Next Generation Partners

Regulatory: anti-corruption and compliance in Hong Kong

Davis Polk & Wardwell LLP

Drawing upon a ‘deep understanding of the relevant laws’, including as it relates to sanctions, FCPA, anti-money laundering, and various forms of financial and trading misconduct, Davis Polk & Wardwell LLP is a popular choice among global, Chinese, and regional financial institutions and investment funds subject to high-stakes investigations and enforcement actions. Able to tap into ‘unparalleled experience in relation to financial and regulatory disputes’, Martin Rogers is a giant in the space, regularly acting on high-profile mandates before regulatory authorities in Hong Kong, as well as throughout Asia Pacific, often in mandates involving parallel regulatory probes. Leveraging the firm’s deep credibility in the US (including that of former Hong Kong-based practitioner Patrick Sinclair, who is now based in New York), the firm also excels in advising Chinese-based US-listed companies across a range of inquiries and enforcement actions before the US SEC and in white-collar matters before the DOJ. Although it is best known for contentious work, the practice also regularly advises on compliance and risk management. James Wadham co-heads the team alongside Rogers.

Practice head(s):

Martin Rogers; James Wadham

Other key lawyers:

Bo Huang; Yuan Zheng


The team has deep understanding of the relevant laws and is able to present them in a relatable way.’

Martin Rogers brings with him unparalleled experience in relation to financial and regulatory disputes.’

Herbert Smith Freehills

The ‘very experienced and knowledgeable’ Hong Kong team at Herbert Smith Freehills is the centrepiece of the firm’s global corporate crime and investigations practice. It is highly adept at representing US and European multinationals across a range of industry sectors, including financial services, life sciences, and energy on anti-corruption and compliance matters throughout Greater China and across APAC. Practice head Kyle Wombolt has been key to the firm’s success over the years, with his ‘strong leadership qualities and high expertise’ across a wide range of corruption, fraud, and sanctions issues, ensuring that the office is regularly instructed on ‘complex and sensitive investigation and enforcement matters, not just in Asia, but across the globe’.

Practice head(s):

Kyle Wombolt

Other key lawyers:

Pamela Kiesselbach; Jeremy Birch; Hannah Cassidy


The practical and knowledgeable team are market leaders.’

‘It is a truly global team that has local expertise or connections to provide practical legal and business advice on anti-corruption and compliance in multiple markets.’

‘Kyle Wombolt is an extremely good technical lawyer and has a tremendous presence, strong leadership qualities and high expertise. He has a long history of dealing with complex and sensitive investigation and enforcement matters, not just in Asia, but across the globe.’

Gibson Dunn

Led by the vastly experienced Kelly Austin, who now divides her time between Hong Kong and Denver, the globally integrated team at Gibson Dunn has an excellent reputation, primarily acting for US and European headquartered companies across a wide range of high-stakes white-collar and fraud matters (including FCPA, AML and securities violations) involving a nexus to Greater China and Asia Pacific. Drawing upon her private practice experience, which has included investigations and enforcement actions throughout APAC, as well as her tenure in-house at General Electric, Austin is a popular choice among corporates and financial institutions, not only to represent them in internal investigations and regulatory probes, but also in the context of regulatory compliance and advisory matters. Oliver Welch is also a key member of the team due to his broad expertise, which includes advising Asia-based entities on dealings with the US DOJ and SEC, anti-corruption due diligence pursuant to M&A work, and Korea-related work.

Practice head(s):

Kelly Austin

Other key lawyers:

Oliver Welch; Brian Gilchrist; Elaine Chen; Sébastien Evrard; William Hallatt

Key clients


Ropes & Gray LLP

Led by Andrew Dale, Ropes & Gray LLP's ‘highly experienced’ anti-corruption and international risk team is best known for its work on behalf of an impressive roster of private equity clients, which are appreciative of its ability to provide ‘commercial and solutions-focused advice’. The scope of this work runs across the gamut of anti-corruption mandates, from due diligence on potential corruption, FCPA, sanctions, and money-laundering risks associated with transactions in the region, through to compliance, monitoring, and investigations work for portfolio companies. Splitting his time between Boston and Hong Kong, Geoffrey Atkins handles a range of APAC-related anti-corruption work, including internal and regulatory investigations for life sciences and financial services clients.

Practice head(s):

Andrew Dale

Other key lawyers:

Geoffrey Atkins


The highly experienced team provides commercial and solutions-focused advice.’

Skadden, Arps, Slate, Meagher & Flom LLP

Leveraging its ‘market-leading position in corporate and capital markets work in Hong Kong’, Skadden, Arps, Slate, Meagher & Flom LLP handles a broad range of internal investigations, regulatory enforcement, litigation, and compliance work. While it adeptly handles inbound work for US corporates, the team is particularly skilled at assisting Chinese financial and technology companies which have expanded into the US with responding to US regulators’ inquiries and related investigations. Hong Kong and US-qualified team head Steve Kwok has ‘vast experience in US-China matters in the anti-corruption and compliance space’, where he combines language capabilities, legal expertise, and an excellent insight into US regulatory workings, which was enhanced through his time as the DOJ’s attaché in China.

Practice head(s):

Steve Kwok

Other key lawyers:

Beatriz Paterno; Siyu Zhang


‘They have a lot of great momentum from the firm’s market-leading position in corporate and capital markets work in Hong Kong.’

‘The strengths and capabilities lie in the familiarity and experience it has, especially with the US stock exchange authorities and other regulators.’

Steve Kwok is very well thought of and is known for his US background and experience in US-China matters in the anti-corruption and compliance space.’


Drawing upon ‘extensive experience in cross-border investigations, compliance, and enforcement’, Steptoe's Hong Kong office has, since it was opened at the beginning of 2020, gained a significant market share, providing ‘practical and commercially sensible advice’ to Chinese companies on regulatory compliance and white-collar defence of international laws, US sanctions, and export controls. Team head Wendy Wysong is ‘among the world’s leading compliance experts particularly when dealing with complex situations’, and she is supported by Ali Burney, who has ‘a wealth of experience in front of law enforcement agencies and regulators’. The arrival from Shearman & Sterling of Cáitrín McKiernan in May 2023, who splits her time between the Hong Kong and New York offices, bolsters the team's abilities to advise multinational companies on compliance matters with the FCPA and related laws.

Practice head(s):

Wendy Wysong

Other key lawyers:

Ali Burney; Cáitrín McKiernan


The team provides practical and commercially sensible advice, because they are extremely well-versed with the sanctions laws and the likelihood of enforceability, and are acutely familiar with the challenging business environments that companies have to deal with in the Southeast Asia and North Asia regions.’

They have extensive experience in cross-border investigations, compliance, and enforcement.’

Their team has decades of experience in advising clients on the ever evolving sanctions landscape, and representing clients in front of the US government.’

Work highlights

  • Assisted a client with the implementation of a comprehensive compliance programme, including anti-bribery and anti-corruption, AML, and sanctions matters.
  • Advised a multinational development bank on best practices for transactional due diligence and ad-hoc advice on the application of US and other international sanctions.

Baker McKenzie

Led from Hong Kong by the ‘superb’ Mini vandePol, and also able to leverage significant resources throughout APAC and globally, Baker McKenzie is well-positioned to handle internal and regulatory investigations for regional and global multinationals relating to a wide range of alleged anti-corruption activity, including on AML, sanctions, and financial fraud matters. Special counsel Christine Cuthbert is another key name who is pivotal to the firm’s success on the investigative side, and the team also provides anti-corruption regulatory due diligence in relation to M&A and capital markets work, and is regularly called upon to establish robust anti-corruption compliance programmes.

Practice head(s):

Mini vandePol

Other key lawyers:

Christine Cuthbert; Gerald Lam

Debevoise & Plimpton LLP

Debevoise & Plimpton LLP's main focus in the regulatory space is on defence work for financial services clients, as well as for senior executives, who are subject to regulatory investigations and private litigation. Mark Johnson has substantial experience and familiarity with regulatory investigations, including mis-selling, insider trading, and market manipulation probes by the SFC and HKMA. Johnson also represents Hong Kong publicly-listed companies in internal investigations and regulatory scrutiny by bodies including the ICAC and the HKSE. Gareth Hughes co-heads the team alongside Johnson and is also a core member of the team.

Practice head(s):

Mark Johnson; Gareth Hughes

Other key lawyers:

Philip Rohlik; Samuel Fung

DLA Piper

Leveraging ‘good language skills and hands-on international experience’, DLA Piper is well-positioned to represent international, Hong Kong, and China-based multinational corporates from a range of industries on compliance reviews, regulatory matters, and internal regulatory investigations. Team head Sammy Fang regularly defends clients in local and cross-border regulatory probes throughout Greater China, including as it relates to white-collar crime, anti-bribery, and anti-corruption, as well as cybercrime work predominantly regarding ransomware and data breaches.

Practice head(s):

Sammy Fang

Other key lawyers:

Christine Liu; Rose Le


‘They have good language skills and hands-on international experience that we find very helpful in dealing with demanding situations.’

Sammy Fang stands out in his specialisation as he has the requisite skills and experience in advising clients in dealing with challenging situations and the fact that he is bilingual enables him to pick up salient messages and issues.’

King & Wood Mallesons

Deploying a multi-disciplinary approach which incorporates regulatory, corporate finance, and dispute resolution expertise, King & Wood Mallesons is well-placed to advise local and international corporates and financial services clients across the entire spectrum of their compliance needs, as well as in relation to responding to regulatory inquiries. As part of her broad commercial litigation expertise, Barbara Chiu frequently represents clients in regulatory investigations and litigation proceedings, as well as in SFC actions, including market misconduct tribunal and court proceedings.

Practice head(s):

Paul Starr; Barbara Chiu

Other key lawyers:

Rachel Yu; Crystal Luk; Leonie Tear


‘It has advantages in the fields of anti-corruption and has strong legal service capabilities.’

Key clients

Westpac Banking Corporation

CNOOC International Trading Company Limited

Osaka Gas Energy Supply and Trading Pte Limited

Novatek Gas and Power Asia Limited

Hua Xia Bank

Top Wisdom Overseas Holdings Limited

Masterwork Group Co., Ltd.

FTX Trading Ltd

Hatch Associates Limited

Work highlights

  • Assisting Hong Kong Association of Banks with conducting a consultation with its members in relation to the proposed Anti-Money Laundering and Counter-Terrorist Financing (Amendment) Bill 2022, submitted to the Hong Kong Monetary Authority.
  • Acted for Westpac Banking Corporation, Hong Kong branch in an HKMA disciplinary action.
  • Acting for Mr Li Han Chun and his wholly owned company Top Wisdom Overseas Holdings Limited in relation to matters concerning China Forestry Holdings Co.

Kirkland & Ellis

Led by Cori Lable, the ‘experienced, knowledgeable and responsive’ team at Kirkland & Ellis provides ‘practical and solutions-oriented’ advice to international clients from a range of sectors on government-led and internal investigations throughout APAC, as well as handling a considerable volume of risk analysis work for the firm’s market-leading roster of private equity clients relating to transactions throughout the region. Jodi Wu has ‘good knowledge of the regulatory and compliance landscape in China’, ensuring she is a popular choice among international companies, including many within the pharmaceutical sector, to conduct internal investigations regarding potential improper activity relating to operations on the mainland. As well as the team’s regular collaboration with its Shanghai office, the group is well-placed to represent Chinese entities subject to US SEC and DOJ regulatory scrutiny by virtue of its market-leading government enforcement defence and internal investigations group in New York, Chicago, and Washington DC.

Practice head(s):

Cori Lable

Other key lawyers:

Jodi Wu


‘They provide to-the-point and clear advice.’

They have the relevant domain knowledge and the advice they provide is very practical and solutions-oriented.’

‘The team is experienced, knowledgeable and responsive to the client’s demands.’

‘Jodi Wu has good knowledge of the regulatory and compliance landscape in China and can highlight the important issues very quickly. She is also solid and experienced compliance lawyer who has experience in China and the US.’

Sidley Austin

Sidley Austin provides ‘practical, commercial and pragmatic advice’ to clients from a wide range of industry sectors, including asset management, financial services, life sciences, and technology, across a broad array of anti corruption-related matters. Leveraging the firm’s strong presence in other critical offices in the region, the team is best known for its ability to provide a unified, Asia-wide offering to clients engaged in regulatory investigations and enforcements, as well as compliance counselling on inter alia sanctions and AML, and FCPA matters associated with transactional work handled by the firm. In addition, the team is noted for its aptitude at handling mandates which also touch upon UK and US regulatory concerns. Although now both based in Singapore, following their return to the firm after a brief stint at McDermott Will & Emery Singapore LLP, ‘highly intellectual and pragmatic’ co-heads Yuet Ming Tham and Shu Min Ho are both well-versed in anti-corruption matters with a nexus to Hong Kong, having spent many years practising in the country. Stephanie Chan, who joined in February 2023 from Reed Smith Richards Butler LLP, adds firepower to the firm’s offering on the ground in Hong Kong, particularly as it relates to regulatory investigations conducted by regulatory and enforcement authorities, including the HKSE, SFC, and HKMA.

Practice head(s):

Yuet Ming Tham; Shu Min Ho

Other key lawyers:

Stephanie Chan


‘They provide practical, commercial and pragmatic advice.’

‘Very experienced in the area of compliance investigations, with a global network of legal professionals they can tap in and out of.’

‘Yuet Ming Tham and Shu Min Ho are highly intellectual and pragmatic in their approach, ensuring a solutions-oriented outcome.’


Led by James ComberAshurst has developed strong ties with international and regional banks and brokerages, which it represents across a range of contentious matters. The firm has strong experience handling investigations and enforcement actions before the various Hong Kong financial regulators and is also well-placed to advise on matters proceeding in a multi-pronged fashion alongside other international regulators by dint of its wide global network of offices. Drawing upon his strong language capabilities, Cliff Chow handles a large volume of China-facing work for international financial services institutions, as well as HKSE investigations involving mainland companies.

Practice head(s):

James Comber

Other key lawyers:

Cliff Chow; Sylvia Tee; Benjamin Ng; Melanie Wong; Jenny Liu

Key clients

HNA Group Co Limited

Royal Bank of Canada

Asia Debt Management

China Merchant’s Bank

Bank of America, National Association

Credit Suisse

Duff & Phelps

HNA Group Company (International) Limited

Swiss Re

Samsung Securities

CNCB (Hong Kong) Investment Limited

Beijing Energy International Holdings Limited

Work highlights

  • Advised RBC Investment Services (Asia) Limited on responding to an SFC inquiry into alleged breaches of the Client Money Rules.
  • Acted for CMB in two sets of Norwich Pharmacal proceedings in the High Court of Hong Kong, in which disclosure orders and anonymity orders were sought by the plaintiffs against CMB, who it was alleged had processed fraudulent payments made by the plaintiff to the alleged fraudster.

Haldanes, Solicitors and Notaries

Since it was established in 1975, independent Hong Kong-based firm Haldanes, Solicitors and Notaries has had a core focus on defending clients in criminal mandates and has developed ‘a strong reputation in handling white-collar crime’ and anti-corruption matters. The team, which is led by the vastly experienced Felix Ng, is highly adept at handling enforcement and investigation proceedings before a myriad of agencies, including SFC, HKMA, and ICAC, with many of the matters involving cross-border considerations and involvement from other international regulators. Native Mandarin and Cantonese-speaking partner Paul Wang has developed a strong reputation advising on complex commercial criminal matters often involving a significant nexus to the mainland, where he is appreciated for his ability to provide ‘clear and pragmatic advice’. The ‘unbelievably hard working, clever and caring’ associate Christina Ma is also developing an excellent reputation in the field, regularly working alongside Wang on high-profile matters, including cases of fraud and money laundering.

Practice head(s):

Felix Ng

Other key lawyers:

Geoffrey Booth; Andrew Powner; Paul Wang; Timothy Wan; Florence Yan; Christina Ma


‘The team has always provided exceptional support. Their preparation is intelligent, well organised and researched, thorough, flexible and ongoing. You could not ask for better.’

‘Haldanes is one of the leading criminal law firms in town with a strong reputation in handling white-collar crime matters. It has a strong team of criminal practitioners who are able to help clients in complex matters on short notice.’

‘Paul Wang is intelligent and intuitive with a positive, cheerful and outgoing personality. He provides a strong and safe link across the border for those in need of help on the other side. He is warm and caring towards even difficult clients and inspires their trust and confidence.’

‘Paul Wang is a up and coming junior partner who is excellent in dealing with his clients’ needs at any time of the day. Clients appreciate his clear and pragmatic advice.’

‘Christine Ma is a delight to work with. The professional bond between her and Paul Wang is key to the quality of their work and a pleasure to see. Christina is unbelievably hard working, clever and caring.’

Mayer Brown

Leveraging the firm’s broader commercial litigation credentials, Mayer Brown's white-collar group, which is led by Alan Linning, is well-positioned to represent a myriad of financial services entities and listed companies regarding regulatory investigations and enforcement actions. As well as his significant experience in private practice, clients also benefit from Linning's in-house experience at a major investment bank, as well as the regulatory insights he gained in his former role as executive director of enforcement at the SFC. Raymond Chan is also a key member of the team and has experience handling internal investigations, as well as investigations before the ICAC and the SFC.

Practice head(s):

Alan Linning

Other key lawyers:

Raymond Chan; Wilson Fung; Raymond Yang; Wei Na Sim

Morrison Foerster

With an ‘excellent understanding of the local market’ and being able to call upon the expertise of practitioners in many key global offices, Morrison Foerster is well-placed to handle cross-border mandates for Chinese and multinational clients facing regulatory and enforcement risks on multiple fronts. Timothy Blakely and Chen Zhu head up the integrated contentious and non-contentious practice and are both well-versed across the panoply of issues in this space, including as it relates to economic sanctions, AML, FCPA, securities, and accounting fraud, as well as related governance and corporate compliance issues.

Practice head(s):

Timothy Blakely; Chen Zhu

Other key lawyers:

Gary Zeng


‘They understand the local market, have a strong ability to serve international cross-border projects, and are good at handling large and complex cases.’

‘Chen Zhu and Timothy Blakely understand the needs of clients and are good at grasping the diverse legal issues in complex cross-border projects.’

Paul Hastings LLP

Increasingly active in Hong Kong following the arrival in 2020 of the ‘very experienced' white-collar practitioner Shaun Wu from Kobre & Kim, and also able to leverage a strong global presence, including in Shanghai and the US, Paul Hastings LLP is well-versed at managing investigations, prosecutions, compliance reviews, and associated litigation involving China. Wu, who splits his time between Shanghai and Hong Kong, heads the team that also includes the ‘very professional and competent’ of counsel John Tso.

Practice head(s):

Shaun Wu

Other key lawyers:

John Tso; Sarah Zhu


‘Shaun Wu is a very experienced legal practitioner and has led many of the most significant engagements in the past decade, and has increased exposure also in the past three years.’

‘John Tso is very professional and competent.’

‘One of the larger regulatory/compliance teams that is led by senior practitioners that had over a decade of experience. Big on diversity and inclusion.’