Geoffrey M. Atkins
Geoff is a partner in the litigation and enforcement practice group at Ropes & Gray in Hong Kong. Geoff advises public companies, fund sponsors, and financial services clients in the United States and throughout Asia in connection with civil and criminal government enforcement matters before the SEC, DOJ, and other state and foreign regulators, and in connection with complex securities and commercial disputes.
Geoff regularly advises corporate management and directors conducting internal investigations, evaluating sensitive governance issues, and establishing regulatory compliance programs. He has particular experience advising clients regarding potential violations of global anti-corruption, anti-money laundering and sanctions laws; conducting international risk assessments; and evaluating risks associated with complex mergers and acquisitions in India, China and throughout Southeast Asia. In addition, Geoff has been advising on potential areas of investment-related fraud, including considerations for PE clients related to their Asia-based portfolio companies, in light of the global COVID-19 pandemic.
Geoff has extensive experience working with clients in the pharmaceutical, medical device, and technology sectors, as well as private equity funds, investment advisory firms and broker-dealers.
Geoff is recognized in Global Investigations Review, The Legal 500 Asia Pacific and Benchmark Litigation.
Anti-Corruption and International Risks
- Independent Counsel to Fortune 500 U.K pharmaceuticals manufacturer regarding SEC and DOJ inquiry pertaining to potential FCPA violations in China.
- Represented Fortune 500 U.S. pharmaceuticals manufacturer in connection with SEC inquiry regarding potential FCPA violations in Malaysia.
- Represented Fortune 500 U.S. technology company in connection with SEC and internal investigation regarding potential bribery and internal control violations in Thailand.
- Represented U.K. investment bank in internal investigation relating to potential FCPA and U.K. bribery act violations regarding potential hiring practices in Hong Kong.
- Represented numerous multinational clients in the pharmaceutical, medical device, life sciences, and technology sectors in connection with internal investigations and risk assessments relating to the FCPA and U.K. Bribery Act throughout the Asia-Pacific Region.
- Assisted a U.S. private equity firm in designing an FCPA/AML/OFAC Sanctions program pertaining to a feeder fund partnership with a large Chinese investment manager.
- Advised a U.S. private equity firm in connection with the FCPA and OFAC/EU sanctions implications of a potential investment in the Russian energy sector.
- Counsel to numerous multinational private equity firms regarding FCPA, AML, and OFAC risks associated with investments throughout the Asia-pacific region, establishing portfolio company monitoring and training programs, and in evaluating potential regulatory risks and reporting obligations under U.S. and H.K. law.
- Represented a global private equity firm in SEC enforcement inquiry related to fiduciary duties under Investment Adviser’s Act in connection with the receipt of fees, distribution of expenses, and disclosure of potential conflicts of interests.
- Represented a Fortune 500 retail goods company in connection with SEC inquiry regarding potential accounting improprieties and alleged gaps in financial disclosure.
- Counsel to unregistered and registered investment advisers in SEC and state regulator investigations related to the use and disclosure of complex subprime asset backed securities in fixed income funds.
- Counsel for expert network and associated registered broker-dealer and investment adviser in SEC inquiry into insider trading issues arising from operations of industry-specific expert network.
- Represented fixed income and equity mutual fund advisers in connection with SEC enforcement inquiries into potential trading violations, valuation issues, and disclosure shortcomings regarding industry concentrations and leverage limits.
- Counseled the audit committee for a publicly-listed U.S. consumer goods manufacturer in connection with SEC inquiry into allegations of improprieties relating to financial reporting and disclosure.
- Counsel for the audit committee for a U.S.-based publicly-listed technology company regarding allegations in short seller report of financial accounting and reporting violations.
- Represented Ovascience, Inc. in obtaining a dismissal of a putative securities class action at the district court level.
- Counsel for State Street in multiple federal actions relating to losses in subprime asset-backed securities in mutual funds and unregistered collective trust funds. Cases include Yu v. State Street Corp. (S.D.N.Y. 2011), dismissing securities class action regarding mutual fund disclosures for lack of causation, and a bench trial in the Southern District of New York in ERISA litigation arising from subprime mortgage exposure in State Street fixed income funds.
- Represented a U.S.-based hedge fund in connection with shareholder action against directors of publicly-listed life sciences company alleging breaches of fiduciary duty and mismanagement.
- Provided strategic advice to multiple fund sponsors in connection with potential disputes, arbitration, and litigation alternatives in relation to investments in the Asia-Pacific region.
- Co-author, “Bribery and corruption reporting obligations: China,” Thomson Reuters (November 2020)
- Co-author, “Insight: DOJ Revises Policy on Instant Messaging Apps in Foreign Corrupt Practices Act Enforcement,” Bloomberg Law (April 18, 2019)
- Co-author, “Hong Kong Is Becoming A Top Int'l Arbitration Venue,” Law360 (April 11, 2019)
- Co-author, “Key Amendment to India’s Anti-Corruption Legislation Has Significant Implications for Multinationals Doing Business in India,” Legal Era (April 2019)
- Co-author, “New Burma Act Would Hinder US Investment In Myanmar,” Law360 (December 4, 2017)
- Co-author, “Smith & Wesson Settlement Raises FCPA Concerns for U.S. Businesses,” Bloomberg BNA Corporate Law & Accountability Report (August 22, 2014)
- Co-author, “The Implications of the ‘‘Big Four’’ Suspension Ruling,” Bloomberg BNA Corporate Law & Accountability Report (March 14, 2014)
- Virtual presenter, “2020 Global Enforcement and Compliance Updates,” European Chamber of Commerce Annual Compliance Conference, Shanghai (October 2020)
- Speaker, “Enforcement and Compliance during COVID-19: Impact on Investigations and Expectations on Corporate Compliance Programs,” The Association of Corporate Counsel (ACC) Hong Kong Event with Ropes & Gray (September 2020)
- Co-host, “China Investigations COVID-19: Potential risks and responses – Peer to Peer Virtual Roundtable Discussion,” (July 2020)
- Co-host, “India Compliance and Investigations COVID-19: Potential risks and responses – Peer to Peer Virtual Roundtable” (June 2020)
- Presenter, “Anti-Corruption in Southeast Asia,” Client Virtual Training (April 2020)
- Moderator, “Handling Internal Compliance Investigations,” European Chamber of Commerce Annual Compliance Conference, Shanghai (October 2019)
- Moderator, “An update on sanctions, export control and financial crime compliance in Asia Pacific,” Asialaw Asia-Pacific In-House Counsel Summit 2019, Hong Kong (May 2019)
- Moderator, “Global Anti-Corruption Enforcement And Emerging Challenges For Multinationals In Asia,” Asia Legal Business, Singapore (August 2018)
- Panelist, “Bracing for Regulatory Action in the Indian Pharma and Medical Device Industry,” Berkeley Research Group and Ropes & Gray Co-Hosted Roundtable, Mumbai India (October 2017)
- Panelist, “The FCPA Pilot Program and considerations in evaluating voluntary self-disclosure,” Ropes & Gray Medical Device Roundtable (May 2017)
- JD, cum laude, Boston University School of Law, 2008; G. Joseph Tauro Distinguished Scholar; Administrative Editor, Boston University Law Review
- BA, Boston College, 2005
Admissions / Qualifications
- Hong Kong, Solicitor, 2017
- Massachusetts, 2008
- U.S. District Court for the District of Massachusetts, 2015
- Global Investigations Review: “40 Under 40” (2020)
- Legal 500 Asia Pacific: Next Generation Partner in Regulatory: Anti-Corruption and Compliance (2020-2021)
- Benchmark Litigation: Dispute Resolution Star (White Collar, and Commercial and Transactions) (2019)