التقاضي والتحكيم

ممارسات الصين

Cross-border disputes, enforcement, and investigations involving Chinese parties, assets, and counterparties, drawing on deep regional networks and Hong Kong and CIETAC experience.

Disputes that span the United States and Greater China rarely fit neatly within either legal system. A breach-of-contract claim in New York implicates evidence held in Mandarin on servers in Shenzhen. A Hong Kong arbitration generates an award that requires recognition in U.S. federal court while parallel proceedings continue in mainland courts. A judgment debtor moves assets through Hong Kong holding entities, mainland operating companies, and offshore structures designed to fragment recovery efforts.

Seiden Law’s China Practice is built for matters those cross borders, languages, and legal systems. From U.S. litigation and international arbitration to judgment enforcement, sanctions and export controls, and cross-border IP and securities disputes, the firm’s lawyers serve Chinese enterprises, U.S. companies with China exposure, investors, and high-profile individuals in their most complex matters. The team includes partners with decades of China-related experience and native Mandarin speakers licensed in the U.S. and China, enabling the firm to manage facts, witnesses, and documents without translation friction and to move fast when timing is decisive.

The firm appears regularly in U.S. federal and state courts, in international arbitral forums (including Hong Kong), and in enforcement and recognition proceedings tied to PRC- or Hong Kong-related awards and judgments. The firm also advises on export controls and sanctions, regulatory compliance and investigations, and cross-border employment and HR issues, giving clients one integrated team for disputes and risk.

Why Bilingual, Cross-System Capability Matters

Most U.S. firms manage China-exposed matters by working through translators, foreign counsel, and the documentary intermediation that adds layers of cost, delay, and lost nuance to every step of the work. The firm’s bilingual capability is not a marketing claim; it is a working method that affects how matters are prepared and tried. Chinese-language evidence is reviewed directly by the lawyers managing the substantive work. Mandarin witnesses are interviewed and prepared by counsel who can engage with them without intermediation. Briefs and submissions in cross-border arbitrations are developed with awareness of how the underlying facts read in both languages.

What Sets Seiden Law Apart

  • Trial-ready, bilingual advocacy. The firm pairs courtroom strength with Chinese-language capability across the team, so strategy, briefs, evidence, and witness preparation are aligned in both English and Chinese from day one. This mirrors the bilingual, cross-disciplinary model that leading international China practices use to deliver efficient results in complex matters.
  • End-to-end dispute lifecycle. The firm handles the full arc: front-end investigations, asset intelligence, arbitration or litigation, and award or judgment enforcement; so, clients are not left with a paper win that cannot be collected.
  • Cross-border coordination without silos. The firm’s lawyers are comfortable threading matters through parallel proceedings (PRC litigation plus HKIAC arbitration plus U.S. recognition actions), coordinating with local counsel where needed and providing U.S. law opinions for foreign courts. Major international practices highlight the value of fully integrated cross-border teams; the firm brings that same cohesion with a lean, agile team.

Core Focus Areas

  • Cross-border litigation (U.S.–China). Contract and joint-venture disputes, fiduciary-duty and fraud claims, shareholder and control battles, books-and-records issues, and post-transaction litigation; often on expedited schedules in New York or Delaware.
  • International arbitration. Hong Kong-seated proceedings and other forums, complex evidentiary hearings with Mandarin witnesses, and vacatur/confirmation actions in U.S. courts tied to PRC-related awards.
  • Judgment and award enforcement. Recognition and collection strategy for HKIAC/PRC awards and U.S. judgments, asset-tracing, alter-ego cases, and turnover. Recovery is real, not theoretical.
  • Export controls, sanctions, and investigations. Counseling and defense in matters touching U.S. trade controls (sanctions and export restrictions), internal investigations, and responses to government inquiries.
  • Cross-border IP and brand protection. Copyright, trademarks, unfair competition, and trade-secret claims spanning manufacturers, platforms, and distributors, plus online enforcement.
  • Securities, investment, and regulatory risk. China-linked investment and securities-fraud disputes, disclosure issues, and cross-border compliance programs.
  • Employment and HR (跨境人事). Sensitive separations, restrictive covenants, confidentiality and data issues, and internal controls for cross-border teams.

How We Deliver Outcomes

  • Evidence without translation bottlenecks. Bilingual lawyers review Chinese-language evidence directly, conduct Mandarin interviews, and prepare witnesses for bilingual proceedings. This reduces delay, cost, and risk of nuance loss.
  • Forum strategy that anticipates enforcement. The firm chooses and sequences forums with collection in mind (structuring HKIAC claims alongside U.S. discovery or recognition actions) and aligns interim relief with the asset map.
  • Integrated regulatory defense. In matters touching sanctions, export controls, or data/security rules, the firm tailors the dispute plan to minimize regulatory fallout while preserving litigation leverage.
  • Trial-caliber preparation. Whether it is a merit hearing in Hong Kong or an expedited motion in New York, the firm builds a concise, credible record with the right fact and expert testimony, often across languages and legal systems.

Representative Matters

  • Hanfor Asset Management Group fraud litigation. Representation of Chinese investors in New York state court litigation seeking more than $50 million in connection with the Hanfor Asset Management Group fraud, one of the largest publicly known China-related investment fraud matters of recent years.
  • $130 million Hong Kong arbitration. Representation of a China-based company in HKIAC arbitration involving more than $130 million in claims. The tribunal ruled in favor of the firm’s client on its counterclaim for abetting breaches of fiduciary duty, following a contested evidentiary hearing in which multiple witnesses testified in Mandarin.
  • HKIAC award enforcement in U.S. federal court. Representation of an international estate in Maryland federal court to enforce HKIAC arbitration awards, with parallel litigation continuing in China and Hong Kong. The firm provided expert opinion on U.S. law to a Hong Kong court in one of those proceedings. The matter is on appeal to the U.S. Court of Appeals for the Fourth Circuit.
  • $450 million Chinese arbitration award recognition matter. Representation of the respondent in proceedings in New York federal court seeking recognition of a $450 million Chinese arbitration award.
  • $475 million arbitration award for Chinese insurer. The firm secured a $475 million arbitration award on behalf of a Chinese insurer in international arbitration in Hong Kong arising from a $5 billion cross-border M&A transaction. The matter included an eight-day Hong Kong trial with multiple fact and expert witnesses.
  • Vacatur of international arbitration award. Successfully briefed and argued a petition in New York state court to vacate an international arbitration award against the firm’s client, a financial-services firm based in mainland China. The court vacated the award based on fraud.
  • Hidden-asset identification for Hong Kong investment company. Representation of a leading Hong Kong-based investment company in pursuing and exposing the hidden assets of a notorious Chinese fugitive, including the identification of a New York apartment, a yacht, and aircraft.
  • U.S.-listed China-operations receiverships. Appointed as receiver in multiple matters involving U.S.-listed companies with substantial China and Hong Kong operations, by Delaware Chancery Court, Nevada state and Supreme Courts, and other appointing authorities.
  • Hong Kong and Cayman Islands receivership appointments. Served as appointed receiver in Hong Kong and Cayman Islands proceedings arising from U.S.-listed companies accused of dissipation of corporate assets.
  • Delaware bankruptcy court representations. Defended Chinese manufacturers in Delaware bankruptcy court litigation, including a $15 million claim resolved on favorable terms after motion practice, and a separate matter brought by a liquidating trustee that settled following the firm’s motion to dismiss.

Some matters listed above include experience of the firm’s lawyers prior to joining Seiden Law.

Common questions

Frequently asked questions

Does the firm represent both Chinese and non-Chinese clients?

Yes. The firm regularly represents PRC and Hong Kong businesses and individuals in U.S. proceedings, and U.S. and international clients in China-related arbitrations and enforcement actions. Engagements are accepted based on the substantive issues involved, the firm’s ability to provide effective representation, and the absence of any conflict.

Can U.S. court actions and Hong Kong arbitrations run in parallel?

Yes, and frequently they should. The firm regularly coordinates HKIAC and other Hong Kong-seated arbitrations with U.S. court proceedings on related issues, including U.S. recognition of Hong Kong awards under the New York Convention, vacatur or confirmation petitions, Section 1782 discovery in support of foreign proceedings, and direct U.S. merits litigation arising from U.S.-based conduct.

How does Mandarin-language capability change how matters are handled?

Substantially. The firm reviews Chinese-language evidence directly, conducts Mandarin interviews of witnesses and clients, prepares Mandarin-speaking witnesses for testimony in arbitration and litigation, and engages directly with Chinese-language documentary records throughout the case. The result is faster preparation, lower translation cost, and reduced risk of nuance loss in the development of factual narratives.

Does the firm advise on sanctions, export controls, and data issues affecting China-related matters?

Yes. The firm’s integrated regulatory and white-collar practices handle the regulatory dimensions of China-exposed matters, including U.S. sanctions affecting Chinese counterparties, export controls and the Foreign Direct Product Rule extensions affecting transactions involving Chinese counterparties, technology-transfer issues, and the data and security rules that increasingly affect cross-border operations.

How are recoveries typically structured in China-related enforcement matters?

Recoveries against China-exposed counterparties typically require coordinated enforcement across multiple jurisdictions. Common pathways include U.S. enforcement against assets located in the United States, Hong Kong enforcement under the city’s well-developed commercial-law regime, mainland enforcement where the relevant judgment or award qualifies for recognition under Chinese law, and offshore enforcement against assets held in Cayman Islands, BVI, or other jurisdictions frequently used for China-related corporate structures.