Sarah (Xiaohua) Zhao


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Valparaiso University School of Law


Indiana University


Beijing Language and Culture University


Previous Experience

  • Baker Hostetler (Partner)
  • Holland Knight (Managing Partner, Beijing office)


  • District of Columbia


  • English
  • Mandarin

Professional Experience

Sarah (Xiaohua) Zhao has substantial experience in international transactions with an emphasis on technology transactions, data protection, privacy and cybersecurity from both regulatory and corporate perspectives. Her counsel includes advising major companies on international and China’s cybersecurity, privacy and data protection legal environment, establishing data protection policies and compliance programs, conducting due diligence on data security for mergers and acquisitions, handling data breaches, and advising on compliance matters related to existing rules and regulations. Her technical understanding facilitates first-class guidance to clients in a range of industries, including information technology, energy, financial services, insurance, aviation, transportation, agriculture, manufacturing, entertainment and sports. Ms. Zhao also has an extensive background in cross-border corporate transactions -- including joint ventures, mergers and acquisitions, project financing and corporate formation -- and her arbitration and litigation skills have assisted Chinese clients in the United States, as well as U.S. companies in China.

Highlighting the cross-practice utility of the firm’s privacy and data protection team, Ms. Zhao brings a unique blend of in-depth knowledge of both the U.S. and Chinese regulatory landscapes. Her comprehension of different legal systems and cultural subtleties, combined with her fluent Chinese language capability, ensures accurate internal and external communications within a global setting. For more than 20 years, she has advised private companies, trade associations, and government officials on foreign investment in China, the United States, Europe, and a number of Asian countries. She has also advocated for enhanced business environments for foreign companies in China. During the course of her career, Sarah’s efforts have resulted in several cumbersome Chinese internet and wireless rules being either amended or abolished.

Before her legal career, Ms. Zhao was an accomplished journalist. She has also worked at the current Ministry of Industry and Information Technology of China (MIIT) which is equivalent to the FCC in the United States. 

Selected Experience

Corporate Transactions

  • Numerous major mergers and acquisitions in internet, digital media, cloud computing, software and wireless industries
  • A $6 billion satellite cable television transmission system financing
  • Numerous major cross-border joint ventures formation and maintenance
  • An aviation company FCPA investigation
  • Numerous high-tech, life science, and drug companies public listing and maintenance in the U.S.
  • An auto service company acquisition of a publicly listed company in the U.S. 
  • A coal thermal power plant financing and acquisition
  • An auto manufacturing equity transfer
  • A lease finance company restructuring and acquisition
  • An online advertisement joint venture formation and maintenance
  • Numerous technology companies’ restructuring, technology transfer, licensing transactions


  • Numerous regulatory due diligences on cybersecurity, data protection, and privacy issues for acquisitions over billions of dollars
  • Advised major companies, including Microsoft and Facebook, on China cybersecurity, data protection and privacy issues
  • Advised major companies on designing and enforcing their internal data security and privacy programs
  • Advised major companies on breach incidents response in different countries
  • Advised major data-related transactions on CIFUS issues
  • Advised major companies on legislative issues on rule amendment issues for Internet and wireless industries  

Awards & Recognition

  • Attended Harvard Business School Executive Leadership Education Program (2010)


Ms. Zhao is a frequent writer and commentator on cybersecurity, data protection and privacy issues related to China. She has written for and has been interviewed by the Legal Times, Chicago Tribune, Telecommunication Report International of FCC, Corporate Counsel, Boao magazines, and Law360. She has been regularly invited to give speeches by prominent institutions and international organizations include: Harvard China Review Annual Conference, Practice Law Institute, International Telecom American Association, Pacific Basin Economic Council Policy Conference, Global Forum, and International Bar Association.

Other Activities

Ms. Zhao has been a member of the International Association of Privacy Professionals since 2016. She is also a committee member of the Steering Committee for Asian affairs as part of Global Forum, an international telecom organization.