Gina Yao

Gina has worked with clients across diverse industries such as financial services, healthcare and life sciences, real estate, retail, manufacturing, infrastructure, and insurance. She regularly collaborates with both in-house and external counsel on regulatory and investigative matters.

Examples of her professional experience include:

Forensic Investigation

• Conducted privileged investigations into distributors of a global medical device company in Asia and the Middle East to address concerns over product diversion and sanctions risk. Reviewed sales records and perform targeted sample testing to identify unauthorized sales activities. Interviewed relevant personnel and led open-source research to gain additional insight. Delivered findings in a comprehensive report to aid in-house counsel in evaluating and making informed decisions about distributor relationships.
• Provided investigative support for a U.S.-headquartered medical device company facing allegations of bid rigging and corruption in Mainland China, initiated by a whistleblower report. Collaborated with external legal counsel to investigate compliance and operational irregularities via e-review and document analysis and open-source research. Facts gathered assisted the counsel advising the client its risk exposure to FCPA regulation.
• Conducted forensic accounting analysis of the financial information of an oil & gas storage business based in Mainland China in relation to a shareholder dispute in the High Court of Hong Kong. Identified accounting irregularities and potential fraudulent transactions and provided comprehensive forensic expertise support, including drafting expert witness report and delivering expert support during trials, to counsel.
• Performed analytical review into facilitation payments over a 10-year period in South-east Asia markets for an international consultancy firm with respect to a potential merger & acquisition (M&A) deal. Reviewed the transactions captured from the data analytics, identified any transactions that would potentially violate the UK Bribery Act and categorized the transactions by risk level. Presented the risk assessment and trend analysis of such transactions by country/service line to facilitate management decision and the M&A negotiation.
• Conducted internal investigation on alleged related party transactions and kickbacks for a China-listed real estate company. Performed analysis on cash flows between group companies and a major contractor over a 10-year period. Performed quantification of damages due to alleged misconduct by a major shareholder. Delivered report to support Counsel in application of injunction order in the U.S.
• Performed multiple fraud/financial crime investigations with a focus on FCPA violation for several international pharmaceutical companies. Conducted transaction testing on employee expenses including reviewing supporting documents and researched external information sources, performed data analytics to analyze spending pattern and identify falsified expense, and composed case summary. The work performed assisted the companies in making disciplinary actions against the involved employees and enhancing their internal controls.
• Conducted electronic review for the private banking arm of a global bank to examine business conduct of its private bankers. Led a team of 16 people to perform review on email communications and trading calls between private bankers and their clients. The engagement assisted the bank in identifying business misconduct and in making disciplinary actions against its employees.

Risk & Compliance Review

• Managed a compliance review on a newly acquired business for a Hong Kong-headquartered global design and manufacturing company to evaluate bribery and corruption risks, focusing on high-risk jurisdictions in Asia and the Americas where the acquiree operates. Performed data profiling by analyzing financial records including keyword search to identify transaction anomalies and samples for testing, alongside employee interviews. Assembled a team with local expertise for on-site sample testing and evaluation of ethical awareness. Provided detailed findings highlight compliance risks and areas for internal control improvement.
• Led a comprehensive compliance review of multiple third-party distributors for a global medical device company to assess adherence to contractual obligations and compliance with anti-bribery and corruption (ABC) and sanctions regulations. Devised a structured approach involving analysis of contractual agreements, sales records, and financial transactions, alongside interviews and on-site visits. Leveraged Ankura’s global network of professionals for effective communication in local language and on-site sample testing. Delivered comprehensive findings and practical recommendations to improve business compliance of the distributors, enhance oversight by the client, strengthen the third-party compliance program and mitigate distribution channel risks.
• Carried out internal audit review to assess the implementation and operational effectiveness of the ABC program at portfolio companies of a global alternative asset manager including those in the real estate and infrastructure industry. Based on employee interviews, policy and procedures (“P&P”) review and walkthrough and transaction sample testing, management action plan was proposed to assist the portfolio companies improve its ABC program and mitigate relevant risks.
• Conducted independent operational due diligence review on impact investing fund managers in emerging markets for European institutional investors. Reviewed the adequacy and quality of operational policies and procedures around corporate governance, risk management, and cash management, tested the implementation of internal controls and adherence to the fund documents via sample testing of capital call, disbursement, distribution and fund/manager expenses. Benchmarked the operations with market best practices and proposed recommendations to the fund managers for improvement which are often conditions precedent.