Government Enforcement & Internal Investigations

• Led numerous internal investigations for multiple multinational pharmaceutical and medical devices companies. Underlying issues included potential bribery of government officials or medical professionals, fraudulent events and expenses, conflicts of interest, misconduct related to bidding, third-party misconduct and so on.
• Represented the special committee of the board of directors of a China-based pharmaceutical company in an investigation of whistleblower complaints alleging misconduct by senior executives, including potential corruption, bribery and conflicts of interest.
• Represented the audit committee of the board of directors of a Chinese company listed on the NYSE in an internal review of allegations made by a short-selling firm that the company overstated its reported revenue.
• Represented the audit committee of the board of directors of a manufacturer of high-precision components in an internal review of potential misconduct by individual executives. Issues included bribery, embezzlement, expense fraud and evidence tampering.
• Represented an international consulting firm in its investigation responding to U.S. Department of Justice (DOJ) inquiries into a senior executive’s alleged misconduct involving overseas projects with Chinese companies that may have violated the Foreign Corrupt Practices Act (FCPA).
• Represented an international spice company in an internal investigation into its operations in Vietnam regarding potential bribery solicitation by employees from third parties.
• Represented a Fortune 500 appliance manufacturer in reaching a settlement with the U.S. Department of Justice (DOJ) regarding potential violations of the U.S. Consumer Product Safety Commission (CPSC).
• Represented a former CEO of a U.S.-listed company in responding to an internal investigation of the company’s special committee and prepared the client for potential SEC enforcement actions.

Compliance Risk Assessment and Risk Management

• Assisted a multinational rolling stock company in a comprehensive post-investment compliance risk review of its acquired entities and joint ventures in China and designed detailed remediation measures for implementation.
• Assisted a multinational technology company in strengthening its compliance program in accordance with the requirements of a deferred prosecution agreement with the U.S. Department of Justice (DOJ) and provided solutions and risk recommendations for its global business compliance.
• Represented an international pharmaceutical retail company in compliance risk assessment of its joint venture program in China and provided advice on the corresponding compliance program implementation.
• Assisted several international pharmaceutical and medical devices companies in developing and improving compliance policies and procedures for China.
• Assisted multiple private equity firms and asset management companies with comprehensive pre-investment due diligence and post-investment risk remediation from a compliance perspective, focusing on anti-corruption, anti-money laundering, sanctions and export control issues. Pre-investment actions include drafting and negotiating contract provisions and preliminary assessment of compliance risks. Post-investment actions include annual compliance risk assessment, developing compliance policies and delivering training programs.
• Conducted an internal review for an international consulting firm regarding its internship programs, assessed associated risks under the FCPA and provided remediation recommendations.

• Co-author, “China’s New Anti-Foreign Sanctions Law: Understanding Its Scope And Potential Liabilities,” JDSupra.com, 2021