Jan Dunin-Wasowicz is Partner and Co-Chair of Hughes Hubbard & Reed’s Sanctions, Export Controls & Anti-Money Laundering practice group. He is also a member of the firm’s Anti-Corruption & Internal Investigations and Arbitration groups. Jan focuses his practice on cross-border compliance and enforcement, multi-jurisdictional internal and government investigations, as well as international dispute resolution.
As Co-Chair of the firm’s sanctions, export controls & anti-money laundering practice group, Jan has significant multi-sectoral experience advising on compliance with economic sanctions and trade controls from both European Union (E.U.) and U.S. perspectives. His sanctions and trade controls practice covers the full spectrum of regulatory compliance and implementation and enforcement matters, including risk assessments, design and evaluation of sanctions and export control compliance programs, merges & acquisitions, contractual negotiation and reviews, transaction due diligence, licensing, internal investigations, remediation and related disputes. Jan has particular experience with enhanced sanctions and export controls due diligence, particularly in the context of detecting and preventing circumvention risks.
Concerning his anti-corruption practice, Jan has experience navigating the multi-jurisdictional and international aspects of compliance assessments and internal investigations. He has designed and audited compliance programs, performed internal investigations and due diligence reviews on third-party agents and joint-venture partners around the world, including in connection with the U.S. Department of Justice (DOJ), the U.S. Securities & Exchange Commission (SEC), the French Parquet National Financier (PNF) and anticorruption agency (AFA), the U.K. Serious Fraud Office (SFO), as well as multilateral development bank (MDB) and export credit agencies (ECAs) inquiries.
In his international dispute resolution work, Jan has experience serving as counsel to companies and States in both commercial and investor-State arbitrations under a variety of arbitration rules (including ICC, UNCITRAL, LCIA and ICSID) and laws. He has served as assistant to the chair of an International Center for Settlement of Investment Disputes (ICSID) arbitral tribunal and previously served as a senior research assistant to Professor George A. Bermann. Jan was an Alternate Member of the Legal Advisory Task Force to the Energy Charter Treaty Secretariat.
Jan speaks and writes frequently on subjects related to sanctions and export controls, anti-corruption compliance, and international law. He has been quoted and has appeared in several leading media on EU sanctions and trade controls topics. Jan is an Associate Fellow of the Royal United Services Institute (RUSI)’s Centre for Financial Crime and Security Studies (CFCS).
Jan has lectured Sciences Po Law School, , the European University Institute, the International Anti-Corruption Academy, and the Sorbonne, and is the coeditor of a collective book on “the Transnationalization of Anti-Corruption Law” (Routledge, 2020). He has served as Chair of the Anti-Corruption Law Interest Group of the American Society of International Law and served on France’s National Bar Council (CNB) working group on developing guidelines for French lawyers conducting internal investigations. He has given evidence to OECD Working Group examiners during a peer review evaluation of the implementation of the OECD Anti-Bribery Convention.
Sanctions, Export Controls & Trade Compliance Experience
Anti-Corruption & Internal Investigations Experience
International Commercial & Investment Arbitration Experience