Regulatory Investigations and Enforcement

Jingtian & Gongcheng has an extensive track record in advising and defending the directors and officers of listed companies and financial institutions who are under, or being threatened with, investigations by the Hong Kong Stock Exchange or the Hong Kong Securities & Futures Commission. Our Hong Kong office team engages in discreet and comprehensive investigations, including a thorough review of internal policies and procedures relating to specific events, implementing preventive countermeasures to safeguard against future recurrences, and undertaking remedial action.

Jingtian & Gongcheng also has extensive experience in handling a great variety of other kinds of statutory and/or regulatory investigations and judicial reviews. 


Notable Experience*

  • Assisted a Hong Kong listed company based in Shenzhen in lifting a trading suspension imposed by the SFC under the Securities and Futures (Stock Market Listing) Rules, the first-ever case of its kind.
  • Successfully represented a Hong Kong listed company based in Shenzhen in an enquiry by the SFC Corporate Finance Division under section 179 of the SFO in relation to the fairness of the transactions announced by the listed company.
  • Successfully defended a Hong Kong listed company based in Hangzhou and its board of directors in HKEx's enquiry and subsequent SFC investigation into the accuracy of the contents of the company's announcements under sections 277, 298 (disclosure of false or misleading information) and 384 (Provision of false or misleading information) of the SFO.
  • Acted for a director of a listed company in court proceedings commenced by the SFC under section 214 of the SFO in which the SFC applied for disqualification order and compensation order for alleged corporate mismanagement by the board of directors.
  • Acted for the Chairman of a Hong Kong listed company and his associates in an SFC investigation into suspected market manipulation of his own company's shares.
  • Advised the Chairman of a Hong Kong listed company based in Shanghai regarding potential regulatory liabilities under regulations administered by the HKEx and the SFC.
  • Represented the Hong Kong licensed subsidiary of an international investment management company in an SFC investigation concerning suspected unlicensed activities and successfully resolved the disciplinary action under section 194 of the Securities and Futures Ordinance (SFO).
  • Successfully defended a Hong Kong licensed asset manager in an SFC inspection and subsequent investigation in relation to its internal controls and record keeping issues.
  • Represented various listed developers in the investigations conducted by the Sales of First-hand Residential Properties Authority regarding various potential breaches of the Residential Properties (First-hand Sales) Ordinance in their promotional activities during the sales campaigns.   
  • Represented a leading tobacco multinational corporation to defend a prosecution instituted by the Customs and Excise Department for a breach of the import and export licence condition. 
  •  Represented a leading mobile manufacturer listed in the Mailand to mitigate in relation to a prosecution instituted by the Environmental Protection Department for importing electronic waste to Hong Kong without obtaining a permit.
  • Represented the Broadcasting Authority of the HKSAR in conducting a large-scale statutory investigation concerning cross-media ownership under the Broadcasting Ordinance.
  • Represented a contractor to defend an investigation instituted by the Independent Commission Against Corruption concerning conspiracy to defraud the Buildings Authority.
  • Assisted the Insider Dealing Tribunal in conducting an inquiry regarding a listed company distributing industrial products and equipment.
  • Represented a multinational testing and certification company in conducting an internal investigation concerning (1) a complaint against its surveyors in the PRC for asking for bribe money and (2) a suspected unauthorized leakage of samples entrusted by its clients for testing purposes to the market.
  • Represented a Christian School to answer the Education Bureau’s inquiry concerning its school policy under the Race Discrimination Ordinance, Cap. 602 of the Laws of Hong Kong.  
  • Represented the Commissioner for Television and Entertainment Licensing in a judicial review in which its decision to impose conditions on the grant of a licence to operate an amusement game centre was challenged.   
  • Represented the Commissioner for Inland Revenue in defending a judicial review in which its decision to impose additional profits tax was challenged.
  • Acted as legal adviser to the Inquiry Committee for an inquiry under Section 10 of the Public Service (Administration) Order and the Public Service (Disciplinary) Regulation.
  • Advised a multinational transport company on the statutory and governmental requirements in the acquisition of Hong Kong Tramways and the subsequent operation of tram business in Hong Kong. 


* Includes experience from partners prior to joining Jingtian & Gongcheng.


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