Trade Compliance Counsel

Reflection • San Francisco, CA

2d

About The Position

As Trade Compliance Counsel, you will help build, scale, and operationalize our global trade compliance function, with a focus on sanctions, export controls, national-security-adjacent regulatory regimes, and the practical application of those regimes 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 not simply answer one-off legal questions; 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.

Requirements

• 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, including meaningful 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, especially in sectors such as artificial intelligence, cloud computing, semiconductors, advanced computing, cybersecurity, infrastructure, data centers, or other strategically sensitive technologies.
• Experience building, scaling, or materially improving a trade compliance program in a high-growth, technically complex, or operationally dynamic environment.
• Strong ability to exercise independent judgment and take proactive steps in areas where the law is evolving, agency guidance is incomplete, or the business context does not fit neatly into legacy regulatory categories.
• Excellent cross-functional communication skills, including the ability to explain 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.

Nice To Haves

• 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. Bonus points for experience with open source access technology.
• Experience working directly with, or across from, BIS, OFAC, DDTC, CFIUS, DOJ, Commerce, State, Treasury, or other national-security or trade-control authorities, and 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.
• Familiarity with 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.

Responsibilities

• 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 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 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 and 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, and escalation protocols.
• Partner with Security, Compliance, Infrastructure, Finance, Operations and GTM teams to implement practical trade compliance controls that allow for secure model releases, international collaborations, remote access, restricted-party screening, and the transfer of controlled technologies to non-U.S. persons.
• 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, and other third-party relationships.
• Monitor legal and regulatory developments from BIS, OFAC, DDTC, Congress, the White House, the EU, UK, and other relevant authorities, and translate those developments into practical guidance for leadership and operators.
• 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, and cross-border access.

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. Financial support for family planning.
• 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 are provided daily. We have regular off-sites and team celebrations.

What This Job Offers

• Job Type: Full-time
• Career Level: Senior
• Education Level: Ph.D. or professional degree