N. Tien Pham advises corporations, individuals and other entities on compliance, internal investigations, corporate governance, and securities and accounting investigations. Tien has represented clients on matters before the US Department of Justice, the UK Serious Fraud Office, US Securities and Exchange Commission (SEC), and the Financial Industry Regulatory Authority (FINRA).
In particular, Tien has performed internal investigations (including those stemming from whistleblower reports) and due diligence exercises around the globe, including in Brazil, China, Japan, France, Kuwait, Indonesia, Cyprus, Thailand, and Venezuela. Tien has led trainings on anti-corruption risk assessments and third-party due diligence reviews and has developed and enhanced policies and procedures in key risk areas for domestic and global organizations across various industries.
Tien also has experience conducting securities investigations involving alleged disclosure and accounting improprieties, insider trading, stock fraud and trade manipulation. She has successfully represented corporations and individuals in investigations and inquiries by the SEC and FINRA.
Prior to joining Hughes Hubbard, Tien was a tax associate at a large national law firm. Prior to entering law practice, she was a securities fraud analyst at the Financial Industry Regulatory Authority and an auditor at Ernst & Young LLP. Tien also law clerked for the SEC’s Enforcement Division and the Maryland Attorney General’s Securities Division. She has taught numerous auditing and forensic accounting courses, including at American University, Georgetown University Law Center, and the U.S. SEC. Tien welcomes relevant speaking engagement invitations.
Tien is a Board Member of the Vietnamese American Bar Association of the Greater Washington D.C. area. She is also a certified public accountant in the states of Maryland and Virginia.
2015 Capital Pro Bono Honor Roll, sponsored by the District of Columbia Court of Appeals and the Superior Court of the District of Columbia
Board of Directors, Vietnamese American Bar Association of the Greater Washington DC Area, 2016
Highlighted Publications and Lectures
"The New Foreign Corrupt Practices Act Enforcement Policy," The Knowledge Group LLC, webinar, October 2018
"The Foreign Corrupt Practices Act: Understanding Key Issues and Ensuring Compliance in 2017 and Beyond," The Knowledge Group LLC, webinar, October 2017
“Practice note: Audit rights power up a compliance program,” co-authored with Benjamin S. Britz,The FCPA Blog, Dec. 22, 2015
“FCPA Compliance Audits: Best Practices in 2016 & Beyond,” American University, Nov. 16, 2016
Anti-Corruption and Integrity Compliance
Current representation of multinational “supermajor” oil and gas company in connection with a worldwide risk assessment and compliance audit, in coordination with a compliance monitor
Current representation of CAC 40 French multi-national engineering and construction company in a worldwide review, including with respect to activities in South America, Asia, Europe, and the Middle East
Current representation of world-leading aerospace and defense company in connection with anti-corruption reviews, risk assessments, and related investigations
Current representation of a NASDAQ-listed multinational automotive company in connection with an internal investigation and compliance program review
Current representation of world’s top luxury company (CAC 40) to enhance its anti-corruption compliance program, with a focus on complying with AFA’s guidance
Conducted anti-corruption internal investigation for a multinational manufacturing company with worldwide operations with an investigative focus in China
Conducted due diligence reviews, including of third parties and joint ventures, for various companies, including manufacturing, construction, and oil and gas companies
Reviewed and enhanced an internal audit program, with a focus on FCPA compliance, for Fortune 500 pharmaceutical company
Conducted internal investigations stemming from whistleblower reports on behalf of various multinational corporations
Conducted risk assessments for various companies with global operations
Reviewed and enhanced compliance processes and protocols for manufacturing, oil and gas, pharmaceutical, engineering, aerospace and defense, and other companies with worldwide operations
Developed, drafted, and enhanced policies and procedures in key risk areas (including on escheatment) for domestic and global companies across various industries
Developed, enhanced, and conducted trainings on anti-corruption risk assessments and third-party due diligence reviews
Securities Investigations and Enforcement
Current representation of a NASDAQ-listed company in an SEC investigation involving alleged disclosure violations
Successful representation of a large South Asian technology company in SEC inquiry involving alleged accounting improprieties
Successful representation of former Chief Compliance Officer of a financial services company before the Financial Industry Regulatory Authority
Representation of Fortune 500 automotive company in response to an insider trading subpoena from the U.S. Securities and Exchange Commission
Current representation of Sudanese individual on a pro bono basis seeking asylum in the U.S.
Current representation of a tenant on a pro bono basis in an eviction matter
Representation of minor on a pro bono basis seeking SIJS (Special Immigrant Juvenile Status)