News Locations
EN | FR
Practices
People
Careers
Associate Recruiting Working At HHR Available Positions
Culture
About Us Inclusion Pro Bono
Practices
People
Careers
Associate Recruiting Working At HHR Available Positions
Culture
About Us Inclusion Pro Bono
News Locations
EN | FR
Practices
People
News
View All Results >

Michael H. Huneke

Washington, DC

+1 (202) 721-4714

[email protected]
Download V Card
Share/Print
Email Print
   
Biography
Selected Matters
Client Advisories
News

Michael H. Huneke is a Co-Chair of the Sanctions, Export Controls, and Anti-Money Laundering practice group and a partner in the Global Investigations, Enforcement and Compliance practice group at Hughes Hubbard & Reed.

Mike’s current work focuses on helping companies to identify and mitigate export controls and economic sanctions enforcement risks in today’s dynamic, geopolitically charged enforcement environment.

Mike’s recent thought leadership includes several “fresh looks” at all aspects of sanctions and export controls compliance, synthesizing key concepts from these complicated, dynamic regulatory topics and providing general counsel and chief compliance officers with helpful tools for focusing resources on the greatest risks for companies, directors, and officers.

The Legal 500 has recognized Mike as a “voice of reason when it comes to compliance matters,” with clients’ feedback including that Mike “stands out for his multi-jurisdictional knowledge of compliance, pragmatism and efficiency in handling cases.”

Mike received Lexology’s Client Choice Award for Investigations-USA for 2023, 2024, and 2025. Clients’ feedback included that Mike is “one of the top investigative lawyers around,” “a trusted advisor and valued partner to our company,” and “always able to quickly respond to the client’s queries even on a short notice and provides guidance which is at the same time precise and compelling.”

Mike was also recognized as one of four Hughes Hubbard attorneys honored to receive Global Investigations Review’s (GIR’s) “Most Important Development in the Practice or Law of International Investigations” 2020 award on behalf of the firm and its Global Investigations, Enforcement and Compliance team for his representation of Airbus in its historic settlement to successfully resolve bribery and corruption allegations.

Previous Experience

  • Associate, white-collar group at the Washington, DC office of an international law firm, 2005 – 2006 and 2007 – 2010
  • Clerk, the Honorable Henry Coke Morgan Jr., senior U.S. District Judge for the Eastern District of Virginia, 2006 – 2007

Recognitions & Accomplishments

  • Appointed to the Steering Committee of the Export Controls & Economic Sanctions Committee of the American Bar Association's Section on International Law, 2025
  • Completed the Export Compliance Training Institute’s Export Compliance Professional (ECoP) EAR Exam, Nov. 2024
  • Completed the Export Compliance Training Institute’s Export Compliance Professional (ECoP) ITAR Exam, Dec. 2023
  • Recognized as one of four Hughes Hubbard attorneys honored to receive Global Investigations Review’s (GIR’s) “Most Important Development in the Practice or Law of International Investigations” 2020 award on behalf of the firm and its Anti-Corruption & Internal Investigations team for his representation of Airbus in its historic settlement to successfully resolve bribery and corruption allegations
  • Hughes Hubbard was honored to receive the “Best Provider Collaboration” award at the 2020 American Lawyer Industry Awards for creating a virtual law firm that resolved a record-setting, multijurisdictional corruption case for France-based Airbus that addressed conduct in 16 different countries
  • Recognized in Legal 500 EMEA- France: Compliance as a Hall of Fame Lawyer, 2022 – 2024
  • Recognized in Legal 500 EMEA- France: Compliance as a Leading Individual, 2021
  • Recognized in Legal 500 EMEA- France: Compliance as a Recommended Lawyer, 2018 – 2020
  • Recognized in Washington, DC, Super Lawyers as a Rising Star, 2014 – 2015
  • 2015 Capital Pro Bono Honor Roll, sponsored by the District of Columbia Court of Appeals and the Superior Court of the District of Columbia

​Published Treatises

  • Anti-Corruption Law and Compliance: Guide to the FCPA and Beyond (Bloomberg BNA, 2014) (with Kevin Abikoff and John Wood) (updated 2019)
  • "The International Perspective: Lessons from US Authorities' Enforcement of the Foreign Corrupt Practices Act," Lissack and Horlick on Bribery and Corruption Second Edition (LexisNexis Butterworths, 2014) (with Kevin Abikoff) (updated 2020)

Court Admissions

  • United States Court of Appeals for the Fourth Circuit
  • United States District Courts for the District of Columbia, Eastern District of Virginia, and Western District of Virginia
  • District of Columbia Court of Appeals
  • Supreme Court of Virginia

Other Highlighted Publications

  • Quoted in “Trump Adds Tariffs to U.S. Economic Coercion Arsenal,” Dow Jones Risk Journal, Mar. 31, 2025.
  • Quoted in “BIS seen as likely to step up export control enforcement under Trump,” Inside U.S. Trade, Jan. 3, 2025.
  • “Trust, But Verify…Therein Lies the Rub: A Fresh Look at Audits of Export Controls Compliance Programs,” NYU Program on Corporate Compliance & Enforcement, Compliance & Enforcement Blog, Nov. 19, 2024 (with Brent Carlson of Berkeley Research Group LLC)
  • Quoted in “US lawmakers say BIS has “failed” to enforce export controls,” Global Investigations Review, Dec. 20, 2024
  • Cited in “Majority Staff Report: The U.S. Technology Fueling Russia’s War In Ukraine,” U.S. Senate Permanent Subcommittee on Investigations, Dec. 18, 2024
  • Outbound Investment Rule Embraces New National Security Paradigm, Bloomberg Law, Nov. 7, 2024
  • Quoted in “Lawyers: Second Trump Presidency Wouldn’t Break the Mould for DOJ Corporate Enforcement,” Global Investigations Review (Nov. 5, 2024)
  • “Semiconductors export controls: A look ahead for the rest of 2024 and beyond,” WorldECR Issue 133 (Oct. 2024) (with Brent Carlson of Berkeley Research Group LLC)
  • “Avoid Kicking the Hornet’s Nest: A Fresh Look at How to Anticipate, Avoid, and Respond to BIS Administrative Subpoenas (Part 2),” NYU Program on Corporate Compliance & Enforcement, Compliance & Enforcement Blog, Sept. 26, 2024 (with Brent Carlson of Berkeley Research Group LLC)
  • “Avoid Kicking the Hornet’s Nest: A Fresh Look at How to Anticipate, Avoid, and Respond to BIS Administrative Subpoenas (Part 1),” NYU Program on Corporate Compliance & Enforcement, Compliance & Enforcement Blog, Sept. 19, 2024 (with Brent Carlson of Berkeley Research Group LLC)
  • “Export Controls ‘Loopholes’ Are a Risky Path for Trade Compliance,” Bloomberg Law, Sept. 12, 2024
  • “It May Not Be Worth the Paper (or Pixel) It’s Written On (Part 2): A Fresh Look at Common Responses to Bolster Export Controls Compliance Programs as BIS Primes the Corporate Enforcement Engine,” NYU Program on Corporate Compliance & Enforcement, Compliance & Enforcement Blog, Sept. 9, 2024 (with Brent Carlson of Berkeley Research Group LLC)
  • “It May Not Be Worth the Paper (or Pixel) It’s Written On (Part 1): A Fresh Look at Letters of Assurance Used to Bolster Sanctions and Export Controls Compliance,” NYU Program on Corporate Compliance & Enforcement, Compliance & Enforcement Blog, Aug. 2, 2024 (with Brent Carlson of Berkeley Research Group LLC)
  • “BIS Primes the Corporate Enforcement Engine: A Fresh Look at What Recent BIS Actions & Statements Mean and a Proposed Framework for How U.S. Companies Can Best Prepare,” NYU Program on Corporate Compliance & Enforcement, Compliance & Enforcement Blog, May 30, 2024 (with Brent Carlson of Berkeley Research Group LLC)
  • “Gut Check: Are You Applying the ‘High Probability’ Standard?” WorldECR Issue 129 (May 2024)
  • “BIS Update 2024: Key Takeaways from Assistant Secretary for Export Enforcement Matthew Axelrod’s Remarks,” Export Compliance Manager (Issue 42, April 2024) (with Justin Campbell)
  • “A Whole New National Security Ballgame: Key Practical Takeaways for Export Control Compliance from the 2024 BIS Update Conference,” NYU Program on Corporate Compliance & Enforcement, Compliance & Enforcement Blog, Apr. 5, 2024 (with Brent Carlson of Berkeley Research Group LLC)
  • The Blind Men and The Elephant: Understanding the Need for Holistic Compliance, WorldECR Issue 128 (April 2024).
  • Quoted in “BIS Rule Adding End-User Controls to Sanctioned Persons is a ‘Force-Multiplier,’” WorldECR Issue 128 (April 2024).
  • “Monitoring What Matters: A Fresh Look Proposal to Government and Industry for How Post-Resolution Oversight Can Best Deny Hostile Actors the Means to Cause Deadly Harm,” NYU Program on Corporate Compliance & Enforcement, Compliance & Enforcement Blog, Mar. 28, 2024 (with Brent Carlson of Berkeley Research Group LLC)
  • "'Expect Some Illumination': A Fresh Look at U.S. Congressional Hearings in the Era of Sanctions and Export Controls as the New FCPA,” NYU Program on Corporate Compliance & Enforcement, Compliance & Enforcement Blog, Mar. 14, 2024 (with Brent Carlson of Berkeley Research Group LLC)
  • “Whack-a-Mole Sanctions Compliance Can Benefit From War Lessons,” Bloomberg Law, Feb. 29, 2024 (with Kevin Carroll and Sean Reilly).
  • “How Not to Stand Out Like a Sore Thumb (Part 2): A Fresh Look at the 'High Probability' Definition of Knowledge Applied to Export Controls and Sanctions Enforcement,” NYU Program on Corporate Compliance & Enforcement, Compliance & Enforcement Blog, Feb. 21, 2024 (with Brent Carlson of Berkeley Research Group LLC) 
  • “US Products in Enemy Weapons Need Scrutiny Across Supply Chains,” Bloomberg Law, Feb. 14, 2024 (with Kevin Carroll and Sean Reilly)
  • “How Not to Stand Out Like a Sore Thumb (Part 1): A Fresh Look at the 'Willful' Intent Standard for Criminal Liability in Export Controls and Sanctions Corporate Enforcement,” NYU Program on Corporate Compliance & Enforcement, Compliance & Enforcement Blog, Feb. 13, 2024 (with Brent Carlson of Berkeley Research Group LLC)
  • "Boards of Directors Lovin’ It after McDonald’s? A Fresh Look at Directors’ Duty of Oversight in the New Era of Sanctions & Export Control Corporate Enforcement,” NYU Program on Corporate Compliance & Enforcement, Compliance & Enforcement Blog, Jan. 12, 2024 (with Brent Carlson of Berkeley Research Group LLC)
  • “An Ounce of Prevention is Worth a Pound of Cure . . . or an Imposed Compliance Monitorship: A Fresh Look at the DOJ’s Corporate Enforcement Toolkit Applied to Sanctions and Export Controls Enforcement,” NYU Program on Corporate Compliance & Enforcement, Compliance & Enforcement Blog, Dec. 4, 2023 (with Brent Carlson of Berkeley Research Group LLC)
  • “How to Prepare for Sanctions Compliance & Investigations (“SCI”) in the Era of the 'New FCPA',” Lexology, Nov. 21, 2023
  • “From Peanuts to Prison Time – A Fresh Look at the Evolution of Export Controls Penalties,” NYU Program on Corporate Compliance & Enforcement, Compliance & Enforcement Blog, Nov. 14, 2023 (with Brent Carlson of Berkeley Research Group LLC), (cited by Richard Vanderford, “U.S. Likely to Levy Higher Penalties for Export-Control Violations,” Wall Street Journal (Jan. 17, 2024); cited by Amy Mackinnon, “Russia’s War Machine Runs on Western Parts,” Foreign Policy (Feb. 22, 2024)).
  • “The Blind Men and the Elephant: Manufacturers and exporters who only view sanctions and export controls evasion risks from a technocratic item classification perspective will fail to recognize and correctly analyze evasion risks in the era of sanctions as the 'new FCPA',” Client Advisory, Dec. 18, 2023
  • “Slow is Smooth, Smooth is Fast: A Fresh Look at Planning and Executing Internal Investigations into Allegations of Sanctions or Export Controls Evasion,” NYU Program on Corporate Compliance & Enforcement, Compliance & Enforcement Blog, Oct. 30, 2023 (with Brent Carlson of Berkeley Research Group LLC)
  • “Know Your Customer, But Also Yourself: A Fresh Look at Sanctions & Export Controls Risk Assessments in the Era of the ‘New FCPA,’” NYU Program on Corporate Compliance & Enforcement, Compliance & Enforcement Blog, Sept. 28, 2023 (with Brent Carlson of Berkeley Research Group LLC)
  • "Converging Practices for Bribery, Export Controls, and Sanctions Anti-Evasion Regimes” (Part 2), Thomson Reuters Westlaw Today, July 6, 2023 (with Jan Dunin-Wasowicz) (featured in Westlaw Today’s “Week in review: What lawyers are reading on Westlaw Today,” July 7, 2023)
  • "Converging Practices for Bribery, Export Controls, and Sanctions Anti-Evasion Regimes” (Part 1), Thomson Reuters Westlaw Today, June 22, 2023 (with Jan Dunin-Wasowicz)
  • “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 Jan Dunin-Wasowicz)
  • "Anti-Corruption Due Diligence Can Help Buyers, Sellers, and Their Advisers to Facilitate Acquisitions," Risk and Compliance Magazine, Oct-Dec 2022
  • "What is the General Counsel’s role in CEO and CCO compliance certifications?," The FCPA Blog, August 16, 2022
  • "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 Jan Dunin-Wasowicz)
  • "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, May 28, 2020 (with Jan Dunin-Wasowicz)
  • "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, May 21, 2020 (with Jan Dunin-Wasowicz)
  • "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, May 15, 2020 (with Jan Dunin-Wasowicz) 
  • Quoted in "Navigating the Coronavirus Crisis for Compliance Professionals: Part 5 – Final Thoughts," FCPA Compliance Report, April 3, 2020 
  • Quoted in "Navigating the Coronavirus Crisis for Compliance Professionals: Part 2 – Specific Tactics," FCPA Compliance Report, March 31, 2020
  • "There is No COVID-19 Defense to Corruption," The FCPA Blog, March 18, 2020 (with Kevin Abikoff)
  • "SCOTUS News: Limits on Immunity for Multilateral Development Banks Should Spur Increased Anti-Corruption Efforts," The FCPA Blog, May 28, 2019 (with Ayoka Akinosi)
  • FCPA Update: Third-Party Risks and Enforcement Actions, The Review of Securities & Commodities Regulation, vol. 51 no. 1 (January 2018) (with Ashley Hodges)
  • Quoted in "Five Stages of Corruption and Myriad Internal Controls Failures: Compliance Takeaways From the VimpelCom Settlement," The FCPA Report, March 9, 2016
  • Quoted in "VimpelCom Settlement Highlights US Government’s New Holistic Approach to Anti-Corruption Enforcement," The FCPA Report, Feb. 24, 2016
  • Quoted in "The Multimillion Dollar Question: When to Self-Report?" Compliance Week, April 28, 2015
  • "NY Financial Compliance Landscape May Get Treacherous," Law360, April 22, 2015 (with John Wood)
  • Quoted in "Global Reach of US Enforcement Collides with Domestic Pressure to Charge Individuals," Main Justice, April 8, 2015
  • Contributor, Lissack & Horlick on Bribery (LexisNexis, 2nd ed.) (Ch. 12, The International Perspective: Lessons from US Authorities' Enforcement of the Foreign Corrupt Practices Act) (with Kevin Abikoff, John Wood and Ed Little)
  • "How the Proposed Amendments to the Organizational Sentencing Guidelines Will Affect Corporate Compliance and Ethics Programs," 11 Engage vol. 2 (September 2010)
  • "When Does an ADR Program Give US Authorities FCPA Jurisdiction over a Foreign Issuer?" 4 Int'l Crim. L. Comm. Newsletter 2:10 (May 2010) (with Patrick O. Hunnius)
  • "International Legal Developments in Review: 2008, International Criminal Law," 43 The Int'l Lawyer 473, 2009 (with Don Shaver and Elizabeth Bingold)

Highlighted Podcasts and Speaking Engagements

  • "Beyond Borders: The Impact of the New Administration on Global Sanctions and Export Controls,” Hughes Hubbard & Reed, webinar, Feb. 27, 2025.
  • "DeepSeek and the Sputnik Moment,” FCPA Compliance Report Podcast, Compliance Podcast Network, Feb. 5, 2025.
  • "DeepSeek and the Recalibration of Risk with Mike Huneke and Brent Carlson,” FCPA Compliance Report Podcast, Compliance Podcast Network, Feb. 3, 2025.
  • “Mike Huneke on Navigating Uncharted Waters: Compliance Strategy in a Changing Administration,” Hughes Hubbard and Reed’s All Things Investigations Podcast, Compliance Podcast Network, Episode 65, Dec. 16, 2024
  • “Mike Huneke’s Top 5 Takeaways from The 2024 ECCP,” Hughes Hubbard and Reed’s All Things Investigations Podcast, Compliance Podcast Network, Episode 58, Oct. 21, 2024
  • “The ‘High Probability’ Standard for Export Controls: Challenges and Opportunities for Internal Compliance,” Association of Certified Sanctions Specialists (“ACSS”), Oct. 3, 2024
  • “In Focus: Sanctions Watch – July 2024,” Association of Certified Anti-Money Laundering Specialists (“ACAMS”), July 10, 2024
  • “Demystifying Economic Sanctions: Strategies for Success in a Global Economy,” The Knowledge Group, webinar, May 14, 2024
  • “Beyond the DPA: Maintaining an Effective Compliance Culture Post-Release,” Hughes Hubbard and Reed’s All Things Investigations Podcast, Compliance Podcast Network, Episode 48, Mar. 11, 2024 (with Mei-Li Zhen)
  • Guest Speaker, ICC Mexico’s “VIII Diplomado Anticorrupción” program, Mar. 7, 2024
  • "Huneke and Carlson on Directors’ Accountability for Compliance and Risk Management,” Hughes Hubbard and Reed’s All Things Investigations Podcast, Compliance Podcast Network, Episode 47, Feb. 26, 2024 (with Brent Carlson of Berkeley Research Group LLC)
  • Panelist, “Matthew Axelrod, Assistant Secretary for Export Enforcement at the United States Department of Commerce, Bureau of Industry & Security, to Discuss Corporate Voluntary Self-Disclosure Policies for Export Control Violations,” NYU School of Law, Jan. 16, 2024
  • "Damn the Torpedoes – New DOJ Safe Harbor for M&A with Mike Huneke,” Hughes Hubbard and Reed’s All Things Investigations Podcast, Compliance Podcast Network, Episode 40, Nov. 13, 2023
  • "Privileges in Document Production with Mike Huneke,” Hughes Hubbard and Reed’s All Things Investigations Podcast, Compliance Podcast Network, Episode 37, September 25, 2023
  • “The Convergence of ABC, AML and Export Controls with Mike Huneke and Jan Dunin-Wasowicz,” Hughes Hubbard and Reed’s All Things Investigations Podcast, Compliance Podcast Network, Episode 30, July 10, 2023
  • “Mike Huneke and Laura Perkins on Changes to Corporate Enforcement Policy,” Hughes Hubbard and Reed’s All Things Investigations Podcast, Compliance Podcast Network, Episode 22, February 27, 2023
  • "The Power of Pre-Acquisition Due Diligence," Hughes Hubbard & Reed All Things Investigations Podcast, Compliance Podcast Network, Episode 15, November 7, 2022
  • "The GC Role in CCO Certification," Hughes Hubbard & Reed All Things Investigations Podcast, Compliance Podcast Network, Episode 11, September 12, 2022 
  • “Coburn and the Attorney/Client Privilege,” Hughes Hubbard & Reed All Things Investigations Podcast, Compliance Podcast Network, Episode 1, April 4, 2022  
  • Guest Speaker, ICC Mexico’s “V Diplomado Anticorrupción 2020” program, February 1, 2022
  • Panelist, "The Collaborative Approach: Combatting Conflict Through Cooperation," The George Washington International Law Review, panel, March 12, 2021
  • "Global Anti-Bribery and Corruption Legislation: Demystifying Trends, Developments, and Legal Issues," The Knowledge Group, webinar, February 4, 2021
  • "Abikoff and Huneke on Corruption Enforcement During the Coronavirus Crisis," Compliance Podcast Network, Podcast, April 14, 2020
  • Quoted in "FCPA Compliance Report – This Week in FCPA (Episode 197) – The Compliance Doesn't Sleep Edition," Podcast, March 20, 2020
  • "Significant FCPA Trends and Developments: Bolstering Your Compliance Program," The Knowledge Group, webinar, September 23, 2019
  • "Anti-Bribery and Anti-Corruption Compliance: Trends, Developments and Best Practices in 2019," The Knowledge Group, webinar, July 10, 2019
  • "Responding to Investigations by the World Bank and Other Multilateral Development Banks," Hughes Hubbard & Reed, webinar, July 3, 2019
  • Moderator, “Data Compliance: How Industry Has Updated Policies for Data Collection, Transfers, and Retention,” C5’s 3rd Advanced Conference on Anti-Corruption, Zurich, Switzerland, April 3, 2019
  • "Third-Party Due Diligence Best Practices: Uncovering the Things You Need to Know," The Knowledge Group, webinar, February 26, 2019
  • “East Asian Legal Studies Lunchtime Talk Series: Pursuing a Career in Global Anti-Corruption Law,” Harvard Law School, Cambridge, MA, February 21, 2019
  • "The 2019 Anti-Bribery Landscape: Trends, Developments and Updates," The Knowledge Group, webinar, January 8, 2019
  • "How DPAs are Affecting Companies' Compliance Function and Compliance Initiatives," C5's 6th Conference on Anti-Corruption, Paris, France, October 16, 2018
  • “Corruption Scandals: Practitioner-led Case Study," UC Berkeley Law Compliance Academy, Paris, France, July 25, 2018
  • "US & EU: Conducting and Evaluating Complex Anti-Corruption Investigations with FCPA and Bribery Act," The Knowledge Group, webinar, May 2, 2018
  • “White Collar Enforcement in 2018: Navigating Recent Changes and Clearing Uncertainties,” The Knowledge Group, webinar, March 1, 2018
  • “Managing and Mitigating Third-Party Fraud and Corruption Risks: Your Guide for 2017 and Beyond,” The Knowledge Group, webinar, December 1, 2017
  • "FCPA Enforcement Actions: Highlighting the Importance of Implementing and Monitoring Effective Compliance Programs," The Knowledge Group, webinar, September 18, 2017
  • "Anti-Corruption Compliance: Trends and Developments in 2017," The Knowledge Group, webinar, August 21, 2017
  • “Trends and Developments in International Anti-Corruption Enforcement,” Clear Law Institute, webinar, June 29, 2017 
  • "The A-Z's of Anti-Corruption Compliance: What You Need to Know in 2016 and Beyond," The Knowledge Group, webinar, Feb. 16, 2016
  • "Mitigate Potential Whistleblower Violations Amidst Increased SEC Investigations," The Knowledge Group, webinar Dec. 10, 2015
  • "Anti-Corruption Outlook for 2016: China, Brazil, the UK and Other Enforcement Hot-Spots," Bloomberg BNA, webinar Dec. 2, 2015
  • "Best Trends and Practices in Responding to Corporate Whistleblower Reports Explored!" The Knowledge Group, webinar panel discussion, May 1, 2015
  • "The US Foreign Corrupt Practices Act (FCPA) and International Anti-Bribery Compliance," (part of the US State Department International Visitor Leadership Program’s Regional Program on "Transparency and Accountability," administered by the Meridian International Center, Washington, DC, Feb. 26, 2015)
  • "Compliance Programs for Government Contractors in 2015 Explored," The Knowledge Group, webinar Feb. 5, 2015
  • "The World Bank's Expectations and Debarment Powers," C-5 Southern Africa Anti-Corruption Summit 2014, Johannesburg, South Africa, Nov. 18, 2014
  • "Global Anti-Corruption Compliance and Enforcement: Strategies for Managing the Risks Posed by Third Parties, Business Combinations, and Allegations or Evidence of Misconduct," Bloomberg BNA, webinar, Oct. 29, 2014
  • "Minimizing Third Party Risks: How to Apply the Right Level of Due Diligence When Monitoring Your Agents, Distributors, Brokers, and CROs," American Conference Institute's 7th Advanced Forum on FCPA & Anti-Corruption for the Life Sciences Industry, New York, May 14, 2013
  • "Negotiating, Drafting and Executing Robust Contracts with Third Parties to Protect your Organisation from Corruption and Bribery Risks," C-5 Second Forum on Anti-Corruption Southern Africa, Cape Town, South Africa, Sept. 18 – 19, 2012)
  • "Anti-Corruption Risk Assessments & Third-Party Due Diligence," on behalf of Kevin Abikoff (GCM Parker, 2nd Annual Business Ethics Anti-Corruption & Fraud Prevention Strategies in CEE, SEE & CIS, Prague, Czech Republic, March 24, 2011)

Highlighted Matters

International Economic Sanctions & Export Controls

  • Advising an international logistics company on U.S. export controls compliance (including Foreign Direct Product (“FDP”) rules’ applicability)
  • Conducted a compliance risk assessment for a UAE-based renewable energy business
  • Represented a multinational oil and gas company regarding an internal review of compliance with economic sanctions, specifically related to distributor and reseller networks
  • Representing a multinational oil and gas company regarding an internal review of compliance with economic sanctions
  • Assisting a multinational client to design and implement economic sanctions and export controls due diligence on third-party distributors, resellers, and freight forwarders
  • Representing a manfacturing company regarding concurrent Bureau of Information & Security (“BIS”), Office of Foreign Assets Control (“OFAC”), and U.S. Attorney’s Office reviews of a joint venture’s acquisition target and regarding integration of the target into the joint venture’s compliance program
  • Representing a manufacturing company regarding the repurposing of now-secondhand industrial equipment originally intended for Russian end-use prior to the imposition of economic sanctions that made the original sale impossible to fulfill
  • Represented a purchaser on several transactions collectively for more than USD 700 million regarding pre-acquisition economic sanctions and export controls due diligence and integration-planning
  • Advised a U.S.-based manufacturer of medical products regarding its distribution networks into otherwise-sanctioned countries
  • Represented an international aerospace and defense company in connection with a review of third parties and related reporting requirements under the U.S. International Traffic in Arms Regulations (“ITAR”)

Highlighted Matters

Internal and External Anti-Corruption Investigations or Reviews

  • Represented a world-leading aerospace and defense company in connection with criminal investigations by multiple jurisdictions related to its historical use of third parties
  • Represented a Chinese state-owned enterprise regarding an MDB investigation into sanctionable practices, which was ultimately dropped
  • Represented a central Chinese state-owned enterprise in connection with the resolution of an African Development Bank investigation into conduct in Africa
  • Represented an executive of a company cooperating with a World Bank investigation for sanctionable practices, in the resolution of which the executive was not charged
  • Represented a multinational CAC40-listed power, energy, and transportation company regarding its cooperation commitments under a settlement with the World Bank and regarding proffers made to the U.S. Department of Justice (DOJ) regarding conduct in Brazil
  • Represented an Indian company in connection with an audit and inspection of multiple projects by the World Bank’s Integrity Vice Presidency
  • Represented a Norwegian consulting company in contested proceedings before the World Bank's Sanctions Board
  • Represented a NYSE-listed pharmaceutical company in responding to a civil investigative demand (CID) by a U.S. Attorney’s office, regarding potential FCPA and False Claims Act (FCA) violations
  • Represented a client in parallel criminal and civil export controls investigations by the U.S. DOJ and the US Department of Commerce, Bureau of Industry & Security
  • Conducted an internal investigation at a Fortune 10 energy company regarding a whistleblower’s health, safety, and environmental allegations, and presenting the investigation’s results and recommendations to senior management

Highlighted Matters

Post-Resolution Monitorships or Other Commitments

  • Represented a global, NYSE-listed company with regard to its independent compliance monitor imposed by U.S. authorities
  • Acted as “buffer counsel” between a central Chinese state-owned enterprise and an independent compliance monitor imposed by the African Development Bank
  • Represented a multinational "supermajor" oil and gas company in connection with a worldwide risk assessment and compliance audit, in coordination with a compliance monitor
  • Represented an internal oil services company regarding post-resolution regional anti-corruption reviews, in coordination with the company’s compliance monitor
  • Acted as “buffer counsel” between a CAC40-listed power, energy, and transportation multinational and its independent compliance monitor imposed as part of the company’s resolution of a World Bank sanctions investigation; the monitorship was successfully completed and was the first-ever cited by the U.S. DOJ as reason for not subsequently imposing a monitorship in the resolution of the company’s U.S. investigation
  • Assisted the independent compliance monitor as imposed on Innospec by the U.S. DOJ, U.S. Securities and Exchange Commission (SEC), U.K. Serious Fraud Office (SFO), and U.S. Office of Foreign Assets Control (OFAC)
  • Assisted with an independent compliance review regarding an independent compliance review of a United Nations contractor

Highlighted Matters

Due Diligence on Third Parties

  • Helped to design and successfully implement a strategy to identify, analyze, and (where possible) mitigate compliance risks associated with nearly 300 historical third parties, which was cited by regulators as one of the reasons for deferring prosecution of the company
  • Represented a leading aerospace and defense company with its due diligence on new third parties or third parties proposed for renewal
  • Represented a NYSE-listed company with due diligence on select high-risk third parties
  • Represented a medical device company with due diligence on third-party distributors or channel partners
  • Represented an international defense company with due diligence on third parties to assess compliance with U.S. International Traffic in Arms Regulations (ITAR)
  • Represented companies in defense, aerospace, pharmaceutical, medical device, oil and gas, oil services, power, energy, and transportation industries with the design and implementation of risk-based due diligence on third parties, including hundreds of interviews of client personnel and third parties in connection with such reviews

Highlighted Matters

Mergers & Acquisitions Anti-Corruption Due Diligence and Related Investigations

  • Assisting a multinational company with its pre-acquisition due diligence and post-acquisition integration of a U.S. target company
  • Provided anti-corruption and trade sanctions pre-acquisition due diligence advice to an NYSE-listed buyer across multiple transactions, several of which closed
  • Represented a world-leading aerospace and defense company regarding select pre- or post-acquisition anti-corruption due diligence reviews and/or compliance program integration
  • Currently representing a global company in its implementation of a due diligence protocol regarding the former parent company’s due diligence on payments for agents supporting the since-acquired business line
  • Represented a multinational company regarding the unwinding of several joint ventures, projects, or other investments with third parties, with a focus on the identification, analysis, and mitigation of potential anti-corruption risks
  • Represented a NYSE-listed company in conducting due diligence on an acquisition target’s third parties and conducting a subsequent review into a target subsidiary
  • Represented a NYSE-listed pharmaceutical company regarding its pre- and post-acquisition anti-corruption due diligence of a target in Brazil

Highlighted Matters

Compliance Program Enhancements, Risk Assessments, and Second-Level Controls

  • Assisted a global technology company in conducting a worldwide, risk-based assessment of its anti-corruption risk, following a resolution of criminal investigations
  • Advised a leading aerospace and defense company with ongoing review and enhancement of compliance policies and procedures
  • Assisted a leading aerospace and defense company with the design of compliance verification visits to perform second-level controls at regional subsidiaries
  • Assisted a leading aerospace and defense company with the design and execution of a comprehensive compliance risk assessment
  • Conducted a comprehensive compliance program review for a leading U.S. government defense contractor
  • Conducted a comprehensive anti-corruption compliance program review for a central Chinese state-owned enterprise’s international operations

Highlighted Matters

Other Litigation and Arbitration Experience

  • Assisted arbitration counsel in identifying and raising public policy arguments sounding in anti-corruption in defending claims by a client’s former third parties
  • Served as a witness regarding anti-corruption controls in practice in an international arbitration proceeding
  • Represented Americans taken hostage, and their families or descendants, by the Islamic Republic of Iran in November 1979 in civil litigation under the U.S. Foreign Sovereign Immunities Act (FSIA)
  • Represented a defendant who provided substantial assistance to the United States in the prosecutions of a then-sitting U.S. Senator and several state legislators
  • Represented a former U.S. cabinet official regarding several inquiries into events during his tenure and related civil litigation
  • Represented a defendant charged with criminal violations of U.S. federal campaign finance law
  • Represented a defendant in his U.S. federal plea and sentencing hearings in a case involving false bank records
  • Represented an attorney in disciplinary proceedings relating to his use of evidence in a U.S. federal agency proceeding
BIS Lays Groundwork for More ‘High Probability’-Based Enforcement, Including First-Ever ‘High Probability’ Presumption Warning and Policy Statement on the WMD and Military-Intelligence Catch-All Provisions
Client Advisories
View News Article
Treasury Announces First Steps Toward Fast-Track CFIUS Process
Client Advisories
View News Article
Commerce’s Section 232 Pharmaceutical Investigation: Opportunities for Companies Able to Comment by the May 7, 2025 Deadline
Client Advisories
View News Article
Commerce’s Section 232 Semiconductor Investigation: Opportunities for Companies Able to Comment by the May 7, 2025 Deadline
Client Advisories
View News Article
China’s Anti-Foreign Sanctions Law Gets Teeth: Understanding the 2025 Implementation Regulations
Client Advisories
View News Article
Designation of Criminal Cartels as Foreign Terrorist Organizations Increases Compliance Risks for Companies (US or Not) Operating in Mexico and Greater Latin America
Client Advisories
View News Article
Navigating the Pause: FCPA Compliance Under Trump’s New Order
Client Advisories
View News Article
Navigating New US AI Controls: Practical Guidance and Case Study for Companies in “Middle Tier” Countries
Client Advisories
View News Article
U.S. Senate Staff Report Calls for “High Probability” Export Controls Enforcement and Compliance — Key Takeaways and How to Respond
Client Advisories
View News Article
Treasury’s 2024 Annual CFIUS Conference Highlights Final Rule Enhancing Monitoring and Enforcement Provisions of CFIUS Regulations
Client Advisories
View News Article
Treasury Adopts the “High Probability” Standard in Final Rule Restricting Certain Outbound Investments to China: What this Means, and How to Respond
Client Advisories
View News Article
New U.S. Guidance Raises the Export Controls Due Diligence Bar for Financial Institutions under the “High Probability” Standard
Client Advisories
View News Article
BIS Issues Guidance Regarding Expectations for Companies and Universities Notified of Specific Export Diversion Risks
Client Advisories
View News Article
BIS’s 2024 Update Conference: Key Takeaways from Assistant Secretary for Export Enforcement Matthew Axelrod’s Remarks
Client Advisories
View News Article
Latest Tri-Seal Compliance Note Highlights Applicability of U.S. Sanctions and Export Control to Persons and Entities Located Outside of the United States
Client Advisories
View News Article
How We Can Apply Lessons from War to Exit Endless Whack-A-Mole Sanctions & Export Controls Compliance
Client Advisories
View News Article
US Products in Enemy Weapons Need Scrutiny Across Supply Chains
Client Advisories
View News Article
The U.S. Government Significantly Ramps Up Authority to Impose Sanctions against Foreign Financial Institutions that Facilitate the Supply of Russia’s War Machine
Client Advisories
View News Article
The Blind Men and the Elephant
Client Advisories
View News Article
Quint-Seal Compliance Note–Know Your Cargo: Best Practices for Maritime and Other Transportation Industries
Client Advisories
View News Article
Don't Lose the Trees for the Forest: Drafting Sanctions Clauses for a Multipolar World
Client Advisories
By Michael H. Huneke and Anna Hamati
View News Article
Damn the Torpedoes? Key Takeaways from the DOJ’s New M&A “Safe Harbor” Policy
Client Advisories
View News Article
DOJ Criminal Division Revises Corporate Enforcement Policy to Further Incentivize Voluntary Self-Disclosure and “Extraordinary” Cooperation
Client Advisories
View News Article
Cutting Through the Noise: Take-Aways from the DOJ’s Recent Announcements Regarding Corporate Criminal Enforcement
Client Advisories
View News Article
L’impact de l’arrêt Schrems II sur les programmes de conformité anticorruption
Client Advisories
View News Article
​Impact of Schrems II On Anti-Corruption Compliance Programs
Client Advisories
View News Article
Compliance Continuity in the Face of COVID-19
Client Advisories
View News Article
U.S. Supreme Court Ruling in Jam v. IFC Increases Pressure on Multilateral Development Banks and Recipients of MDB-Financed Contracts to Detect and Prevent Corruption and Other Sanctionable Practices
Client Advisories
View News Article
How is this Guidance Different from All Other Guidance? ― DOJ Asks Three Questions of Corporate Compliance Programs
Client Advisories
View News Article
In The Review of Securities & Commodities Regulation: FCPA Update: Third-Party Risks and Enforcement Actions
Client Advisories
View News Article
New FCPA Corporate Enforcement Policy May Move the Needle in Voluntary Disclosure Analysis
Client Advisories
View News Article
Resource Alert: From Car Wash to Fox Hunt -- A Strange Brew
Client Advisories
View News Article

News

Hughes Hubbard Announces New Cartel/Foreign Terrorist Organization Designations Taskforce
News & Events
View News Article
Michael Huneke Quoted in Global Investigations Review on “High Probability” Standard
Articles & Press
View News Article
U.S. Senate Staff Report on “High Probability” Standard Cites Two Articles Co-Authored by Michael Huneke
Articles & Press
View News Article
Firm Named to Global Investigations Review’s GIR 30 List for Second Year in a Row
News & Events
View News Article
Firm Reps Sotheby’s in $1 Billion Investment Round
News & Events |
Deals & Matters
View News Article
Retour sur la conférence « Actualités de la Compliance aux États-Unis et en France » organisée par Sorbonne Compliance et le Club des juristes
Articles & Press
By Michael H. Huneke, Jan Dunin-Wasowicz, Aurore Maroteau and Timothe Radosavljevic
View News Article
Taking a “Fresh Look” at Sanctions Compliance & Investigations Trends in the Era of the “New FCPA": Mike Huneke Co-Authors Two Recent Posts With Practical Tips and Guidance
News & Events |
People
View News Article
Michael Huneke and Jan Dunin-Wasowicz Author "Converging Practices for Bribery, Export Controls and Sanctions Anti-Evasion Regimes" in Westlaw Today
Articles & Press
View News Article
Michael Huneke Publishes Article on Pre-Acquisition Anti-Corruption Due Diligence for Financier Worldwide
Articles & Press
View News Article
Hughes Hubbard Assists Large Chinese SOE with Successful Release from World Bank Sanction | HHR团队助力中国某国有施工企业顺利获得世界银行解除制裁
News & Events
View News Article
HHR Team Represents a Chinese SOE in Obtaining a Successful Release from World Bank Sanction | HHR团队助力中国某综合性国企顺利获得世界银行解除制裁
News & Events
View News Article
Litigation Wrap: First Quarter 2022
News & Events |
Awards |
People
View News Article
Firm Launches All Things Investigations Podcast
News & Events
View News Article
HHR Team Assists Large Chinese Company with Successful Release from World Bank Sanction | HHR 团队协助中国某大型企业成功获得世界银行解除制裁
News & Events
View News Article
Litigation Wrap: First Quarter 2021
News & Events |
Awards |
Pro Bono
View News Article
Hughes Hubbard Honored for Airbus Probe at AmLaw Industry Awards
News & Events |
Awards
View News Article
Hughes Hubbard Wins GIR Award for Airbus Investigation
News & Events |
Awards
View News Article
HHR’s Anti-Corruption Team Shortlisted for GIR Award
News & Events |
Awards |
Deals & Matters
View News Article
In Jota: Compliance Continuity in the Face of COVID-19
Articles & Press
View News Article
Litigation Wrap: First Quarter 2018
News & Events |
Awards |
Deals & Matters |
People
View News Article
Litigation Wrap: Third Quarter 2017
News & Events |
Awards |
Deals & Matters
View News Article
FCPA & Anti-Bribery Alert Fall 2016
News & Events
View News Article
Hughes Hubbard Promotes Two to Partnership and Five to Counsel
News & Events |
People
View News Article
NY Financial Compliance Landscape May Get Treacherous
Articles & Press
View News Article
FCPA/Anti-Bribery Alert Winter 2015
News & Events
View News Article
FCPA/Anti-Bribery Alert Winter 2013
News & Events
View News Article
FCPA/Anti-Bribery Summer 2012 Alert Featured on The FCPA Report
News & Events
View News Article
FCPA/Anti-Bribery Alert: Summer 2012
News & Events
View News Article
FCPA/Antibribery Spring 2011 Alert Featured on FCPA Blog
News & Events
View News Article
FCPA Anti-Bribery Spring Alert 2011
News & Events
View News Article
Education
  • Harvard Law School, J.D., 2005
  • University of Virginia, B.A., 2002, with High Distinction, Phi Beta Kappa
Bar Admissions
  • District of Columbia, 2006
  • New York, 2022
  • Virginia, 2005
Languages
  • English
  • French
Areas of Focus
Defense Industry
Global Investigations, Enforcement and Compliance
Litigation
Multilateral Development Bank Investigations and Sanctions
Sanctions, Export Controls & Anti-Money Laundering
White Collar & Regulatory Defense

Hughes Hubbard & Reed LLP

Copyright 2025


Legal Notices Attorney Advertising Sitemap
𝕏
  • Locations
  • New York City
  • Kansas City
  • Los Angeles
  • Miami
  • Paris
  • Rio de Janeiro*
  • Tokyo
  • Washington, DC

*In cooperation with Saud Advogados

Privacy Policies and Notices

Careers
Associate Recruiting Working At HHR Available Positions
Culture
About Us Inclusion Pro Bono
Contact
𝕏