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Patrick S. Sinclair


Patrick S. Sinclair

White Collar Defense & Investigations
New York

Former federal prosecutor with extensive experience in cross-border corporate investigations. Led over 100 Asia-based investigations with focus on U.S.-China matters.

Admitted in both Hong Kong and New York, Patrick has over two decades of experience representing corporations, audit committees, banks, individuals and governments in corporate criminal investigations. He has lived and worked across the United States and Asia and regularly represents clients facing inquiries from the DOJ, the SEC, CFTC and other regulators.

Patrick is widely recognized as a leading litigator in Asia, and he led over 100 investigations in Asia. He has deep experience in China, Thailand, Vietnam, Singapore, Malaysia and Korea. He has relationships with local counsel and professionals and brings valuable insight to the cultural and legal challenges that face companies in Asia.

Earlier, as a federal prosecutor in New York, Patrick supervised, investigated and prosecuted high-stakes business fraud investigations and other criminal matters. He received the U.S. Attorney’s Excellence in Criminal Litigation Award and commendations from the SEC, FBI and Treasury Department.

Experience highlights

  • Luckin Coffee in its negotiations and settlement with the U.S. SEC in connection with alleged accounting fraud
  • A multinational technology company in obtaining declinations from the DOJ and SEC after a three-year investigation into allegations of potential improper payments to government officials in China, including related advice on uplifts to the company’s compliance program
  • The former President and Chief Technology Officer of a Chinese-based/U.S.-listed medial company in connection with insider trading allegations arising out of a 10b5-1 plan
  • A Chinese technology company on adopting governance structures to address compliance issues arising from the manner in which certain global data is collected and maintained
  • The Investor Relations Officer of a Chinese-based/U.S.-listed retail company in connection with insider trading allegations
  • Conduct over 75 internal investigations responding to whistleblower allegations and/or compliance escalations in various jurisdictions in Southeast Asia for Fortune 100 pharma/life sciences companies
  • Regularly develop and guide implementation of corporate governance structures, policies and procedures to promote compliance with the U.S. FCPA, U.S. Anti-Money Laundering statutes, U.S. sanctions programs, insider-trading laws and ESG initiatives
  • Advise and provide due diligence assistance and divestiture advice to several major private equity companies on investments in Asia

Before joining Davis Polk, Patrick:

  • Developed and implemented an investigative protocol for compliance escalations within the Asian operations of a multinational life sciences company
  • Represented a multinational life sciences company in connection with inquiries from the World Bank about the company’s operations in Malaysia
  • Represented a Japanese bank faced with unwinding several long-term oil contracts with Iranian suppliers to comply with new OFAC regulations/Iranian sanctions
  • Represented a large U.S. financial institution in a review of its Bank Secrecy Act compliance following the discovery of several questionable and unreported cash/traveler’s check transactions involving Mexican currency exchange businesses
  • Represented a Canadian bank in connection with an adversarial enforcement proceeding with the SEC in which the bank challenged the SEC’s interpretation of several “pay to play” prohibitions within the MSRB rules
View more experience



J.D., Boston University School of Law
  • cum laude
B.A., George Washington University
  • magna cum laude
  • Phi Beta Kappa


Law Clerk, Hon. Joseph P. Nadeau, Supreme Court of New Hampshire, 2000-2001

Professional history

  • Davis Polk since 2017
  • New York office, 2022-present
  • Hong Kong office, 2017-2022
  • Partner, Ropes & Gray (Hong Kong), 2014-2017
  • Assistant U.S. Attorney, U.S. Attorney's Office, Eastern District of New York, 2007-2014
  • Associate, Skadden, Arps, Slate, Meagher & Flom, 2004-2007
  • Associate, McDermott Will & Emery, 2001-2004

Qualifications and admissions

  • Hong Kong
  • State of New York
  • U.S. Court of Appeals, Second Circuit
  • U.S. District Court, E.D. New York
  • U.S. District Court, S.D. New York
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