Ethan (Yichen) Cao advises Chinese and multinational companies on economic sanctions, export controls and international trade compliance, with a focus on cross-border matters involving China and the United States.
Ethan has extensive experience advising on sanctions and export control due diligence in connection with Hong Kong IPOs and M&A transactions. He also advises clients on sanctions and export control issues arising from cross-border investments, ongoing business operations and other international transactions. His experience includes conducting trade compliance risk assessments, assisting with export control classifications and CCATS submissions, supporting U.S. export license applications, and developing and implementing trade compliance programs. Ethan also assists clients with internal investigations, audits and regulatory inquiries involving U.S. sanctions and export controls.
Representative Experience
- Advised SICC Co. Ltd. on U.S. export control, economic sanctions, U.S. outbound investment rules and U.S. tariffs in connection with its listing on the main board of HKEX, which raised HKD 2.04 billion.
- Counseled ROKAE (Shandong) Robotics Group Inc. on U.S. export controls, economic sanctions, U.S. outbound investment regulations and U.S. tariffs in connection with its HKEX Main Board IPO, raising approximately HKD 875 million.
- Represented Shanghai Able Digital Science & Technology Co. Ltd. on U.S. export controls, outbound investment regulations and tariffs in connection with its HKEX Main Board listing, which raised approximately HKD 507 million.
View More
- Advised a domestic new-energy battery company on proactively addressing congressional allegations with the U.S. government, including supply-chain investigation and preparation of a clarification submission.
- Supported semiconductor design companies in obtaining U.S. export control classification determinations, including product analysis and preparation of submissions in coordination with U.S. counsel.
- Advised a semiconductor design company on U.S. outbound investment regulations in connection with a U.S. green-card-holding shareholder and related regulatory notification requirements.
- Counseled a Singapore data center in responding to a joint investigation by the U.S. government and Singapore Customs concerning its cross-border technology transactions.
- Represented a semiconductor manufacturer following the seizure of U.S.-origin equipment, coordinating with U.S. counsel and suppliers to address potential Entity List designation risks.
- Counseled financial leasing companies on U.S. trade-control risks arising from cross-border leasing structures, including analysis of underlying transactions, counterparties and applicable restrictions.
- Advised domestic and international banks on compliance risks under China’s Anti-Foreign Sanctions Law arising from cross-border transactions and sanctions-related business activities.
- Developed trade-control compliance assessments and programs for domestic companies, covering sales, procurement and external cooperation in light of U.S. government compliance expectations.
Education
-
LL.M., Cornell Law School, 2022
LL.B., East China University of Political Science and Law (ECUPL), 2020
Admissions
-
People's Republic of China
Languages
-
Chinese (Mandarin)