South Korea’s Jipyong served as the overall co-ordinating counsel for RIMAN and Bangkok-based Kudun and Partners acted as Thai local counsel.

Jipyong advised on structuring and scheduling the market entry, preliminary analysis of the licensing and regulatory framework, and instructing and reviewing work carried out by Kudun and Partners.

Partners Sehun Ko and Jong Hun Collin Lee, as well as senior foreign attorney Ki Il Ban, spearheaded the Jipyong team.

“The most challenging aspect of the project was that the licensing and approval process for the cosmetics direct sales business in Thailand had to be completed in a sequential and interdependent manner,” Ko told Asia Business Law Journal.

“Jipyong addressed this by designing a critical path for each licence and managing step-by-step milestones throughout the process,” he said.

“In RIMAN’s Thailand market entry project, Jipyong and [Kudun] worked together as a single integrated team from start to finish.”

Kudun and Partners assisted on RIMAN’s establishment in Thailand, covering corporate structuring, regulatory and licensing matters, and strategic advice related to direct marketing and ongoing operational compliance. The firm also assisted with applicable foreign investment and commercial regulatory frameworks.

The team was led by founding partner Kudun Sukhumananda, corporate and M&A partner Chai Lertvittayachaikul, and head of regulatory, permits and licensing Thanyaluck Thongrompo.

“Our scope included advising on suitable business structures for operating in Thailand, foreign business restrictions under the Foreign Business Act, product commercialisation considerations, corporate establishment matters, and general regulatory compliance relevant to its intended operations in Thailand,” Lertvittayachaikul told ABLJ.

He said that supporting RIMAN’s establishment in Thailand was a key highlight, but noted the importance of adhering to local regulations.

“While the transaction itself was relatively straightforward from an execution perspective, the main focus was ensuring that the proposed structure and operations were compliant with Thai regulatory requirements while remaining commercially workable for a foreign investor entering a new jurisdiction.”

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The transaction, which amounted to about JPY336 billion (USD2.1 billion), also included Chevron Singapore’s 50% non-operated interest in the Singapore Refining Company.

For ENEOS, Japan’s largest integrated energy company, the deal marks its first overseas refinery investment and significantly expands its downstream footprint.

Norton Rose Fulbright advised ENEOS on all aspects of the acquisition, including multijurisdictional legal support across the Asia-Pacific. The team was led by Sydney-based partners Shamim Razavi and Fridoun Chee.

Razavi noted one of the challenges of the acquisition stemmed from supply issues related to the ongoing conflict in the Middle East.

“The deal involved several jurisdictions, all with an interest in ensuring the assets remain in safe hands,” he told Asia Business Law Journal. “In this regard, ENEOS’ first-class reputation made our job easier. Navigating the transaction in the midst of the supply constraints caused by the conflict in the Middle East created its own considerations.”

Chee added that the cross-border nature of the deal also contributed to its complexity.

“The industry is highly regulated and the transaction involves approval from relevant governments,” he said.

Manila-based law firm Ocampo & Suralvo Law Offices guided ENEOS on all aspects of Philippine due diligence and co-operated with Norton Rose Fulbright on drafting and negotiating the definitive agreement. Partners Jude Ocampo, Charity Aurellano, Cristina Suralvo and Christine Antonio made up the team.

“This was a major engagement involving a thorough review of a large corporation’s operations in a heavily regulated industry,” Ocampo told ABLJ. “The project included many interconnected workstreams, where analysis in one area often intersected with others.”

Malaysian law firm Adnan Sundra & Low acted for Chevron and confirmed that the deal included ENEOS’ acquisition of the Caltex network in Malaysia, comprising more than 450 fuel stations.

Gibson Dunn & Crutcher also advised Chevron, with the team led by London-based partner Simon Tysoe.

Other firms involved included Latham & Watkins and Malaysia’s Rahmat Lim & Partners.

The transaction is expected to be completed in 2027, subject to regulatory approvals and customary closing conditions.

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A delegation of 25 in-house counsel and legal professionals from the KICA, including president Jaehwan Lee and vice-president Yoonkyo Ryu, attended a seminar organised by JILA focusing on recent trends in Japan’s M&A market.

The discussions also covered the operational models, activities and distinguishing characteristics of the two associations.

“The meeting with the JILA was particularly meaningful, as both organisations share a similar role and structure within their respective jurisdictions, allowing for a uniquely balanced and practical exchange of perspectives,” said Lee.

The KICA delegation also visited the offices of Japanese law firms TMI Associates and Nozomi Sogo Attorneys at Law, and exchanged views with the legal department of LY Corporation on the Japanese legal market and cross-border business practices.

The discussions revolved around developments in Japan’s corporate legal environment, recent M&A trends, the evolving role of in-house legal teams, and regulatory responses within technology companies.

“This programme served as a meaningful opportunity for Korean and Japanese in-house counsel to directly share practical insights and legal trends while building a foundation for long-term collaboration,” said Lee.

He noted that the KICA will continue its collaboration with the JILA and Japanese law firms through future seminars and networking events.

The KICA will host its next cross-border exchange programme in Shanghai in 2027.

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Russian disputes shift to courts

Before 2020, most high-profile disputes involving Russian entities and individuals were resolved abroad. The London Court of International Arbitration served as the preeminent hub, favoured for its sophisticated arbitration framework. The International Chamber of Commerce and Stockholm Chamber of Commerce were also preferred venues. The use of Asian arbitral institutions, such as the CIETAC, HKIAC and SIAC, was limited by Russian parties.

But in 2020, amendments to the Russian Commercial Procedure Code (CPC) conferred exclusive jurisdiction of Russian courts over disputes involving sanctioned Russian individuals and legal entities.

Russian courts override foreign arbitration

Under the CPC, exclusive jurisdiction of Russian Arbitrazh (commercial) courts covers disputes:

1. 1. Involving parties subject to Russia-related sanctions; or
   2. Arising from such sanctions and involve Russian and/or foreign parties (even if no party is sanctioned).

Such parties may apply to the Russian court for:

1. 1. Resolution of the dispute on its merits; and/or
   2. An anti-suit injunction.

The key provision for Asian companies is that these remedies may be used despite any arbitration/prorogation agreements if sanctions make recourse to a foreign forum – whether the CIETAC, HKIAC, SHIAC or SIAC – “impossible to perform”.

Russian courts interpret this broadly. The CPC provides that an anti-suit injunction may order a party to discontinue ongoing foreign proceedings or prohibit the other party from initiating new proceedings, and courts  may support anti-suit injunction with financial penalty plus legal costs.

Sanctions expand Russian court jurisdiction

• 1. In Uraltransmash v PESA, the mere existence of sanctions sufficed to show that a Russian party faced restricted access to justice abroad.
  2. In NS Bank v NK Lukoil, Russian courts decreed exclusive jurisdiction over a dispute between two Russian entities, even though non-sanctioned, because of “sanctions-related background”. Explaining the likely impartiality of a foreign forum, they stated: “A predetermined finding that the imposition of restrictive measures is lawful may influence the resolution of the dispute on its merits”.
  3. Hong Kong has not imposed sanctions on Russia. Also, the HKIAC, unlike the CIETAC or SIAC, was the first overseas institution recognised by the Russian Ministry of Justice as a permanent arbitral institution in 2019, underlining its respected reputation in Russian arbitration. Despite this, the court, in VTB v OWH, granted VTB’s anti-suit injunction on the grounds that sanctioned status per se restricted access to justice in arbitration seated in Hong Kong.

Russian affiliate co-defendant jurisdiction trap

Under the CPC, a claim against several co-defendants must be filed with the court at the location of one of them. If a claimant directs its claim not only to a foreign but also to a Russian co-defendant, such claim may also be lodged in Russia.

This manoeuvre was first tested in 2023, in SMR v Citibank Companies, when a claimant sued US bank Citibank and its Russian affiliate, KB Citibank, claiming the former breached contractual duties due to sanctions, and both banks inflicted non-contractual damage acting in co-operation in the same group.

The courts initially granted the claim, but the Russian Supreme Court subsequently cancelled the judgments and sent the case for retrial.

In October 2025, the Supreme Court reviewed a similar case, SMR v JP Morgan Companies, claiming recovery of non-contractual damages against UK bank JP Morgan Securities and its Russian affiliate KB JP Morgan Bank International.

The Supreme Court ruled mere affiliation insufficient for joint liability. The claimant had to prove the UK bank de facto ran direct business in Russia and used its Russian affiliate to avoid liability risk.

Russian risks persist; arbitration limits

While the trend toward jurisdictional expansion remains, the Russian Supreme Court is now tightening rules on the merits of joint liability. For Asian groups with Russian subsidiaries, the risk of being dragged into Russian courts still exists – but the “jurisdictional hook” alone is no longer enough.

For arbitration clauses, the HKIAC remains the best option, but it may be overridden if the Russian counterparty is sanctioned. The CIETAC has been successfully tested in at least one case. SIAC is officially designated an “unfriendly” jurisdiction and should be avoided for contracts with Russian counterparties.

Georgy Daneliya and Natalia Kozyrenko are partners, and Igor Sokolov is a senior associate at SL LEGAL in Russia

SL LEGAL
10 Presnenskaya Nab., block A
123112 Moscow, Russia

Contact details:
T: +7 495 134 22 00
E: info@sl-legal.ru

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The move marks the firm’s first presence in the region, adding to its existing offices in London, New York and the British Virgin Islands (BVI).

Ashkhan Candey, founder and managing partner for London and BVI, told Asia Business Law Journal that regional collaborations were also on the firm’s radar.

With Singapore as a regional base, a strategy centred on alliances with firms in key jurisdictions would be pursued.

“The current focus is on Singapore, which provides a perfect hub for the region. Our preferred plan is to work in collaboration with law firms in other [areas] such as in China, India and the Middle East,” said Candey.

He said the firm had enjoyed steady long-term growth, and it was the right time to focus on the Asia-Pacific market.

“We are very keen on the Asia-Pacific region and with our other offices, particularly London and the BVI, linking up to provide a one-stop shop in Asia for clients to be able to solve problems which have an English, BVI and US dimension,” he said following the new office’s 18 May launch.

“We are driven by the most interesting disputes work, and Singapore’s history and culture of enterprise is highly attractive. Why now? We have grown carefully over the 17 years we have been in business and, personally, with almost 30 years in the business, it’s now or never.”

Candey confirmed that Christopher Bailey would be the managing partner of the Singapore office and APAC region. The office will initially comprise three to four fee earners and focus on arbitration, commercial litigation, insolvency, corporate crime and trust disputes.

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Tsurumaki joins from King & Wood, where he served as a partner for nearly a decade. He previously spent more than nine years as a partner at Japanese firm Atsumi & Sakai.

Tsurumaki specialises in domestic and cross-border M&A finance, capital markets, corporate venture capital investment, ESG investment, data centres, real estate, general corporate, and dispute resolution.

“Yoshiki’s appointment reflects LPA Tokyo’s continued commitment to strengthening its corporate and M&A capabilities, and supporting the development of its Japan practice in line with evolving client needs,” Lionel Vincent, managing partner of LPA Tokyo, told Asia Business Law Journal.

Vincent said that Tsurumaki’s appointment would further enhance the firm’s ability to meet increasing client demand across complex areas.

“His arrival also forms part of LPA Tokyo’s broader strategic development and its continued adaptation to the growing demand in the Japanese market for sophisticated M&A, investment and projects-related legal expertise,” he said.

“It further enhances the team’s ability to support both domestic and international clients on complex cross-border matters, in close co-ordination with LPA Law’s offices across Europe and Asia.”

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While South Korea ranks as the world’s 13th-largest economy by nominal GDP, the nation’s commercial landscape presents operational complexities that may not be immediately apparent to foreign investors.

Speaking with Asia Business Law Journal, SongYi Son examines the legal and operational challenges confronting international businesses in South Korea, from data protection to labour laws and corporate governance.

She also discusses the growing strategic role of in-house counsel and highlights how early legal engagement and a culture of integrity serve as essential “licences to operate” in this dynamic market.

Asia Business Law Journal: What makes South Korea a top-tier destination for multinational investors despite global economic shifts?

SongYi Son: South Korea continues to distinguish itself as one of Asia’s most sophisticated and attractive destinations for inbound investment. Its advanced industrial base, strong infrastructure, world-class engineering capabilities and increasingly globalised corporate environment offer significant opportunities for multinational companies operating across technology-driven and capital-intensive industries.

For global investors, these advantages represent not only scale and technical excellence, but also reliability as a long-term business partner.

ABLJ: What perspective can you offer international companies entering South Korea?

Son: From the perspective of an in-house counsel at a multinational group, South Korea’s attractiveness is inseparable from a legal and regulatory environment that is both highly developed and uniquely complex.

The challenge for international investors is rarely the absence of rules, but rather navigating a system that is dynamic, enforcement focused and deeply influenced by local legal culture and regulatory expectations.

ABLJ: Has the regulatory environment matured in South Korea?

Son: South Korea’s regulatory framework has evolved rapidly in the past two decades and today reflects a high degree of maturity and alignment with global standards across areas such as competition law, anti-corruption, data protection, labour, trade compliance and corporate governance.

At the same time, regulatory authorities are well resourced, technically sophisticated and increasingly assertive. Enforcement actions are no longer viewed as exceptional events but as an integral part of regulatory supervision. Investigations tend to be comprehensive, documentation driven and time sensitive, requiring companies to respond quickly and with clear internal alignment.

For multinational organisations, this creates a dual obligation: to comply with laws and enforcement practices while simultaneously meeting global compliance expectations originating from other jurisdictions, including the US and Europe.

ABLJ: In an era of “borderless” regulation, what challenges are arising in South Korea?

Son: One of the most consistent challenges facing multinational groups operating in South Korea is the convergence of domestic regulation with extraterritorial enforcement regimes. Anti-bribery and corruption laws, trade sanctions, export controls and data protection obligations increasingly extend beyond national borders.

Decisions made at the local level – whether in structuring sales models, engaging intermediaries, or managing cross border data flows – can have regulatory implications in multiple jurisdictions. In practice, this means local business teams must operate with awareness that their actions may be scrutinised by South Korean regulators and foreign enforcement authorities alike.

For in house counsel, the task is not limited to legal interpretation. It requires active risk orchestration: ensuring local compliance frameworks are sufficiently robust while remaining practical and workable within South Korea’s fast-paced business environment. Global policies that function well elsewhere may require careful adaptation to local realities, without compromising core compliance principles or regulatory expectations abroad.

ABLJ: Does this apply to digitalisation in South Korea?

Son: Digitalisation presents a particularly acute example of this balancing act. South Korea maintains one of the most stringent data protection regimes in Asia at a time when businesses increasingly rely on digital platforms, remote monitoring, AI-enabled systems and centralised data analytics.

The challenge is not only legal compliance but operational design. Global organisations depend on shared systems and regional or global data hubs to operate efficiently. Yet these models must be carefully aligned with local data protection requirements.

Achieving this alignment requires close collaboration between legal, IT and business teams, and a willingness to embed compliance into system design rather than retrofitting it after issues arise.

ABLJ: What are common pitfalls for foreign firms regarding labour laws?

Son: Inbound investors must navigate complexity with care. Employee protection is strong, union engagement is increasingly active, and enforcement risks are real. For multinational companies accustomed to more flexible employment regimes, misunderstandings can arise around working hours, termination protections, consultation obligations and collective labour dynamics.

In this context, effective legal support depends on early involvement, continuous engagement with HR leadership, and a deep understanding of both legal requirements and workplace culture. Many compliance challenges in this area stem not from intent, but from a lack of familiarity with local norms and expectations.

ABLJ: How is the role of the in-house lawyer evolving within the Korean business context?

Son: Business leaders increasingly expect legal teams to act not only as technical legal advisers but as strategic partners – anticipating risks, enabling informed decision making and contributing to sustainable value creation.

In South Korea’s highly competitive and fast-moving market, legal advice delivered late in the process is often perceived as an obstacle. By contrast, legal input provided early – framed in commercial terms and aligned with business objectives – is more likely to be welcomed as a strategic asset.

This shift requires legal teams to understand the business deeply, appreciate the pressures under which leaders operate, and engage with risk in a pragmatic and solution-oriented manner.

Across all regulatory themes, one principle remains constant: integrity is not optional. For multinational companies operating in South Korea, a strong culture of integrity is not merely a compliance requirement but “a licence to operate”.

Regulators increasingly assess not only whether companies comply with specific rules but whether they demonstrate genuine ownership of ethical conduct through leadership tone, governance structures and internal accountability.

Organisations that invest in a speak-up culture, transparent escalation mechanisms and clear risk ownership are better positioned to manage regulatory scrutiny and respond effectively when issues arise.

ABLJ: What fundamentals does a multinational need to succeed in the Korean market?

Son: Looking ahead, South Korea will continue to be a compelling destination for inbound investment. Its regulatory environment will remain demanding. But it is also predictable and navigable for those who invest the time to understand it properly.

For international investors and in-house counsel alike, success rests on three fundamentals: early legal engagement, alignment between global standards and local execution, and a clear commitment to integrity as a core business value. When approached thoughtfully, legal and regulatory complexity does not hinder investment – it strengthens it.

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The firms, which merged in 2018, are splitting at a time when Singapore’s Ministry of Law and the Legal Services Regulatory Authority are reviewing collaborations between international and local law firms.

Despite this, Ryan Dwyer, K&L Gates’ regional managing partner, Asia, told Asia Business Law Journal the decision was not driven by any particular factor.

“No single event prompted this change,” he said. “The combination with Straits has been highly successful over the past seven years.

“We closely monitor key markets to ensure we are best positioned to meet our clients’ evolving needs, and concluded that operating as a foreign law practice will significantly enhance our ability to do so while supporting our long-term growth strategy.”

Dwyer remained tight-lipped on whether K&L Gates would pursue a new partnership with another local firm in Singapore, but said that the separation from Straits Law would not alter the firm’s strategy in the jurisdiction.

“Singapore remains an important market for us,” he said. “While the jurisdiction offers a range of models for collaboration between international and Singapore law firms, we have nothing further to announce at this time.

“As we move forward, we will continue to assess the collaborative options that best support our clients’ needs and our long-term business strategy in Singapore and across the region.”

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Partners Reuben van Werkum and Robert Tang led the team, providing advice on multiple aspects of the transaction.

“We provided regulatory and compliance advice on foreign investment review board consideration, corporate structuring, directors’ duties and employment laws,” Tang told Asia Business Law Journal.

Partner Chad Bochan and Counsel Julian Brun also advised on the transaction.

Van Werkum said that sorting out the funding structure and investment arrangements were among the most complex elements of the transaction.

“One of the most complex and commercially interesting aspects of establishing an early-stage data centre platform is negotiating the funding structure and investment arrangements,” he told ABLJ.

“At this stage, there is an inherent tension between the founders’ objectives to secure fully committed capital to develop a credible platform, and incoming financial partners wanting to build in protections to manage any downside risk before key dependencies – such as development approvals and customer contracts – are secured.

“This creates a classic ‘chicken-and-egg’ dynamic; founders and customers want to see a well- funded, viable investment platform, while investors are reluctant to scale up the deployment of capital until approvals are obtained and customers are secured.”

Arnold Bloch Leibler advised Alceon on all corporate and commercial aspects, with the team led by corporate and M&A partner Jeremy Leibler and senior associate Ari Bendet.

Banking and finance partner Nathan Briner and senior associate Luise Squire provided financing advice, while property-related matters were handled by partner Tyrone McCarthy and senior associate Tamsen Kempster.

Alceon’s investment in INSITE DC is part of the launch of its new DC Catalyst Fund and provides INSITE DC with a scalable source of capital to support its data centre development plans.

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The technology disputes practice will be led by partners Tan Kai Liang, deputy co-head of the firm’s international arbitration practice, and Melissa Mak. It will complement the existing technology and corporate intellectual property practice, and provide advice on tech-related matters.

The healthcare, life sciences and pharmaceuticals practice will be headed by partners Mak Wei Munn and Christopher Koh, who also serves as deputy head of the corporate M&A department. The team will advise on cross-border M&A, healthcare regulations and requirements, corporate reorganisation and restructuring, commercial agreements and contracts, establishment of healthcare infrastructure and other operational agreements.

Managing partner Jerry Koh said the launch of the two new practices was partly influenced by developments discussed at the 27th Asean Economic Community Council Meeting and the 48th Asean Summit.

“Our firm is always on the lookout for ways we can enhance our value offerings to clients and meet the evolving needs of the market. One way we do so is through vigilantly and constantly augmenting our offerings to address critical needs and capture emerging opportunities for our clients,” he told Asia Business Law Journal.

“As such, we proactively moved to set up our healthcare, life sciences and pharmaceuticals practice, and our technology disputes practice, to consolidate our expertise and enhance our capabilities in these areas.”

Jerry Koh added that the new practices would be able to leverage Allen & Gledhill’s network of associate firms and offices in Singapore, Malaysia, Myanmar, Indonesia, Vietnam and China to “provide fit-for-purpose counsel on any matter our clients may have across the business landscape”.

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