B. Chen Zhu
  1. Counsel - Registered Foreign Lawyer

Mr. Zhu is counsel in Davis Polk's Litigation Department, currently practicing as a Registered Foreign Lawyer in Hong Kong. He relocated from the firm’s New York office to Hong Kong in 2013. He represents multinational corporations, financial institutions and individuals in cross-border regulatory enforcement and internal investigations relating to the Foreign Corrupt Practices Act, U.S. economic sanctions, anti-money laundering, market manipulation, securities fraud and related governance and compliance advice. 

Mr. Zhu has extensive experience in compliance due diligence for M&A and IPO transactions. He also has experience in U.S.-based civil litigation involving Asia-based defendants. He has represented clients in banking, healthcare, technology, entertainment, insurance and hospitality, with a particular focus in China, Japan and Southeast Asia. Mr. Zhu also frequently advises on risks associated with state secrecy, data privacy and cross-border data export issues.


Work Highlights

Economic Sanctions and Anti-Money Laundering

  • Representing a major Asian state-owned enterprise in a multi-year investigation by U.S. regulators into alleged sanctions and anti-money laundering issues

  • Conducting a comprehensive review of a major state-owned enterprise’s group-wide anti-money laundering, counter-terrorist financing, and sanctions compliance policies and procedures

Anti-Corruption Investigations and Compliance

  • Advising a multinational pharmaceutical company on multi-year investigations by U.S. and Chinese authorities into FCPA issues in the company’s China operations

  • Conducting an investigation of anti-corruption and internal controls issues for a global investment bank’s Asia operations and coordinating responses to multiple regulators in the United States, Europe and Asia

  • Conducting complex internal investigations for leading financial and professional services firms arising from internal controls issues and whistleblower allegations

  • Advising a major entertainment and media company on inquiries by the Securities Exchange Commission into potential books and records and anti-bribery issues

  • Advising a leading U.S. technology company on controls enhancements for procurement transactions and distributor relationships in high risk markets

  • Conducting multiple FCPA internal investigations for a major food & beverage company’s Southeast Asia operations and advising on controls enhancements and employee discipline

  • Representing institutions investigated by U.S. authorities in respect of their hiring practices in Asia

  • Developing anti-corruption policies and procedures for a company in the Telecommunications, Media and Technology sector in Vietnam

Market Misconduct and Other Criminal Matters

  • Representing a trader in investigations by the Department of Justice and the Commodities and Futures Trading Commission into a major investment bank’s alleged spoofing and other manipulative practices

  • Defending an individual foreign national in a criminal prosecution in U.S. District Court

  • Advising various U.S.-listed companies based in the United States, Japan and China in civil suits, including securities litigation, bankruptcy and breach of contract claims

Compliance Advisory Matters

  • Conducting anti-corruption, sanctions, and anti-money laundering due diligence for IPO and M&A transactions in various industries, including real estate, oil and gas, finance, logistics and pharmaceuticals

Civil Litigation

  • Advising various U.S.-listed companies based in the United States, Japan and China in civil suits, including securities litigation, bankruptcy and breach of contract claims

Of Note

  • Mr. Zhu was recognized as a Future Leader in Corporate Investigations by Who’s Who Legal and Global Investigations Review 2019

Mr. Zhu regularly speaks at legal seminars and conferences. Recent presentations include:

  • IAS Hong Kong: International Sanctions Compliance: Case Studies and Best Practices (April 2018)

  • In-House Community’s In-House Congress Beijing: Recent U.S. Sanctions Developments: What Banks and Corporates Operating in China Should Know (March 2018)

  • In-House Community’s In-House Congress Hong Kong: Sanctions Administered by the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) (October 2017)

  • ALB’s Anti-Corruption Forum: Third-Party Risk Mitigation Through Enhanced Due Diligence (March 2017)
  • Davis Polk/PwC Joint Breakfast Seminar: Managing Sanctions Risk For Financial Institutions (February 2017)
  • In-House Community’s Regional In-House Congress: Hong Kong and U.S. Regulatory and Enforcement Update (October 2016)
  • ACI’s Anti-Corruption China Forum: How to Resolve Complex Issues on Privilege, State Secrets and Data Privacy for Cross-Border Investigations (June 2016)
  • Davis Polk Client Seminar: Privilege and Employment-Related Issues in Investigations (May 2016)

Professional History

  • Davis Polk since 2011
  • Paul Hastings, 2007-2010

Bar Admissions

  • State of New York
  • U.S. District Court, E.D. New York
  • U.S. District Court, S.D. New York
  • Hong Kong Law Society - Registered


  • B.A., Foreign Affairs, University of Virginia, 2003
    • Echols Scholar
  • J.D., University of Pennsylvania Law School, 2007
    • Senior Editor, University of Pennsylvania Journal of International Law


  • Mandarin