 27, 2017," WSGR Alert, November 21, 2016
Co-author, "U.S. Further Eases Embargo on Cuba," WSGR Alert, October 17, 2016
Co-author, "BIS Modifies Rules Governing the Export of Information Security Items Under the Export Administration Regulations; Updates to Cuba Regulations Coming Next Week," WSGR Alert, October 14, 2016
Co-author, "Second Continuation of General License for Exports, Reexports, and Transfers to ZTE," WSGR Alert, August 18, 2016
Co-author, "Continuation of General License for Exports, Reexports, and Transfers to ZTE," WSGR Alert, June 28, 2016
Co-author, "Department of Commerce to Ease License Requirement for Exports, Reexports, and Transfers to ZTE as of March 24, 2016," WSGR Alert, March 22, 2016
Co-author, "License Required for All Exports, Reexports, and Transfers to ZTE Corporation as of March 8, 2016," WSGR Alert, March 7, 2016
Co-author, "Iran Not Open for U.S. Business: U.S. Trade Embargo Remains in Place; Nuclear Sanctions Lifted," WSGR Alert, January 19, 2016
Co-author, "Proposed Rule to Subject Certain Cybersecurity Items to Greater Export Restrictions," WSGR Alert, July 9, 2015
Co-author, "U.S. Companies with Foreign Subsidiary or Affiliate Granted One-Month Extension to File Mandatory Forms," WSGR Alert, June 1, 2015
Co-author, "Restrictions Eased for Communications-Related Items Exported to Sudan," WSGR Alert, March 24, 2015
Co-author, "Reporting Requirements for U.S. Companies Regarding Direct Investment," WSGR Alert, March 18, 2015
Co-author, "U.S. Relaxes the Half-Century-Old Embargo on Cuba," WSGR Alert, January 16, 2015
Co-author, "Increasing Russian Sanctions Target Financial and Energy Sectors," WSGR Alert, July 21, 2014
Co-author, "More Restrictions on Business with Russia," WSGR Alert, May 1, 2014
Co-author, "U.S. Expands Sanctions on Russia in Light of Crisis in Ukraine," WSGR Alert, March 26, 2014

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