Paul Tan

He works closely with general counsel and in-house legal teams to establish facts and to understand how internal fraud schemes have operated in practice. He helps clients assess whether issues are isolated or systemic, and to design reviews that are proportionate, defensible, and respectful of China-specific legal, regulatory, and data-compliance requirements. He has extensive experience navigating cross-border data issues in matters involving multiple jurisdictions.

Paul has more than 20 years of experience supporting multinational organizations on fraud, misappropriation, corruption, and misconduct matters. His work includes numerous reviews involving collusion with third parties, deceptive or falsified transactions, and the use of off-book funds to circumvent internal controls.

Paul is highly experienced in conducting information-gathering interviews in the local language in China, ensuring nothing gets “lost in translation” and that interviews are objective and non-adversarial. He is known for helping clients move beyond fact-finding to practical decision-making, particularly in situations where early missteps can lead to unnecessary escalation.

Paul currently leads Ankura’s global investigations and forensic accounting practice in Mainland China. He is a Fellow of the Association of Chartered Certified Accountants (FCCA), and prior to joining Ankura, he was a partner in the forensics services practice of a Big Four firm. He is fluent in both English and Mandarin Chinese.

A selection of Paul’s prior engagements includes:

• Conducted an independent review for the audit committee of a Hong Kong-listed company with operations in China, in relation to misappropriation of RMB 75 million by the company’s finance personnel, potential improper payments, and other issues.
• Conducted a forensic accounting and data analytics review for the audit committee of a Chinese technology company listed in the U.S., in response to short-seller allegations that the company had engaged in substantial fraud to inflate its financial performance, including revenue inflation, subscriber inflation, and expense inflation.
• Worked with external counsel to conduct an internal review into an alleged improper payment and bid-rigging involving collusion between employees of a medical equipment company, several dealers, and a hospital official.
• Conducted an audit of marketing expenses for an international retail company to identify whether certain vendors had fraudulently overcharged, leading to losses for the company, potential off-book slush funds, and inaccurate books and records.
• Assisted a client in conducting an internal review of a sales team’s travel and entertainment expenses in response to a local tax authority’s inquiry into fraudulent tax invoices.
• Conducted an internal review for a global life sciences company in response to allegations that a regional manager had directed team members to falsify meetings and inflate expense claims in order to fund improper payments.
• Conducted a range of compliance assessments and internal reviews for multinational clients in relation to fraud and bribery matters. Provided recommendations for remediation, based on the identification of control deficiencies and root causes of issues.
• Conducted a range of third-party audits of marketing vendors, event organizers, grant recipients, and tier-one and tier-two dealers to evaluate potential fraud and compliance risks.
• Conducted anti-bribery and corruption / Foreign Corrupt Practices Act due diligence of Chinese acquisition targets for multinational clients, working closely with clients’ legal advisors.
• Led a forensic data analytics project to develop a suite of compliance dashboards for proactive monitoring of compliance risk in the life sciences sector. The dashboards helped the client to identify high-risk sales teams, vendors, and consultants for de-risking through training, blocking, or enhanced transactional monitoring.