
Overview
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, and compliance 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 defends investigations and enforcement actions before the U.S. Department of Justice (DoJ), Securities and Exchange Commission (SEC), U.K. Serious Fraud Office (SFO) and FCA, the U.S. Treasury’s Office of Foreign Assets Control (OFAC), the World Bank Integrity Unit Vice Presidency, and numerous other government and quasi-governmental agencies.
He has defended dozens of companies and individuals over the years in diverse industries such as financial services, metals and mining, oil and gas, light manufacturing, pharmaceuticals and medical devices, and many others.
Mr. Best is known for his practical, business-focused approach to the international challenges facing companies. He is also known for his willingness to “roll up his sleeves” and be hands-on for his clients. His on-the-ground investigations experience includes major economies in Sub-Saharan Africa, India, Latin America, Asia, Russia, and Europe. Given his experience as a former M&A attorney at a major international law firm in the United Kingdom, clients often turn to Tom to assist them with managing FCPA/anti-corruption, economic sanctions, and other risks in complex M&A transactions.
Recognitions
- The Legal 500's Dispute Resolution – Economic Sanctions (2021)
- Recognized in Global Investigations Review’s "40 Under 40" List (2014)
Education
- University of Michigan Law School, J.D. 2002, cum laude
Associate Editor, Journal of International Law - Princeton University, A.B., 1997, Economics
Representations
- A global financial institution as international defense counsel in parallel investigations by the United States Department of Justice, Securities and Exchange Commission, U.K. Financial Conduct Authority, and other national law enforcement agencies relating to corruption and fraud allegations in a sub-Saharan African country.
- A major European industrial conglomerate in an investigation by the U.S. Department of Justice and an Eastern European nation into allegations of corruption. Secured a public declination-of-enforcement by the U.S. Department of Justice.
- A publicly-traded U.S.-based oilfield services company in its FCPA investigations and resolutions with the U.S. Department of Justice and Securities and Exchange Commission.
- 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.
- Senior legal executives before the U.S. Securities and Exchange Commission and foreign regulators in ongoing parallel FCPA/anti-corruption investigations.
news
- Paul Hastings Named ‘White Collar Group of the Year’ by Law360 - January 27th, 2022
- Paul Hastings Named to World’s Top 10 Best Investigations Practices by Global Investigations Review - October 23rd, 2020
- Paul Hastings Accelerates Lateral Growth with Addition of Leading Entertainment and Media Litigation Partner - June 22nd, 2020
- Paul Hastings Wins National Law Journal’s Washington, D.C. White Collar Litigation Department of the Year Award - May 29th, 2020
- Paul Hastings Hires OECD Director of Legal Affairs Nicola Bonucci - November 18th, 2019
- Paul Hastings Energizes Houston Transactional Practice with Partner Duo, Continues Global Lateral Surge - October 1st, 2019
- Paul Hastings Continues Corporate Growth Hot Streak, Adding Prominent Capital Markets Partner in Los Angeles - August 19th, 2019
- Paul Hastings’ Leading Latin America Practice Welcomes Preeminent M&A/Capital Markets Team in São Paulo - August 8th, 2019
- Barrick Gold Deputy General Counsel Joins Paul Hastings in Washington, D.C. - May 13th, 2019
- Paul Hastings Continues Growth, Adding Top FCPA White Collar Litigators in Washington D.C. - April 10th, 2019
Recognitions
- Paul Hastings Ranked Top 5 in Global Investigations Review's "The GIR 30" 2022 - November 22nd, 2022
- Paul Hastings Championed as Most Impressive Investigations Practice by Global Investigations Review - November 10th, 2021
- Recognized among the World’s Top 10 Best Investigations Practices by Global Investigations Review for 2020 - October 23rd, 2020
- Recognized as the National Law Journal’s Washington, D.C. White Collar Litigation Department of the Year - May 27th, 2020
- Recognized in the Global Investigations Review’s GIR 100 for 2019 - October 24th, 2019
insights
- New U.S. Outbound Investment Restrictions on High-Technology Sectors in China - August 11th, 2023
- DOJ OFAC BIS Joint Compliance Note and Enhanced Coordination Highlights Increased Enforcement Risk - August 4th, 2023
- OFAC-OFSI Enhanced Working Partnership - October 20th, 2022
- U.S. Government Agencies Continue to Highlight Risks of Money Laundering Associated with Russia Kleptocrats, Deny Access to U.S. Financial System - May 10th, 2022
- Three Weeks In, the West Continues to Impose Severe Sanctions on Russia; U.S. Begins Enforcement Push - March 16th, 2022
- Three Weeks In, the West Continues to Impose Severe Sanctions on Russia; U.S. Begins Enforcement Push - March 16th, 2022
- Western Countries Enact Sweeping Sanctions Packages In Response to Invasion of Ukraine - March 1st, 2022
- Western Countries Enact Sweeping Sanctions Packages In Response to Invasion of Ukraine - February 28th, 2022
- The Ukraine Crisis: Sanctions Scenarios in the Event of Russian Invasion - February 16th, 2022
- The Ukraine Crisis: Sanctions Scenarios in the Event of Russian Invasion - February 16th, 2022
- PL 117-78 (December 23, 2021): The Uyghur Forced Labor Prevention Act - December 27th, 2021
- U.S. Expands Sanctions on Belarus, Aligning More Closely with Canada, EU, and UK - December 3rd, 2021
- On Your Mark, Get Set, Get Ready to Go -- Release of National AML Priorities Means Financial Institutions Will Need to Assess, Amend Their Anti-Money Laundering Programs - July 2nd, 2021
- China Enacts Anti-Foreign Sanctions Law: Increasing Uncertainty for Companies with China Operations - June 16th, 2021
- Biden Administration Ratchets Up Pressure by Refining Trump-Era Limits on Investing in PRC Companies - June 8th, 2021
- Biden Administration Ratchets Up Pressure by Refining Trump-Era Limits on Investing in PRC Companies - June 8th, 2021
- Biden Administration Pursues Suite of Actions Against Russia - April 15th, 2021
- U.S. Reimposes Sanctions on Myanmar (Burma) in Response to Military Coup - February 12th, 2021
- The United States, Canada, and United Kingdom Take Action on Forced Labor in Xinjiang - February 4th, 2021
- The Trump Administration Adds 77 Companies to the Entity List - December 18th, 2020
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