Jan Dunin-Wasowicz

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. Jan’s training and experience in both common law and civil law systems makes him uniquely qualified to assist multinational companies with their most pressing transnational issues.

As Co-Chair of the firm’s sanctions, export controls & anti-money laundering practice group, Jan has experience advising on compliance with economic sanctions and trade controls from both European Union and U.S. perspectives. His sanctions and trade controls practice covers the full spectrum of compliance 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, investigations, and remediation. 

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 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

• Assisted several companies with economic sanctions and export control risk assessments and related remediation across sectors and trade sanctions programs and regulations
• Assistance with and advice on enhanced sanctions and export controls due diligence in a variety of contexts, including but not limited to, investments, mergers & acquisitions, or divestments 
• 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 U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) trade sanctions programs and regulations, and the U.S. Department of Commerce’s Bureau of Industry and Security (BIS)
• 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)

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

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

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