Distinguished Practitioner




Practice area:


Mr. Gary GAO is the Partner and the Head of Compliance & Regulatory Department of Zhong Lun Law Firm. Before admitted by PRC Bar in 1995, Mr. Gao had worked as a criminal judge in a district court in Shanghai since 1990. Mr. Gao has practiced law for 27 years, which makes him an experienced lawyer in both compliance & regulatory as well as international dispute resolution.

Mr. Gao has been consecutively recommended as the Leading Individual in Compliance & Regulatory by The Legal 500 Asia Pacific 2021 and The Legal 500 Asia Pacific 2020 and in Corporate Investigation/Anti-bribery by Chambers Asia-Pacific 2022, Chambers Asia-Pacific 2021, Chambers Asia-Pacific 2020, Chambers Asia-Pacific 2019 and Chambers Asia-Pacific 2018. Besides, Mr. Gary GAO was honored as the 2022 Distinguished Practitioner in Regulatory by Asialaw Profiles, the “Litigation China 2022 Litigation Star” by Benchmark, the “Litigation Asia-Pacific 2021 Litigation Star” by Benchmark, the “Litigation China 2021 Litigation Star” by Benchmark, the “Litigation Asia-Pacific 2020 Lawyer” by Benchmark, “the Deal of the Year 2020” by China Business Law Journal, “2020 Band 1 Lawyer of Compliance & Government Affairs”, “2019 Band 1 Lawyer of Compliance” and “2019 China Top 10 Lawyers – Government Affairs” by LegalBand, “The A-List China’s Elit 100 Lawyer 2019” by CHINA BUSINESS LAW JOURNAL, the 2017 “Regulatory & Compliance Lawyer of the Year” by China Law & Practice, the 2016 “Client Choice Top 20 Lawyer” by ALB and the “Asia’s Leading Lawyers for Business of Dispute Resolution” recommended by Chambers Asia-Pacific 2013.

More than 27 years of work experience in compliance & regulatory and international dispute solution makes Mr. Gary GAO has full understanding of the whole operation of the enterprises, and, he is very familiar with the international business skills and traps in the negotiations and accumulate rich experience for the compliance of companies. Mr. Gary GAO has assisted many multinational enterprises, institutions and large domestic enterprises in different industries to deal with compliance issues, including dealing with cross-border investigations, joint investigations by multinational governments, criminal investigations by overseas law enforcement agencies, building a comprehensive compliance system, cyber security and data compliance services, state secrets review, judicial assistance and witness preparation for cross-border investigation, strategy for crisis issues and firewall program design and implementation at home and abroad, provide clients with criminal defense, conduct internal compliance investigations on management, initiate criminal procedures and deal with employee dismissals, and provide compliance training services to management, employees and business partners.

Gopher Asset Management & Noah Holdings Limited - To provide comprehensive compliance legal services for Gopher Asset Management, the top private equity funds management, under Noah Holdings Limited which is listed in the US to deal with the regulatory supervision by the China Securities Regulatory Commission after the promulgation and implementation of the Regulations on Strengthening the Supervision of Private Investment Funds (“Document No. 71”). This case is the 1st regulatory supervision case after the promulgation and implementation of Document No. 71, which is specific benchmarking and pioneering in the industry.

Airbus S.A.S. - Gary was engaged as a PRC counsel to assist the client to handle a multi-jurisdictional anti-corruption investigation from the French Parquet National Financier (“PNF”), the U.S. Department of Justice (“DOJ”) and the UK Serious Fraud Office (“SFO”). This case is also the biggest case PNF has worked on in history and the highest fine amount in cross-border anti-corruption sanctions. Gary utilised his extensive experience in government enforcement compliance matters, performed multi-level and multi-faceted legal defence techniques (attorney-client privilege, etc.), and delicately grasped the deep understandings on domestic political sensitivities and of international compliance policies. In this case, Gary also demonstrated his oriental wisdom to closely team up with international well-known offshore law firms and professional lawyers, and to bridge up the civil law and common law mindsets.

SoftBank Group Corporation - The client conducts different M&A projects in PRC, which the total investment amount accumulated is continuously increasing. Gary and his team worked together with the newly promulgated laws and regulations regarding the cyber security, data protection and personal individual information protection and etc. to provide cyber security legal due diligence review in the client’s different pre-M&A proceedings. Till the end of 2021, Gary totally assisted the client to complete the compliance review for 12 projects.

  • ZEG (the largest domestic trust management enterprise) – deal with the cross-border business disputes arising from Chinese capital’s investment in overseas on behalf of the client. The subject matter of dispute reaching tens of billions yuan. In the case, Mr. Gary GAO cooperated with international law firms and filed legal proceedings on behalf of clients in PRC, Hong Kong, ICC and Cayman Islands simultaneously. In the PRC legal process, Mr. Gary GAO’s team finally won the victory in PRC legal process for the client, and by seamless corporation with foreign firms successfully recovered all assets plus significant proceeds.
  • ICBC Standard Bank – Mr. Gao has successfully assisted the client to claim compensation from insurance company through an arbitration conducted in South Africa; Mr. Gao has also worked as leading counsel in a series of litigation in Shandong for declaratory relief over the ownership of disputed cargos worth USD 180 million, ICBC Standard Bank being the only international bank to have recovered the ownership of the cargos via the litigation process in the 2014 “Qingdao Port Fraud”.

  • Competition/antitrust
  • Corporate and M&A
  • Dispute resolution
  • Regulatory
  • Restructuring and insolvency

  • Aviation and shipping
  • Industrials and manufacturing
  • Oil and gas
  • Pharmaceuticals and life sciences
  • Technology and telecommunications

  • PRC Bar Admission

  • Member of the “Addressing Issues of Corruption in International Arbitration” Task Force of the ICC Commission on Arbitration and ADR
  • Council Member of China Academy of Arbitration Law
  • Anti-Corruption Committee of International Bar Association (IBA), Committee Member
  • Arbitration Committee of International Bar Association (IBA), Committee Member
  • Business Crime Committee of International Bar Association (IBA), Committee Member
  • Litigation Committee of International Bar Association (IBA), Committee Member

  • LLM from the University of Hertfordshire in the UK (1999-2000)
  • LLB from the East China Institute of Political Science and Law (1986 - 1990) (Currently: East China University of Political Science and Law)