From New York to Saudi Arabia: forging a path in criminal law

Cybersecurity is “a cat-and-mouse game,” says Will Hauptman—and not so different from his early investigative work. Today, he’s practice area lead counsel, investigations, data privacy and cybersecurity, compliance transformation, at Aramco, one of the world’s largest integrated energy and chemicals company.

He credits his four years as an assistant district attorney (ADA) and his regulatory compliance work at Shearman & Sterling with teaching him the skills he still uses.

Criminal law has defined Will’s career: “I’ve always said if I wasn’t doing criminal legal work, I’d just as soon work in a bakery. This one area of the law really spoke to me.”

This wasn’t always the case, though. When Will graduated with a major in Political Science and minor in English, he wasn’t sure what he wanted to do. “I was interested in politics and law,” he says, “but I hadn’t figured out what that meant yet.”

He worked on Capitol Hill—the U.S. Congress in Washington, D.C.—before taking a job as a paralegal at the Department of Justice. There, he was assigned to a large criminal investigation in Miami involving narcotics and arms trafficking, money laundering, and other financial crimes.

“That was my first exposure to criminal law,” he says, “and after six months in Miami, I knew that was what I wanted to do.”

Trial Phase

Will attended New York Law School and took every criminal law and evidence class available. After his first year, he spent his summer as an intern at the U.S. Attorney’s Office for the Eastern District of New York, assisting on a large, organized crime case. During his second-year summer, he interned in the Trial Division of the Manhattan District Attorney’s Office. “Those experiences heightened my interest in that line of work,” he says.

After law school, Will joined the Manhattan District Attorney’s Office as an ADA, handling cases involving narcotics, bank fraud and violent crime. As much as he enjoyed his four years there, he didn’t see himself as a career prosecutor; he wanted to work on complex matters involving clients from all over the world.

White-collar work

So Will joined Shearman & Sterling. He first worked in the Bankruptcy group, utilizing his advocacy skills in Delaware Bankruptcy Court. After two years, he moved to the Litigation group, where he spent the next six years focused on white-collar defense and regulatory compliance work—which would be useful later, first at Caterpillar and then at Aramco.

“Shearman & Sterling was a wonderful place to work,” says Will. “It was a very collegial atmosphere—and that can be rare in big law firms. The hours were long, of course, but the work was always interesting and the lawyers and support staff were exceptional.”

The merger has given A&O Shearman a much stronger international presence, which, Will says, is essential: “One of the things I always look for when hiring a law firm is whether they have feet on the ground where I need them, and whether they have local law expertise.

“What I really want, though, is someone who understands that my internal clients often aren’t lawyers, and they don’t need or want a legal treatise on an issue: they want practical, strategic and actionable legal advice that helps the company achieve its goals.”

A highlight from Will’s time at Shearman & Sterling was his involvement in a criminal trial in Eastern District New York.

“The trial team lived in Central Islip, on the eastern end of Long Island, in the dead of winter for six weeks,” Will recalls. “It was very cold, and the days were very short; we would wake up in the morning and there would be another 10-12 inches of snow.

“We worked around the clock preparing dozens and dozens of witnesses. It was full-on, with multiple defendants and a 90-page indictment. It was a remarkable experience—a great team and a good result for the client. It was challenging but also rewarding.”

Another experience that has stayed with him was spending six weeks with the prosecutor’s office of the U.N.War Crimes Tribunal for Rwanda in Arusha, Tanzania, in 2006. “I was fortunate to be a part of cross-examinations, direct examinations and witness prep. The case I was working on involved a Hutu priest in a remote part of Rwanda.

"When the genocide started, his entire congregation of 2,000 Tutsis came to the church for refuge. When the Hutu militia came, not only did he not do anything to protect his flock, but he actively assisted in their genocide. Horrific does not begin to describe it.”

Career chrysalis

After seven-and-a-half years with the firm, Will left Shearman & Sterling, and in 2010 joined Caterpillar at its world headquarters in Peoria, Illinois. “At the time, my wife and I had three young daughters, and I had been considering moving in-house so I would be able to spend more time with them,” he says. “A recruiter contacted me about the Caterpillar position, and I jumped at the opportunity.”

Caterpillar had just completed a risk assessment of its global anti-bribery compliance program. It called for a variety of enhancements and new measures, and Will was hired to design, implement and manage the new program.

“My work involved everything, including training, due diligence, compliance advice and investigations,” he says. Three years later, Caterpillar created a standalone investigation group, walled off from the compliance team to prevent any appearance of conflicts of interest, and Will was asked to lead it.

After five years at HQ, Will was asked to provide commercial legal support to Caterpillar’s subsidiary, Solar Turbines in San Diego. In 2016, he was asked to lead its export controls compliance team.

That same year, a recruiter for Aramco in Saudi Arabia got in touch. “My wife and I had always wanted to live as expats and experience life overseas,” he says. “Given our kids’ ages, the timing was good for us to make the move.”

A new challenge

Will served as the lead attorney for Aramco’s regulatory investigations practice area. Then, in 2022, he was asked to become a practice area lead attorney for investigations, data privacy and cybersecurity and compliance transformation. He says: “I’ve been fortunate to have been involved in developing the compliance programs at both Caterpillar and Aramco, and I credit much of what I’ve done to what I learned at Shearman & Sterling, and in particular, to Dan Newcomb who was a terrific mentor and teacher.”

Cybersecurity is an ever-evolving challenge. “It seems like every day you read in the news about a new data leak, cybersecurity breach or other technology-related incident, which requires companies to react in real time before any damage can be done,” he says. “It’s imperative that they—and, importantly, their vendors and suppliers—have appropriate measures in place to ensure a strong and stable network to protect the company and its clients against cyberattacks.”

One of the biggest challenges now is artificial intelligence (AI). “Companies are racing at breakneck speed to develop AI models for all sorts of uses and the law is struggling to keep up,” he says. “The challenge for lawyers is to figure out how to stay on top of all the AI-related initiatives and to ensure compliance with all relevant laws and guidance.”

Saudi life

Life in Saudi Arabia is “very good,” says Will, but he and his wife miss family, friends, and the fish tacos in San Diego—although he can now recommend some great shawarma places! He says: “The Saudi people are wonderfully gracious and kind, and there is no question that our family has taken something important away from our experience here and it has made us much better people for it.

“There’s really no substitute for experiencing other cultures first-hand, and being able to share that with our kids has been transformative for all of us.

"We have had the good fortune to meet and work with people from all over the world and our kids have been to places that we never dreamed possible: Thailand, Oman, the Maldives, Ethiopia, Tanzania, Egypt and virtually every country in Europe.

“I’ve been extremely fortunate in my career. I found something I’m interested in, and I was able to pursue that work in a variety of places and settings. I’ve also had several mentors along the way, including the partners at Shearman & Sterling, who were willing to take the time to help me develop as an attorney, and for which I am grateful.”

Reconnect with Will Hauptman