Professional profile
About Nannan
Nannan Xu advises pharmaceutical companies, medical device manufacturers and healthcare organizations on enforcement response, anti-corruption investigations and compliance program design from Shenzhen.
Ms. Xu practices at a Shenzhen law firm. She was admitted in 2014 and has about twelve years of professional experience, working in English and Mandarin with Guangdong Bar Association credentials on file.
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Raid kits fail when only lawyers know they exist. Sales leadership must rehearse the first hour. She trains teams to verify badges, call compliance hotlines, avoid refusing lawful inspection, and route document requests through designated liaisons.
She builds one-page response cards for pharma sales and medical affairs teams: what to say, what not to delete, and how to reach counsel fast.
Do not delete WeChat, re-image laptops, or tidy cupboards. Answer factually; do not speculate about how HQ does it. Document holds on email and messaging begin when a dispute or regulatory inquiry is reasonably anticipated.
When a warning letter names a China site, she coordinates US regulatory CAPA with PRC employment, vendor and dual-regulator risk. Do not re-image systems before forensic hold. Do not fire scapegoats without labour process. Do not invent root causes that contradict the regulatory narrative.
She reviews customer-facing materials, training decks and KOL engagement plans with a focus on anti-bribery controls and third-party intermediary management.
CSO structures become enforcement stories when money moves without provable promotion work product. She applies a substance test: named deliverables, people who exist, fapiao and bank flow that match the contract narrative, and hospital-facing activity that does not collapse into individual HCP benefits.
Institutional sponsorship still needs brand and promotion review. Individual speaker fees need HCP engagement controls. Mixing both without a chart of accounts creates inconsistent stories in a raid.
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