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 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, Journal of International Law


  • Mandarin