Trade Compliance Counsel

Reflection is a research lab making intelligence open and accessible for everyone to use customize and build on. We build open models that let anyone control their intelligence and help shape the future of AI. Our mission: make intelligence open and accessible to all.

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 Reflections 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.

• Act as Reflections 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 Reflections business including model development open-weight releases compute access cloud and neocloud infrastructure data center arrangements international collaborations and customer transactions.

• Design and mature Reflections 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.

• 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.

• 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.

We believe that to make intelligence open and accessible to all you need to start at the foundation. Joining Reflection means building from the ground up as part of a talent-dense team. You will help define our future as a company and help define the future of open foundational models.

We want you to do the most impactful work of your career with the confidence that you and the people you care about most are supported.

• Top-tier compensation: Salary and equity structured to recognize and retain our talent globally.

• Stock options: Everyone who joins and contributes to Reflections success gets to share in the upside through stock options.

• Health & wellness: Comprehensive medical dental vision and life with an annual wellness allowance.

• Meals: Lunch and dinner are provided in the office daily.

• Life & family: 22 weeks paid parental leave for all new birthing and non-birthing parents including adoptive and surrogate journeys.

• Vacation days: Unlimited paid time off in the U.S. and 30 days in the U.K.

• Sponsorship support: We sponsor visas to help exceptional talent join our team and support long-term immigration pathways where applicable.

• Team building: We have regular off-sites happy hours and team celebrations.