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Michael H. Huneke

Partner

Washington, D.C., Paris

+1 (202) 721-4714

+33 (0) 1 44 05 76 20

michael.huneke@hugheshubbard.com
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“Michael H. Huneke”

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Michael H. Huneke is a partner in the Anti-Corruption & Internal Investigations practice group at Hughes Hubbard & Reed. 

Mike advises clients on the navigation and resolution of multi-jurisdictional criminal or Multilateral Development Bank (MDB) anti-corruption investigations, assisting companies subject to post-resolution monitorships or other commitments, designing and executing risk-based strategies for due diligence on third parties, conducting pre- and post-acquisition anti-corruption due diligence and integration, and the design and implementation of compliance risk assessments, compliance program enhancements, and second-level controls.

Mike's work is often under the shadow of potential or actual U.S. Foreign Corrupt Practices Act (FCPA) investigations, investigations involving other international anti-corruption laws, investigations by MDBs or other international institutions for potential sanctionable practices, export credit agency assurance reviews, or combinations of the above.

The Legal 500 has recognized Mike as a “voice of reason when it comes to compliance matters.”

Mike received Lexology’s Client Choice Award for Investigations-USA for 2022. Clients’ feedback included that Mike “is 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 Anti-Corruption & Internal Investigations 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

  • Winner of the 2022 Lexology Client Choice Award for "Investigations in USA”
  • 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
  • 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

  • “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 Anti-Corruption Lectures

  • "The Power of Pre-Acquisition Due Diligence," Hughes Hubbard & Reed All Things Investigations Podcast, Compliance Podcast Network, Podcast, Episode 15, November 7, 2022
  • "The GC Role in CCO Certification," Hughes Hubbard & Reed All Things Investigations Podcast, Compliance Podcast Network, Podcast, Episode 11, September 12, 2022 
  • “Coburn and the Attorney/Client Privilege,” Hughes Hubbard & Reed All Things Investigations Podcast, Compliance Podcast Network, Podcast, 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

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

  • Currently representing 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 Kevin Abikoff as the independent compliance monitor 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 Kevin Abikoff 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
  • Currently representing a leading aerospace and defense company with its due diligence on new third parties or third parties proposed for renewal
  • Currently representing a medical device company with due diligence on third-party distributors or channel partners
  • Currently representing a NYSE-listed company with due diligence on select high-risk third parties
  • 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

  • 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

  • Currently assisting 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
DOJ Criminal Division Revises Corporate Enforcement Policy to Further Incentivize Voluntary Self-Disclosure and “Extraordinary” Cooperation
Client Advisories
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Cutting Through the Noise: Take-Aways from the DOJ’s Recent Announcements Regarding Corporate Criminal Enforcement
Client Advisories
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L’impact de l’arrêt Schrems II sur les programmes de conformité anticorruption
Client Advisories
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​Impact of Schrems II On Anti-Corruption Compliance Programs
Client Advisories
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Compliance Continuity in the Face of COVID-19
Client Advisories
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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
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How is this Guidance Different from All Other Guidance? ― DOJ Asks Three Questions of Corporate Compliance Programs
Client Advisories
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In The Review of Securities & Commodities Regulation: FCPA Update: Third-Party Risks and Enforcement Actions
Client Advisories
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New FCPA Corporate Enforcement Policy May Move the Needle in Voluntary Disclosure Analysis
Client Advisories
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Resource Alert: From Car Wash to Fox Hunt -- A Strange Brew
Client Advisories
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News

Michael Huneke Publishes Article on Pre-Acquisition Anti-Corruption Due Diligence for Financier Worldwide
Articles & Press
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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
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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
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Litigation Wrap: First Quarter 2022
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Awards |
People
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Firm Launches All Things Investigations Podcast
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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
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Litigation Wrap: First Quarter 2021
News & Events |
Awards |
Pro Bono
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Hughes Hubbard Honored for Airbus Probe at AmLaw Industry Awards
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Awards
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Hughes Hubbard Wins GIR Award for Airbus Investigation
News & Events |
Awards
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HHR’s Anti-Corruption Team Shortlisted for GIR Award
News & Events |
Awards |
Deals & Matters
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In Jota: Compliance Continuity in the Face of COVID-19
Articles & Press
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Litigation Wrap: First Quarter 2018
News & Events |
Awards |
Deals & Matters |
People
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Litigation Wrap: Third Quarter 2017
News & Events |
Awards |
Deals & Matters
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FCPA & Anti-Bribery Alert Fall 2016
News & Events
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Hughes Hubbard Promotes Two to Partnership and Five to Counsel
News & Events |
People
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NY Financial Compliance Landscape May Get Treacherous
Articles & Press
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FCPA/Anti-Bribery Alert Winter 2015
News & Events
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FCPA/Anti-Bribery Alert Winter 2013
News & Events
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FCPA/Anti-Bribery Summer 2012 Alert Featured on The FCPA Report
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FCPA/Anti-Bribery Alert: Summer 2012
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FCPA/Antibribery Spring 2011 Alert Featured on FCPA Blog
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FCPA Anti-Bribery Spring Alert 2011
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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
Africa
Anti-Corruption & Internal Investigations
Defense Industry
Litigation
Multilateral Development Bank Investigations and Sanctions
White Collar & Regulatory Defense

Hughes Hubbard & Reed LLP

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