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).
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
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
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
"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
“HSBC Awarded Landmark French Settlement Despite Minimal Cooperation,” GIR, November 28, 2017
“Un Show a l'Americaine.“ Midi Libre, October 20, 2016
"Crise à la Cour Suprême," Midi Libre, February 25, 2016
U.S. Supreme Court (2009)
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.