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Jan Dunin-Wasowicz

Counsel

Paris, Washington, D.C.

+33 (0) 1 44 05 76 23

jan.dunin-wasowicz@hugheshubbard.com
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Jan Dunin-Wasowicz is a member of the firm’s Sanctions, Export Controls & Anti-Money Laundering, Anti-Corruption & Internal Investigations, and Arbitration practice groups. He focuses his practice on cross-border compliance and regulatory enforcement, multi-jurisdictional internal and government investigations, as well as international dispute resolution. Having received full legal training in both the common law and civil law systems, Jan is an attorney-at-law and an avocat à la Cour.

As part of his sanctions and trade controls practice, Jan has experience navigating economic sanctions, export controls and trade compliance issues from both EU and U.S. perspectives in a variety of contexts, including risk assessments, design and evaluation of sanctions and export control compliance programs, merges & acquisitions, contractual negotiation and reviews, transaction due diligence, licensing, and investigations. He has experience in a broad range of industries, including in the aerospace, energy, luxury, mining, retail, and financial sectors

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 has lectured Sciences Po Law School, 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 is the current 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. 

Published Books

  • The Transnationalization of Anti-Corruption Law, co-edited volume with Régis Bismuth and Phil Nichols (May 2021) Routledge (London, New York)

Highlighted Publications

  • "The Elements of Good Trade Sanctions Judgment. Practical Tips to Improve Reviews of Proposed Transactions for Compliance with Trade Sanctions," International Review of Compliance and Business Ethics, December 2022 (with Michael Huneke)
  • “The Long Arm of EU Sanctions”, Op-Ed, EU Law Live (25 October 2022) 
  • “Compliance and International Arbitration: Once Separate, Now Becoming Inextricably Linked,” Corporate Compliance Insights (11 May 2022) (with Kevin T. Abikoff, Laura N. Perkins, and Laura Vittet-Adamson)
  • “What Constitutes Sustainable Activity? EU Taxonomy Has Compliance Lost in Shades of Green,” Corporate Compliance Insights (16 March 2022) (with Bryan J. Sillaman)
  • “Entreprises et droits humains à l’aune de l’autonomie stratégique européenne,” La Revue des Juristes de Sciences Po, March 2022 (with Adèle Bourgin and Nicolas Burnichon)
  • “The EU Blocking Statute at a Crossroads,” International Review of Compliance and Business Ethics, February 2022 (with Nicolas Burnichon and Niki Khonkarova-Helsing)
  • “Collision Avoided? Court of Justice of the European Union Gives Effect to EU Blocking Statute While Offering a Way Out of Conflict with U.S. Secondary Sanctions,” Compliance & Enforcement, a blog of NYU Law’s Program on Corporate Compliance and Enforcement (2 February 2022) (with Nicolas Burnichon)
  • “The EU Guidance on Forced Labor: A Roadmap to Prepare for Mandatory Human Rights Due Diligence?”, International Review of Compliance and Business Ethics, October 2021 (with Adèle Bourgin)
  • "The Elements of Good Due Diligence Judgment: Practical Tips to Improve Compliance Reviews of Third-Party Relationships," International Review of Compliance and Business Ethics, January 2021 (with Michael Huneke)
  • "Is Foreign Bribery Jurisdiction an Element of Economic Sovereignty? (Part III of III)," Compliance & Enforcement, a blog of NYU Law’s Program on Corporate Compliance and Enforcement (28 May 2020) (with Michael Huneke)
  • "Is Foreign Bribery Jurisdiction an Element of Economic Sovereignty? (Part II of III)," Compliance & Enforcement, a blog of NYU Law’s Program on Corporate Compliance and Enforcement (21 May 2020) (with Michael Huneke)
  • “Is Foreign Bribery Jurisdiction an Element of Economic Sovereignty? Thoughts on Recent Policy Guidance from France and the U.S.,” Compliance & Enforcement, a blog of NYU Law’s Program on Corporate Compliance and Enforcement (15 May 2020) (with Michael Huneke)
  • “Does an Award Enforcing a Contract Procured Through Bribery Violate Public Policy? A First Look at the Emerging Dutch Perspective” IBA Arbitration Committee Newsletter (10 March 2020) (with Stijn Winters)
  • “French Anti-Corruption Law Reform: A Paper Tiger or a Paradigm Shift?” FCPA Professor (17 May 2016) (with Bryan J. Sillaman)
  • “Enhancing Foreign Investment Protection Through Anti-Corruption Compliance: A Perspective on Doing Business in Africa,” Issue 2, Africa Law Today (2015) (with Bryan J. Sillaman) 
  • “Judicial Review of Arbitral Awards in the United States – The Uncertain Future of ‘Manifest Disregard of the Law,’” No. 1-2(16-17) Arbitration e-Review (2014) (with James H. Boykin)
  • “Emmanuelle Jouannet, Le droit international llibéral-providence: Une histoire du droit international,” 25(4) Leiden Journal of International Law (2012) (Book Review)
  • “To Enforce or Not to Enforce: Two Recent Illustrations of Problems Enforcing International Arbitration Awards Against Foreign Sovereigns in U.S. Courts,” 5(1) New York Dispute Resolution Lawyer (2012) (with James H. Boykin)
  • “Collective Redress in International Arbitration: An American Idea, A European Concept?” 22(2) American Review of International Arbitration (2011)
  • “The Transparency Regulation in Context: A Proxy for Legitimacy or An Instrument of Regulatory Practice?” 16(3) Columbia Journal of European Law (2010)

Highlighted Lectures

  • Speaker, “From cradle to grave: The policy cycle of EU restrictive measures,” University of Groningen, 25 November 2022
  • Speaker, “A Discussion on EU Sanctions Compliance,” Diplôme d'université Compliance Officer, Paris Panthéon-Assas University, 7 October 2022 
  • Speaker, “An Update on EU Sanctions against Russia,” Women in Ethics & Compliance Global, 24 May 2022
  • Speaker, “New Trends in Prevention of Integrity Risks in MDB-financed projects,” MIPA MDB Integrity Professionals Association, 24 May 2022
  • Speaker, “An Introduction to Economic Sanctions and Export Controls in a Time of Crisis,” Master Droit et Ethique des affaires, CY Cergy Paris University, 12 May 2022
  • Co-organizer, “OSD-OCDE-ASIL Symposium on Supranational Responses to Corruption,” Vienna, 28-29 April 2022
  • Speaker, “HHR Client Briefing on Additional U.S./EU Sanctions in Response to the Crisis in Ukraine,” HHR Webinar, 17 March 2022
  • Speaker, “HHR Client Briefing on New U.S./EU Sanctions in Connection with the Crisis in Ukraine,” HHR Webinar, 25 February 2022
  • Speaker, “Tackling Corruption and Bribery Through New Means: The Examples of Economic Sanctions and Private Settlements,” Economic Crime Seminar, University of Portsmouth, 1 December 2021
  • Speaker, “The Impact of Economic Sanctions on Respect for Human Rights,” HHR Compliance Webinar, 13 July 2021
  • Co-organizer, “The First-Ever UN General Assembly Special Session against Corruption: Where do we go from there?”, webinar, American Society of International Law & International Bar Association, 8 July 2021
  • Moderator, “International Anti-Corruption Policy and Enforcement under the Biden Administration,” webinar, American Society of International Law, 12 January 2021
  • Lecturer, "Corruption and International Arbitration," 12 November 2020, International Anti-Corruption Academy, Vienna, Austria
  • Panelist, “The Role of the International Investment Regime in Anti-Corruption Efforts” LDRN Annual Conference, Humboldt University of Berlin, 23 September 2019, Berlin, Germany
  • Participant, “United Nations Office on Drugs and Crime expert group meeting on anti-corruption modules," Oxford University Blavatnik School of Government, 2-3 April 2019, Oxford, U.K.
  • Co-moderator, “Assessing Professional and Judicial Integrity in International Tribunals: Problems and Solutions,” 113th Annual Meeting of the American Society of International Law, 29 March 2019, Washington D.C.
  • Co-organizer and Moderator, Sciences Po, “The Transnationalization of Anti-Corruption Law”, 6-7 December 2018, Paris, France
  • Panelist, Columbia Law School, “The Impact of Extraterritorial Application of Legal Norms on International Business Transactions: A Transatlantic Perspective (New York Session)," 19 November 2018, New York, NY
  • Panelist, ILERI, “Investissements étrangers en Afrique: comment gérer les risques de corruption?" 17 October 2018, Paris, France
  • Panelist, Sorbonne Law School, “The Impact of Extraterritorial Application of Legal Norms on International Business Transactions: A Transatlantic Perspective (Paris Session)," 9 July 2018, Paris, France
  • Lecturer, Cornell Law School, "The Geopolitics of Extraterritoriality," 11 April 2017, Ithaca, New York
  • Speaker, 8th Annual Business Ethics Anti-Corruption Compliance & Fraud Prevention Strategies in CEE, SEE & CIS Conference, “Domesticating Deferred Prosecution Agreements: A Comparative Analysis of the U.K. and French Approaches,” 23 March 2017, Prague, Czech Republic
  • Auditionné par des membres de la Commission des finances, “projet de loi ‘Sapin II’ pour la transparence et la modernisation de la vie économique,” Assemblée nationale (interviewed at the French Parliament in connection with French anti-corruption law and policy reform), 16 February 2016, Paris, France
  • Panelist, Woodrow Wilson International Center for Scholars, Brown Capital Management Africa Forum, “Doing Business in Africa: Addressing the Corruption Factor,” 1 December 2015, Washington, D.C.
  • Panelist, IBA/UBA 3rd Polish-Ukrainian Legal Day, “Implementation and Enforcement of Global Anti-Corruption Standards in Poland: A Case Study,” 18 September 2015, Kiev, Ukraine
  • Panelist, ABA Section of International Law and ILSA Spring Conference/Final Jessup Competition, “Pathways to Employment in International Law,” 11 April 2014, Washington, D.C

Highlighted Interviews, Quotes & Podcasts

  • “Brussels’ uphill battle to confiscate Russian assets,” Politico, 21 November 2022
  • EU approves more sanctions against Russia over Ukraine war,” Reuters, 5 October 2022
  • “Comment l’Union européenne pourrait bannir les produits issus du travail forcé,” La Croix, 14 September 2022 
  • “Erdoğan walks a fine line as the Ukraine war’s double agent,” Politico, 17 August 2022
  • “Anti-Corruption Issues in International Arbitration,” Hughes Hubbard and Reed’s All Things Investigations, Episode 7, Podcast, 11 July 2022
  • “Could seizing Russian assets help rebuild Ukraine?”, The Economist, 6 June 2022
  • “Commission proposes EU-wide ‘criminalisation’ of sanctions evasion and asset confiscation plans”, WorldECR, 26 May 2022
  •  “EU moves to confiscate Russian oligarchs’ assets”, Politico Europe, 24 May 2022
  • “The EU Anti-Coercion Instrument”, EU Law NOW, Podccast, 22 April 2022
  •  “Guerre en Ukraine : Poutine sème le trouble, en imposant le paiement en roubles du gaz russe », Le Monde, 24 mars 2022
  • “Soutenir l'Ukraine sera compliqué pour les Occidentaux”, Les Echos, 24 February 2022
  • “Des sanctions modestes contre une Russie aux finances solides”, Le Figaro, 23 February 2022
  • “France and the OECD Anti-bribery Convention,” TRACE Bribe, Swindle or Steal, Podcast, 23 February 2022
  • Guest Interviewee, “Lutte contre la corruption: l'arsenal juridique est-il suffisant?”, l'Entretien de l'intelligence économique, France 24, 10 August 2021

Professional & Teaching Activities

  • Chair, Anti-Corruption Law Interest Group (ACLIG) of the American Society of International Law (ASIL) (Vice Chair, 2017 – 2019)
  • Member, International Law Association (ILA) – French Branch – Member of the Organization Committee of the 2023 150th Anniversary of the ILA
  • Adjunct Faculty, Sciences Po Law School, Spring 2021-2022, “Navigating Across Multiple Economic Sanctions Regimes”
  • Adjunct Faculty, Sciences Po Law School, Spring 2020-2021, “International Anti-Corruption Regulation in Practice”
  • Adjunct Faculty, International Master in Anti-Corruption Compliance and Collective Action (IMACC), International Anti-Corruption Academy, 2020-2022
  • Adjunct Faculty, Paris I - Panthéon-Sorbonne University School of Law, Spring 2018 – 2020, “Global Anti-Corruption Law and Corporate Social Responsibility in Practice”

Recognitions

  • Honored for International Pro Bono Excellence by the Vance Center for International Justice for work on behalf of Proética – the Peruvian chapter of Transparency International – in connection with a project on crimes against humanity
  • 2013 Capital Pro Bono Honor Roll, sponsored by the District of Columbia Court of Appeals and the Superior Court of the District of Columbia
  • 2012 Capital Pro Bono Honor Roll, sponsored by the District of Columbia Court of Appeals and the Superior Court of the District of Columbia

Highlighted Matters

Sanctions, Export Controls & Trade Compliance Experience

  • Assisted several companies with economic sanctions and export control risk assessments and related remediation
  • Assessment of economic sanctions and export controls compliance programs and creation of related training 
  • Assisted multiple companies regarding EU / U.S. licensing requirements, procedures and related inquiries (including in connection with the French Direction générale du Trésor (DG Trésor), Service des biens à double usage (SBDU), other National Competent Authorities in the EU, the European Commission, and the U.S. Office of Foreign Assets Control (OFAC))
  • Supported product classifications and performed jurisdictional assessments and provided related advice to several European companies 
  • Assisted an international defense company with due diligence on third parties to assess compliance with U.S. International Traffic in Arms Regulations (ITAR)

Highlighted Matters

Anti-Corruption & Internal Investigations Experience

  • Represented a world-leading aerospace and defense company in connection with criminal investigations by multiple jurisdictions related to its historical use of third parties and related compliance matters
  • Assisted a multinational “supermajor” oil and gas company in connection with a worldwide risk assessment and compliance review as part of an independent monitorship
  • Represented a NYSE-listed company in conducting anti-corruption due diligence during a cross-border acquisition
  • Assisted multinational engineering and construction company in worldwide review of activities 
  • Represented multinational industrial manufacturing company in resolution of World Bank investigation

Highlighted Matters

International Commercial & Investment Arbitration Experience

  • Representation of Ukrainian investors in the energy sector in UNCITRAL arbitration proceedings against the Russian Federation concerning the Russian Federation’s breaches of international law following the annexation of Crimea
  • Representation of West African State in arbitration proceedings brought by a foreign investor under the ICSID Convention
  • Representation of Turkish investor in arbitration proceedings against the Republic of Kazakhstan under the ICSID Convention
  • Representation of generator manufacturer in International Chamber of Commerce (ICC) arbitration arising out of alleged defects in equipment supplied to power plants around the world 
  • Served as assistant to the President of the Tribunal in Garanti Koza LLP v. Turkmenistan (ICSID Case No. ARB/11/20)
  • Representation of an industrial company in an ICC arbitration under the expedited procedure
  • Advising investment funds on structuring investments to obtain protections available under bilateral investment treaties

Highlighted Matters

Pro Bono

  • Representation of the Peruvian chapter of Transparency International in connection with a project on crimes against humanity
  • Representation of juvenile foreign nationals in deportation proceedings
EU Announces New Rounds of Sanctions as Russia’s War in Ukraine Marks One Year
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EU Adopts Ninth Package of Sanctions Against Russia in Response to its Attacks Against Civilians and Civil Infrastructures
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EU Adopts Price Cap for the Trading, Brokering and Transport of Russian Crude Oil to Third Countries and Releases a Draft Directive to Harmonize Definitions and Penalties for Violations of EU Sanctions
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EU Adopts Eighth Package of Sanctions Against Russia in Response to the Illegal Annexation of Ukraine's Donetsk, Luhansk, Zaporizhzhia and Kherson Regions
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European Commission Unveils Forced Labor Ban Proposal; U.S. Department of Homeland Security Publishes More Details on UFLPA Entity List
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EU Adopts “Maintenance and Alignment” Package of Sanctions Against Russia
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​EU Adopts Sixth Package of Sanctions Against Russia and Belarus and Makes Proposals to Strengthen Sanctions Enforcement
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EU Adopts Fifth Package of Sanctions Against Russia Over its Continued Military Aggression Against Ukraine
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U.S. Intensifies Russia Sanctions in Response to Bucha Charges in Ukraine
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U.S. and EU Announce Subsequent Rounds of Sanctions in Response to Russia’s Ongoing Aggression Against Ukraine
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U.S. and EU Announce Next Rounds of Sanctions in Response to Russia’s Military Aggression Against Ukraine
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U.S. and EU Announce Export Controls for Belarus and Russia, Additional Sanctions Targeting Russia
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U.S. Imposes Additional Sanctions, EU Imposes Second and Third Rounds of Sanctions on Russia for Ukraine Invasion
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U.S. Imposes Second Round of Sanctions on Russia and Belarus for Ukraine Invasion
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U.S. and EU Impose Sanctions in Connection with the Crisis in Ukraine
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L'UE étend les sanctions contre la Biélorussie dans un contexte d’attaque hybride et de répression continue
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EU Expands Sanctions against Belarus Amid Hybrid Attack and Continued Repression
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The New EU Dual-Use Regulation Enters into Force: Overview of the Main Changes
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News

HHR's Crimea Team Wins Two Major Cases in Dutch Court
News & Events
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In Corporate Compliance Insights: Compliance and International Arbitration: Once Separate, Now Becoming Inextricably Linked
Articles & Press
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Hughes Hubbard Promotes Four to Partnership and Four to Counsel
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People
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Hughes Hubbard Associate Jan Dunin-Wasowicz Elected Chair of ASIL's Anti-Corruption Law Interest Group
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People
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Firm Honored for Pro Bono Excellence by Vance Center for International Justice
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Awards |
Pro Bono
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FCPA & Anti-Bribery Alert Fall 2016
News & Events
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Enhancing Foreign Investment Protection Through Anti-Corruption Compliance: A Perspective on Doing Business in Africa
Articles & Press
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FCPA/Anti-Bribery Alert Winter 2015
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Supreme Court Cites Hughes Hubbard Brief in BG Group Ruling
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Deals & Matters
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FCPA/Anti-Bribery Alert Winter 2013
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Education
  • Columbia University, School of Law, J.D., 2012, Harlan Fiske Stone Scholar, Parker School Recognition of Achievement in International and Comparative Law, American Review of International Arbitration, Senior Editor
  • Université de Paris I - Panthéon-Sorbonne, M.A., 2012
  • Sciences Po Paris (Institut d'Etudes Politiques de Paris), M.A., 2007
Bar Admissions
  • District of Columbia, 2014
  • France (Paris), 2017
  • New York, 2013
Languages
  • English
  • French
  • German
  • Polish
Areas of Focus
Africa
Anti-Corruption & Internal Investigations
Arbitration
Defense Industry
Investment Treaty Arbitration
Multilateral Development Bank Investigations and Sanctions
Sanctions, Export Controls & Anti-Money Laundering

Hughes Hubbard & Reed LLP

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