David Zhang is a partner of Ropes & Gray LLP, and is currently on assignment in Hong Kong as a Senior Foreign Legal Consultant. His practice concentrates on advising clients on government-facing and internal investigations, due diligence, and compliance programs, particularly with a focus on anti-corruption and anti-bribery matters in the Greater China region.
David has counseled clients and conducted a number of internal investigations for multinational and U.S.-listed clients across different industries, including pharmaceutical, medical device, internet and technology, hotel and hospitality, venture capital/private equity and aerospace and aviation. David is natively bilingual in English and Mandarin Chinese, and he is based in Greater China. Through his deep experience with the local business and cultural environment, he provides relevant and practical advice to clients on navigating the particular compliance challenges that they face in the region.
- Advised numerous multinational life sciences companies on internal investigations related to suspected bribery misconduct, off-label promotion, sponsorships and grants, clinical studies, bid-rigging and export compliance, and third party and distributor misconduct.
- Conducted an FCPA internal investigation for U.S.-listed leading provider of cloud computing services in one of its international markets, including advising the client on self-disclosure and settlement with the U.S. DOJ and SEC, resulting in a public declination by the DOJ and a Non-Prosecution Agreement with the SEC.
- Conducted internal investigations regarding anti-corruption and revenue recognition issues for U.S.-listed industrial equipment manufacturer.
- Advised medical research institutions and organizations on internal investigations related to regulatory reporting and disclosure obligations.
- Conducted internal investigations regarding procurement fraud, conflict of interest and embezzlement for U.S.-headquartered company with manufacturing operations in China.
- Conducted an anti-corruption internal investigation for U.S.-listed and privately-held companies across different industries, including hotel management, food & beverage, and manufacturing.
- Advised multi-national medical device company regarding its government-appointed compliance monitorship.
- Counseled a number of multinational life sciences clients on compliance risk assessments, health checks and post-acquisition due diligence local subsidiaries and operations, and advised on compliance risk management and enhancement solutions.
- Advised life sciences companies, international venture capital and private equity funds on various anti-corruption and trade compliance due diligence for investments in Asia.
- Advised clients on developing and implementing anti-corruption compliance policies and procedures, channel and third-party risk management measures, and internal monitoring and control mechanisms for business operations in Greater China.
- Conducted anti-corruption training in Mandarin and English for local employees of multinational corporations and portfolio companies of international investment funds.
- Previously seconded to a Fortune 50 pharmaceutical company to assist with compliance and internal investigation matters.
- Co-author, “Insight: DOJ Revises Policy on Instant Messaging Apps in Foreign Corrupt Practices Act Enforcement,” Bloomberg Law (April 18, 2019)
- Co-author, “China’s Blocking Statute Creates New Challenges for Multinational Companies,” FCPA Professor (March 6, 2019)
- Co-author, “China's Blocking Statute Creates New Challenges For Cos.,” Law360 (February 20, 2019)
- Co-author, “Compliance Challenges When Working With JV Partners in China,” The Anti-Corruption Report (September 19, 2018)
- Co-author, “What Companies Need to Know About China’s New Market Regulator,” Law360 (April 12, 2018)
- Co-author, “Justice Department Moves to Bolster Subpoena Powers for Foreign Bank Records,” Bloomberg BNA’s Corporate on Bloomberg Law (July 3, 2017)
- Co-author, "China Anti-Bribery Rules Raise Questions For Life Sciences," Law360 (February 27, 2014)
- Keynote speaker, “US Enforcement: Developments in 2019 and Outlook for 2020,” European Chamber of Commerce Annual Compliance Conference, Shanghai (October 2019)
- Panelist, “China’s Blocking Statute on Judicial Sovereignty and the Interplay with FCPA Investigations: Securing Local Government Approval for Data Transfers While Avoiding DOJ Penalties,” American Conference Institute China Forum, Shanghai (June 2019)
- Speaker, “FCPA Corporate Enforcement Policy Update, Recent Medical Device Enforcement Actions, and Heightened Focus on Sanctions and Trade Compliance,” Ropes & Gray Medical Device Compliance Roundtable, Shanghai (May 2019)
- Speaker, “Navigating Compliance Risks in the China Life Sciences Industry,” Ropes & Gray and Control Risks Joint Seminar in Shanghai (May 2019)
- Speaker, “Tackling Compliance Issues: Creating a Compliance Culture and Recent US Enforcement Trends,” Japan In-House Counsel Network (JICN) Event with Ropes & Gray in Tokyo (March 2019)
- Moderator, “Leveraging Data and Behavioral Sciences In Legal Risk Management,” Ropes & Gray Risk Management Roundtable, Hong Kong (January 2019)
- Keynote speaker, “2019 Bribery and Corruption Outlook - Case Studies and Recent Enforcement Trends”; and moderator, “Tone from the Top – What Does It Mean and Experiences in Execution?” European Chamber of Commerce Annual Compliance Conference, Shanghai (September 2018)
- Panelist, “The FCPA Pilot Program and considerations in evaluating voluntary self-disclosure” Ropes & Gray Medical Device Roundtable (May 2017)
- Panelist, “FCPA Pilot Program: The Value of Self-disclosure” Ropes & Gray Roundtable in conjunction with Chambers, Shanghai (May 2017)
- Speaker, “Differences between the FCPA and PRC Law: Compliance Traps Posed by Distributors Under Different Laws” Everpro Law Seminar on Distributor Compliance (March 2017)
- JD, The George Washington University Law School, 2009
- BA (Psychology), summa cum laude, The George Washington University, 2005; Presidential Academic Scholarship Award 2002-2005