Global Accountants' Liability Update - October 2021
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Global Accountants’ Liability Update October 2021
Contents The Netherlands
Recent Court Decisions
The evaporation of deductible losses: Accountant’s professional error,
but client also to blame
United States
Recent Court Decisions
Deloitte settles data breach class action for $4.95 million
Recent Regulatory and Enforcement Decision
PCAOB adopts PCAOB sanctions PCAOB sanctions
framework to Deloitte Canada for KPMG Australia for
determine whether it quality control failures quality control failures
is unable to inspect related to testing
foreign auditors
Our global team of securities and professional liability lawyers
at Hogan Lovells is uniquely positioned to monitor legal Hong Kong
developments across the globe that impact accountants’ Recent Regulatory and Enforcement Decisions
liability risk. We have experienced lawyers on five continents FRC completes investigation on material misstatement by an auditor
ready to meet the complex needs of today’s largest accounting of a listed entity
firms as they navigate the extensive rules, regulations, and case
law that shape their profession. We recently identified
developments of interest in The Netherlands, the United Italy
States, Hong Kong, Italy, and Spain which are summarized in Recent Regulatory and Enforcement Decisions
New voluntary procedure for Procedure for the adoption
the pages that follow. companies under financial of administrative sanctions
distress and postponement of by the Ministry of Economy
the entry into force of the new and Finance
bankruptcy law
Spain
Recent Regulatory and Enforcement Decisions
New regulation increases auditors’ obligation to guarantee
liability judgments
George A. Salter Dennis H. Tracey, III
Partner, New York Partner, New York
T +1 212 918 3521 T +1 212 918 9524
george.salter@hoganlovells.com dennis.tracey@hoganlovells.com
Our Global Accountants’ Liability Team
The Netherlands
Recent Court Decisions
The evaporation of deductible losses: Accountant’s professional error,
but client also to blame
Introduction and facts the opinion that the remaining deductible
losses from 2009 had already evaporated
A company that specialized in the design
as of 1 January 2016. The Accountants
and production of optical instruments
unsuccessfully objected to this assessment.
(hereafter: the Company) hired an
accounting firm and a tax consultancy
The claim and decision of the court
firm (hereinafter: the Accountants) to
prepare its annual accounts between 2010 The Company claimed the Accountants are
and 2016 and tax returns between 2010 (jointly and severally) liable for the damage
and 2017. In doing so, the Accountants suffered by the Company. According to the
advised the Company to exercise the right Company, the Accountants failed to comply
of option to set-off losses (keuzerecht with their obligations arising from the
The Netherlands verliesverrekening) (hereinafter: the agreement entered into with the Company,
Right of Option). or they breached their duty of care towards
the Company.
The Right of Option was introduced in
2010 and provides that the loss carry-back Specifically, the Company asserted that the
United States
(achterwaartse verliesverrekening) can evaporation of the deductible losses could
be extended by two years, with a maximum have been prevented if the Accountants
of three years. In exchange the loss carry- had warned the Company in time for it to
Hong Kong forward (voorwaartse verliesverrekening) set up a sale and leaseback transaction to
is reduced by three years (from nine to prevent the evaporation of the deductible
six years). losses. The Accountants countered that the
Company would not have been able to set
In the annual accounts for 2010 to 2016
Italy up a sale and leaseback transaction quickly
and the tax returns for 2010 to 2017, the
enough to avoid all damages.
Accountants incorrectly assumed that a
loss carry-forward of nine years was still Not in dispute between the parties is the
possible even with the extended loss carry- fact that the Accountants consistently used
Spain an incorrect loss carry-forward period
back. In 2017, the Tax Authorities imposed
a final corporate income tax assessment of nine years. The court ruled that the
for 2015 on the Company. This assessment Accountants did not act as a reasonably
Our Global Accountants’ showed that the tax authorities were of competent and reasonably acting
Liability Team
professional and thus did not exercise the least to ask questions of the Accountants
care of a good contractor. By virtue of these if it had the impression that the Right of
failures, the Accountants have imputably Option had not been correctly incorporated
failed towards the Company to comply with into the annual accounts. After all, this is
the letter of engagement between the kind of information on which strategic
the parties. choices must be based; the necessary
knowledge and skills - also of non-tax
Although the court ruled that the
specialists - may be expected in a board of a
Accountants had failed to fulfill their
large company.
obligations, the court is of the opinion
that the Company is also to blame. The Against this background the court ruled
Company should not have (blindly) relied that the Company should not have blindly
on the Accountants, but in this case also trusted the Accountants. In light of the
had its own duty to pay attention and to foregoing, the court attributed half of the
investigate. The Company knew that in damage suffered to the Company.
view of its difficult financial and economic
situation, a different arrangement with
Next steps
regard to the loss set-off would be applied
for the first time as of 2009. In view of In order to establish the causal link
this, the Company was expected to have between the error and the alleged damage
The Netherlands carefully checked the first subsequent and the amount of damages suffered, an
annual accounts (and to some extent the expert opinion is ordered. An expert may
successive annual accounts) for the correct now consider, among other things, whether
application of the Right of Option. The it is likely (if possible, expressed as a
United States Right of Option is not a difficult deductible percentage) that the Company could have
item that can only be understood by set up a transaction in 2015 to prevent or
those with in-depth tax knowledge, limit the evaporation of losses as of 2016
after consulting detailed accounting and what benefits this would have brought
Hong Kong the Company.
documents. A large professional company
such as the Company is expected to have
the knowledge required to assess the
Italy application of The Right of Option, or at
Contacts:
Spain
Manon Cordewener Jessica Booij
Partner, Amsterdam Associate, Amsterdam
manon.cordewener@hoganlovells.com jessica.booij@hoganlovells.com
Our Global Accountants’
Liability Team
United States
Recent Court Decisions
Deloitte settles data breach class action for $4.95 million
Plaintiffs, who were residents of Illinois, Claimants will receive $20 per hour for
Colorado, and Ohio, alleged that their all the time they spent dealing with the
personal information located on state data breach, as long as they are able to
employment agency websites was left adequately demonstrate that the time in
vulnerable after the sites were hacked. The question was spent doing activities related
class, which was comprised of more than to the breach.
237,000 individuals, specifically claimed
The court preliminarily approved
that Deloitte did not use reasonable data
the settlement that the parties
security measures while designing and
proposed, though the judge did strike
maintaining states’ employment agency
language imposing additional objection
websites where people could apply for
requirements on settlement class members
benefits from the Pandemic Unemployment
who were represented by counsel seeking
Assistance Program.
The Netherlands fees from non-settlement class members.
The settlement created a $4.95 million The court found that such a requirement
non-revisionary settlement fund meant to could act as a deterrent for certain class
compensate plaintiffs, pay attorneys’ fees members who wanted to make an objection
United States (1/3 of the total fund), and cover service in good faith.
awards for the class representatives.
Hong Kong Contacts:
George A. Salter Dennis H. Tracey, III
Partner, New York Partner, New York
Italy george.salter@hoganlovells.com dennis.tracey@hoganlovells.com
Spain Sam Dougherty
Jonathan G. Coppola
Associate, New York Associate, New York
jonathan.coppola@hoganlovells.com sam.dougherty@hoganlovells.com
Our Global Accountants’
Liability Team
Recent Regulatory and Enforcement Decisions
PCAOB adopts framework to determine whether it is unable to inspect
foreign auditors
The PCAOB took the first step toward position will impair (1) its ability to select
implementing the Holding Foreign engagements, audit areas, and potential
Companies Accountable Act (HFCAA) by violations to review or investigate, (2) its
adopting PCAOB Rule 6100 on September timely access to work papers and other
22, 2021. The rule creates a framework relevant documents as well as relevant
for the PCAOB to determine whether it is personnel as part of an inspection or
unable to inspect or completely investigate investigation, and (3) its ability to conduct
registered public accounting firms located inspections and investigations consistent
in foreign jurisdictions where authorities with its statutory mandate and applicable
deny or limit PCAOB access to conduct rules. The PCAOB is not required to
oversight activities. That determination attempt an investigation and get stymied in
is the first step in a process that could order to make this determination—it
result in the issuers who have retained can rely on its past experience.
those foreign accounting firms getting
After the PCAOB makes its determination,
delisted from U.S. exchanges. This rule will
The Netherlands it will issue a report to the Securities and
primarily impact companies in Hong Kong
Exchange Commission (SEC). If, for three
and China, where the Chinese government
consecutive years, the PCAOB determines
has long resisted inspections of audits.
that it cannot inspect or investigate a
United States Rule 6100 requires the PCAOB to make specific accounting firm, or all accounting
annual determinations as to whether, firms in a specific jurisdiction, the SEC
based on a position taken by one or more will delist the issuers using those
authorities in a foreign jurisdiction, it is accounting firms from U.S. exchanges.
Hong Kong unable to inspect or completely investigate Rule 6100 will go into effect upon approval
registered public accounting firms that by the SEC, and then the three-year clock
are headquartered in that jurisdiction or will start ticking for the approximately 270
that have offices in that jurisdiction. In Chinese companies currently trading in
Italy making these determinations, the Board U.S. capital markets.
will assess whether the foreign authority’s
Spain
Our Global Accountants’
Liability Team
PCAOB sanctions Deloitte Canada for quality control failures
The PCAOB announced a settled without oversight. The firm knew about
disciplinary order that imposed this loophole at the time but neglected to
sanctions on Deloitte Canada after implement any controls measures (through
finding that the firm did not comply with trainings, written policies, etc.) to address
PCAOB’s audit documentation standards the problem.
in connection with audits and reviews.
Firm employees backdated workpaper
Specifically, Deloitte Canada did not
production or review dates in at least six
implement a quality control system that
issuer audits and two quarterly reviews.
was able to provide reasonable assurance
Furthermore, some auditors replaced sign
that its employees appropriately dated their
off dates to ensure that reviews were shown
preparation and review of audit documents.
to have occurred after the document was
As a result of Deloitte Canada’s failures, actually created.
the PCAOB: (1) levied a censure; (2) issued
The PCAOB made clear that Deloitte
a $250,000 fine; (3) required the firm
Canada’s extraordinary cooperation
to revise its quality control policies and
while responding to the violations was a
procedures to ensure similar problems
significant factor in the Board’s decision
would not happen again; and (4) required
The Netherlands to issue certain sanctions. Had Deloitte
the firm to provide four hours of training to
Canada handled the situation differently,
all relevant employees.
the PCAOB would likely have levied a
The PCAOB requires auditors to properly higher monetary penalty and issued
United States document when workpapers were created more severe punishments. First, Deloitte
and reviewed. In November of 2016, Canada was extremely cooperative during
Deloitte Canada removed a feature from the entire process. The firm self-reported
its internal electronic work paper system the violation within 15 days of learning
Hong Kong that allowed users to manually select about the transgression, conducted its own
preparer and reviewer sign off dates of internal investigation, and remained in
work product. In the new system, the close contact with the PCAOB throughout
current date would be automatically added the process. Second, Deloitte Canada
Italy whenever a preparer or reviewer signed off took steps to remediate the issue quickly
on a document. This caused issues because by retaining an expert consultant and
employees could override the system retraining employees. Third and finally,
by changing the date in their computer, the firm disciplined personnel identified as
Spain which would allow them to backdate involved in the misconduct.
their workpaper preparation or review
Our Global Accountants’
Liability Team
PCAOB sanctions KPMG Australia for quality control failures
related to testing
The Public Company Accounting Oversight The PCAOB stated that KPMG Australia’s
Board (PCAOB) issued a settled disciplinary violations included PCAOB Rule 3400T,
order imposing sanctions against KPMG and Quality Control Standards §§ 20.01,
Australia for findings that KPMG Australia 20.08 20.09, 20.13 (.b-.c), 20.20 (.c-.d),
violated PCAOB rules and quality control 30.02 (.c-.d), and 40.02 (.b-.c). These rules
standards in connection with the firm’s internal include requirements that a firm “[has] a
training tests. The PCAOB censured the firm, system of quality control for its accounting
imposed a $450,000 civil money penalty, and and auditing practices” that provides the firm
required the firm to take remedial measures. with reasonable assurance that personnel
In its order, the PCAOB noted the firm’s “perform all professional responsibilities
extraordinary cooperation in with integrity” and “provide the firm with
the matter. reasonable assurance that . . . [w]ork is assigned
to personnel having the degree of technical
The PCAOB order stated that KPMG Australia
training and proficiency required in the
violated PCAOB rules and
circumstances.”
quality control standards from 2016 to early
2020 by failing to establish proper policies and Importantly, the PCAOB cited the firm’s
procedures for administering and monitoring extraordinary cooperation in this matter.
training testing. After becoming aware of testing-related
The Netherlands The PCAOB noted that this failure resulted misconduct in early 2020, the firm voluntarily
in the firm’s failure to identify personnel who self-reported the matter to the PCAOB within
were involved in improper answer sharing 15 days and quickly began implementing
(either by providing or receiving answers) in remedial policies and procedures. The firm also
United States connection with the firm’s mandatory testing. provided substantial assistance to the PCAOB’s
The firm’s mandatory testing included topics investigation by conducting a thorough
of professional independence, auditing, and investigation and providing the results to the
accounting. PCAOB. The firm also instituted remedial
Hong Kong measures. Finally, the firm took disciplinary
action against 1,131 personnel engaged in
misconduct.
Contacts:
Italy
George A. Salter Dennis H. Tracey, III
Partner, New York Partner, New York
george.salter@hoganlovells.com dennis.tracey@hoganlovells.com
Spain
Our Global Accountants’ Jonathan G. Coppola Sam Dougherty
Associate, New York Associate, New York
Liability Team jonathan.coppola@hoganlovells.com sam.dougherty@hoganlovells.comHong Kong
Recent Regulatory and Enforcement Decisions
FRC completes investigation on material misstatement by an auditor
of a listed entity
On 12 August 2021, Hong Kong’s Financial regulators to obtain audit working papers
Reporting Council (FRC) adopted a report located in the mainland as mainland
on an audit investigation based, in part, authorities consider audit papers to be
on a review of various audit working “state secrets.”
papers having been obtained under a
Under Hong Kong Accounting Standard
memorandum of understanding with the
39 (HKAS 39), an entity is required to
People’s Republic of China (PRC) signed
recognize an impairment loss on available-
in 2019. The investigation concerned an
for-sale equity investments if there is
auditor’s failure to identify a material
objective evidence of impairment. In this
misstatement during an audit of a client’s
case, concerning an “available-for-sale”
financial statements.
equity investment of a listed entity, the fair
The Netherlands The memorandum was signed in May value of the investment declined by more
2019 between the FRC and the Supervision than half over a twelve-month period. Such
and Evaluation Bureau (SEB) of the a significant and prolonged decline in fair
PRC Ministry of Finance with the aim of value was objective evidence of impairment
United States facilitating cross-border cooperation and (impairment loss) under HKAS 39 but
collaboration in respect of audit regulation. the entity failed to record it in its 2017
The objective of the memorandum is to financial statements, which constituted a
enhance the quality and reliability of listed material misstatement.
Hong Kong entities’ audits, protect the interests of
The entity’s auditor failed to identify the
investors and the public, and strengthen
material misstatement and was found to
both investors’ confidence and public trust
have issued an inappropriate audit opinion.
in financial reporting.
Italy The auditor failed to properly apply the
Under the memorandum, the FRC can applicable financial reporting standard
make requests to the SEB for assistance in in evaluating the entity’s accounting
audit regulatory responsibilities in relation treatment of the impairment assessment of
Spain to inspection, investigation and discipline, the investment, and to exercise appropriate
such as gaining access to audit working professional judgment in evaluating what
papers of Hong Kong listed entities kept constituted an impairment loss under
Our Global Accountants’ by accounting firms in the mainland. It HKAS 39.
Liability Team had previously proved difficult for foreignThe engagement quality control reviewer with other regulatory authorities, including
also failed to identify the material the Securities and Futures Commission
misstatement. Both the engagement (SFC) in February 2021, the Stock
partner and engagement quality control Exchange of Hong Kong in June 2021,
reviewer were found to have failed or and the Independent Commission Against
neglected to observe, maintain or otherwise Corruption in September 2021.
apply professional competence and due
Auditors should look out for further
care as set out in the Code of Ethics for
reforms of the regulatory regime for the
Professional Accountants.
accounting profession in the near future,
All in all, it is clear that the powers of the including the Financial Reporting Council
FRC as an independent regulatory body (Amendment) Bill 2021 which seeks
continue to grow, despite a limited budget to develop the FRC into a fully-fledged
and concerns that it may not have enough independent regulatory and oversight body
teeth to exercise effective oversight. This for the accounting profession.
year, the FRC also signed memoranda of
understanding on regulatory cooperation
Contacts:
The Netherlands
Chris Dobby Yolanda Lau
Partner, Hong Kong Senior Associate, Hong Kong
chris.dobby@hoganlovells.com yolanda.lau@hoganlovells.com
United States
Hazel Law Nigel Sharman
Associate, Hong Kong Sr. Knowledge Lawyer, Hong Kong
Hong Kong hazel.law@hoganlovells.com nigel.sharman@hoganlovells.com
Italy
Spain
Our Global Accountants’
Liability TeamItaly
Recent Regulatory and Enforcement Decisions
New voluntary procedure for companies under financial distress and
postponement of the entry into force of the new bankruptcy law
Law Decree no. 118 of 24 August 2021 (Law failure to fulfil such informative duties
Decree no. 118/2021 – full text in Italian may trigger their liability under Article
available here) introduced a new voluntary 2407 of the Italian civil code, i.e. the
procedure to address situations of financial provision governing general duties and
distress affecting undertakings operating in responsibilities of statutory auditors under
Italy. Under the procedure, an independent Italian law.
expert is appointed to assist the company
As provided under Article 4(2), the
in the preparation of a negotiation scheme
independent expert may also appoint an
with the creditors. Access to the new
external auditor to provide assistance in
procedure will be available starting from
the negotiation procedure.
15 November 2021 through the local
Chambers of Commerce. Both the statutory auditors and the
The Netherlands
company’s external auditors (if any) are
In order to facilitate access to the
required to cooperate with the independent
procedure, Article 15 of Law Decree no.
expert and provide all required
118/2021 binds statutory auditors to
information.
United States promptly inform the company’s directors
if the company meets the preconditions Finally, Law Decree no. 118/2021 also
to apply for this voluntary scheme. The postponed the entry into force of the new
bankruptcy law to May 2022.
Hong Kong
Italy
Spain
Our Global Accountants’
Liability TeamProcedure for the adoption of administrative sanctions by
the Ministry of Economy and Finance
With Decree no. 135 of 8 July 2021 vi. lack of the requirements provided for
(Decree full text in Italian available here), under Article 14 of Legislative Decree no.
the Ministry of Economy and Finance 39/2010 in the audit report and in the
(MEF) established the rules governing opinions to the financial statements;
the procedure for the adoption of
vii. lack of or inadequate adoption of an
administrative sanctions in the event of
internal reporting systems.
breach of the duties under Article 25 of
Legislative Decree no. 39 of 27 January Once the MEF has collected the elements
2010 (full text in Italian available here), required to assess the existence of
applicable to auditors and auditing firms. the breach, an internal commission
The Decree was published in the Italian (Commissione Centrale per i Revisori
Official Journal no. 237 of 4 October 2021 Legali) triggers the sanctioning procedure
and will enter into force on 19 and submits to the auditor/auditing firm
October 2021. a letter with the description of the alleged
breach(es), and of the estimated timing
In particular, administrative sanctions may
for the completion of procedure. The letter
be applied by the MEF in case of:
The Netherlands shall be sent as soon as the commission is
i. failure to comply with the obligation to informed of the alleged breach, and in any
periodically attend training courses; case within 180 days therefrom (or 360
days, if the party concerned resides or is
ii. failure to communicate certain items
United States based abroad).
to be included in the Auditors Register
pursuant to Article 7 of Legislative Decree The auditor/auditing firm have 30 days
no. 39/2010, as well as data pertaining to from the receipt of the letter to provide
the identification of the auditor/auditing their written observations to the charges
Hong Kong firm and their assignments; and to ask to be heard in person.
iii. false declarations in trainees’ annual Once the observations are acquired, the
reports by their supervisors; commission submits - within 120 days from
Italy iv. breach of the duties of professional
the receipt of the letter by the auditor/
auditing firm - a non-binding proposal
ethics, independence and objectivity, and
to the MEF, where it reports the reasons
auditing standards;
underlying the proposed sanction and
Spain v. failure, incompleteness, or delay in the type and extent of the latter or, in
taking the actions indicated in the report the alternative, proposes to dismiss the
issued following a quality control pursuant proceedings. The MEF - which is not bound
Our Global Accountants’ to Article 20 of Legislative Decree no. by the opinion of the commission – may
Liability Team 39/2010;then apply sanctions by means of motivated 39/2010. In the event that the addressees
administrative order. do not comply with the sanctions, the MEF
orders their cancellation from the Auditors
Possible sanctions include both monetary
Register. Decisions can be appealed before
and non-monetary measures, as defined
Civil Courts within 30 days from their
under Article 24 of Legislative Decree no.
communication.
Contacts:
Andrea Atteritano Emanuele Ferrara
Partner, Rome Senior Associate, Rome
andrea.atteritano@hoganlovells.com emanuele.ferrara@hoganlovells.com
The Netherlands
United States
Hong Kong
Italy
Spain
Our Global Accountants’
Liability TeamSpain
Recent Regulatory and Enforcement Decisions
New regulation increases auditors’ obligation to guarantee
liability judgments
The financial guarantee in Spain The specific requirements for such
guarantees are established by
Statutory auditors and audit firms are liable
Article 65 of Royal Decree 2/2021,
for any damages arising from the breach of
of 12 January, approving the Regulations
their duties under the general rules of the
implementing Law 22/2015, of 20 July,
Spanish Civil Code and more specifically
on Account Auditing (Regulation), which,
Article 26 of Law 22/2015 of 20 July
came into force on 1 July 2021, introducing
2015 on Account Auditing (Audit Act).
numerous new provisions.
This liability must be:
The new provisions of the Regulation
1) proportional to the economic damage increases the minimum amounts of the
that may be caused by their professional financial guarantee. While the previous
The Netherlands performance both to the audited entity and Regulation established that in the case
to a third party; of natural persons, the guarantee for the
2) personally and individually enforceable, first year of activity was EUR 300,000,
excluding the damage caused by the the new Regulation raises this figure up to
United States EUR 500,000. This amount shall be the
audited entity itself or by third parties; and
minimum amount for subsequent years.
3) joint and several between the statutory
auditor who has signed the audit report As for audit firms, this amount for the
Hong Kong and the audit firm when the audit is carried first year of activity is multiplied by each
out by a statutory auditor on behalf of an of the partners – whether or not they are
audit firm. auditors – and by each of the non-partners
auditors appointed to sign audit reports on
Italy Pursuant to Article 27 of the Audit Law, behalf of the firm. This amount shall be the
when such liability is declared, auditors minimum amount for subsequent years.
and audit firms are due to provide a
financial guarantee in the form of a cash The new Regulation also provides for
deposit, public debt securities, financial surety insurance in addition to the liability
Spain insurance already set out in the previous
institution guarantee or civil liability
insurance policies. Regulation.
Our Global Accountants’
Liability TeamWhat’s driving this change? Very recently another Spanish criminal
court in a high-profile case (Abengoa),
Some experts believe this striking increase
extended the investigation to include the
in the guarantee threshold is a response to
auditing firm, Deloitte.
recent high-profile criminal indictment of
auditors, seeking millions in civil liability. These recent cases underscore the risk that
audit firms may face millions in damages if
Specifically, in an 6 October 2020
they fail to detect accounting fraud.
judgment in the Pescanova case, BDO, one
of the leading auditing firms in Spain, was Therefore, the increase in the amount of
convicted of “a crime of misrepresentation the financial guarantees required by the
of economic and financial information” in new Regulation appears to be an effort to
regard to Spanish fishing company which ensure that investors can be compensated
went into receivership in 2013 after the by making the liability system more secure.
scandal about its accounting irregularities
broke out. This judgment set a historic
milestone since it was the first time an
auditing firm and the partner who signed
the accounts were convicted in Spain.
The Netherlands Contact:
Jose Luis Huerta
United States Partner, Madrid
joseluis.huerta@hoganlovells.com
Hong Kong
Italy
Spain
Our Global Accountants’
Liability TeamOur Global Accountants’ Liability Team
Americas
Federico De Noriega Olea Jonathan G. Coppola Jose Luis Huerta Erik Willem Brouwer
Partner, Madrid Trainee Solicitor, Rome
Partner, Mexico City Associate, New York
joseluis.huerta@hoganlovells.com erikwillem.brouwer@hoganlovells.com
federico.denoriega@hoganlovells.com jonathan.coppola@hoganlovells.com
Asia
Cristina Rodriguez Sam Dougherty Kim Lars Mehrbrey Chris Dobby
Partner, Houston Associate, New York Partner, Dusseldorf Partner, Hong Kong
christina.rodriguez@hoganlovells.com sam.dougherty@hoganlovells.com kim.mehrbrey@hoganlovells.com chris.dobby@hoganlovells.com
George A. Salter Charles Barrera Moore Emanuele Ferrara Roy G. Zou
Partner, New York Associate, New York Senior Associate, Rome Partner, Beijing
george.salter@hoganlovells.com charles.moore@hoganlovells.com emanuele.ferrara@hoganlovells.com roy.zou@hoganlovells.com
Arturo Tiburcio Juan Manuel Moran Sosa Sophia Jaeger Byron Phillips
Partner, Mexico City Associate, Mexico City Senior Associate, Hamburg Counsel, Hong Kong
arturo.tiburcio@hoganlovells.com juan.moran@hoganlovells.com sophia.jaeger@hoganlovells.com byron.phillips@hoganlovells.com
Dennis H. Tracey, III Maura Allen Nathan Sherlock Yolanda Lau
Partner, New York Associate, New York Senior Associate, London Senior Associate, Hong Kong
dennis.tracey@hoganlovells.com maura.allen@hoganlovells.com nathan.sherlock@hoganlovells.com yolanda.lau@hoganlovells.com
Europe
Mitra Anoushiravani Andrea Atteritano Eugenio Vázquez Hazel Law
Senior Associate, New York Partner, Rome Senior Associate, Madrid Associate, Hong Kong
mitra.anoushiravani@hoganlovells.com andrea.atteritano@hoganlovells.com eugenio.vazquez@hoganlovells.com hazel.law@hoganlovells.com
Luis Giovanni Sosa Manon Cordewener Benjamin Hansen Nigel Sharman
Senior Associate, Mexico City Partner, Amsterdam Associate, Dusseldorf Sr. Knowledge Lawyer, Hong Kong
giovanni.sosa@hoganlovells.com manon.cordewener@hoganlovells.com benjamin.hansen@hoganlovells.com nigel.sharman@hoganlovells.com
Allison M. Wuertz Alexei Dudko Jessica Booij
Senior Associate, New York Partner, Moscow Associate, Amsterdam
allison.wuertz@hoganlovells.com alexei.dudko@hoganlovells.com jessica.booij@hoganlovells.com
Gary Yeung Nicholas Heaton Blanca Romero de Ory
Senior Associate, New York Partner, London Junior Associate, Madrid
gary.yeung@hoganlovells.com nicholas.heaton@hoganlovells.com blanca.romero@hoganlovells.comAlicante
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