Trade Compliance Counsel

OUR MISSION Reflection’s mission is to build open superintelligence and make it accessible to all. We’re developing open weight models for individuals, agents, enterprises, and even nation states. Our team of AI researchers and company builders come from DeepMind, OpenAI, Google Brain, Meta, Character.AI, Anthropic and beyond. ABOUT THE ROLE 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. 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 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. WHAT WE’RE LOOKING FOR - 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