Tom Best is an international investigations, enforcement defense and compliance lawyer, and a partner in the Investigations and White Collar Defense practice based in the firm’s Washington, D.C. office. He advises senior management and boards of directors on complex investigations, enforcement, compliance, and commercial issues arising under the U.S. Foreign Corrupt Practices Act (FCPA) and other countries’ anti-corruption laws, economic sanctions and export controls, the U.S. securities laws, and other legal regimes affecting major multinationals’ operations.
Mr. Best has defended dozens of companies and individuals over the years before the U.S. Department of Justice, Securities and Exchange Commission, U.S. Treasury’s Office of Foreign Assets Control (OFAC), UK Serious Fraud Office (SFO), Financial Conduct Authority (FCA) and other countries’ authorities. He routinely advises large corporate and financial institutions on compliance with economic and financial sanctions in high-value transactions.
Mr. Best is known for his practical, business-focused approach. His willingness to “roll up his sleeves” for clients has resulted in numerous declinations-of-prosecution from the U.S. Department of Justice, SEC and OFAC, and a strong track record of achieving innovative solutions, often working with regulators and enforcement agencies, to business problems presented by the complex and difficult sanctions and export control environment prevailing today.
- The Legal 500's Dispute Resolution – Economic Sanctions (2021)
- Recognized in Global Investigations Review’s “40 Under 40” List (2014)
- University of Michigan Law School, J.D. 2002, cum laude
Associate Editor, Journal of International Law
- Princeton University, A.B., 1997, Economics
- Cross-Border Investigations and Enforcement
- Global coordinating defense counsel on a near-half-billion dollar settlement between a global financial institution and the United States DOJ, SEC and UK FCA, and other national law enforcement agencies relating to corruption and fraud allegations in a sub-Saharan African country.
- Secured a declination-of-prosecution from the US DOJ on behalf of a major European industrial conglomerate relating to an Eastern European nation and allegations of corruption.
- Secured a declination-of-prosecution from the US DOJ on behalf of an oilfield service provider relating to corruption allegations in India.
- Representing a global medical device manufacturer before DOJ and SEC in connection with an FCPA investigation in India.
- Secured the removal of sanctions/de-listing of numerous individuals and entities subject to US, UK and EU, sanctions.
- Represented a consortium of international banks in connection with their ongoing obligations to comply with economic sanctions under multiple U.S., EU, and other sanctions regimes and their credit exposure to sanctioned companies.
- Representing multiple international financial institutions in connection with ongoing sanctions compliance and enforcement matters before OFAC, OFSI, and other regulators globally.
Engagement & Publications
- Moderator, “How to Effectively Structure, Scope and Manage the Process from Start to Finish,” C5’s 5th Annual Anti-Corruption Nordics Conference, Oslo, Norway, January30, 2019
- Moderator, “A Deep Dive into the Newest Third Party Risks Confronting Multinationals in the APAC Region,” C5’s 7th Annual Asia-Pacific Summit on Anti-Corruption, Singapore, November 2, 2018
- Moderator, “What Would You Do If …Practical Guidance for Working through Pressing, High-Stake Scenarios,” C5’s 7th Annual Asia-Pacific Summit on Anti-Corruption, Singapore, November 1, 2018.
- “Status Report on FCPA Enforcement Priorities,” American Conference Institute’s 12th Houston Forum on the Foreign Corrupt Practices Act, Houston, TX, January 24, 2018
- “Export Controls, Sanctions, and Transparency Requirements,” Georgetown Law Institute of International Economic Law, Washington, D.C., November 17, 2017
- “Global Corruption Risk Assessments: How to Effectively Map Your Company’s Greatest Risks,” 8th Global Forum on Anti-Corruption Compliance in High Risk Matters, Washington, D.C., July 26, 2017
- “Effective Benchmarks for Your Anti-Corruption Compliance Program,” The Knowledge Group, March 8, 2017
- “Walking the Thin Line Between Business and Bribe: Gifts, Travel and Hospitality,” American Conference Institute’s Houston Forum on the Foreign Corrupt Practices Act, Houston, TX, January 31, 2017
- “FCPA Year in Review 2016,” TRACE Webinar, December 14, 2016
- “Foreign Corrupt Practices Act,” Federal Publications Seminars, Arlington, VA, October 24, 2016
- “What is a Good Compliance Metric?,” American Conference Institute’s 10th Houston FCPA Boot Camp, Houston, TX, January 26, 2016
- “Foreign Corrupt Practices Act,” Federal Publications Seminars, Arlington, VA, October 26, 2015