Andy SEE（International Partner）- AnJie Broad

Andy See has 25 years of cross-border and regional legal experience across high-tech and telecom industries, of which 18 years in two Fortune 500 companies and 7 years in a top international law firm. He was previously Managing Director for APAC Geographic Legal Services and Legal Director for Greater China, and he is the first Chinese to serve as a member of the Global Legal Executive Leadership Team in Accenture.

Andy See brings a wealth of experience in law, compliance, and corporate management, with a multifaceted background as an international lawyer, strategic consultant, general counsel, and senior executive. He specializes in integrating legal, business, and technological perspectives to deliver practical solutions in high-stakes international transactions, complex commercial negotiations, cross-border dispute resolution, and mediation.

With strong local roots and a global outlook, Andy See advises clients in China on complex regulatory compliance matters, regulatory enforcement actions, and criminal investigations. Internationally, he supports MNCs in navigating high-stakes government enforcement actions and managing cross-border crisis situations.

Andy See delivers comprehensive corporate compliance services, assisting clients in establishing robust compliance framework aligned with both domestic and international standards. He conducts internal investigations to recover significant corporate losses, performs risk assessments through compliance audits, and resolves complex regulatory challenges. His expertise spans a wide array of compliance areas, including sanctions and export controls, integrity and white-collar crime compliance (such as anti-fraud measures), anti-corruption and anti-bribery programs, cybersecurity and data protection, crisis management, global compliance strategies, compliance system implementation, and compliance certification.

Representative Cases

Major Crisis Management

Served a Fortune 500 multinational company in China during a major crisis involving an investigation into China’s Anti-Monopoly Law, responding to the government’s investigation and successfully resolving the crisis.
Provided services to a high-tech company facing a cash flow crisis, negotiating with several banks, leading the negotiation strategy, and successfully persuading the banks to agree to a RMB 10 billion accounts receivable acquisition, which enabled the company to survive the cash flow crisis.
Provided compliance and legal services for a well-known domestic game company whose game was removed by Apple, involving an amount of RMB 100 million. Assisted the company in establishing an anti-money laundering and anti-gambling compliance system, promoting its implementation, and facilitating the negotiation, which contributed to the successful resolution of the case.

Sanctions and Export Controls

Participated in a case where a listed company was placed on the SDN Sanctions List by the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC), conducting an internal investigation into the company’s products, customers, overseas operations, and export control and sanctions compliance system, and advocating for the company’s removal from the SDN List (still in progress).
Provided legal support to a domestic cross-border logistics company (with operations in more than 30 countries across Europe and North America) in understanding the legal requirements and compliance risks related to export controls and sanctions in the European Union, the United Kingdom, China, the United States, and Australia.

Anti-Corruption

Provided legal counseling to a domestic cross-border logistics company (with business in more than 30 countries across North America and Europe) regarding compliance with the UK Bribery Act, France’s anti-corruption laws, Germany’s anti-corruption laws, the U.S. Foreign Corrupt Practices Act (FCPA), and China’s anti-corruption laws.
Participated in the anti-corruption compliance system construction services for the Hungarian subsidiary of a domestic lithium battery manufacturing company (listed company), assisting the company in formulating anti-corruption compliance system, manuals, and related processes, and promoting the implementation of the system.
Responsible for resolving key compliance and regulatory issues at a Fortune 500 multinational, conducting forward-looking risk management, assisting with corporate investigations and dispute resolution, such as anti-corruption investigations, employee reimbursement monitoring and analysis, misuse of competitors' confidential information, government raids, streamlining of business intermediary processes, and assisting with dispute resolution.
In the case of an Asian subsidiary of a Fortune 500 multinational company suspected of local bribery and tax compliance issues, led the negotiations with local prosecutors and tax authorities to minimize the impact on the company and reduce the company’s losses.
Led a compliance investigation for a China-based multinational company suspected of commercial bribery in the U.S., assisting in the anti-bribery compliance investigation, which resulted in a successful resolution of the case, saving the company hundreds of millions of dollars in business.

Cybersecurity and Data Protection

Provided legal services for a domestic cross-border logistics company (operating in more than 30 countries across Europe and North America), including legal services for offshore data compliance and other ongoing legal counseling services.
Advised a renowned technology R&D center in Hong Kong on cross-border data transfer compliance, assisting the client in effectively addressing the legal challenges of data compliance in the face of a myriad of domestic and international regulatory requirements.
Provided data compliance management system assessment and personal information protection impact assessment for a well-known centrally administered telecommunication enterprise.
Served as the head of the corporate cybersecurity working group at a Fortune 500 multinational company, responsible for cybersecurity and EU GDPR legal risk analysis and compliance assessment, supporting the business team in providing cybersecurity services to multiple Fortune 500 multinational companies.

Corporate Compliance Management System

Provided ISO 37301 compliance management system certification legal services for a well-known centrally administered telecommunication enterprise.
Provided ISO 37301 and ISO 37001 compliance management system certification legal services for a prominent centrally administered enterprise.
Provided compliance management system construction services for a well-known state-owned investment group.
Provided compliance management system construction services for a well-known real estate state-owned enterprise.
Provided compliance management system construction services for a well-known state-owned major industry enterprise.
Provided compliance management system construction services for a well-known state-owned enterprise in the precious metals and real estate business.
Provided compliance management system construction services for a well-known real estate and parks development enterprise.
Provided compliance management system construction services for a well-known state-owned architecture design enterprise.
Provided compliance management system construction services for a well-known gas investment state-owned enterprise.
Provided compliance management system construction services for a well-known investment and development state-owned enterprise.
Provided compliance management system construction services for a well-known construction state-owned enterprise.
Provided compliance management system construction services for a well-known investment state-owned enterprise.
Provided compliance management system construction services for a well-known venture capital state-owned enterprise.
Provided compliance-specific legal services to a well-known smart energy company.

Honors & Recognition

LegalOne Greater Bay Area Special Awards 2025 : Top 15 Legal Practitioners (Foreign-related Legal Services)
LegalOne Greater Bay Area Special Awards 2025 : Top 15 Legal Practitioners (TMT)
Delivered a keynote speech titled “How Infrastructure Businesses Cope with Challenges of Corruption in Belt and Road Countries” at the 2023 United Nations Global Compact (UNGC) Asia-Pacific 15 Annual Conference, held in conjunction with the China International Import Expo (CIIE); served as a core member of the anti-corruption report drafting team
Participated as an expert in the assessment and acceptance team for Shenzhen SASAC’s initiative on the "Pilot Construction of Corporate Compliance Systems and Integrity Programs" in four municipal state-owned enterprises: Shenzhen Investment Holdings Company Limited, Shum Yip Group, Shenzhen Metro Group Co., Ltd. and Guosen Securities Co., Ltd.
Served as an external expert invited by the Shenzhen Commission for Discipline Inspection and Supervision to contribute to the drafting of local standard Guidelines for Corporate Integrity and Compliance Governance (DB4403/T 585-2025); actively involved in the pilot evaluation of integrity and compliance in 10 Shenzhen enterprises
Guest lecturer for the Training Course on Capacity Enhancement of International Economic and Trade Rules, organized by the Organization Department of the CPC Shenzhen Municipal Committee and the CPC Greater Bay Area Office
Delivered lectures on risk prevention and dispute resolution at the Training Course for Enterprises Going Global in the Greater Bay Area, organized by the CPC Greater Bay Area Office, Shenzhen Federation of Industry and Commerce (SZFIC), and Shenzhen Council for the Promotion of International Trade (SCPIT)
Special compliance lecturer – Shenzhen Fair Trade Promotion Agency
Chief compliance lecturer – Shenzhen Baoan District Listed Enterprises Association.
Special lecturer on data compliance and legal technology – China Banking Association.
Leading Lawyers – Asian Law & Practice (1999-2001) (Andy See did not participate in any rankings from 2001 to 2019 during which he was in-house with Nortel Networks and Accenture)
Lawyer of the Year in Labor Law (China) – Asian Law & Practice (1998)

Professional Association

Member of National Technical Committee for Standardization of Institutional Governance (SAC/TC600)
Committee Member of Lan Hai Institute
Co-Director of Center for Data and Personal Information Compliance Research and Evaluation of Shenzhen University Compliance Research Institute
Expert Member of Special Committee on Shenzhen Data Transaction Compliance Consensus

Publications

International Compliance & Crisis Response

Opportunities and Challenges of Brazil-China Trade under the Impact of US Tariffs
How Chinese Enterprises Navigate and Respond to Overseas Crises
The Chip Wars: How Companies Should Respond to Escalating U.S. Sanctions on China's Semiconductor Industry
In-Depth Interpretation of the Chinese Military Enterprise List: Evolution and Strategic Responses
Navigating Export Controls: A Full Interpretation of the PRC Regulations on Export Control of Dual-Use Items

Anti-Corruption & Commercial Bribery

How Infrastructure Businesses Cope with Challenges of Corruption in Belt and Road Countries (UNGC Keynote)
Anti-Corruption Compliance in Private Enterprises: Perspectives on the Criminal Law Amendment (XII)
Commercial Bribery Risk in China: Five Typical Cases from the Supreme People’s Procuratorate
Global Bribery Risk Identification through the Case of Zhang Li

Data Protection

Eight Q&As on the Cross-Border Data Flow Provisions
SCC or BCR No Longer Required? Understanding the New EU–US Data Transfer Rules
Data Desensitization vs. Anonymization: What’s the Difference?
Special Provisions for Data Compliance in Shenzhen
Building Effective Data Compliance Systems under the Shenzhen Enterprise Data Compliance Guidelines
Data Compliance Essentials for Precision Marketing
Data Compliance Guidance Manual: Capital Markets, Finance, and Internet Industries
Data Compliance Challenges and Responses in China’s Gaming Industry
The “Internet Digital Regulation” and Its Impact on Business
Building Enterprise Data Compliance Systems in the Era of Enhanced Governance

Generative AI & Legal Ethics

The Compliance Essentials and Management Suggestions for AI under Chinese and Western Laws
Legal and Ethical Challenges of ChatGPT
Compliance Essentials and Regulatory Recommendations for AI under Chinese and Western Legal Frameworks

ESG

ESG Compliance for Chlor-Alkali Enterprises
ESG in Practice: Evolution, Purpose, and Key Requirements

Compliance Standards & Certification (ISO 37301)

What Are the Benefits of ISO 37301 Certification?
How to Build a Compliance System to Achieve ISO 37301 Certification
ISO 37301 Trends in International and National Certification
From Certification to Execution: Promoting SOE Compliance with the Draft Measures
Compliance Study: Comparing ISO 37301 with the Compliance Measures for Centrally Administered Enterprises

SOE (State-Owned Enterprises) Compliance

Compliance Challenges and Opportunities for SOEs under the Draft Measures for Centrally Administered Enterprises
Lessons from Shenzhen SASAC: Building SOE Compliance Systems
Highlights from Guangdong’s Provincial Action Program for Compliance in SOEs
Synergizing the Three Lines of Defense in Compliance Management
The Compliance Struggles and Deep-Water Zone for Chinese Enterprises
Integrated Innovation: An Analysis of the Impact of the Company Law on Compliance in State-Owned Enterprises and Strategic Responses

Working Experience

Partner, AnJie Broad Law Firm
Chair, Compliance & Regulatory Committee, Sundial Law Firm
Chief Legal Officer, Benchmark Chambers International & Benchmark International Mediation Center
Managing Director of Geographic Legal Services (Asia Pacific), Accenture
Head of Legal, Nortel Networks
Senior Associate, Clifford Chance

Education Background

Peking University, Bachelor of Laws (LLB)
Manchester Metropolitan University, Law Society Finals (Honors)
The University of Hong Kong, Common Professional Examinations in Law
Hong Kong Polytechnic University, Bachelor of Business Studies (Honors)

Qualifications

High Court of Hong Kong, Solicitor
Supreme Court of England and Wales, Solicitor
Greater Bay Area of the PRC, Lawyer