Practice Areas
Vivian Wu is the Partner of FenXun, Beijing office, she leads the Firm's Investigations, Compliance & Ethics team in Beijing. Her practice focuses on China-related corporate regulatory and compliance matters, anti-corruption, data protection, and sanctions in particular. She has more than 15 years of experience in compliance investigations, due diligence, risk assessment, compliance programs and training. In 2020, Vivian was appointed as a member of the Foreign-related Attorney Talent Panel by Beijing Bar Association.
Experience
- Represented a European-headquartered global conglomerate in multiple internal investigations regarding various allegations on inventory stock, reimbursement fraud and trade compliance violation.
- Represented a leading Chinese high-technology firm with global operations in investigating various serious allegations against senior members of the company's internal compliance investigation team based in China, including without limitation to bribery, embezzlement and retaliation.
- Represented a US-listed company in an internal investigation into its Chinese subsidiary concerning the allegations on use of a large-scale third-party agent, improper gifts and hospitalities, expense fraud, bid rigging, and other internal controls issues.
- Represented a US-headquartered medical device company in investigating its managers for conspiring with distributors to pursue personal benefits, altering sales data and cashing out money in the guise of marketing expenses.
- Assisted a global medical technology company listed in the US in handling an investigation against the general manager of its Chinese subsidiary regarding allegations including conflicts of interest, fraud, pulling-in sales and retaliations.
- Assisted a leading US health technology company in investigating former management personnel of its acquired Chinese subsidiary who were involved in alleged fraud, embezzlement and bribery by using slush funds, and advised on the potential legal risk exposure under PRC anti-bribery law and the US FCPA.
- Assisted a US-headquartered multinational medical device manufacturer in conducting a risk assessment regarding personal information protection, particularly the cross-border data transfer-related risks.
- Advised a US-based high-tech company on collecting, processing and using personal information, personal health information, population health information and important healthcare information.
- Advised various US and European companies on managing the challenges associated with conflicts of law in trade compliance, including the requirements and implications of China countermeasures, counterespionage law and other national security related laws and regulations.
- Assisted multiple Chinese companies in preparing compliance guidelines for holistically managing the risks associated with their overseas operations, covering anti-bribery, trade compliance, antitrust, data protection, national security, employment and immigration.