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.