Samuel Pong

Drawing on a unique blend of experience in law enforcement and forensic consulting, Samuel is an expert in combating corporate misconduct and a trusted advisor to companies and legal counsel in complex regulatory investigations. He has assisted multinational organizations and legal counsel with contentious issues, including alleged corporate fraud, directors’ misconduct, accounting irregularities, public disclosure issues, initial public offering (IPO) fraud, and conspiracy schemes. Samuel is adept at leading complex regulatory investigations through their entire lifecycle, from initial planning and execution to the preparation of civil and criminal proceedings, and has collaborated extensively with multiple law enforcement agencies in Hong Kong, mainland China, and around the globe.

Samuel has also been involved in the “biggest investigation of market malfeasance” in Hong Kong’s history, in relation to the complex financial affairs of one of the largest independent financial advisors listed on a major Asian stock exchange, including acquisition and disposal of assets, financing arrangements, money lending activities, and securities investments.

Prior to Ankura, Samuel served as a law enforcement officer at the Securities and Futures Commission (SFC) of Hong Kong and as a director at a global business advisory firm. He also worked for an international law firm and a Big Four accounting firm, both based in Hong Kong.

A selection of Samuel’s engagements includes:

Investigations

• Planned and executed a landmark joint operation involving various regulators in Hong Kong and mainland China, focusing on allegedly falsified corporate transactions across multiple Hong Kong-listed companies.
• Assisted in wide-ranging regulatory investigations with a particular focus on the suspicious IPO activities of certain Hong Kong-listed companies. The work included performing extensive document and email review, fund tracing, and financial analysis, as well as assisting in the preparation of regulatory interviews and evidence matrices for further assessment of merits.
• Served as project manager for a global investment management firm to design and lead multiple investigative workstreams across offices in Hong Kong, India, and the United Kingdom. This engagement involved conducting a thorough document and email review relating to complex financial transactions and investments associated with a multinational travel company facing significant law enforcement investigations.
• Engaged by a buyer’s insurers to conduct a forensic review investigating alleged off-book loans of a German-listed Chinese sanitary manufacturer prior to its acquisition.
• Investigated allegations of embezzlement by the management of a Chinese construction company utilizing deceptive means, including suspicious consultancy fees and loan interest payments to related parties.
• Performed complex fund tracing analysis into the overstated profits of a recycling company facing delisting in Hong Kong.

Accounting Expert Work and Litigation Support

• Advised external counsel in a high-profile professional negligence lawsuit against the former auditor of Singapore’s largest environmental services company. Provided critical analysis to support the civil claim by evaluating the appropriateness of accounting treatments applied to complex service concession arrangements.
• Assisted an independent forensic expert in opining on the nature and appropriate accounting treatment of a People’s Republic of China state-owned enterprise’s capital injection into Australian mining assets. This involved meticulously reconstructing and analyzing available accounting records to identify key documentation explaining the financial transaction.
• Retained by the legal counsel of a minority shareholder of a Hong Kong-based licensed bank to conduct targeted document reviews to ascertain facts surrounding alleged management misconduct. The team identified the transfer of the bank’s key assets to a majority shareholder at an undervalue and breaches of a shareholders’ agreement, directly assisting counsel in preparing statements of claim and requesting additional documentation.
• Provided litigation support and forensic investigation services to address allegations of non-arm’s length transactions between a Hong Kong-based airline and its related parties.

Compliance and Internal Control Reviews

• Reviewed the existing compliance policies of an independent financial advisor listed on a major Asian stock exchange to identify potential deficiencies in its internal control practices and advised the client on necessary remediation. The work included targeted interviews with employees to understand business processes, walkthrough testing, and summarizing findings in a formal report.
• Engaged by a global sports association to perform on-site document reviews to identify potential irregularities regarding fund usage by its Guam-based affiliated association.
• Reviewed the anti-money laundering policies and procedures of a Hong Kong-listed casino in Macau, performing sample testing on fund movements and suspicious transaction reports.
• Performed a compliance assessment for the Hong Kong branch of a multinational financial institution to ensure adherence to SFC Client Money Rules. This involved identifying deficiencies in daily handling practices through employee interviews and internal control testing.