Regulatory: anti-corruption and compliance in Hong Kong

Davis Polk & Wardwell LLP

At Davis Polk & Wardwell LLP, the team is acting for a Fortune 100 life sciences company in ongoing internal investigations in response to whistleblower allegations in multiple Southeast Asian jurisdictions. Martin Rogers is noted for his expertise in financial services regulatory matters; he shares leadership of the practice with Patrick Sinclair, who is very experienced in handling anti-money laundering, sanctions, and matters involving the Foreign Corrupt Practices Act (FCPA), as well as acting for multinational corporations in internal investigations.

Practice head(s):

Martin Rogers; Patrick Sinclair

Work highlights

  • Assisting a prominent multinational company with an internal investigation concerning alleged corruption on the part of its management in Shanghai.

Herbert Smith Freehills

Herbert Smith Freehills is 'a clear market leader with a practice that is unrivalled in Asia'. The practice is well versed in handling a broad spectrum of work, for example, anti-money laundering and anti-corruption issues, internal investigations, anti-bribery matters, and corporate investigations. Practice head Kyle Wombolt garners praise as 'the pre-eminent regulatory and white-collar lawyer in the Asian market'. The 'very responsive' consultant Pamela Kiesselbach and Jeremy Birch are also singled out.

Practice head(s):

Kyle Wombolt

Other key lawyers:

Pamela Kiesselbach; Jeremy Birch


The HSF team has been a clear market leader with a practice that is unrivalled in Asia and that continues to grow even stronger and bigger year-on-year when it comes to anti-corruption investigations, compliance, criminal and regulatory enforcement. The global practice is run by Kyle Wombolt in Hong Kong and he and his team have a tremendous reputation and presence across Asia‘.

Excellent practical experience, very strong technical knowledge, and always available and ready to help at short notice‘.

Kyle Wombolt is among the best in this field worldwide. Much greater practical experience and a more hands-on approach than any others I’ve come across‘.

Gibson Dunn

Gibson Dunn's team is led by Kelly Austin, who has extensive experience in advising on the creation and implementation of effective compliance programmes. The firm counts government and corporate internal investigations as the backbone of the practice, often involving the FCPA. Recently promoted partner Oliver Welch is also noted.

Practice head(s):

Kelly Austin

Other key lawyers:

Oliver Welch

Ropes & Gray LLP

Andrew Dale heads the team at Ropes & Gray LLP, which has been kept busy advising clients drawn from, among other areas, the life sciences, private equity, and telecoms sectors on risk assessments involving anti-corruption compliance matters and bribery-related cases. Geoffrey Atkins is a key name to note. In 2020 Mimi Yang left the firm to join Sequoia Capital China as chief compliance officer, and David Zhang has left the firm.

Practice head(s):

Andrew Dale

Other key lawyers:

Geoffrey Atkins

Debevoise & Plimpton LLP

Noted for being 'very strong in this area', Debevoise & Plimpton LLP's practice advises clients on internal investigations, compliance matters, and bribery and corruption-related cases, often with cross-border elements. Mark Johnson and Gareth Hughes head up the team.

Practice head(s):

Mark Johnson; Gareth Hughes

DLA Piper

At DLA Piper, recent work for the team includes handling internal investigations involving fraud, misconduct, and bribery-related issues. China head of compliance and investigations Sammy Fang  shares leadership of the practice with Asia head of investigations Nathan Bush, who is based in the Singapore office.

Practice head(s):

Sammy Fang; Nathan Bush

King & Wood Mallesons

Paul Starr and Barbara Chiu head up the team at King & Wood Mallesons, which has been kept busy representing clients drawn from a wide spectrum of sectors in internal investigations concerning allegations of corruption, fraud, and misconduct.

Practice head(s):

Paul Starr; Barbara Chiu

Work highlights

  • Acting for two minority shareholders of a manufacturing company in an internal investigation involving alleged fraud committed by the majority shareholders of the company.
  • Advising the Malaysian subsidiary of a microchip manufacturing company on an investigation into an alleged $8m commercial fraud.

Kobre & Kim

Kobre & Kim's key focus is on investigations and disputes, and has a track record of advising on high-value fraud and misconduct cases. Vasu Muthyala has expertise in handling securities, sanctions, and anti-money laundering issues, and FCPA investigations. Ryan Middlemas is also singled out.

Practice head(s):

Vasu Muthyala

Other key lawyers:

Ryan Middlemas

Skadden, Arps, Slate, Meagher & Flom LLP

The team at Skadden, Arps, Slate, Meagher & Flom LLP is jointly led by the 'exceptional' Steve Kwok and Washington DC-based Bradley Klein. Recent areas of instruction for the group include internal and SEC investigations, FCPA matters, and the implementation of compliance programmes.

Practice head(s):

Steve Kwok; Bradley Klein

Steptoe & Johnson

Steptoe & Johnson's team was bolstered by the arrival of Wendy Wysong from Clifford Chance in December 2019. Wysong - who divides her time between Hong Kong and Washington DC - heads up a practice that counts sanctions work as a core strength, as well as advising clients drawn from a wide range of sectors on compliance matters. Susan Munro and Ali Burney are key names, and of counsel Nicholas Turner is also recommended.

Practice head(s):

Wendy Wysong

Other key lawyers:

Susan Munro; Ali Burney; Nicholas Turner

Work highlights

  • Representing a logistics company in a global internal investigation regarding alleged violations of US economic sanctions.
  • Advising a Japanese corporation on regulatory matters concerning global sanctions.

Baker McKenzie

Baker McKenzie's practice is headed up by Mini vandePol, who is the firm's Asia Pacific head of compliance and investigations. Internal investigations related to allegations of whistleblowing, bribery, and corruption have been prominent in the team's recent workload. Compliance issues are another area of strength for the group.

Practice head(s):

Mini vandePol

Kirkland & Ellis

The team at Kirkland & Ellis is jointly led by Cori Lable and Shanghai-based Tiana Zhang. The practice is strong in handling cross-border internal investigations for a client base of private equity firms, and has also been kept busy advising on compliance issues. Richard Sharpe is another key contact.

Practice head(s):

Cori Lable; Tiana Zhang

Other key lawyers:

Richard Sharpe