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Kyle Wombolt

Head of Global Corporate Crime & Investigations practice

Hong Kong

Kyle is the global head of the corporate crime and investigations practice.



Based in Hong Kong, he has more than a decade of experience in Asia, and has led investigations and compliance projects in more than 40 countries. Kyle focuses on multi-jurisdictional regulatory and criminal securities, anti-corruption, fraud and accounting investigations, as well as trade and sanctions issues involving multinational and major regional corporates.

Kyle has extensive experience implementing regulatory and anti-corruption compliance programmes for clients including investment banks, other financial institutions and multinational companies. 

Kyle also regularly advises on regulatory and corruption risks across a wide range of transactions, including initial public offerings (IPOs), mergers and acquisitions, and joint venture relationships. Kyle has significant experience working with government agencies and regulators in Asia, Europe, Russia and the United States.

Kyle has advised:

  • a US medical devices company on an Asia-wide investigation into payments to government officials
  • a global financial institution in connection with investigations by Korean prosecutors and banking regulators
  • a Japanese energy company in connection with potential investments in Papua New Guinea
  • a US financial services institution on an investigation of potential violations of Japanese securities regulations
  • a global financial institution on a large-scale investigation into potential regulatory violations in Korea, China, the Philippines, Singapore and Taiwan
  • a global energy company on a compliance review in connection with a divestment in China


  • Leading Individual: Dispute Resolution, China/Hong Kong - Asia Pacific Legal 500 2014-2015
  • Leading Lawyer:  Financial Services Regulatory, Hong Kong - IFLR 1000 2012-2015
  • Leading Individual: Anti-corruption, China/Hong Kong - Chambers Asia Pacific 2012-2014
  • Leading Individual Financial Services: Contentious Regulatory, China/Hong Kong - Chambers Asia Pacific 2012-2014
  • Corporate Investigations, Band 1 - Chambers Global 2014
  • "Practice head Kyle Wombolt is ‘highly experienced and hardworking’ and ‘well known not just in Asia, but globally’. - Asia Pacific Legal 500 2015
  • "He has exceptional business judgement. Clients 'highlight his strong interpersonal skills, which are very useful in contentious investigation situations.'" - Chambers Asia Pacific 2014
  • Kyle has "strong interpersonal skills" and a "high level of familiarity with regulators and prosecutors across Asia." - Chambers Asia Pacific 2014
  • Wombolt "won plaudits for his high-quality anti-corruption practice… he is very responsive and sensitive to the demands of clients…" - Chambers Asia Pacific 2013
  • "He stands out among other counsel for being very user-friendly. He's got terrific communication skills, he conveys things well and he's reliable." - Chambers Asia Pacific 2013
  • "Peers acknowledge his skills, including a keen FCPA expertise. Clients praise his accurate and practical advice." - Chambers Asia Pacific 2013
  • "Kyle Wombolt leads the way on the investigations side."  - Asia Pacific Legal 500 2013
  • "Wombolt has extensive US experience as well as a cross-border capability, particularly in respect of Indonesia and other South-East Asian jurisdictions." - Chambers Asia Pacific 2012
  • "Very responsive and sensitive to the demands of clients. Respected by his peers" - Chambers Asia Pacific 2012

Editorial board appointment

  • Asia-Pacific member of the Editorial Board of "Commercial Dispute Resolution" magazine, published by Global Legal Group
  • Member of the Editorial Board of "Corporate Crime, Fraud and Investigations Multi-jurisdictional Guide" published by Thomson Reuters
  • Member of the Editorial Board of "Global Investigations Review" published by Legal Business Research
  • Member of the Editorial Board of "Practical Law China" published by Thomson Reuters

Recent speaking engagements

  • "Competition and Anti-Corruption Investigations in the PRC – Prevention is Better than Cure" Herbert Smith Freehills Breakfast Briefing (Hong Kong, 11 December, 2014)
  • "Anti Corruption Report Forum", Herbert Smith Freehills (Melbourne, 23 October, 2014)
  • "Anti-Corruption Report Forum", Herbert Smiht Freehills (Sydney, 21 October 2014)
  • "Anti-Corruption Enforcement in Asia and the Risks Presented by Local Regulators"; Herbert Smith Freehills Seminar (Singapore, 14 October 2014)
  • "Ethics Officers Forum", - panellist , Herbert Smith Freehills (London, 2 October 2014)
  • "Multijurisdictional enforcement actions – Issues to consider when operating in Asia", Herbert Smith Freehills Seminar,  Chair and panellist (Hong Kong, 24 September 2014) 
  • "How non-Chinese regulators can impact organisations doing business in China", - China Risk & Compliance Symposium 2014 (Beijing, 8 July 2014)
  • "FCPA, Bribery Act and Local Anti-Corruption Laws: How Different Regulators Approach Anti-Corruption Enforcement", - the In-House Congress Bangkok 2014 (Bangkok, 25 June 2014)
  • "Status Update on Bribery Risks in Asia Neighbour Countries", - American Conference Institute 7th China Summit on Anti-Corruption  (Shanghai, 18 June 2014) 
  • "Changing lead into gold: the transformative role of legal counsel in Malaysia"; " FCPA, Bribery Act and Local Anti-Corruption Laws: How Different Regulatory Bodies Approach Anti-Corruption Enforcement" - In-House Congress Kuala Lumpur 2014 (Kuala Lumpur, 12 June 2014)
  • "How multinational companies should minimize compliance risks in China" – 6th Anti-Corruption Compliance in China Summit (Beijing, 29-30 May 2014)
  • "Enforcement Issues Today" - PLI 2nd Annual Institute conference on Corporate and Securities Law in Hong Kong (Hong Kong, 23 May 2014)
  • "Corporate Crime and Investigations Conference", Moderator for "International developments: FCPA and local developments - what do companies need to know?" and panel member on  "Employee relations: the latest on whistleblowing, investigations and disciplinary outcomes" -  presented by Herbert Smith Freehills (London, 20 May  2014)
  • "Anti-Corruption: Mergers, Acquisitions and Third Party Diligence" - Twelfth Annual Corporate Accountability Conference (Hong Kong, 14 May 2014)
  • "Anti-corruption enforcement in Asia – Local regulatory risks" - the In-House Congress Jakarta (Jakarta, 23 April 2014)
  • "Regulatory trends and forecasts 2014" - Herbert Smith Freehills Seminar (Hong Kong, 9 April 2014)
  • "FCPA, Bribery Act and Local Anti-Corruption Laws: How different regulatory bodies approach anti-corruption enforcement" – Korea Outbound Symposium (Seoul, 8 April 2014)
  • "Managing dispute resolution and corruption risks in Russia" – Herbert Smith Freehills Breakfast Briefing (Hong Kong, 10 March 2014) 
  • "Anti-Corruption Enforcement in Asia and the Risks Presented by Local Regulators" - Singapore Outbound Symposium (Singapore, 4 March 2014) 
  • "Avoiding the Headlines: Best Practices for Managing Disputes and Corruption Risks."- Annual Dispute Resolution Seminar 2014 (Tokyo, 27 February 2014) 
  • "Managing corruption risk in Asia" - Anti-Corruption Conference (Paris, 6 February 2014) 
  • "Whistleblowing- what it means for businesses in Asia" – Anti-corruption Compliance APAC Summit (Hong Kong, 13 December 2013) 
  • "Fraud and Corruption in the Financial Services Industry:  Anti-bribery and Corruption Legislation and Enforcement Trends; Corruption-Related Fraud in the Financial Sector  " – Thomson Reuters 2nd Annual Indonesia Regulatory Summit (Jakarta, 4-5 July 2013) 
  • "Managing Fraud and Corruption Risks by Aligning your Global Compliance Programs to the Various International Anti-Corruption Laws" - Corruption & Compliance Asia Congress 2013 (Hong Kong, 24-25 June 2013) 
  • "Developing a Culturally-Sensitive and Robust Gift, Travel and Hospitality Policy"- 6th China Summit on Anti-Corruption (Shanghai, 20 June 2013) 
  • "Conducting Internal Investigations: A Primer" - Hong Kong Outbound Risk & Corruption Symposium (Hong Kong, 30 May 2013) 
  • "Anti-Corruption and Sanctions Compliance Systems: Avoiding Exposure from the Conduct of Third Parties" - ACI Seminar (Sydney, 21 May 2013) 
  • "Managing Exposure for Corruption-Related Misconduct when Operating in High-Risk Markets" - Australian Institute of Company Directors Conference (Singapore, 9-10 May 2013) 
  • "How to Conduct Effective Due Diligence on Third Parties to Minimise the Risk of Corruption" - Anti-Corruption Australia (Sydney, 1 May 2013) 
  • "Managing Business Opportunities in Burma" - British High Commission Singapore (Singapore, 25 April 2013) 
  • "International Anti-Corruption Cooperation" - Guest Lecture University of Indonesia (Depok, Indonesia 22 April 2013) 
  • "Enforcement Issues Today" - PLI's First Annual Institute on Corporate & Securities Law in Hong Kong (Hong Kong, 19 April 2013) 
  • "Global Whistleblowing Webinar: The Implications of Dodd-Frank" – HSF Risk Management Webinar (Hong Kong and London, 12 March 2013) 
  • "Global sanctions regimes and their implications for companies operating in Southeast Asia" - Herbert Smith Freehills Breakfast Briefing (Singapore, 7 March 2013) 
  • "Global sanctions regimes and their implications for Hong Kong/Chinese companies" -  Herbert Smith Freehills Breakfast Briefing (Hong Kong, 5 March 2013)   
  • "Launch of the Second Edition of Asia Anti-corruption Report" - Herbert Smith Freehills Seminar (Hong Kong, 28 February 2013) 
  • "Transparency in Public Procurement - The Role of Business in Anti-corruption Programmes" - GOPAC Global Conference of Parliamentarians Against Corruption 2013 (Manila, 1 February 2013) 
  • "Trade and Economic Sanctions Round-Up" - Herbert Smith Freehills Client Academy Breakfast Briefing (London, 11 December 2012) 
  • "A Resource Guide to the U.S. Foreign Corrupt Practices Act:  How does it Impact Anti-corruption Enforcement?" - Herbert Smith Freehills Ethics Officer Roundtable (London, 12 December 2012) 
  • "Step by Step Guidance on Best Practice for Investigations" - Advanced Anti-corruption Compliance Strategies Conference (Beijing, 4-6 December 2012) 
  • "Future of Anti-corruption Enforcement - Insights from the Australian Federal Police, Deloitte and Herbert Smith Freehills" - Herbert Smith Freehills Seminar (Melbourne, 28 November 2012) 
  • "The UK Bribery Act and its Implications for Banks in Hong Kong" - Independent Commission Against Corruption Sharing Session for Corruption Prevention Network for Banks (Hong Kong, 30 October 2012) 
  • "Economic Sanctions and their Impact on the Insurance Industry" - 2012 Anti-Money Laundering Conference and Workshop (Macau, 25 October 2012) 
  • "Practical Considerations for Dealing with Corruption in Hong Kong, China and Beyond" - Hong Kong Corporate Counsel Association Annual Conference (Hong Kong, 11 October 2012) 
  • "Corruption Risks in Hong Kong and the PRC:  Recent Developments and Enforcement Trends" - French Chamber of Commerce Seminar (Hong Kong, 10 October 2012) 
  • Moderator for "Anti-Corruption and Risk Management:  Latest Developments and Issues Impacting the Asian Construction Industry" - In-House Congress Hong Kong 2012 (Hong Kong, 4 October 2012) 
  • "A Culture of Corruption: Dilemmas Faced by Companies Operating in Asia" - Corruption & Compliance South & South East Asia Summit (Singapore, 19 September 2012) 
  • "Global Sanctions Regimes and Their Implications for Japanese Companies" - The Japan Institute for Overseas Investment Seminar (Tokyo, 11 September 2012) 
  • "Anti-Corruption & Compliance - The Indonesian Regulatory Summit" (Jakarta, 5 September 2012) 
  • "Investigations and Compliance in Thailand" - Herbert Smith Freehills Seminar (Bangkok, 4 September 2012) 
  • "Ethics Officers' Roundtable" - Herbert Smith Freehills Seminar (London, 28 June 2012) 
  • "Cross-border Anti-corruption Investigations and Practice: Deferred Prosecution Agreements" Herbert Smith Freehills Client Academy Breakfast Briefing (London, 26 June 2012) 
  • "Compliance Programmes:  The Challenges of Design and Implementation" - MIS Training Institute Fraud and Corruption Summit (Hong Kong, 20 June 2012) 
  • "Navigating Dodd-Frank: A Practitioner's Perspective on the Act's Implications in Asia on the US securities and Anti-corruption Regimes" - Hong Kong Risk & Corruption Conference (Hong Kong, 22 May 2012) 
  • "Corporate Governance" - Southeast Asia In-House Congress (Singapore, 17 May 2012) 
  • "Sanctions and the Korean Petroleum Industry" - Korean Chamber of Commerce and Industry (Seoul, 19 April 2012) 
  • "Cross-border Mergers & Acquisitions for PRC-based Entities:  Identifying and Mitigating Risk" - CIETAC In-house Conference (Chongqing, 12 April 2012) 
  • "Global Anti-corruption Round Table: Trends in Compliance and Anti-corruption Enforcement Initiatives" - Herbert Smith Freehills Conference (Paris, 22 March 2012) 
  • "Foreign Corrupt Practices Act in China for 2012 - Compliance Strategies Given China’s Unique Cultural and Governmental Intricacies" - Strafford Publications Seminar (Hong Kong, 1 March 2012) 
  • "Understanding the Difficulties of Running Investigations in High-Risk Jurisdictions" - Beacon Events Summit (Hong Kong, 14-16 February 2012) 
  • "Sanctions & Trade Restrictions – What Do They Mean for PRC Companies Investing Abroad?" - In-house SOE Seminar (Beijing, 10 February 2012) 
  • "Cross-Border Investigations" - Moderator for Discussion with SFO Director Richard Alderman – British Chamber of Commerce Seminar (Beijing, 9 February 2012) 
  • "Step by Step Guidance to Design or Improve Your Compliance Programme" - Beacon Events Anti-Corruption China Summit (Beijing, 15 November 2011) 
  • "Exploring the Implications of the Dodd Frank Act and the Whistleblower Provisions" - Beacon Events Fourth Annual South and SE Asia Anti-Corruption Summit (Singapore, 15 September 2011) 
  • "Global Forum on Anti-Corruption in Emerging Markets" - American Conference Institute (Washington, D.C., 14-15 June 2011) 
  • "The Foreign Corrupt Practices Act in China" - Strafford Publications Seminar (3 March 2011) 
  • "White Collar Crime Conference:  Enforcement and Prevention, The FCPA and Its Implications for Companies Operating in China and Hong Kong" - Courses and Seminars Training (Hong Kong, 19 November 2010) 
  • "The Foreign Corrupt Practices Act, Enforcement and Compliance" - Director’s College at Stanford University (Palo Alto, 22 June 2010) 
  • "FCPA Compliance in Emerging Markets" - American Conference Institute (Washington, D.C., 8-9 June 2010) 
  • "Russia and C.I.S. Summit on Anti-Corruption" - American Conference Institute (Moscow, 2010) 
  • "Securities and Financial Litigation" - Director’s College at Stanford University (Palo Alto, 2009) 
  • "India Summit on Anti-corruption Compliance and Enforcement" - American Conference Institute (Mumbai, 2009) 
  • "Conducting Business in China Under  the US Foreign Corrupt Practices Act" - Strafford Publications Seminar (2009) 
  • "Foreign Corrupt Practices Act in India: Compliance Strategies for India’s Unique Cultural and Governmental Intricacies" - Strafford Publications Seminar (2008) 
  • "D&O Insurance Coverage in Securities Disputes" - National Association of Corporate Directors (Washington, D.C., 2008) 
  • "Foreign Corrupt Practices Act: Insights into Heightened S.E.C. and D.O.J. Enforcement" - Strafford Publications Seminar (2008) 


  • "The long arm of US law: implications for Hong Kong companies" published in CSj, the journal of the Hong Kong Institute of Chartered Secretaries, December 2014 
  • "The symbiosis of corruption and competition enforcement in China", Global Investigations Review, December 2014
  • "Five tips for managing corruption risks" – China Law and Practice September/October 2014
  • "Asia Anti-corruption Report" - Herbert Smith Freehills Publication August 2014
  • "Corruption in Asia – A Year in Review" – white paper presented at the Second Annual Institute on Corporate & Securities Law in Hong Kong 2014 Practising Law Institute 22-23 May 2014
  • Authored the Hong Kong, Indonesia and Thailand chapters in Pickworth, Jonathan & Williams, Deborah (contributing editors) (2013). Bribery and Corruption 1st edition Global Legal Insights: London
  • "A Tougher Regime: A Review of the Hong Kong Anti-Money Laundering and Counter-Terrorist Financing (Financial Institutions) Ordinance" – InCompliance magazine June 2013
  • "Who Goes There: Risk Management in Myanmar" - Commercial Dispute Resolution News 15 April 2013
  • "Asia Anti-corruption Report - Second Edition" - Herbert Smith Freehills Publication February 2013
  • "BNA Insights:  Impact of US Iranian Sanctions on Chinese Companies" - Bloomberg BNA:  Daily Report for Executives 4 January 2013
  • "Minimising Corruption Risk: Foreign investors in China face the challenge of dealing with corruption in an unfamiliar business culture" - China Law and Practice November/December 2012
  • The Self-Reporting Dilemma - International Financial Law Review 25 September 2012
  • "Corruption and Bribery Civil Litigation Risks" - International Financial Law Review 29 August 2012
  • "The Importance of Risk Assessment Before Investing in Indonesia" - International Financial Law Review 31 July 2012
  • "Asia Anti-corruption Report" - Herbert Smith Freehills Publication July 2012
  • "Chinese Foreign Direct Investment:  Risk and Reward - The Chinese Approach to African Investment Differs from the West" - International Financial Law Review April 2012
  • "Ignore at your Peril:  The US Economic Sanctions Regime and Asian Business" - International Financial Law Review March 2012
  • "The Anti-corruption Campaign in Thailand:  Foreign Companies Beware" - Bloomberg Law Reports 7 March 2012
  • "Guide to Anti-corruption Regulation in Asia" - Herbert Smith Freehills Publication February 2012
  • "Gifts and Entertainment: Compliance with Anti-bribery Regulation in Asia" - Herbert Smith Freehills Publication February 2012
  • "Why Multinationals Must Be Wary of China's Anti-corruption Authorities" - International Financial Law Review 30 January 2012
  • "A Watchdog With A Strong Bite:  The ICAC and Hong Kong Anti-Corruption Laws" - International Financial Law Review December/January 2012
  • "Rooting Out Corruption:  The UK Bribery Act Signals the Start of A New Era of Enforcement for Chinese Organisations" - China Law and Practice July/August 2011
  • "The Chinese Market:  Understanding Characteristics that Affect Corruption Risk - Understanding Anti-Corruption Issues in Asia" - Aspatore Books 2010
  • "The FCPA and Its Impact on Organisations Doing Business in China - Best Practices for International Business Transactions in China" -  Aspatore Books 2010 
  • "Turning a Blind Eye: Misconceptions Over the Reach and Application of the U.S. Foreign Corrupt Practices Act Leave Many India-based Businesses Vulnerable to the Imposition of Hefty Fines" - India Business Law Journal December 2009
  • "Doing Business in India: Compliance With US and Indian Anti-Corruption Laws" - The Recorder 6 October 2008
  • "Beware Foreign Corrupt Practices Act Traps" - New York Law Journal 21 July 2008


Kyle is admitted to practise in Hong Kong, California and New York and is a registered foreign lawyer in England and Wales. He has business-side experience in the investment banking and private equity sectors. Kyle speaks English and Mandarin.