[Hiring] Trade Compliance Counsel @Reflection

Role Description

As Trade Compliance Counsel, you will help build, scale, and operationalize our global trade compliance function, focusing on sanctions, export controls, national-security-adjacent regulatory regimes, and their practical application to frontier AI.

You will advise on U.S. and international export controls, economic sanctions, and related trade-control regimes as they apply to Reflection’s products, model development, open-weight strategy, compute infrastructure, international operations, and customer and partner relationships.

This is a high-impact, build-stage role. You will help design the policies review processes, escalation pathways, and business-facing guidance that allow Reflection to move quickly while maintaining a mature and defensible compliance posture.

What You’ll Do

• Act as Reflection’s central expert and primary legal contact for all trade, sanctions, and export control related issues.
• Advise on existing and developing U.S. and international trade compliance laws and regulations, including:
  • Export Administration Regulations (EAR)
  • Office of Foreign Assets Control (OFAC) sanctions programs
  • International Traffic in Arms Regulations (ITAR)
  • Anti-boycott rules
  • Other applicable trade-control regimes
• Counsel relevant cross-functional teams on the application of sanctions and export controls to Reflection’s business, including:
  • Model development
  • Open-weight releases
  • Compute access
  • Cloud and neocloud infrastructure
  • Data center arrangements
  • International collaborations
  • Customer transactions
• Design and mature Reflection’s sanctions and export controls compliance program, including:
  • Policies
  • Procedures
  • Screening
  • Customer and counterparty diligence
  • Technology-control planning
  • Licensing workflows
  • Escalation protocols
• Partner with Security, Compliance, Infrastructure, Finance, Operations, and GTM teams to implement practical trade compliance controls.
• Advise on trade compliance and related 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
  • Other third-party relationships
• Monitor legal and regulatory developments from BIS, OFAC, DDTC, Congress, the White House, the EU, UK, and other relevant authorities.
• Support engagement with BIS, OFAC, DDTC, and other authorities on licensing, interpretive guidance, regulatory inquiries, and potential disclosure matters.
• Support internal reviews, investigations, and remediation plans relating to potential sanctions, export control, or trade compliance issues.
• Advise on the intersection of trade compliance, national security, AI governance, cybersecurity, and frontier model deployment.
• Help establish a risk-based compliance posture for AI-specific questions involving:
  • Model weights
  • Derivative models
  • Training data
  • Inference access
  • Compute clusters
  • Technical know-how
  • Research collaboration
  • Evaluations
  • Cross-border access

Qualifications

• J.D. 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.
• Deep familiarity with BIS, OFAC, DDTC, and related regulatory frameworks.
• Experience advising technology companies on trade compliance issues, especially in sectors such as:
  • Artificial intelligence
  • Cloud computing
  • Semiconductors
  • Advanced computing
  • Cybersecurity
  • Infrastructure
  • Data centers
• Experience building, scaling, or materially improving a trade compliance program in a high-growth environment.
• Strong ability to exercise independent judgment and take proactive steps in evolving legal areas.
• Excellent cross-functional communication skills.
• Experience advising on customer, vendor, partner, investor, and acquisition diligence involving export controls and national security issues.

Nice to Have

• Prior experience at a high-growth technology company, AI lab, cloud provider, or other export-control-sensitive business.
• Experience working directly with national-security or trade-control authorities.
• Experience with deemed export/deemed reexport issues and technology-control plans.
• Familiarity with AI-specific regulatory and national security developments.

Benefits

• Top-tier compensation: Salary and equity structured to recognize and retain the best talent globally.
• Health & wellness: Comprehensive medical, dental, vision, life, and disability insurance.
• Life & family: Fully paid parental leave for all new parents, including adoptive and surrogate journeys.
• Benefits & balance: Paid time off when you need it, relocation support, and more perks that optimize your time.
• Opportunities to connect with teammates: Lunch and dinner provided daily, regular off-sites, and team celebrations.