Audrey Koh

Audrey is one of the smartest and most diligent lawyers I have worked with. She does her homework to thoroughly understand a case, no matter the complexity, and remembers the details for several months afterwards (presenting a lot of value to the client).

—Client Choice

Audrey Koh leads the Corporate Investigations & White Collar Defense practice of the London office and has a broad range of experience across energy and natural resources, financial services, and life sciences and pharmaceuticals sectors, advising corporations, senior executives and high-net-worth individuals.

Audrey specializes in cross-border investigations focused on anti-bribery laws, including the Foreign Corrupt Practices Act (FCPA) and UK Bribery Act, sanctions, money laundering and financial fraud that involves multi-jurisdictional regulators and enforcement authorities and parallel civil fraud litigation and asset tracing. Audrey also advises on anti-bribery, anti-corruption (ABC), anti-money laundering, anti-facilitation of tax evasion, sanctions and ESG compliance, due diligence and related training. Additionally, she has experience in both conducting (on behalf of enforcement authorities) and responding to dawn raids, and representing clients in antitrust investigations.

Audrey has worked at leading law firms in London, Singapore, Hong Kong, Moscow, Paris and Geneva. She was also seconded to the UK Serious Fraud Office (SFO) as an investigative lawyer in the Bribery & Corruption Division. Audrey also has in-house experience as the head of legal and compliance, chief compliance officer and money laundering reporting officer of an oil & gas private equity firm.

Representative Experience

Successfully represented one of the key suspects in a multibillion-pound cross-border bribery and money laundering investigation by the SFO of an international oil and gas group, which resulted in a declination of charges.
Successfully represented a senior executive in a multibillion-pound investigation by the UK Insolvency Service (IS) of an international financial services group, which resulted in a declination of charges.
Represented a U.S. private equity-backed portfolio company in a dispute over the potential enforcement of debt facilities, which included successfully obtaining injunctive relief.

Represented two major French banks before six and five U.S. government agencies, respectively, in cross-border OFAC sanctions investigations, one of which resulted in the largest ever sanctions-related settlement.

Represented a senior executive in a multibillion-pound cross-border criminal and civil fraud investigation by the SFO, the UK Financial Conduct Authority, IS and various multinational enforcement authorities of an international financial services group.

Represented several senior executives in a multimillion-pound cross-border bribery and money laundering investigation by the SFO of an international energy services group.

Represented an Asian asset management firm in multiple ICC arbitrations and asset tracing investigations.

Represented an African oil trading firm in its multimillion-dollar claim against a Big Four accounting firm for fraud and negligence.

Represented a high-net-worth individual in a multibillion-dollar cross-border cryptocurrency investigation by the DOJ and FBI.

Represented major life sciences corporations in various FCPA investigations in China, India and Australia on grants, improper payments to doctors and kickbacks from distributors.

Represented a high-net-worth individual in a multibillion-pound asset-tracing investigation which relates to an international banking fraud.

Advised a U.S. medical device company in ABC compliance reviews of its consultancy agreements and conducting ABC compliance training for its C-suite and ultimate beneficial owners.

Professional Highlights

Awards

Named a Future Leader in Investigations by Lexology’s Who’s Who Legal.
Awarded Lexology’s Client Choice Award 2024 for “Business Crime Defence UK.”

Publications
- - "A Closer Look at Recent Trends Reveals Crackdown on Money Laundering in Europe,” The Guide to Anti-Money Laundering – Second Edition, Global Investigations Review, June 2024
  - “SFO Corporate Co-Operation Guidance,” August 2019
  - “Opportunistic Insider Trading Related to a Personal Data Breach,” August 2019
  - “Anti-Money Laundering Update,” Association of Corporate Counsel (ACC) Magazine, May 2021

Press Mentions

Extensive interview by Law360: “Pillsbury’s New UK White Collar Chief Eyes Success In London,” April 4, 2024

Interviewed by The Anti-Corruption Report and quoted in:

- “SFO Guidance Moves Toward Transparency but Offers No Guarantees,” September 2019

- “In New Guidance, SFO Indicates It Wants Companies to Waive Privilege,” October 2019

- “In New Guidance, SFO Outlines Internal Investigation Expectations,” November 2019

- “Dealing with the SFO after its ‘Fundamental Failures,’” September 2022

Interviewed by Legal Business and quoted in:

- “SFO: Staying Alive,” Disputes Yearbook 2022

- “The ESG Report – Russia: All Bite, No Bark,” June 2022

Speaking Engagements
- Lex Mundi Cross Border Investigations: Business Crimes and Global Compliance Group Annual Meeting, September 2019 in Dublin – panelist on “Cross Border Investigations with Various Financial U.S./European Regulators and a Discussion of Privilege”
- Lex Mundi Cross-Border Investigations Practice Group Annual Roundtable & Networking Meeting, October 2020 – panelist on “Impact of Brexit on Internal Investigations, Criminal Justice and Sanctions”
- ACC Compliance and Ethics Network – panelist on Anti-Money Laundering Update, March 2021

Memberships
- Member, Women’s White Collar Defense Association, London Chapter (WWCDA)
- Member, Female Fraud Forum (FFF)
- Member, Financial Services Lawyers Association (FSLA)
- Member, Women In Criminal Law (WICL)

Education

Legal Practice Course, BPP Law School, 2004
Distinction

LL.B., Queen Mary College, University of London, 2003
1st Class Honours; RM Goode Prize (top student for entire graduating cohort of 2003); Drapers’ Company Prizes for two consecutive years 2002 & 2003; Dechert Company Law Prize 2003

Admissions

England and Wales

Languages

Chinese (Mandarin)

Chinese (Cantonese)

Areas of Focus

Practices

Representative Experience

Professional Highlights

Audrey's Insights