Nicolas Tollet is a Partner within Hughes Hubbard. He joined the firm from Technip, a CAC 40 oil and gas service firm, where he served as Vice President for Compliance and was based between Paris and Rio de Janeiro.

Nicolas has a decade of experience working on anti-corruption-related matters in a variety of contexts:

On the investigative side, he has worked on some of the largest resolutions by the U.S. DOJ and the SEC in both the pre- and post-settlement contexts, including inter alia the Alcatel, TSKJ and Lava Jato (Carwash) cases. He has also been assisting a multinational company in the frame of a joint investigation by the British SFO and the French PNF.

Nicolas is experienced with monitorships, and worked on the very first monitorship imposed on a French company by the DOJ and the SEC while he was at Technip. He is currently assisting a government anti-corruption agency through their monitorship of a company in the frame of a settlement with the prosecutor’s office following allegations of corruption.

On the preventive side, Nicolas has in-depth experience and knowledge of compliance programs and the internal functioning of multinational companies after having worked in-house for five years, both at headquarters and operational levels. He is assisting an important number of CAC 40 and SBF 120 companies, private equity firms, and more, in diverse industries for the development and implementation of their compliance programs around the world, conducting compliance audits in various jurisdictions, and M&A due diligence. He is also assisting a number of companies in the frame of the controls conducted by the French Anticorruption Agency (AFA), including a few of the first six companies of the first wave of controls.

Nicolas received the Best Compliance Department Award in 2016 while at Technip and was the only French lawyer selected among the 38 in-house investigations and compliance specialists worldwide for Global Investigation Review (GIR) in 2017. He is listed as Best Lawyer 2020 for Corporate Governance & Compliance, referred to by Chambers Partners, and he is recognized by Legal 500 EMEA where he is ranked Tier 1 and a Next Generation Lawyer.

Nicolas is admitted to practice in New York, Paris and the U.S. Supreme Court and he has been teaching anti-corruption compliance at the University of California Berkeley.

Nicolas also serves as Counselor to the President of the International Association of Lawyers (UIA) which brings together more than two million lawyers through its individual and collective members, promotes the rule of law, and defends the independence and freedom of lawyers around the world.

Recognitions

Best Lawyers 2021 for Corporate Governance & Compliance Practice
Recognized in Tier 1, The Legal 500 EMEA for Compliance & Investigations
Recognized as a Next Generation Lawyer by The Legal 500
2017 Selected as the only French lawyer among the top Investigations Specialists worldwide by GIR Inside In-House
2016 Compliance Department Award by the Leaders’ league (Trophées du Droit)
2015 Alumni Excellence in Service Award from the University of California Berkeley

Professional Activities

Counselor to the President of the Union Internationale des Avocats
Founder of The European Compliance Network, a network of thousands of compliance professionals
Regularly publishes articles on compliance
Speaks at international conferences, including lectures on anti-corruption at the University of California Berkeley
Founder and President Emeritus of the Berkeley Club of France
Received the 2015 Alumni Excellence in Service Award from the University of California Berkeley
Member of Transparency International and Cercle France-Ameriques

Highlighted Publications

"Quel rôle pour l’avocat post-enquête interne?" Dalloz Avocats, April 2020, n°4
"Quand l’avocat s’impose en partenaire privilégié de l’évaluation des tiers" Dalloz Avocats, March 2020, n n°3
“How to Assess Risk Under Sapin II,” The Anti-Corruption Report, December 11, 2019 (article co-authored with Bryan Sillaman)
“Première audience de la Commission des sanctions de l’AFA : Récit d’une passe d’armes sur ce qu’il convient d’attendre d’un programme de conformité anticorruption” (“First Hearing of the Sanction Commission of the French Anticorruption Agency: Story of a Sparring Match Over What is to be Expected from a Compliance Program”), International Review of Compliance and Business Ethics (August 2019) (article co-authored with Marie-Agnès Nicolas)
“Anti-Corruption Agency’s Sanctions Committee Holds Blockbuster Hearing,” FCPA Blog, July 8, 2019 (article co-authored with Marie-Agnès Nicolas)
“Une première entreprise française sous les feux des sanctions anti-corruption,“ Le Monde, July 1, 2019
Co-author, with Bryan Sillaman, "La France, suiveuse ou contributrice à la prevention mondiale de la corruption ? La loi Sapin 2 a-t-elle une vocation européenne voire internationale ? ", Revue Internationale de la compliance et de l’Ethique des Affaires, n°39, September 27, 2018
Co-author, with Marie-Agnès Nicolas, "Le déroulement des contrôles de l’AFA Scénographie tirée des premiers contrôles", Revue Internationale de la compliance et de l’Ethique des Affaires, n°39, September 27, 2018
Co-author, with Athena Arbes, “Upholding Human Rights Through the Lens of Due Diligence,” Ethical Boardroom, February 7, 2018
“Cartographie Des Risques: Retour d’expérience brésilien pour réussir l’exercice,” article publié dans le dossier “Loi Sapin 2, FCPA, UKBA, CCA: Comment ne pas se perdre dans le dédale de la conformité?”, Cahiers de Droit de l’Entreprise n° 2, March-April 2017 / "Risk Mapping: Feedback from Brazilian Experience for Successful Exercise ” Article published as part of the Article Series “Loi Sapin 2, FCPA, UKBA, CCA: How Not to Get Lost in the Compliance Maze”, Cahiers de Droit de l’Entreprise n° 2, March-April 2017 (article co-authored with Salim J. Saud Neto)
"New French anti-corruption law: Shall we be scared of France now?" The FCPA Blog, September 30, 2016
"France: Will a new anti-corruption law end U.S. mega-sanctions against French companies?" The FCPA Blog, December 3, 2015
"La « loi Sapin II », la fin des méga-sanctions américaines contre les sociétés françaises?" Revue Lamy de Droit des Affaires I Numéro 110, December 1, 2015
"A coordinated fight against corruption could help save the European Union," The FCPA Blog, November 16, 2015
"Évaluer et se protéger des risques de corruption en cas d’acquisition d’une entreprise industrielle," Revue Lamy de Droit des Affaires I Numéro 103, April 1, 2015
"Assessing and Protecting Yourself from the Corruption Risks When Acquiring an Industrial Business," International In-house Counsel Journal, Vol. 7, No. 28, Summer 2014, 1, June 27, 2014
"L'alternance pour Paris: quand l'éthique en politique porte enfin un nom," Le Huffington Post, March 13, 2014
"The Societas Europea: Europeanization via Americanization of Corporate Law. Corporate Governance: Only One Model?" Berkeley Electronic Press, June 2005

Highlighted Anti-Corruption Lectures

"How to Handle AFA Controls that Go Wrong," webinar, May 13, 2020
"Handling Anti-Corruption in the Private Equity Context," webinar, April 22, 2020
"Handling Anti-Corruption within M&A Transactions," webinar alongside the French Anticorruption Agency (AFA), March 26, 2020
"Introduction to Compliance," HHR Compliance Academy, March 6, 2020
"Investors' Perspective on Corruption Risks in the MENA Region," OECD and Union for the Mediterranean, Barcelona, Spain, February 18, 2020
“Overview of 2019 Anti-Corruption Activity in the U.S. and Around the Globe and 2020 Challenges,” American Bar Association, SIL Anti-Corruption Meeting, December 19, 2019
“Internal & External Investigations, and Voluntary Self-Disclosure,” French Association of In-House Counsels (AFJE) – Campus, Paris, November 29, 2019
“Enforcement Update,” International Forum on Business Ethical Conduct (IFBEC), Washington D.C., October 16, 2019
“Conducting Third Party Due Diligence,” Paris Bar School (EFB) and French Anticorruption Agency (AFA), Paris, October 8, 2019
"2019 Compliance Breakfast Series: Compliance Reviews," Hughes Hubbard & Reed LLP, Paris Office, October 3, 2019
“To Self Report or Not to Self Report,” Union Internationale des Avocats, Milan, September 13, 2019
"Responding to Investigations by the World Bank and Other Multilateral Development Banks," Hughes Hubbard & Reed, webinar, July 3, 2019
"Anti-Corruption Update on Investigations," Hughes Hubbard & Reed LLP, webinar, June 12, 2019
"Working Group: Anti-Corruption Due Diligence and M&A Transactions," Hughes Hubbard & Reed LLP, Paris Office, May 7, 2019
Cercle Montesquieu Annual General Assembly, Paris, April 11, 2019
"Due Diligence on Third Parties," EFB (Paris Bar School), performed jointly with the French Anticorruption Agency (AFA) and the Cercle Montesquieu, Paris, February 21, 2019
"Working Group: The French Anticorruption Agency (AFA)," Hughes Hubbard & Reed LLP, Paris Office, February 19, 2019
“French Anti-Corruption Update,” Hughes Hubbard & Reed LLP, webinar, January 23, 2019
"The French Anti-Corruption Landscape," Cercle Montesquieu, Paris, September 19, 2018
"Human Rights Becomes a Legal and Compliance Issue," UC Berkeley Law Compliance Academy, Paris, July 2018
“Navigating Compliance Risks in Europe,” GAN Integrity, webinar, May 14, 2018
"2018 Compliance Breakfast Series: Cross-Border Data Protection," Hughes Hubbard & Reed LLP, Paris, April 5, 2018
"2018 Compliance Breakfast Series: First Controls Performed by the French Anticorruption Agency (AFA)," Hughes Hubbard & Reed LLP, France-Amériques, Paris, January 25, 2018
"Compliance in the Supply Chain," French Association of In-House Counsels (AFJE) – Campus training performed jointly with Anheuser Bush InBev's Global Compliance Director, Chateauform George V, Paris, November 24, 2017
“2017 Compliance Breakfast Series: Criminal Business Law,” Hughes Hubbard & Reed LLP, Paris Office, November 22, 2017
“The Roles of the French Anticorruption Agency and Outside Counsel in the Context Post Sapin II,” Ecole Nationale de la Magistrature – Continuing Legal Education training performed jointly with the Head of the French Anticorruption Agency, Paris, November 14, 2017
“Legal Privilege and Lawyer Secrecy,” Hughes Hubbard & Reed and the Paris Bar, France-Ameriques, Paris, October 2, 2017
“2017 Compliance Breakfast Series: Personal Privacy and Data Protection Regulations,” Hughes Hubbard & Reed LLP, Paris Office, September 20, 2017
“2017 Compliance Breakfast Series: Anti-Corruption Perspective,” Hughes Hubbard & Reed LLP, Paris Office, July 12, 2017
“M&A, Compliance and Corruption,” Advanced Academic Seminar on Compliance, University of California BerkeleyLaw and Hughes Hubbard & Reed LLP, Paris, June 20, 2017
“2017 Compliance Breakfast Series: M&A Lawyers’ Perspective,” Hughes Hubbard & Reed LLP, Paris Office, June 14, 2017
“2017 Compliance Breakfast Series: Social Lawyers’ Perspective,” Hughes Hubbard & Reed LLP, Paris Office, May 18, 2017
“2017 Compliance Breakfast Series: Banking Lawyers’ Perspective,” Hughes Hubbard & Reed LLP, Paris Office, April 26, 2017
"How to Perform an Internal Investigation and How to Handle an Investigation by Anti-Corruption Authorities," Association of French In-House Counsel (AFJE), InterContinental Paris Le Grand Hotel, Paris, April 25, 2017
"Public-Private Dialogue on the Prevention of Corruption in France," Business Associations and the Fight Against Corruption in the Middle East and North Africa (MENA) Region Program, OECD Conference Center, Paris, March 29, 2017
“Sapin 2: Strategies to Improve Anti-Corruption Compliance Programs & Arguments to Obtain Resources from Management,” Agora des Directeurs Juridiques, Plaza Athénée Palace, Paris, March 23, 2017
“Compliance as a Tool to Enhance Operations and Strategy,” From the Spirit of the Laws Breakfast, Cercle Montesquieu, Paris, February 1, 2017
“ How to Apprehend Anti-Corruption Compliance in an M&A Transaction,” Professional Talks, BerkeleyLaw, Berkeley, June 28, 2016
“Merger Integration Management Forum,” 8th Edition, Thought Leader Global, Amsterdam, March 17, 2016
“Preventing Risks and Antic-Corruption Strategy,” 4th Edition, Marcus Evans, Paris, November 26, 2015
“Corporate Fraud and Corruption Forum,” 11th Edition, Thought Leader Global, Amsterdam, May 12, 2015
“Anti-Corruption France,” 5th Edition, C5, Paris, May 13, 2014
“Advanced European Forum on Anti-Corruption,” 7th Edition, C5, Frankfurt, January 29, 2014

Quotes & Interviews

"Corruption internationale : les entreprises encouragées à dénoncer des faits internes," Les Echos, June 8, 2020
"La France saisit la corruption à bras-le-corps," Les Echos, January 10, 2020
“Ces avocats d’affaires entre deux rives,” L’Agefi, December 12, 2019
Interview, Compliances Magazine, December 2019
Quoted in “Corruption: le Brésil rappelé à l’ordre pour son relâchement,” L’Opinion, November 21, 2019
Interview, Le Monde du Droit, September 19, 2019
“Compliance et entreprises : ce que l’Agence française anticorruption attend, ” Le Monde du Droit, April 17, 2019
Quoted in "As Danske Counts Cost of Money-Laundering Lapses, U.S. Looms," Bloomberg, September 21, 2018
"Monitorship Decision in Société Générale Libya Settlement 'Milestone' for US/France Cooperation," GIR, June 7, 2018
“France Smacks Down Second-Largest Bank to Become Key Bribery Cop,” Bloomberg, June 5, 2018
"La rèvolution de la lutte anti-corruption est en marche," Wansquare, May 2, 2018
Quoted in "Bollore Stays in Custody as French Bribery Cops Face 'Taboo," Bloomberg News, April 24, 2018
"French Prosecutors Reach First Bribery DPAs," GIR, March 8, 2018
“HSBC Awarded Landmark French Settlement Despite Minimal Cooperation,” GIR, November 28, 2017
“Top Investigations Specialists Worldwide - Nicolas Tollet,” GIR Inside In-House, Profiles, December 13, 2016
“Un Show a l'Americaine.“ Midi Libre, October 20, 2016
"Crise à la Cour Suprême," Midi Libre, February 25, 2016

Court Admission

U.S. Supreme Court (2009)

Highlighted Matters

Nicolas Tollet assists a significant number of CAC 40 and SBF 120 companies in a wide range of industries including construction, hospitality, luxury, energy, defense, telecommunication, transportation, logistics, IT, and private equity.

He assists them on their issues relating to anti-corruption, anti-money laundering, sanctions and terrorism financing, human rights, and data protection.

Investigations

Conducting the internal investigation of a then CAC 40 company in the frame of its negotiations with the US DOJ and SEC in view of reaching a deferred prosecution agreement
Assisting a CAC 40 company in its internal investigations and negotiations with the French PNF and British SFO
Conducting in-house for over two years and a half the internal investigations of the Brazilian operations of a CAC 40 company which led to a joint-deferred prosecution agreement with the US DOJ and SEC and the Brazilian authorities (MPF)
Conducting in-house the internal investigations in various jurisdictions for a CAC 40 company
Conducting internal investigations in China, Bangladesh, India, Pakistan and Turkey for a CAC 40 company, and assisting on the remediation strategy
Assisting a CAC 40 company conduct an internal investigation over allegations of private passive corruption in the UK
Assisting a consumer good company (Forbes Global 15) conduct an internal investigation to clear conflict of interests

Regulatory Inspections

Assisting a CAC 40 company in responding in advance to the French Anticorruption Agency (AFA) questionnaire and assessing its compliance program
Ongoing assistance of an SBF company with completion of an inspection launched by the AFA as part of the fourth wave of AFA controls
Ongoing assistance of a CAC 40 company with completion of an inspection launched by the AFA as part of the second wave of AFA controls
Successfully assisting a group through the first ever anti-corruption inspection launched by the AFA as part of the first wave of AFA controls
Assisting a CAC 40 company in responding in advance to the AFA questionnaire and putting together the draft submission and attachments
Assisting a CAC 40 company in reviewing its draft responses to the AFA questionnaire
Assisting a world’s leading transportation and logistics company in reviewing its draft responses to the AFA questionnaire
Assisting a CAC 40 company in the frame of an inspection by the Anti-Money Laundering Authority (COAF) in Brazil
Assisting a CAC 40 company in the frame of an inspection by the Anti-Money Laundering Authority (Assay Chamber) in Russia

Monitorships

Assisting in-house for two years a CAC 40 company successfully complete its monitorship imposed by the US DOJ and SEC
Assisting a governmental anticorruption agency through their first monitorship of a company in the frame of a settlement with the prosecutor’s office following allegations of corruption

Third-Party Due Diligence & Books and Records Audits

Assisting an oil services company in conducting third party due diligence in Angola
Conducting a dozen third party due diligence for a CAC 40 company
Assisting a CAC 40 company in conducting third party due diligence
Assisting an SBF 120 company in conducting third party due diligence
Conducting in-house in-depth on-site due diligence for dozens of commercial agents, logistics agents and joint-venture partners in Latin & Central America, Africa, Asia and Europe for a CAC 40 company
Auditing in-house commercial agents, logistics agents and joint-ventures in Latin America for a CAC 40 company

Risk Assessments & Risk Mappings (incl. in the frame of M&A)

Performing the worldwide risk assessment of a CAC 40 company and turning the results into a risk mapping
Performing the worldwide risk assessment of an SBF 120 company and turning the results into a risk mapping
Performing the worldwide risk assessment of a defense company and turning the results into a risk mapping
Performing the risk assessment of the French operations of a consumer good company (Forbes Global 15) and turning the results into a risk mapping
Assisting a CAC 40 company in conducting its global risk assessment in view of preparing its global risk mapping
Assisting a CAC 40 company in deepening its global risk assessment and in turning the results into its global risk mapping
Assisting a world’s leading transportation and logistics company in designing its global risk mapping
Performing an in-depth on site risk assessment of the UAE operations of a CAC 40 company
Performing an in-depth on site risk assessment of the Tunisian operations of an SBF 120 company
Performing an in-depth on site risk assessment of the Chinese and Middle East operations of a CAC 40 company
Performing an in-depth on site risk assessment of the Jordanian operations of an SBF 120 company
Performing in-house an on-site in-depth risk assessment of the Northern Europe operations of a CAC 40 company

Compliance Programs

Assisting a CAC 40 company significantly improve its overall compliance program
Assisting a CAC 40 company significantly improve its overall compliance program
Assisting a CAC 40 company significantly improve its overall compliance program
Assisting a CAC 40 company design its compliance processes in M&A transactions
Assisting a CAC 40 company design its code of conduct
Assisting an SBF 120 company significantly improve its overall compliance program
Assisting an SBF 120 company significantly improve its overall compliance program
Assisting a consumer good company (Forbes Global 15) improve its overall compliance program
Assisting a world’s largest private equity company improve its compliance program
Assisting a defense company create its overall compliance program
Assisting a renewable energy company create its overall compliance program
Assisting a CAC 40 company in its day-to-day implementation of its compliance program
Assisting a CAC 40 company in its day-to-day implementation of its compliance program
Assisting an SBF 120 company in its day-to-day implementation of its compliance program
Assisting a CAC 40 company with certain questions raised while implementing its compliance program
Assisting a private equity company with certain questions raised while implementing its compliance program
Implementing in-house the worldwide compliance program of a CAC 40 company

Trainings

Performing tailored trainings for compliance officers of a CAC 40 company
Performing tailored trainings for the employees of a renewable energy company
Performing tailored trainings for employees of a consumer goods company (Forbes Global 15)
Performing tailored trainings for investment teams of a private equity company

L’impact de l’arrêt Schrems II sur les programmes de conformité anticorruption

Client Advisories

Impact of Schrems II On Anti-Corruption Compliance Programs

Client Advisories