Richard Sharpe

Investigations

• Currently retained as standing risk and compliance counsel for one of the world’s largest, U.S. listed, private equity/private credit funds for all its Asia Pacific-focused investments, which work involves pre-transaction FCPA, AML, and sanctions diligence into target entities, portfolio risk assessments, and investigations into any issues that arise post-closing.
• Acting for one of Asia’s largest real estate groups in an investigation into a scheme of potential kickbacks and facilitation payments involving a key contractor for the client’s data center business in India.
• Advising a leading U.S. private equity sponsor on its exposure to approximately USD 650 million in Indian linked notes, in the context of U.S. DOJ and SEC actions alleging bribery in connection with Indian government solar contracts—structuring engagement with the Indian conglomerate and implementing tailored deal protections and contingency planning.
• Represented a leading global supplier of engineered materials to run an investigation into whistleblower allegations of widespread corruption by the leadership team at the client’s manufacturing facility in the Philippines.
• Conducted a dawn raid on an Indonesian data centre in connection with an investigation into compliance with US Export Controls around GPUs.
• Conducted a significant FCPA and embezzlement investigation and settlement relating to a Philippines energy platform.
• Representing an U.S. LNG company in a developing Indonesian corruption investigation relating to price-fixing with a state-owned energy company, with potential FCPA implications and material exposure to U.S. enforcement.
• Acted for one of Asia's largest real estate groups in an independent investigation into whistleblower allegations of bid rigging, collusive tendering, and bribery across the group's PRC operations, managing cross-border enforcement exposure under PRC criminal law and Singapore anti-corruption legislation, negotiating the structured exit of implicated executives, and delivering a comprehensive compliance remediation roadmap.
• Represented a global manufacturer of construction and heavy equipment in responding to a Philippines criminal complaint against the company’s regional sales director alleging inappropriate conduct directed at a distributor.
• Undertook an investigation (and subsequent contentious restructuring) on behalf of primary bondholders of listed senior secured bonds in a UAE-based energy company, into allegations of political interference in contractual negotiations.
• Advising one of the largest technology companies in the world in relation to allegations of worker mistreatment and human rights violations at an Indian manufacturing facility owned and operated by one of its contractors for its products.
• Lead counsel to a leading global toy manufacturer on a multi-year internal investigation into whistleblower allegations of bribery, fraud, and embezzlement by senior personnel at its wholly owned China subsidiary.
• Representing one of the leading global suppliers of high-performance servers in its engagement with the Singapore Police Force in a criminal matter in which it was identified as a victim of a fraud scheme and assisting the client in safeguarding its sanctions and export controls position.
• Conducted an internal investigation on behalf of the Audit Committee of a UK-based technology start-up (valued at over USD 1 billion) into allegations of criminal wrongdoing made by the ED in India against the company’s co-founders, ultimately resulting in the resignation of the CEO.
• Led comprehensive compliance risk assessments across portfolio companies in India for a leading global infrastructure investment manager (USD 37B+ AUM), coordinating local counsel and forensic advisory firms to deliver findings, severity ratings, and staged remediation roadmaps.
• Designed an enterprise-wide third-party due diligence framework for Asia’s largest diversified real estate group, tailored to its operations in India and other higher-risk markets, integrating compliance controls into commercial workflows.
• Investigated allegations of financial misconduct (including money laundering) within an Indian listed group of companies, specifically involving the family of the Founder and Chairman, in the context of investigations by the Enforcement Directorate and SEBI.
• Conducted a comprehensive compliance risk assessment for a Fortune 500 company’s India operations, including a week-long on-site assessment at one of the client’s largest manufacturing plants in Gujarat, India.
• Acting for one of Asia’s largest real estate groups in an expedited internal investigation into the group’s engagements with a government liaising firm in India, following law enforcement actions and emerging red flags around payments by the firm, as well as conflicts of interest.
• Advised a large private equity client with significant investment exposure into an Indian listed group of companies on allegations of corruption, sanctions breaches, and financial misconduct within the Group.
• Conducting a wide-ranging investigation into FCPA and insider trading allegations in the China real estate business of a NY-listed, public company.
• Represented the HK branch of a PRC bank under investigation by the HKMA/ICAC for anti-corruption offences, including on-site crisis response to ICAC’s dawn raid of the HK premises resulting in the arrest and prosecution of the branch CEO and two employees.
• Conducted an internal investigation of an SFC- and SEC-regulated fund into multi-million USD employee fraud in its HK offices.
• Comprehensive crisis management, internal investigation, strategic communications tactics in response to a criminal prosecution of a regulated asset management company for the (unwitting) illegal importation of prohibited technology from the U.S. into HK.
• Conducted an investigation in Indonesia and the Philippines around the business interests and political connections of a significant conglomerate.
• Conducted an audit committee investigation into fraudulent accounting allegations in a global energy services platform in India and the Middle East, ultimately owned by a New York listed, public company.
• Multiple representations of individuals and senior executives employed by financial institutions and MNCs under investigation by HK’s ICAC.
• Advising a leading alternative credit manager on sanctions and export controls issues associated with multiple proposed transactions involving financing to data center operators and investors.

Richard Sharpe is a partner in King & Spalding's Singapore office and a member of the firm's Special Matters and Government Investigations Group.

Richard assists multinational clients across the Asia-Pacific and Middle East region with a variety of business-related criminal matters and cross-border investigations, including anti-bribery and corruption, anti-money laundering, international sanctions, cyber-crime and fraud.

An England and Wales barrister, and a Hong Kong-qualified solicitor, Richard’s experience includes representing businesses and individuals under investigation by various international regulators, including the U.S. Department of Justice, the U.S. Securities and Exchange Commission, the U.S. Office of Foreign Assets Control, the U.S. Bureau of Industry and Security, the U.K Serious Fraud Office, the Hong Kong Monetary Authority, the Hong Kong Securities and Futures Commission, and the Hong Kong Independent Commission Against Corruption.

In addition, Richard has significant experience of conducting complex civil litigation and arbitrations arising from fraud and other criminal misconduct, as well as obtaining supporting ancillary relief. He also advises global companies on investment-related international risk and the design and implementation of compliance programs.

Richard was a barrister in England and Wales for the first 11 years of practice, focusing on the prosecution and defence of complex business crime and civil asset recovery, before relocating to Hong Kong in 2013. Richard has been recognised in Chambers Global and Asia-Pacific in the category of Corporate Investigations / Anti-Corruption: International since 2020.

In Chambers Asia-Pacific 2024, clients note "Richard is great, super responsive, fully understands commercial dynamics and what clients are looking to achieve", and "Richard is a great communicator, and can distil very complex regulatory matters into manageable and clear advice".

In a Chambers Global interview, clients describe Richard as “a total professional” who “understands the region well.”, and notes that he advises global organisations on a range of compliance mandates including anti-corruption, anti-money laundering and trade controls.

Clients further noted “Richard Sharpe receives praise for his ability to handle complex regulatory investigations and is singled out for his expert knowledge of the UK Bribery Act. Sources note that his experience acting in court as a barrister in the UK enables him to ‘appreciate the nuances of how the prosecutors will think’ and gives him ‘a great edge’. Clients refer to him as a ‘star performer,’ citing his ‘excellent advice’ and ‘strong work product’ as key strengths.” Clients describe him as a good guy who is making an impact” note: “he knows what he is doing.”

Legal 500 Hong Kong: “Richard Sharpe is qualified as a barrister in London and solicitor in Hong Kong, giving him a ‘unique perspective to analyze complex regulatory/white-collar issues