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Anne Hukkelaas Gaustad

Paris

+33 (0) 1 44 05 80 57

[email protected]
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Anne Hukkelaas Gaustad is Co-Chair of Hughes Hubbard’s Global Investigations, Enforcement and Compliance group in Europe and a member of the Sanctions, Export Controls and Anti-Money Laundering group. She is also 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 as a “Future Leader” by the Who’s Who Legal Guide 2024 (Category: Investigations – Partners – France
  • 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 Guides 2021-2024 (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)

Selected Lectures

  • "The Role of EU Courts in Shaping Sanctions Compliance Standards", Webinar, Association of Certified Sanctions Specialists (ACSS), January 16, 2025 
  • « Håndhevelse av sanksjonsregelverket i EU», Sanksjonsnettverket / CMS Kluge, September 19, 2024
  • “New French Anti-Corruption Investigative Guidance,” Hughes Hubbard and Reed’s All Things Investigations, Podcast, Episode 28, May 22, 2023
  • “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

Quotes & Interviews

  • Quoted in "DJI, le géant chinois des drones que les Etats-Unis détestent", L'Express (January 2025)
  • Quoted in “Forsvaret, Statsbygg og Equinor pumper inntekter til russisk oligark: Har storkontrakter og milliardomsetning i Norge," (The Armed Forces, Statsbygg and Equinor Pump Revenues for Russian oligarchs: Has Large-Scale Contracts and Billion-Dollar Turnover in Norway) Dagens Næringsliv (March 2022)
  • Quoted in “Loi Sapin II : Il est urgent de se mettre en conformité," (Loi Sapin II: Becoming Compliant is a Priority"), DAF magazine n° 39 (June 2019)

Clerkship

  • 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
Marking Three Years of Russian Invasion of Ukraine, the EU Adopts 16th Sanctions Package Against Russia, and Expands Sanctions Against Belarus and Occupied Ukrainian Territories
Client Advisories
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Navigating the Pause: FCPA Compliance Under Trump’s New Order
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EU Adopts 15th Sanctions Package Against Russia, First Designations under Russia Hybrid Threats Sanctions Program, New FAQs on Ukraine-Related Sanctions, and Numerous Designations under the Haiti, Sudan and North Korea Sanctions Programs
Client Advisories
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European Commission Releases FAQs on the “Best Effort” Obligation under EU Sanctions Against Russia and Belarus
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EU Commission Publishes New Guidelines on Scope of Catch-All Controls and Due Diligence Requirements for Exporters of Non-Listed Cyber-Surveillance Items
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EU Adopts New Sanctions Program Targeting Destabilizing Activities by Russia against the EU, its Member States and Third Countries
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Recent Recognitions for Hughes Hubbard’s Anti-Corruption and Internal Investigations Group
Client Advisories |
Awards
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​Impact of Schrems II On Anti-Corruption Compliance Programs
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Compliance Continuity in the Face of COVID-19
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News

Firm Named to Global Investigations Review’s GIR 30 List for Second Year in a Row
News & Events
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Hughes Hubbard Announces New Deputy Co-Chair; Strengthens Global Investigations, Enforcement and Compliance Practice with New Leadership
News & Events
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Firm Named to Global Investigations Review’s GIR 30 List
News & Events |
Awards
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Firm Named to 2021 Global Investigations Review (GIR) 100
News & Events
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Partner Anne Gaustad Named Among Global Investigation Review’s Leading Women in Investigations
News & Events |
Awards
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Anne Gaustad Named to Global Investigations Review's "40 Under 40" List
News & Events |
Awards
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In Jota: Compliance Continuity in the Face of COVID-19
Articles & Press
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In The Anti-Corruption Report: How AFA Compliance Program Controls Are Changing the French Anti-Corruption Compliance Landscape
Articles & Press
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Celebrating International Women's Day
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People
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Hughes Hubbard Promotes Four to Partnership and Ten to Counsel
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FCPA & Anti-Bribery Alert Fall 2016
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Education
  • New York University School of Law, LL.M., 2008, Fulbright Foreign Fellowship
  • The College of Law, London, Diploma, Law, 2007
  • University Panthéon-Assas Paris II, DEA, Public International Law, 2005
  • Oxford University, Diploma, Legal Studies, 2004, with High Distinction
  • University Panthéon-Assas Paris II, LL.B., 2003
Bar Admissions
  • District of Columbia
  • France (Paris)
  • New York
  • Norway
Languages
  • Danish
  • English
  • French
  • German
  • Norwegian
Areas of Focus
Arbitration
Environmental, Social & Governance (ESG)
Global Investigations, Enforcement and Compliance
Multilateral Development Bank Investigations and Sanctions
Sanctions, Export Controls & Anti-Money Laundering

Hughes Hubbard & Reed LLP

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