Overview
Jonathan C. Drimmer is a partner in the firm's Washington, D.C., office, where he resolves anti-corruption, business and human rights and other complex cross-border challenges with the benefit of having sat in every chair at the table: senior legal officer for a global 500 company, federal prosecutor, and seasoned advocate. He is a frequent speaker, author, and commentator on issues related to anti-corruption and business and human rights, and represents and advises companies, individuals, multi-stakeholder initiatives, government entities and civil society organizations on both topics.
Before joining Paul Hastings, he was Deputy General Counsel and Chief Compliance Officer of Barrick Gold, one of the world's largest mining companies, with operations on five continents. The compliance program he built at Barrick has served as an industry standard, and elements of it have largely-been duplicated by numerous other companies inside and outside of the extractive sector.
Aspects of the program he helped build at Barrick are the subject of a 2016 Harvard Business School Case Study.
Mr. Drimmer has directed hundreds of investigations around the world related to anti-corruption and human rights, as well as AML and export controls, tax controversies, environmental incidents, public disclosures, fatalities and health and safety injuries, sexual harassment and discrimination, and similar areas. He has represented companies and individuals in numerous high-profile government enforcement proceedings in the U.S. and overseas, in relation to FCPA and bribery claims, human rights issues, and a wide array of other matters. He has participated in dozens of major disputes in the U.S., Canada, and abroad, including transnational torts, anti-corruption claims, environmental cases, international arbitrations, tax disputes, construction claims, and land controversies. He has been retained as an expert witness, both in relation to anti-corruption and business and human rights, and has assisted companies in building best-in-class anti-corruption and business and human rights compliance programs.
Mr. Drimmer also has wide-ranging experience in helping companies manage multi-faceted dilemmas in overseas activities, developing and managing solutions that may encompass civil, criminal, regulatory, and political dimensions. He has designed a variety of human rights remedy programs, and has particular experience in representing companies in non-judicial and quasi-judicial legal proceedings involving human rights and transnational torts, including OECD National Contact Point disputes, claims before international human rights commissions, and inquiries by UN offices and agencies.
He previously served in the Justice Department as Deputy Director of the Criminal Division's Office of Special Investigations, where he led cross-border investigations, first-chaired numerous prosecutions, and argued federal appeals. He was a partner at an Am Law 100 law firm in Washington, D.C., a former Bristow Fellow in the Office of the U.S. Solicitor General, and a judicial clerk on the U.S. Court of Appeals for the Ninth Circuit. Mr. Drimmer served on the board of directors of the Voluntary Principles on Security and Human Rights Initiative from 2012-2014, and again from 2015-2017. He served on the board of TRACE International from 2012 until 2018, and currently sits on the board of the TRACE Foundation. He is a member of the World Economic Forum's Global Future Council on the Future of Good Governance, and taught international law courses at Georgetown University Law Center for nearly 20 years.
Recognitions
- Chambers Global Market Leaders Business & Human Rights Law - Band 1 (2022)
- Recipient of Charles Fahy Distinguished Adjunct Professor Award, Georgetown University Law Center
- Recognized with the first U.S. Department of Justice Assistant Attorney General Award for Human Rights Law Enforcement
- Recognized by Legal Era as one of the top 100 in-house counsel in the world
- Selected by Legal500 as one of the 100 most influential in-house counsel in the U.S. and Canada
- Recognized by Ethisphere Magazine as one of the world’s leading attorneys in Ethics & Compliance
- Selected by National Law Journal as a Regulatory and Compliance Trailblazer
Education
- UCLA School of Law
- Stanford University
Bar & Court Admissions
- D.C. Bar
- California Bar (inactive)
Engagement & Publications
- "Five Steps for Companies Facing an OECD National Contact Point Process," Anti-Corruption Report (Dec. 2019) (co-author)
- "ESG and Mission-Critical Issues for Director & Officer Liability," Corp Gov (Dec. 2019) (co-author)
- "Behavioral Ethics and Economics, Compliance Culture and Meeting DOJ’s Compliance Expectations," Anti-Corruption Report (June-July 2019)
- "Doing Business in Argentina after the Notebooks Scandal," Anti-Corruption Report (March 2019)
- FCPA Compliance: The Role of Data Collection & Analysis, Securities & Commodities Regulation (May 2018) (co-author)
- OECD Guidelines for Responsible Business Conduct & Sector Specific Guidance: A Manual for Canada, Global Compact Network Canada (April 2018) (working group lead)
- Developing KPIs and Tracking Metrics Using ISO 37001, 5 FCPA Report 22 (Nov.-Dec. 2016) (co-author)
- Children’s Rights and Security Checklist and Handbook, UNICEF (2017, 2018) (working group co-lead)
- A Guidance Document to Assist Companies Assess and Manage Corruption Risk, Global Compact Network Canada (2016) (working group lead, author of several chapters)
- Developing Key Performance Indicators and Tracking Metrics for an Anti-Corruption Compliance Program, 5 FCPA Report No. 4-5 (Feb.-March 2016) (two part article)
- Auditing Implementation of Voluntary Principles on Security and Human Rights: A Guidance Document to Assist Companies and their Auditors Assess Implementation of the Voluntary Principles on Security and Human Rights, Global Compact Network Canada (2015) (primary author and working group lead)
- The Third Pillar: Remedies, Reparations and the Ruggie Principles, in The Business and Human Rights Landscape (Cambridge Univ. Press 2015, K. Bravo & J. Martin eds.) (co-authored book chapter)
- Does the Hand Fit the Glove?: Assessing your Company’s Anti-Corruption Compliance Program, ACC Docket (June 2013)
- Kiobel and the Guiding Principles on Business and Human Rights, ACC Docket (June 2012)
- Think Globally, Sue Locally: Trends and Out-of-Court Tactics in Transnational Tort Actions, 29 Berk. J. Int’l L. 456 (2011)
- Think Globally, Sue Locally, Wall Street Journal (June 2010)
- Emerging Risk, Private Equity Manager Monthly (February 2010)
- Is Second Circuit Ruling a "Talisman" Against Alien Tort Statute Suits? Washington Legal Foundation Legal Backgrounder (February 2010)
- New Costs of Doing Business Abroad, L.A. Daily Journal (December 2009)
- Specific Corporate Compliance Challenges: Extractive Industry, in Corporate Compliance Practice Guide: The Next Generation of Compliance (Carol Basri, ed.) (Oct. 2009)
- When Being Hospitable Can Land You In Trouble, Hospitality (June-July 2009) (2 part series)
- On Location, In Compliance, L.A. Daily Journal (April 2009)
- How to Steer Clear of the Human Rights Litigation Trend, Engineering & Mining Journal (May 2009)
- At Home And Abroad, Corporate Counsel (April 2009)
- It’s a Crucial Process, National Law Journal (August 2008)
- Cross-border Justice the American Way, Law Society Gazette (UK) (January 2008)
- Don’t Be Dubbed A Human Rights Abuser, Legal Times & Law.com (October 2007)
- Corporate Exposure Under the Alien Tort Claims Act, Corporate Counsellor (June 2007)
- Courts Mixed on Foreign Claims, Hart’s E&P (October 2006)
- The Saddam Hussein Verdict: Mixed Progress, National Law Journal (November 2006)
- Appearances include 60 Minutes, NBC Nightly News, ABC World News Tonight, CBS This Morning, CNN, CNN International, BBC, MSNBC, Fox News, FoxFiles, Prime Time Justice, Court TV, The History Channel, The Learning Channel, Canadian Broadcasting Channel, NPR’s Morning Edition, Voice of America, and ABC News Radio. Quoted in such publications as The New York Times, The Wall Street Journal, The Washington Post, Financial Times, The New Yorker, USA Today, Harper’s, The Los Angeles Times, The Chicago Sun Times, The Chicago Tribune, The Boston Globe, The Houston Chronicle, American Lawyer, New York Law Journal, The International Herald Tribune, The Detroit Free Press, AP, Reuters, and UPI
- Numerous conference presentations and panels, and working group roundtables, on FCPA and human rights issues. Numerous Lexis/Nexis Expert Commentaries on issues related to the prosecution of state leaders, human rights, cross-border law enforcement, and other international legal issues
Involvement
- Selected by The Global Business Initiative on Human Rights (GBI) as their Advisor for North America
- Strategic Advisor, Secretariat of the Voluntary Principles on Security and Human Rights
- Senior Advisor, BSR
- Member, World Economic Forum's Global Future Council (GFC) on the Future of Good Governance
- Member of the Board of Directors of the Trace Foundation
- Subject Matter Expert, Canadian Center for Excellence on Anti-Corruption Former Chairman of the Board, Global Compact Network Canada
- Former Member of the Board of Directors of Transparency International Canada
- Former Member of the UN Global Compact's Business for Peace Steering Committee
- Former Member of the Stakeholder Advisory Board, U.S. OECD National Contact Point
- Former Member of the ANSI U.S. working group to create an ISO Anti-bribery Management System Standard