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.
- 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
- 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.
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