Vivian Wu

Vivian Wu

Partner
FenXun Partners
Beijing

Biography

Vivian Wu 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 10 years of experience in compliance investigations, due diligence, risk assessment and training, and has provided legal services to many multinational and domestic companies across various industries and sectors. In 2020, Ms. Wu was appointed as member of Panel for Overseas Issues by Beijing Municipal Bureau of Justice.

Representative Legal Matters

  • Assisted a leading global retailer in conducting gap analysis against the PRC Personal Information Protection Law and implementing the compliance safeguards through updating the policies and contract templates.
  • Assisted a leading global fashion retailer on data protection and privacy risk assessment, prepared internal and external policies and templates, advised on cross-border data transfer and extra-territory application issues.
  • Advised a US based high-tech company on the collection, processing and cross-border transfer of personal information, personal health information, population health information and important healthcare information.
  • Advised a European based healthcare company on the local data residency requirement and the data migration issue in relation to a regional restructuring plan.
  • Represented a US listed company in conducting an internal investigation of its affiliated company in China with respect to large-scale use of third-party agents, improper gifts and hospitalities, expense fraud, bid rigging and internal controls related issues.
  • Assisted a leading US health technology company in investigating the former executive of its acquired Chinese subsidiary who was involved in potential fraud, embezzlement and bribery by using slush funds generated from the Chinese subsidiary, as well as advising the client on its potential risk exposure under PRC law and US FCPA.
  • Assisted a leading US public relations firm in its internal investigation of improper payments conflicts of interest issues from both PRC anti-bribery law and FCPA perspectives.
  • Assisted a US-listed company in handling an investigation launched by Chinese supervisory authorities in Beijing against its senior management personnel on alleged embezzlement and potential bribery issues involving multiple government agencies and research institutions; conducted risk assessment on the company's compliance risk exposure and advised on the auditor reporting.
  • Assisted multiple Chinese companies in preparing their overseas compliance risk management guidelines in a wide range of subject matters including anti-bribery, sanctions and export control, anti-money laundering and data protection, and advised Chinese clients on extra-territory application of foreign laws such as US FCPA, US sanctions and export control.
     

Professional Honors

Leading Individuals: Corporate Investigations/Anti-corruption (PRC Firms) - Chambers Greater China, 2024, 2023, 2022

The A-List Growth Drivers - China Business Law Journal, 2023

Leading Individuals: White-Collar Crime (PRC Firms) - IFLR Asia Pacific Awards, 2022

Leading Individuals: Regulatory/compliance (Foreign Firms) - The Legal 500 Asia Pacific, 2019, 2018

Admission

PRC (2007)

New York (2007)

Education

Renmin University of China (LL.B.)(1998)

Renmin University of China (LL.M.)(2002)

Université Paris 1 - Panthéon Sorbonne (Postmaster Degree)(2002)

Harvard Law School (LL.M.)(2006)

Languages

English

Mandarin