Anne Hukkelaas Gaustad is a partner in Hughes Hubbard’s Anti-Corruption & Internal Investigations, Sanctions, Export Controls and Anti-Money Laundering groups and a member of the firm’s Executive Committee. Her practice focuses on anti-corruption, economic sanctions and export controls, business and human rights, and complex multijurisdictional internal and regulatory investigations. She has assisted on a range of anti-corruption matters as well as international commercial and investment disputes. Anne advises clients on anti-corruption matters involving the U.S. Foreign Corrupt Practices Act, the UK Bribery Act, French and Norwegian anti-corruption laws, economic sanctions and export controls, corporate governance and compliance, as well as on white-collar criminal defense, securities law, and business & human rights matters.
Anne has particular experience assisting clients in conducting anti-corruption compliance reviews, internal investigations, anti-corruption risk assessments, third-party due diligence, designing and implementing risk-based corporate compliance programs, and assessing risks under international and national anti-corruption frameworks, including in connection with inquiries by the U.S. DOJ and SEC, Norway’s Økokrim, France’s Agence française anti-corruption, French prosecution services, and the World Bank. Her experience includes leading an engagement involving the global risk assessment and compliance review of a multinational “supermajor” oil and gas company that includes global risk assessments, compliance reviews, and ongoing compliance monitoring. She also advises a multinational networking and telecommunications company and a multinational automotive company on global anti-corruption compliance matters. In connection with her anti-corruption work, Anne has traveled extensively, including to Algeria, Angola, Azerbaijan, the Republic of the Congo, the Czech Republic, France, Gabon, Indonesia, Italy, Kazakhstan, Kenya, Lebanon, Mauritania, Myanmar, Nigeria, Norway, Papua New Guinea, the Philippines, Poland, Qatar, Russia, South Africa, Turkey, the UAE, Uganda, and the United Kingdom. She has also represented a leading pharmaceutical company in litigation before a Norwegian court.
Prior to joining Hughes Hubbard, Anne worked at law firms located in Oslo, London, and Paris. In addition, she served as a law clerk in the Office of The Prosecutor (Appeals Section) at the International Criminal Court in The Hague.
Recognitions
Recognized in The Legal 500 EMEA- France: Compliance as a Recommended Lawyer (2021, 2022)
Named to Global Investigation Review’s “Women in Investigations 2021” list
Recognized as a “Future Leader” by the Who’s Who Legal Guide 2021 (Category: Investigations – Partners – France)
Recognized as one of 40 of the world’s leading young investigations specialists under 40 by the Global Investigations Review 2020
Selected Publications
"Towards a More Comprehensive Human Rights Due Diligence Regime: The Promise of the New Norwegian Transparency Act," Revue International de la Compliance et de l’Éthique des Affaires (October 2021) (article co-authored with Marie-Agnès Nicolas)
"How to Refit your Company’s Compliance Programme in the Post-Covid 19 Workplace,” Global Investigations Review (April 2020) (article co-authored with Ayoka Akinosi)
"Reflections on the Deferred Prosecution Agreement in the United States and France,” Round table, Cahiers de droit de l’entreprise, N° 6 (November-December 2019)
"Italy Adds Another Piatto to its Anti-Corruption Enforcement Menu: A Look at How the New ‘Bribe-Destroyer’ Law Strengthens Italy’s Existing Anti-Corruption Arsenal and Enhances the Transparency of Contributions to Political Parties,” International Review of Compliance and Business Ethics n° 2 (April 2019) (article co-authored with Arnaldo Bernardi)
"How AFA Compliance Program Controls Are Changing the French Anti-Corruption Compliance Landscape,” The Anti-Corruption Report (April 2019) (article co-authored with Bryan Sillaman)
"Les premiers rapports de contrôle de l’AFA - La révolution préventive se confirme : impossible ne saurait être français !,″ International Review of Compliance and Business Ethics (Article published as part of the Article series ″Les contrôles de l’Agence Française Anticorruption. Lumière sur ses premiers contrôles et réflexions sur sa mission préventive″) (September 2018) (article co-authored with Marie-Agnès Nicolas)
"La Convention Judiciaire d’Intérêt Public : Quelle compatibilité entre intérêt public de la Société et intérêt privé des sociétés?” (“The Judicial Public Interest Agreement: Is the Public Interest Compatible with Companies’ Private Interest?”), article published as part of the Article series “Loi Sapin 2, FCPA, UKBA, CCA: Comment ne pas se perdre dans le dédale de la conformité?” (“Loi Sapin 2, FCPA, UKBA, CCA: How Not to Get Lost in the Compliance Maze?”), Cahiers de Droit de l’Entreprise n° 2 (March-April 2017) (article co-authored with Marie-Agnès Nicolas)
"L’Agence française anti-corruption et la corruption : Vaccin, antidote ou placebo?," Revue internationale de la compliance et de l’éthique des affaires / International Review of Compliance and Business Ethics (March 2017) (article co-authored with Marie-Agnès Nicolas)
"Procédure de sanctions de la Banque mondiale - Guide pratique: à quoi s’attendre, comment y répondre?” Revue internationale de la compliance et de l’éthique des affaires / International Review of Compliance and Business Ethics (June 2016) (article co-authored with Tamara Kraljic)
“Investigating Corruption: different jurisdictions – different ways,” Association of Corporate Investigators & Advokatfirman Vinge KB, webinar, September 13, 2022
“Regulatorisk utvikling – utredning om endringer i bestemmelsene om foretaksstraff og korrupsjon” (“Norwegian regulatory developments: White paper and recommendations to the Ministry of Justice and Public Security regarding changes to the provisions governing corporate criminal liability and corruption”), 8th Norwegian Anti-Corruption Conference, June 9, 2022
“Economic Sanctions & Export Controls in a Time of Crisis: Key Issues & Current Challenges,” Konsernadvokatseminaret – Advokatfirmaet Haavind, Oslo, Norway, May 24, 2022
“Takeaways from Recent Enforcement Activity Involving the Nordics,” C5’s 7th Annual Conference on Anti-Corruption Nordics, January 27, 2021
"Defense Counsel War Stories – Structuring and Managing the Costs of Multi-Jurisdictional Investigations,” C5's 6th Annual Conference on Anti-Corruption Nordics, Oslo, Norway, January 31, 2020
"FCPA Enforcement and Compliance in the Energy Sector: Trends and Updates," The Knowledge Group, webinar, May 7, 2019
"Whistleblowers: Trends & Key Considerations for Internal Programs," C5's 5th Annual Conference on Anti-Corruption Nordics, Oslo, Norway, January 30, 2019
"De l’audit interne à la gestion de crise: Gérer une enquête interne ou externe,ʺ Compliance training seminar for the Association française des juristes d’entreprise, Paris, France, November 7, 2017
"La compliance, vecteur d'amélioration opérationnelle et de stratégie - Les Droits de l’Homme : Les entreprises, face au nouveau défi de la compliance“ (Are Human Rights the Next Thing in Compliance?), Petit déjeuner De l’Esprit des Lois, Cercle Montesquieu, Paris, France, February 1, 2017
"Mitigating Corruption Risks in Joint-Ventures & Consortia,” 6th Annual Business Ethics, Anti-Corruption & Fraud Prevention Strategies in CEE, SEE & CIS Conference, Prague, Czech Republic, March 26, 2015
"The FCPA & Beyond,” 5th Annual Anti-Corruption Compliance Strategies in CEE Conference, Prague, Czech Republic, March 21, 2014
Law Clerk, Office of The Prosecutor, Prosecution Division (Appeals Section), International Criminal Court, The Hague, The Netherlands
Highlighted Matters
Assisting a European telecommunications company in connection with global anti-corruption risk assessment
Assisting a U.S.-based retail company in designing human rights policies and procedures
Assisting a multinational automotive company in connection with the performance of a global risk assessment and design of compliance policies and procedures
Assisted a multinational “supermajor” oil and gas company in connection with a worldwide risk assessment and compliance review as part of an independent monitorship
Assisted with compliance and insider trading issues for a large sovereign wealth fund
Assisting a Norwegian company in connection with anti-corruption investigations related to a development project in Tanzania
Worked on an investigation for a multinational telecom company relating to allegations of corruption involving operations in Tajikistan, Kazakhstan, and Uzbekistan
Assisted on anti-corruption matters involving the World Bank Group, corporate social responsibility, WTO matters, and regulatory EU/EEA matters
Assisted in a range of international commercial and investment disputes in the construction and oil and gas industries
