Nicolas Tollet

Nicolas Tollet is a Counsel within Hughes Hubbard’s Anti-Corruption and Internal Investigations practice group. He previously served as Vice-President Group Compliance for Technip, a French multinational company, and was based between Paris and Rio de Janeiro.

Since he joined Hughes Hubbard, Nicolas has worked on matters relating to anti-corruption, anti-money laundering, human rights, sanctions and embargoes and data protection across many industries, including defense and space, oil and gas services, energy, luxury goods, consumer goods, software, beverage, etc. He also assisted a multinational in the first audit ever performed by the newly created French Anticorruption Agency (AFA).

Indeed, Nicolas has significant experience working on compliance-related matters in a variety of contexts.  He began his career working with another international law firm, where he initially focused on corporate matters.  Since 2008, he has focused primarily on compliance, and has worked on some of the largest resolutions by the US DOJ and the SEC in both the pre- and post-settlement context (including inter alia the Alcatel and TSKJ cases). While at Technip, Nicolas spent time working both at headquarters and in the company’s operations, providing him with insight into the internal functioning of multinational corporations and the implementation of compliance programs into such corporations.

His experience includes navigating monitorships, conducting internal and external investigations, establishing robust compliance programs, conducting third party due diligence, and developing and performing training for diverse employee populations. He has an in-depth knowledge of the FCPA, UKBA, Brazil Clean Company Act and French anti-corruption laws. He worked actively with members of the French Parliament on drafting France’s revised law on anti-corruption “Sapin 2,” which was passed into law in December 2016.

Prior to 2008, Nicolas focused his practice on mergers and acquisitions, LBOs, restructuring and financing, which provides him with the ability to comprehend how compliance functions within such contexts

Nicolas is actively involved in the international compliance community. He has worked on several of the largest ant-corruption cases in the world and he regularly talks about his experience at international conferences, is followed by a community of nearly 14,000 legal and compliance professionals around the world and has taught anti-corruption compliance at the University of California Berkeley. 

In 2016 while at Technip, he received the Best Compliance Department Award (Trophée du Droit) from the Leader’s League and in 2017, Global Investigation Review (GIR) selected him as among the top 37 in-house investigation specialists in the world (the only French).

• Assisting a CAC 40 company with its compliance matters. During the engagement, he assisted the company in the frame of an anti-corruption audit launched by the French Anticorruption Agency (AFA) and with the improvement and implementation of its compliance program.
• Assisting a group in the software industry in the frame of the first ever anti-corruption audit launched by the French Anticorruption Agency (AFA).  During the engagement, he assisted the company in (i) responding to the authorities, (ii) setting up its compliance organization and program around the world, (iii) conducting due diligence on certain of its business partners.
• Assisting a world’s top 5 luxury company (CAC 40) in upgrading its compliance program.  During the engagement, he assisted the company in (i) improving its anti-corruption program, (ii) improving its sanctions and embargoes program, (iii) setting up its anti-money laundering program, (iv) complying with the new French law on the duty of care relating to Human Rights.  His work notably included the review of privacy laws, labor laws and anti-money laundering laws in nearly 70 countries with respect notably to whistleblowing alerts, cross-border transfer of data, and internal investigations. 
• Assisting a group in the aerospace industry (SBF 120) in reviewing its operations and upgrading its compliance program.  During the engagement, he assisted the company in (i) conducting risk assessment of its global operations, (ii) adjusting its anti-corruption policies and procedures and (iii) conducting post-acquisition risk assessments in certain jurisdictions.
• Assisting a group in the consumer goods industry (Forbes Global 15) in reviewing its operations and upgrading its compliance program.  During the engagement, he assisted the company in (i) conducting risk assessment of its operations in select jurisdictions, (ii) adjusting its anti-corruption policies and procedures and (iii) training its personnel.
• Assisting a group in the renewable energy industry in reviewing its operations and creating its compliance program.  During the engagement, he assisted the company in (i) conducting risk assessment of its global operations and (ii) creating its compliance program with respect to anti-corruption, sanctions and embargoes.
• Assisting a group in the defense equipment industry in reviewing its operations and creating its compliance program.  During the engagement, he assisted the company in (i) conducting risk assessment of its global operations and (ii) creating its compliance program with respect to anti-corruption, sanctions and embargoes.
• Assisting another world’s top 5 luxury company (CAC Next 20) in designing its anti-money laundering program and its sanctions and embargoes program worldwide.
• Assisting one of France’s largest private equity firms in training their portfolio companies, training their investment teams and in providing compliance advice. 
• Assisting a Fortune 100 company in the beverage industry in providing compliance advice.