Overview
Tom Best is an international investigations, enforcement defense and compliance lawyer, and a partner in the Investigations and White Collar Defense practice based in the firm’s Washington, D.C. office. He advises senior management and boards of directors on complex investigations, enforcement, compliance, and commercial issues arising under the U.S. Foreign Corrupt Practices Act (FCPA) and other countries’ anti-corruption laws, economic sanctions and export controls, the U.S. securities laws, and other legal regimes affecting major multinationals’ operations.
Mr. Best has defended dozens of companies and individuals over the years before the U.S. Department of Justice, Securities and Exchange Commission, U.S. Treasury’s Office of Foreign Assets Control (OFAC), UK Serious Fraud Office (SFO), Financial Conduct Authority (FCA) and other countries’ authorities. He routinely advises large corporate and financial institutions on compliance with economic and financial sanctions in high-value transactions.
Mr. Best is known for his practical, business-focused approach. His willingness to “roll up his sleeves” for clients has resulted in numerous declinations-of-prosecution from the U.S. Department of Justice, SEC and OFAC, and a strong track record of achieving innovative solutions, often working with regulators and enforcement agencies, to business problems presented by the complex and difficult sanctions and export control environment prevailing today.
Recognitions
- The Legal 500's International Trade: Customs, Export Controls and Economic Sanctions (2024)
- The Legal 500's Dispute Resolution – Economic Sanctions (2021)
- Recognized in Global Investigations Review’s “40 Under 40” List (2014)
Education
- University of Michigan Law School, J.D. 2002, cum laude
Associate Editor, Journal of International Law - Princeton University, A.B., 1997, Economics
Representations
- Cross-Border Investigations and Enforcement
- Global coordinating defense counsel on a near-half-billion dollar settlement between a global financial institution and the United States DOJ, SEC and UK FCA, and other national law enforcement agencies relating to corruption and fraud allegations in a sub-Saharan African country.
- Secured a declination-of-prosecution from the US DOJ on behalf of a major European industrial conglomerate relating to an Eastern European nation and allegations of corruption.
- Secured a declination-of-prosecution from the US DOJ on behalf of an oilfield service provider relating to corruption allegations in India.
- Representing a global medical device manufacturer before DOJ and SEC in connection with an FCPA investigation in India.
- Secured the removal of sanctions/de-listing of numerous individuals and entities subject to US, UK and EU, sanctions.
- Represented a consortium of international banks in connection with their ongoing obligations to comply with economic sanctions under multiple U.S., EU, and other sanctions regimes and their credit exposure to sanctioned companies.
- Representing multiple international financial institutions in connection with ongoing sanctions compliance and enforcement matters before OFAC, OFSI, and other regulators globally.
news
- Paul Hastings Named ‘White Collar Group of the Year’ by Law360 - January 27th, 2022
- Paul Hastings Named to World’s Top 10 Best Investigations Practices by Global Investigations Review - October 23rd, 2020
- Paul Hastings Accelerates Lateral Growth with Addition of Leading Entertainment and Media Litigation Partner - June 22nd, 2020
- Paul Hastings Wins National Law Journal’s Washington, D.C. White Collar Litigation Department of the Year Award - May 29th, 2020
- Paul Hastings Hires OECD Director of Legal Affairs Nicola Bonucci - November 18th, 2019
- Paul Hastings Energizes Houston Transactional Practice with Partner Duo, Continues Global Lateral Surge - October 1st, 2019
- Paul Hastings Continues Corporate Growth Hot Streak, Adding Prominent Capital Markets Partner in Los Angeles - August 19th, 2019
- Paul Hastings’ Leading Latin America Practice Welcomes Preeminent M&A/Capital Markets Team in São Paulo - August 8th, 2019
- Barrick Gold Deputy General Counsel Joins Paul Hastings in Washington, D.C. - May 13th, 2019
- Paul Hastings Continues Growth, Adding Top FCPA White Collar Litigators in Washington D.C. - April 10th, 2019
Recognitions
- Paul Hastings Ranked Top 5 in Global Investigations Review's "The GIR 30" 2022 - November 22nd, 2022
- Paul Hastings Championed as Most Impressive Investigations Practice by Global Investigations Review - November 10th, 2021
- Recognized among the World’s Top 10 Best Investigations Practices by Global Investigations Review for 2020 - October 23rd, 2020
- Recognized as the National Law Journal’s Washington, D.C. White Collar Litigation Department of the Year - May 27th, 2020
- Recognized in the Global Investigations Review’s GIR 100 for 2019 - October 24th, 2019
insights
- Statute of Limitations for IEEPA and TWEA Violations Extended to 10 Years, and Additional Sanctions Developments - July 24th, 2024
- OFAC Revokes General Authorization for Venezuelan Oil and Gas Sector But Permits Limited Wind-Down Transactions - April 26th, 2024
- New Sanctions on Russia Mark Two-Year Anniversary of Ukraine Invasion - March 8th, 2024
- OFAC Issues New General Licenses for Venezuela, Suspending Sanctions in Certain Sectors - November 17th, 2023
- The Russia-Ukraine War: Establishing a Claims Compensation Process - November 14th, 2023
- Safe Harbor in the Coming Enforcement Storm? DOJ Announces New M&A Policy to Encourage Compliance - October 10th, 2023
- First-of-its-Kind E5 Joint Guidance Prioritizes Industry Compliance to Prevent Diversion of Items Critical to Russian Weapons Systems - October 4th, 2023
- New U.S. Outbound Investment Restrictions on High-Technology Sectors in China - August 11th, 2023
- DOJ OFAC BIS Joint Compliance Note and Enhanced Coordination Highlights Increased Enforcement Risk - August 4th, 2023
- OFAC-OFSI Enhanced Working Partnership - October 20th, 2022
- U.S. Government Agencies Continue to Highlight Risks of Money Laundering Associated with Russia Kleptocrats, Deny Access to U.S. Financial System - May 10th, 2022
- Three Weeks In, the West Continues to Impose Severe Sanctions on Russia; U.S. Begins Enforcement Push - March 16th, 2022
- Three Weeks In, the West Continues to Impose Severe Sanctions on Russia; U.S. Begins Enforcement Push - March 16th, 2022
- Western Countries Enact Sweeping Sanctions Packages In Response to Invasion of Ukraine - March 1st, 2022
- Western Countries Enact Sweeping Sanctions Packages In Response to Invasion of Ukraine - February 28th, 2022
- The Ukraine Crisis: Sanctions Scenarios in the Event of Russian Invasion - February 16th, 2022
- The Ukraine Crisis: Sanctions Scenarios in the Event of Russian Invasion - February 16th, 2022
- PL 117-78 (December 23, 2021): The Uyghur Forced Labor Prevention Act - December 27th, 2021
- U.S. Expands Sanctions on Belarus, Aligning More Closely with Canada, EU, and UK - December 3rd, 2021
- On Your Mark, Get Set, Get Ready to Go -- Release of National AML Priorities Means Financial Institutions Will Need to Assess, Amend Their Anti-Money Laundering Programs - July 2nd, 2021
Engagement & Publications
- Moderator, “How to Effectively Structure, Scope and Manage the Process from Start to Finish,” C5’s 5th Annual Anti-Corruption Nordics Conference, Oslo, Norway, January30, 2019
- Moderator, “A Deep Dive into the Newest Third Party Risks Confronting Multinationals in the APAC Region,” C5’s 7th Annual Asia-Pacific Summit on Anti-Corruption, Singapore, November 2, 2018
- Moderator, “What Would You Do If …Practical Guidance for Working through Pressing, High-Stake Scenarios,” C5’s 7th Annual Asia-Pacific Summit on Anti-Corruption, Singapore, November 1, 2018.
- “Status Report on FCPA Enforcement Priorities,” American Conference Institute’s 12th Houston Forum on the Foreign Corrupt Practices Act, Houston, TX, January 24, 2018
- “Export Controls, Sanctions, and Transparency Requirements,” Georgetown Law Institute of International Economic Law, Washington, D.C., November 17, 2017
- “Global Corruption Risk Assessments: How to Effectively Map Your Company’s Greatest Risks,” 8th Global Forum on Anti-Corruption Compliance in High Risk Matters, Washington, D.C., July 26, 2017
- “Effective Benchmarks for Your Anti-Corruption Compliance Program,” The Knowledge Group, March 8, 2017
- “Walking the Thin Line Between Business and Bribe: Gifts, Travel and Hospitality,” American Conference Institute’s Houston Forum on the Foreign Corrupt Practices Act, Houston, TX, January 31, 2017
- “FCPA Year in Review 2016,” TRACE Webinar, December 14, 2016
- “Foreign Corrupt Practices Act,” Federal Publications Seminars, Arlington, VA, October 24, 2016
- “What is a Good Compliance Metric?,” American Conference Institute’s 10th Houston FCPA Boot Camp, Houston, TX, January 26, 2016
- “Foreign Corrupt Practices Act,” Federal Publications Seminars, Arlington, VA, October 26, 2015