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Audrey Zhi advises companies on regulatory, compliance, and investigation matters (particularly China-related anti-corruption matters). Ms. Zhi also has experience in advising multinational companies on corporate matters and transactions, including mergers and acquisitions, foreign direct investments, outbound investments, and employment. Her work focuses on the life science industry, including pharmaceuticals, medical device, cosmetics, and food.
- Advised a world-leading gene sequencing company on the latest Chinese regulations and policies in a variety of fields, including precision medicine initiatives, non-intrusive prenatal testing, new-born screening, and laboratory development testing.
- Assisted multinational pharmaceutical, healthcare, food and cosmetics companies on Chinese regulatory and compliance matters, such as preparing a white paper on microbiome products, monthly and quarterly reports, conducting regulatory and compliance due diligence, providing advice on genetic testing to detect cancers, companion diagnostics, cross-border e-commerce, used medical device, food contact materials, importation of raw meat product, donations to educational institutions, and preparing electronic alerts.
- Assisted multinational pharmaceutical companies and the U.S. industrial association on strategic advice to initiate a new drug in China market, and providing implications for the American pharmaceutical drug industry due to China industry policy.
- Assisted world-leading multinational companies across various industries (such as pharmaceuticals and medical devices, cosmetics, information technology, beverages, and investment bank) on anti-corruption and FCPA investigations, (including SEC China investigation), including due diligence, reviewing documents, preparing interview outlines, verifying regulatory approvals for previous transactions, and conducting interviews.
- Advised a renowned multinational food processing and retail company on its sale of business.
- Advised a global healthcare products company and manufacturer of medical devices and supplies on its restructuring.
- Advised a global prestigious healthcare products company and manufacturer of medical devices and supplies on its spin-off of the pharmaceutical business.
- Advised the world’s largest food, nutrition, health and wellness company on its acquisition of an existing Sino-foreign joint equity company from a state-owned Chinese party.
- Assisted renowned multinational companies on their intra-group restructuring in multiple jurisdictions.
- Advised one of the first internet payment services providers in Europe on its establishment of the first platform in China.
- Advised on Chinese employment matters, including reviewing and commenting on employment contracts, confidentiality agreements and non-competition agreements, hiring of foreign employees in China, employment termination, and employment benefits arrangements (stock option and other incentive schemes).
- Advised renowned multinational companies on mergers and acquisitions, foreign direct investment, outbound investment, regulatory and compliance matters, employment, general corporate matters, etc. in various industries relating to cosmetics, food and milk-products, medical devices and pharmaceuticals, entertainment, human resources, media, internet, drinking water, automotive manufacture, banking, insurance, wholesale and retail, fire-safety, general business consulting and others.
Pro Bono
- Provided China legal services to the client (an international children's medical charity devoting itself to providing free surgeries for children and young adults suffering cleft lip, or other facial deformities, in more than 60 countries), including conducting legal research on the PRC laws and regulations regarding the operation of, and the compliance requirements applicable to, a foreign non-profit organization.
- In support of the asylum application by the client (an LGBT man) in the United States, conducted research and prepared a memorandum on country conditions in the client’s home country, including, but not limited to, the legal, social cultural, and political environment.
- Pennsylvania Law School, which is in partnership with the Pennsylvania Health Law Project, a 501(c)(3) legal service organization, under the supervision of U.S. attorneys, provided pro bono services to the local Philadelphia communities on health law.
- A key member of Pro Bono Project, in the Shanghai office of a previous international law firm, providing legal advice on investments in China to, and the establishment of a micro-financing company in Inner Mongolia by, international nonprofit institutions.
Memberships and Affiliations
- American Bar Association
- New York State Bar Association
February 4, 2021
By: Aaron Gu On December 30, 2020, the State Administration for Market Regulation (“SAMR”) issued a three-year action plan for improving the quality and safety of dairy products in China (the “Plan”), reflecting China’s commitment to continue strengthening the regulatory and legal standards for dairy products, The Plan sets forth eight quantitative goals for the ...
January 25, 2021
By: Muyun Hu On December 25, 2020, the Institute of Food Science and Technology (“IFST”) issued China’s first plant-based meat standard T/CIFST 001-2020 (the “Standard”). The Standard will take effect on June 25, 2021. The Standard is a group standard issued by a government sponsored industry association and adopted by its members.[1] Group standards can ...
October 27, 2020, Covington Alert
On October 21, 2020, China’s National People’s Congress (“NPC”) published revised draft amendments (“Draft Amendments”) to China’s Criminal Law. The legislature will be soliciting public comment until November 19, 2020, and will then review and enact the amendments. Based on previous amendments, we do not expect the final version as enacted to differ ...
May 2020, Covington Alert
On April 13, 2020, China’s National Healthcare Security Administration (“NHSA”) released a draft opinion titled “Guiding Opinions on Establishment of a Drug Pricing and Procurement Creditworthiness System (the “Draft Opinion”; Covington’s translation is available here) setting forth proposed requirements for a creditworthiness evaluation and disciplinary system ...
March 4, 2020, Covington Alert
The following alert is a summary of the district court’s acquittal of UK citizen Lawrence Hoskins, a former senior vice president at the French power and transportation company Alstom S.A. (“Alstom”), on FCPA bribery and conspiracy charges. Alstom pleaded guilty in 2014 to two counts of violating the FCPA in connection with a worldwide bribery scheme that ...
December 12, 2019, Covington Alert
On November 8, 2019, a federal jury convicted Lawrence Hoskins, the former senior vice president of Alstom, of violating the Foreign Corrupt Practices Act (“FCPA”) for his role in a multi-million dollar bribery and money laundering scheme in Indonesia.
October 11, 2019, Covington Alert
On September 27, 2019, the Securities and Exchange Commission (“SEC”) announced a $4.1 million settlement with Westport Fuel Systems, Inc. (“Westport”) and its former chief executive officer, Nancy Gougarty. Based in Vancouver, Canada, Westport is a clean fuel technology company that has shares listed on the NASDAQ. The SEC’s cease-and-desist order finds that ...
February 3, 2019, Covington Alert
On January 29, 2019, Transparency International (“TI”) released its 2018 Corruption Perceptions Index (“CPI”), which ranks countries and territories by their perceived levels of public-sector corruption. The latest CPI figures show that, despite continuous domestics anti-corruption enforcement, China went down in both score and ranking, with a score of 39 out ...
November 14, 2018, Covington Alert
China recently amended its Criminal Procedure Law (CPL) to codify rules encouraging cooperation in government investigations, align with the new national supervision system, and introduce trials in absentia for certain crimes, including bribery and corruption.
November 8, 2018, Covington Alert
Last week, the U.S. Department of Justice announced a new “China Initiative.” According to the press release, the Initiative “reflects the Department’s strategic priority of countering Chinese national security threats and reinforces the President’s overall national security strategy.”
April 26, 2018, Covington Alert
On April 23, 2018, Dun & Bradstreet Corporation (“D&B”), a professional services company providing credit reporting information and other commercial data to businesses, agreed to pay more than $9 million in connection with a cease and desist order with the U.S. Securities and Exchange Commission (“SEC”) to settle allegations that it violated the books and ...
China: Government Reorganization and Trade War Suggest More Anti-Corruption Enforcement in China
March 29, 2018, Covington Alert
China’s biggest government reorganization in a generation, coinciding with rapidly escalating U.S.-China trade tensions, will impact many aspects of doing business in China, including an uptick in anti-corruption enforcement.
February 28, 2018, Covington Alert
On February 21, 2018, Transparency International (“TI”) released its 2017 Corruption Perceptions Index (“CPI”), which ranks countries and territories by their perceived levels of public-sector corruption. The latest CPI figures show that China slightly improved in both score and ranking, with a score of 41 out of 100 (where 0 represents most corrupt and 100 ...
- Fudan University Law School, admitted as ranking top 3% among all the applicants nationwide
- Shanghai University School of International Business and Management, with Honors and with Distinction, Full Scholarship