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Gary GAO
Equity Partner / Shanghai
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Tel +86-21-6061-3666
Email gaojun@zhonglun.com
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Practices

Compliance & Investigation, Litigation & Arbitration, Investment/M&A & Corporate Governance
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Industries

Banking & Financial Services, Financial Innovation & Fintech, Media, Sports & Entertainment
Gary GAO
Mr. Gary Gao, admitted to the PRC Bar in 1995, is currently a partner of Zhong Lun Law Firm.
Mr. Gao boasts in-depth understanding of corporate operations in all aspects, sharp business acumen, and considerable experience in corporate compliance. He has assisted many multinationals, institutions, and large domestic enterprises in different industries to deal with various compliance issues.
In addition, Mr. Gao has a wealth of experience in cross-border arbitration, litigation, mediation, and negotiation. He specializes in devising cross-border dispute resolution strategies and possesses expertise in applying cross-jurisdictional law, collecting and screening evidence, and navigating evidentiary burdens. Mr. Gao also acts as an expert witness on Chinese law in foreign litigation or arbitration proceedings, providing legal advice on Chinese substantive law and procedural law for clients and foreign legal teams.
Representative Matters
Compliance & Regulatory
Airbus – Assisted the client in response to the joint investigation conducted by British, French, and US government, which is the first major investigation by the French anti-corruption agency and has been aided by the UK's Serious Fraud Office (SFO) and the US Department of Justice (DOJ) and served the client from the perspective of Chinese law, resulting in the case honored as the Deal of the Year 2020 by China Business Law Journal
CAE – Assisted the client to deal with PRC criminal investigation concerning bribery involved with a major state-owned airline as well as the company's internal compliance investigation, where Mr. Gao proactively communicated with the procuratorate and creatively proposed the inquiry being conducted with the judicial assistance from Hong Kong ICAC, with the endeavor of him and his legal service team culminating in the assistance from Hong Kong ICAC secured and the interview completed smoothly in ICAC
Goldman Sachs – Provided legal compliance service
Softbank - Provided due diligence services for data compliance and personal information protection involved in the business operation of target enterprises for Softbank's transactions and investment projects in China, especially those operating in high-tech domains, including internet applications
Gopher Asset Management, Noah Holdings Limited - Provided comprehensive compliance legal services to Gopher Asset Management, the top private equity fund management business under US-listed Noah Holdings Limited 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"), with this case standing out as the first regulatory supervision case after the promulgation and implementation of Document No. 71, setting a precedent and paving the way for industry-wide compliance
PayPal – Provided data compliance legal support for PayPal's acquisition of HNA Alipay
A large local comprehensive financial service group – Provided legal consultation regarding data privacy and cybersecurity and issued legal opinion
Tsingshan Holding Group – Provided legal compliance service for client's cross-border transaction
China Merchants Securities – Assisted the client in response to a cross-border investigation
Panasonic - Assisted the client to draft and renew a whole set of Asian Pacific anti-bribery/anti-corruption compliance policy
Baowu Group – Provided the client with legal services for overseas compliance system establishment, including drafting the preliminary overseas compliance system plan as well as the compliance system and the daily operation guidance of overseas compliance manual covering the overseas data compliance, overseas executive criminal compliance, overseas trade compliance, overseas antitrust, and anti-unfair competition compliance
Jinjiang Group – Assisted the client to establish a comprehensive compliance system, including improving the compliance management structure, drafting guidelines, sorting out the legal risk database, and modifying existing rules, policies, and regulations of the client
eToro – Provided criminal compliance services for Israel's largest US listed Forex trading platform
A large State-owned rare metal enterprise – Assisted the client in responding to a criminal case before the federal court of the United States and provided legal analysis and risk control strategies under Chinese law, especially from the perspective of China's international criminal judicial assistance
A famous Spanish chemical engineering enterprise – Provided legal service regarding an environmental protection case and assisted the company to communicate with the authority, including the industry park, the local Administration of Work Safety and the local government, in order to mitigate the administrative punishment
A famous American chemical industrial group - Assisted the client in response to the investigation by local fire safety bureau and public security bureau regarding environmental protection and provided legal consulting for the same
A large local integrated financial services group – Provided legal consulting on data privacy and network security and issued legal opinions
Danone – Provided compliance consulting services, including internal compliance investigations, legal risks, data privacy, etc.
eBay - Provided compliance consulting services, including internal compliance investigations, legal risks, data privacy, and more
Dispute Resolution
Represented the largest domestic trust management enterprise, Zhongzhi Enterprise Group, to deal with the cross-border business disputes arising from Chinese capital's investment in overseas on behalf of the client, involving a disputed amount of tens of billions yuan, where Mr. Gao cooperated with international law firms and filed legal proceedings on behalf of clients in China’s mainland, Hong Kong SAR, ICC, and Cayman Islands simultaneously, and where in the PRC legal process, Mr. Gao's team finally achieved victory in PRC legal process for the client and, by seamless corporation with foreign firms, successfully recovered all assets plus significant proceeds
Successfully assisted ICBC Standard Bank to claim compensation from an insurance company through an arbitration conducted in South Africa and also worked as leading counsel in a series of litigation in Shandong for declaratory relief over the ownership of disputed cargos, with 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"
Represented Tasly in a dispute arising out of a license agreement, with a disputed amount of approximately USD 40 million where a new ADR (i.e., expert determination) was applied to resolve the dispute, resulting in the client winning the case
Represented Jiangsu Hengrui Medicine Group to deal with several cross-border litigation cases
Represented GE Healthcare in a lawsuit over invalidation of contract, successfully safeguarding the interests of the client
Participated in the libel case between Ba Wang International (Group) Holding Co., Ltd. and Next Magazine in HK as a PRC law expert witness, heard by Hong Kong SAR
Represented CBRE Global Investors (Asia Pacific) Ltd in the legal proceedings to recover control of the bank account and obtained a freezing order over the bank account and won the case finally, involving CNY 200 million, where the judge hearing this case wrote an article about the significance and underneath legal theory, and the Supreme People’s Court gave an award to the judge which evidence the recognition of the case
Represented eBay (China) to participate in a series of IP infringement litigations in China and established guiding cases on the neutrality of online trading platform
Represented the Taiwan-listed company EZCONN and won litigation concerning international sales of goods
Heard disputes as arbitrator in arbitrations conducted under the HKIAC arbitration rules
Heard many foreign-related disputes as arbitrator in arbitrations conducted under the SHIAC arbitration rules
Heard many disputes as arbitrator in arbitrations conducted under the SHAC arbitration rules
Heard disputes as arbitrators of several domestic arbitration institutions
Honors and Awards
For Individual
Leading Individual in Compliance & Regulatory, The Legal 500 Asia Pacific, since 2020
Recommended in Corporate Investigation/Anti-bribery, Chambers Asia-Pacific, since 2018
Distinguished Practitioner in Regulatory, asialaw Profiles, 2022-2023
The Litigation China: Litigation Star and the Litigation Asia-Pacific: Litigation Star, Benchmark, since 2020
The A-List Elit Lawyer - The Visionaries, China Business Law Journal, 2023
The A-List China's Elite 100 Lawyer, China Business Law Journal, 2019, 2021-2022
Regulatory & Compliance Lawyer of the Year, China Law & Practice, 2017
Client Choice Top 20 Lawyer, ALB, 2016
The Asia's Leading Lawyers for Business of Dispute Resolution, Chambers Asia-Pacific, 2013
For Deal
Deal of the Year, China Business Law Journal, 2020
Memberships & Affiliations
Arbitrator, Singapore International Arbitration Centre (SIAC)
Specialist Mediator, Singapore International Mediation Centre (SIMC)
Arbitrator, Hong Kong International Arbitration Centre (HKIAC)
National Representative of China, The "Addressing Issues of Corruption in International Arbitration" Taskforce of the ICC Commission on Arbitration and ADR
Co-chair, the ESG Committee of WLG (responsible for the Asia Pacific region)
Arbitrator, Shanghai International Arbitration Center (SHIAC)
Expert Member, Finance and Compliance Special Committee of Shanghai Arbitration Commission
Member, Expert Database of the 3rd Party Supervision and Evaluation Mechanism Management Committee for Enterprises Involved in Criminal Cases of Shanghai
Legal Advisory Specialist, Shanghai State-owned Assets Supervision and Administration Commission
LCIA Database of Arbitrators, London Court of International Arbitration
WIPO List of Neutrals (the List of WIPO Arbitrators and Mediators)
Panel of Arbitrators, The Korean Commercial Arbitration Board
Mediator, Geneva International Dispute Institute
Expert (first batch), Shanghai International Commercial Arbitration Expert Database
Distinguished Professor, Lawyer Institute of East China University of Political Science and Law
Council Member, China Academy of Arbitration Law
Member of the Editorial Board, International Bar Association (IBA) Dispute Resolution International
Committee Member, 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)
Publications
As Author
"Dispute Resolution International: Cross-Border Provision of Information under New Chinese Data Protection Legislation"
"Legal Practice of Online Transactions"
"Compiler for the Oman chapter and Kuwait chapter of the 'One Belt One Road' National Legal Environment Report"
"Practical Guidelines for Foreign Anti-commercial Bribery" (bilingual)
"Compliance and Anti-Corruption of Medical Enterprises, Health Industry: Policy, Trend and Legal Innovation"
As Translator
"ICC: Guidelines on the Application of Mediation to Resolve 'One Belt One Road' Disputes"
"ICC: Terms of Reference of the Selection Committee"
Related
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Articles Related
2025 China’s Anti-Unfair Competition Law Revision: Key Takeaways
The 2025 China AUCL revision enhances rules on unfair competition, false commercial promotions, and internet conducts.
2025-07-09 -
Events Related
Zhong Lun Partner Gary Gao Appointed as Deputy Editor of Dispute Resolution International
Recently, Mr. Jun Gao (Gary Gao), partner at Zhong Lun Law Firm, was appointed as Deputy Editor of Dispute Resolution International by the International Bar Association.
2025-03-14 -
Awards Related
Six Lawyers from Zhong Lun Honored on “The A-List 2025-26: Visionaries”
Six lawyers from Zhong Lun earned their places on the list through demonstration of their exceptional capabilities.
2026-01-08
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Bar Admissions/Professional Qualifications
PRC Bar, 1995
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Education
LL.M. in International Commercial Law, University of Hertfordshire, 1999-2000
LL.B. in Economic Law, East China University of Political Science and Law, 1986-1990 -
Professional Experience
Partner, Zhong Lun Law Firm, 2014 to present
Partner, Shanghai Duan & Duan Law Firm, 1997-2014
Partner, All Bright Law Offices (formerly known as Tian He Law Office), 1995-1997 -
Languages
Chinese
English