On September 30, 2018, China’s Ministry of Public Security (“MPS”) released the Regulation on the Internet Security Supervision and Inspection by Public Security Organs (the “Regulation”;《公安机关互联网安全监督检查规定》), which will take effect on November 1, 2018.
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Huanhuan Zhang
Huanhuan Zhang represents clients in China and across Asia on internal investigations and compliance matters involving anti-corruption (including the Foreign Corrupt Practices Act / FCPA) and export controls and trade compliance under both China’s regime and U.S. laws.
Huanhuan has extensive experience managing highly sensitive anti-corruption / FCPA, conflicts of interest, and corporate fraud investigations in China and other Asian jurisdictions. His work also includes conducting risk assessments for multinational companies operating in China, evaluating internal controls, strengthening corporate compliance programs, and developing and delivering tailored compliance trainings. He also advises on anti-corruption due diligence in mergers and acquisitions, and has led hundreds of witness interviews and reviewed thousands of employee expenses in connection with internal investigations.
Huanhuan also assists multinational companies in understanding China’s evolving export control and trade compliance regimes and on U.S. export controls with a China nexus. He regularly tracks and analyzes legislative and policy developments in China related to export controls and economic sanctions, conducts counterparty and end-user due diligence—including Military End User (MEU) assessments—and provides legal and strategic support on export control compliance for multinational companies with China-based operations or China-facing supply chains. He also works closely with U.S. counsel and conducts internal investigations into potential violations of U.S. export controls and sanctions involving China (e.g., EAR violations), coordinates and leads witness interviews, and supports voluntary disclosures to regulators when warranted.
Huanhuan is an active member of the Association of Certified Fraud Examiners and a Certified Fraud Examiner. He speaks Mandarin and Cantonese.