Nicolas Tollet is 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 ranked Tier 1 by Legal 500 EMEA.

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.

Recognitions

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

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

“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

“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
“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

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

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 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 consumer good company (Forbes Global 15) conduct an internal investigation to clear conflict of interests
Assisting in-house 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
Ongoing assistance of a CAC 40 company complete an inspection launched by the French Anticorruption Agency (AFA)
Successfully assisting a group through the first ever anti-corruption inspection launched by the AFA
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
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 Tunisian operations of an SBF 120 company
Performing an in-depth on site risk assessment of the Chinese 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
Assisting a CAC 40 company significantly improve its compliance program
Assisting a CAC 40 company significantly improve its compliance program
Assisting a CAC 40 company significantly improve its compliance program
Assisting a CAC 40 company design its code of conduct
Assisting an SBF 120 company significantly improve its compliance program
Assisting an SBF 120 company significantly improve its compliance program
Assisting a consumer good company (Forbes Global 15) improve its compliance program
Assisting a world’s largest private equity company improve its compliance program
Assisting a defense company create its compliance program
Assisting a renewable energy company create its 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
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
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

Firm Named to 2019 Global Investigations Review (GIR) 100

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Awards

Hughes Hubbard Elects Leading Compliance Attorney Nicolas Tollet to Partner

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Hughes Hubbard Selected for Inclusion in the 2018 Global Investigations Review (GIR) 100

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Awards

Feedback on a Global Paris Compliance Experience

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Event Recap

Nicolas Tollet Selected to GIR's Inaugural Survey of Top Worldwide Compliance Professionals

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Hughes Hubbard Expands Anti-Corruption and Internal Investigations Practice

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