William D. Semins

Represented a provider of mission-critical program administration solutions for government-funded healthcare programs in connection with inquiries from the US Attorney’s Office and the South Carolina Attorney General’s Office regarding performance and invoicing by the client on a state procurement contract.

Assisted an international manufacturer of electrical supplies in conducting a global compliance risk assessment involving operations or sales in more than 50 countries, including preparation of heat map, risk register, and priority roadmap.

Assisted a leading Singapore-based global marine and offshore engineering group in conducting a multijurisdictional, internal investigation into corruption allegations arising out of Brazil’s high-profile Operation Lava Jato investigation; negotiated resolutions with various regulators and prosecutors.

Acted for a logistics company in relation to a suspected employee bribery issue.

Conducted a full compliance program assessment, including preliminary risk assessment, policy gap analysis, and evaluation of policies, programs, and training across international operations, with a phased implementation roadmap, for a global solar energy company.

Performed a compliance program risk assessment of global operations of a technology manufacturer with operations or sales in 30+ countries. The scope included policy gap analysis, 200 stakeholder interviews, preparation of heat map, risk register, and priority roadmap.

Advised a global nuclear fuel supply company regarding ethical supply-chain risk-management initiatives and the Anti-Modern Slavery Policy for a UK subsidiary.

Provided export control and sanctions compliance advice to a US-based apparel design and sales company, particularly with regard to supply-chain sourcing and dealings with parties in China subject to expanded US sanctions restrictions and complex questions arising under Russia primary sanctions.

Completed a compliance risk program assessment of policies and procedures for a global US defense contractor, including third-party due diligence procedures, with a focus on harmonizing US and non-US policies and procedures. The risk assessment included a full review and gap analysis of US/non-US policies.

Investigated the Indian operations of an international healthcare provider in response to whistleblower complaints alleging real estate-related foreign bribery and kickbacks.

Conducted an internal investigation involving alleged bribery and corruption in South and Central America on behalf of a medical device manufacturer.

Conducted due diligence regarding the business ethics and integrity of numerous global agents and distributors on behalf of a manufacturer of security equipment.

Conducted a compliance audit of Mexican operations of a publicly traded security equipment manufacturer.

Conducted several internal investigations involving potential corruption issues in Saudi Arabia and United Arab Emirates on behalf of a global oilfield services and equipment provider and security equipment manufacturer.

Performed anti-corruption compliance due diligence for a provider of products and services for the energy industry in connection with a US$10 billion multinational merger involving more than 700 global resellers, agents, and distributors.

Conducted a compliance audit of Asian operations of a publicly traded US transportation and logistics company.

Prepared compliance policies and procedures for a US airline company.

Completed a compliance risk assessment of operations at the Philippines subsidiary of a US publicly traded technology manufacturer. The scope included environmental compliance, conflicts of interest, ABAC, procurement procedures, labor union relations, and EHS issues.

Represented a global manufacturer in five separate cross-border investigations involving alleged misconduct at subsidiaries in China, Malaysia, and Australia. Issues included fraud, corruption, and conflicts of interest/self-dealing. The matters involved forensic collections of computers and phones from employees in Malaysia and China and multiple rounds of interviews in both countries. The Australia investigation was in response to a government raid on a subsidiary’s office and subsequent detention and questioning of the managing director of the subsidiary.

Conducted an internal investigation regarding alleged IP theft by the China-based subsidiary of a global software company.

Provided modern slavery due diligence, contract negotiation, and policy advice to a multinational coffee business.

Drafted human rights policies and procedures, including a supplier code of conduct, for a global leader in the development and management of high-integrity, high-impact programs for climate, sustainable development, and environmental projects.

Assisted a global beauty company with supply chain mapping.

Performed a modern slavery risk assessment for an international horticulture company.

Negotiated remediation of allegations of forced labor in APAC facilities on behalf of a manufacturer of safety workwear.

Developed tailored AML programs, including KYC, EDD, and source of funds due diligence, for a global leader in the development and management of high-integrity, high-impact programs for climate, sustainable development, and environmental projects.

Assisted a bank holding company with day-to-day Bank Secrecy Act (BSA), USA Patriot Act, and applicable UK laws and regulations relating to AML compliance and monitoring.

Performed a compliance assessment involving multiple workstreams/disciplines on behalf of a global media and communications company with subsidiaries in more than a dozen countries, including the European Union, United Kingdom, Australia, and China. The scope involved preparation of heat map, risk register, and priority roadmap.

Completed a compliance assessment of operations in China, Brazil, and Mexico, which included engaging and supervising a forensic accounting team, on behalf of a global industrial product manufacturer. Deliverables included a risk register and priority roadmap.

Performed targeted compliance risk assessments on behalf of a cosmetics company with operations in China, Russia, and Mexico.

Completed a compliance risk assessment relating to manufacturing operations in Malaysia, including a focus on third-party involvement in obtaining licenses, permits, and tax incentives.

Engaged as EMEA regional compliance counsel by a global electronics manufacturing company. Activities include monitoring and testing of compliance program effectiveness; establishing key compliance metrics; counseling with respect to development and implementation of compliance policies and procedures; triage of compliance red flags and reported concerns; developing a compliance communication plan, including regular conferences with senior leadership across the region to ensure alignment of principles and commitment to building a compliance culture; conducting due diligence regarding high-risk third parties, including open-source review, interviews, and contract negotiations; and advising regarding EU regulations relating to procurement and supply chain compliance.

Conducted post-acquisition anti-corruption compliance due diligence and risk assessment of a newly acquired Brazil subsidiary on behalf of an engineering and technology conglomerate, including forensic review of the accounting books and records, policy review, and onsite interviews with key personnel in Brazil.

Conducted a cross-border investigation in response to a whistleblower complaint for a global chemical manufacturer. The matter involved more than a dozen interviews in Germany, the United States, Italy, Switzerland, and the Netherlands.