Overview
This role involves building, scaling, and operationalizing a global trade compliance function focused on sanctions, export controls, national-security-adjacent regulatory regimes, and their application to frontier artificial intelligence technologies. The Trade Compliance Counsel will provide expert legal advice on U.S. and international export controls, economic sanctions, and related trade-control regimes as they apply to products, model development, open-weight strategy, compute infrastructure, international operations, and customer and partner relationships.
This is a high-impact, build-stage position requiring the design of policies, review processes, escalation pathways, and business-facing guidance to enable rapid progress while maintaining a mature and defensible compliance posture.
Responsibilities
- Serve as the primary legal expert and contact for all trade, sanctions, and export control matters.
- Advise on U.S. and international trade compliance laws and regulations, including the Export Administration Regulations (EAR), Office of Foreign Assets Control (OFAC) sanctions programs, International Traffic in Arms Regulations (ITAR), anti-boycott rules, and other applicable regimes.
- Counsel cross-functional teams on applying sanctions and export controls to business activities such as model development, open-weight releases, compute access, cloud infrastructure, data center arrangements, international collaborations, and customer transactions.
- Design and enhance the sanctions and export controls compliance program, including policies, procedures, screening, customer and counterparty diligence, technology-control planning, licensing workflows, and escalation protocols.
- Collaborate with Security, Compliance, Infrastructure, Finance, Operations, and Go-To-Market teams to implement practical trade compliance controls for secure model releases, international collaborations, remote access, restricted-party screening, and controlled technology transfers to non-U.S. persons.
- Provide advice on trade compliance and national security considerations in commercial and strategic transactions, including customer agreements, enterprise deployments, compute and infrastructure agreements, research partnerships, data and model collaborations, vendor onboarding, strategic investments, joint ventures, outbound investment restrictions, CFIUS, and other third-party relationships.
- Monitor legal and regulatory developments from relevant authorities such as BIS, OFAC, DDTC, Congress, the White House, the EU, and the UK, translating these into practical guidance.
- Support engagement with regulatory authorities on licensing, interpretive guidance, regulatory inquiries, and potential disclosures.
- Assist with internal reviews, investigations, and remediation related to sanctions, export control, or trade compliance issues.
- Advise on intersections of trade compliance, national security, AI governance, cybersecurity, and frontier model deployment.
- Establish a risk-based compliance posture for AI-specific issues involving model weights, derivative models, training data, inference access, compute clusters, technical know-how, research collaboration, evaluations, and cross-border access.
Requirements
- J.D. degree and active bar membership (or in-house registration) in at least one U.S. jurisdiction.
- Approximately 10+ years of experience advising on U.S. sanctions, export controls, and related trade compliance regimes, including significant experience with OFAC sanctions programs and the EAR.
- Deep familiarity with BIS, OFAC, DDTC, and related regulatory frameworks, including licensing, classification, advisory guidance, enforcement, diligence, and compliance program expectations.
- Experience advising technology companies on trade compliance issues, particularly in sectors such as artificial intelligence, cloud computing, semiconductors, advanced computing, cybersecurity, infrastructure, or data centers.
- Proven experience building, scaling, or materially improving a trade compliance program in a high-growth, technically complex, or operationally dynamic environment.
- Strong independent judgment and proactive approach in areas with evolving laws, incomplete agency guidance, or novel business contexts.
- Excellent cross-functional communication skills, capable of explaining complex legal requirements to engineers, researchers, infrastructure teams, commercial teams, executives, and non-lawyer operators.
- Experience advising on customer, vendor, partner, investor, and acquisition diligence involving export controls, sanctions, restricted parties, national security, or sensitive technology issues.
Preferred Qualifications
- Prior experience at a high-growth technology company, AI lab, cloud provider, semiconductor company, cybersecurity company, defense technology company, or other export-control-sensitive business.
- Experience with open source access technology.
- Experience working directly with or alongside BIS, OFAC, DDTC, CFIUS, DOJ, Commerce, State, Treasury, or other national-security or trade-control authorities.
- Familiarity with non-U.S. sanctions and export control regimes.
- Experience with deemed export/deemed reexport issues, technology-control plans, non-U.S. person access controls, source code or technical data restrictions, and controlled technology in cloud or remote-access environments.
- Knowledge of AI-specific regulatory and national security developments, including advanced computing controls, model weight access, compute thresholds, frontier model governance, and policy debates around open-weight AI.
Compensation & Benefits
- Competitive salary and equity designed to attract and retain top global talent.
- Comprehensive medical, dental, vision, life, and disability insurance.
- Fully paid parental leave for all new parents, including adoptive and surrogate journeys.
- Financial support for family planning.
- Paid time off and relocation support.
- Daily provided lunch and dinner.
- Regular off-sites and team celebrations.
Location
Not specified.