Anti-bribery and corruption is one of our deepest areas of expertise. We have extensive experience representing both MNCs and domestic companies in providing a full range of anti-bribery and anti-corruption services, including establishing compliance policies, advising on and implementing compliance programs, conducting internal investigations, and evaluating and resolving business model compliance risk assessments, as well as handling government investigations and other contentious matters.

• A leading U.S. MNC in the technology sector in handling a criminal investigation by the Chinese Procuratorate and internal investigations relating to potential violations of the FCPA, Chinese commercial bribery laws and accounting fraud involving third parties. In recognition of the client’s thorough investigation and full cooperation, both the Procuratorate and the U.S. Department of Justice (DOJ) declined prosecution.
• A world-leading coating supplier in conducting an internal investigation on potential corruption involving third parties in China which led to the client’s global self-disclosure.
• A well-known energy company in a criminal enforcement case initiated by the Indian Central Bureau of Investigation (CBI) on suspected bribery of Indian government officials by its Chinese subsidiary and conducting an internal investigation based on the U.S. FCPA and PRC anti-commercial bribery laws.
• A Chinese SOE in response to an investigation initiated by the government of Pakistan, resulting in no penalties for the client.
• A China-based, U.S.-listed company and its subsidiaries in their anti-corruption/FCPA due diligence in connection with their multibillion U.S. dollar investments in China for their multibillion-dollar investments in a wide range of industries.
• Several private equity firms on their anti-corruption compliance due diligence.
• A Fortune 500 company in an investigation by Shanghai AIC concerning commercial bribery, in which we successfully caused the case escalated to the state AIC and had the AIC abandon further investigation.
• A leading MNC in a regulatory investigation by the Shanghai AIC relating to potential violations of Chinese commercial bribery and anti-trust laws. We persuaded the regulatory authority not to impose any punishment.
• A Hong Kong-listed company (with its majority shareholder being a U.S.-listed MNC) in an internal investigation into its PRC subsidiary relating to a complex scheme of employee’s misconduct and representing the company in regulatory investigations and inquiries by Hong Kong and the U.S. governments; and assisting the company to establish a comprehensive compliance program to mitigate risks identified in the investigations.

• Multiple leading life science companies in their internal investigations of potential violations of the FCPA, Chinese anti-commercial bribery laws, channel staffing, cross-selling, accounting fraud and employment issues, as well as other violation of laws and corporate compliance policies.
• A leading real estate company in an internal investigation of embezzlement of company executive, and report implicated company executive to the Public Security Bureau (PSB). Advise the client on complex legal issues involved. As a result of our work, the executive returned more than RMB10 million to the company.
• A world-leading elevator manufacturer in its internal investigations, including advising on a criminal case filing, among other issues.
• Several Chinese SOEs with anti-corruption, sanctions, data privacy, environmental and antitrust reviews, and conducting compliance inspections of overseas operations to help the companies establish compliance programs in accordance with requirements of the State-owned Assets Supervision and Administration Commission (SASAC).
• A wide range of companies (including those in the consumer product, pharmaceutical, technology, automotive, finance, energy, entertainment, and other sectors) in formulating compliance policies for their business in China, and establishing compliance management systems, including risk management system, government dawn raid response system and third-party management system.