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Patrick S. Sinclair


Extensive experience in Asia-based corporate investigations. Leads internal investigations for corporations and boards. Former U.S. federal prosecutor.

Patrick has over two decades of experience representing corporations, audit committees, banks, individuals and governments in corporate criminal investigations. He has conducted over 100 internal corporate investigations in Asia, and he represents individuals in inquiries from U.S. Attorneys’ Offices, the SEC, CFTC and other U.S. regulators.

Widely recognized as a leading litigator in Asia, Patrick has extensive experience working in China, Thailand, Vietnam, Singapore, Malaysia and Korea. He has forged relationships with local counsel and professionals and brings valuable insight to the cultural and legal challenges that face companies in Asia.

Formerly, as a federal prosecutor in New York, Patrick supervised, investigated and prosecuted a number of high-stakes business fraud investigations and other criminal matters. He received the U.S. Attorney’s Excellence in Criminal Litigation Award, as well as 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
  • 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
  • The former China CFO of a global life sciences company in inquiries from the U.S. SEC and DOJ
  • The Investor Relations Officer of a Chinese-based/U.S.-listed retail company in connection with insider trading allegations
  • Conduct internal investigations responding to whistleblower allegations and/or compliance escalations in various jurisdictions in Southeast Asia for a Fortune 100 pharma/life sciences company
  • 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 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, leading over 20 internal investigations in China and Thailand
  • Represented a multinational life sciences company in connection with inquiries from the World Bank about the company’s operations in Malaysia
  • Led an investigation for the audit committee of a Chinese-based/U.S.-traded retailer into a short-seller’s allegations of financial fraud and fictitious sales
  • Advised an acquisition deal team on potential exposure related to the target company’s disclosure of export control compliance failings and violations
  • 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 all experience




Chambers Global and Greater China Region – Corporate Investigations/Anti-Corruption (International Firms), China

Legal 500 Asia Pacific – Regulatory: Anti-Corruption and Compliance

Benchmark Litigation – Hong Kong, Litigation Star

J.D., Boston University School of Law
  • cum laude
B.A., George Washington University
  • Phi Beta Kappa
  • magna cum laude
Law Clerk, Hon. Joseph P. Nadeau, Supreme Court of New Hampshire, 2000-2001
Professional history
  • Partner, Davis Polk, 2017-present
  • Partner, Ropes & Gray, 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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