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Image: Tom Best

Tom Best

Partner, Litigation Department

Overview

Tom Best is an international investigations, enforcement defense and compliance lawyer and a partner in the Investigations and White Collar Defense practice of Paul Hastings, based in the firm’s Washington, D.C. office. For more than 20 years he has successfully defended some of the largest and most complex international investigations and enforcement matters before the U.S. Department of Justice, U.S. Securities and Exchange Commission, U.K. Financial Conduct Authority, U.K. Serious Fraud Office, U.S. Treasury’s Office of Foreign Assets Control and other enforcement agencies around the world.

He routinely advises large corporates and financial institutions on sanctions, export controls, foreign corruption, money laundering and other cross-border criminal risks; compliance program risk assessment, design and implementation; and complex sanctions, export controls and other cross-border business problems with regulatory and enforcement risks in the M&A, IPO and other corporate transactional context.

Tom is known for his practical, business-focused approach to disputes and cross-border risk problems. His willingness to “roll up his sleeves” for clients has resulted in numerous declinations-of-prosecution/enforcement from the U.S. Department of Justice, SEC, OFAC and BIS, and a strong track record of achieving innovative solutions, often working with regulators and enforcement agencies, to achieve positive business outcomes in the face of ever-more-complex risks presented by today’s volatile geopolitical situation. Tom is one of the few practitioners recognized internationally in both the economic sanctions and export controls and foreign corruption investigations and enforcement spaces. 

Accolades

  • The Legal 500, International Trade: Customs, Export Controls and Economic Sanctions (2024)
  • The Legal 500, Dispute Resolution – Economic Sanctions (2021)
  • Global Investigations Review, “40 Under 40” List (2014)

Education

  • University of Michigan Law School, J.D. (cum laude) 2002 (Associate Editor, Journal of International Law)
  • Princeton University, A.B., 1997, Economics

Representations

Cross-Border Investigations and Enforcement

  • Global coordinating defense counsel on a half-billion-dollar settlement between a global financial institution and the U.S. DOJ, U.S. SEC, U.K. 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 U.S. DOJ, U.S. SEC and U.S. OFAC on behalf of a major European industrial conglomerate relating to an Eastern European nation and allegations of corruption and sanctions violations.
  • Secured a declination-of-prosecution from the U.S. DOJ and declination-of-enforcement from U.S. SEC on behalf of an oilfield service provider relating to corruption allegations in India.
  • Secured declination-of-prosecution and declination-of-enforcement on behalf of a global medical device manufacturer in connection with corruption allegations in India.

Sanctions and Export Controls

  • Currently leading the defense of numerous corporates and financial institutions in investigations and enforcement actions before U.S. Treasury Office of Foreign Assets Control.
  • Secured the removal of sanctions/de-listing of numerous individuals and entities subject to U.S., UK. .and EU, sanctions.
  • 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.
  • Multiple international financial institutions in connection with ongoing sanctions compliance advisory matters before OFAC, OFSI and other regulators globally.
  • Secured multiple licenses, “comfort letters” and other government clearances from U.S. and other regulators to enable numerous high-value, otherwise unlawful transactions to proceed, securing the continuing existence and operation of the corporates involved as going concerns.

Insights

Engagement & Publications

  • Moderator, “Sanctioning Corruption or Corrupting Sanctions?”, International Bar Association Anti-Corruption Committee Annual Meetings, June 25, 2025.
  • Moderator, “Behind the Scenes of Sanctions Evasion: How Russia Evaded Sanctions to Transport Oil with the Grey and Dark Fleet”, ACI Annual Sanctions Conference, May 1, 2025
  • Moderator, “Strategic Insights into Sanctions Evasion”, March 20, 2025, Kisaco Research Central and Eastern Europe Sanctions and Financial Institutions Conference
  • Moderator, “Developments in the Financial Crime and Sanctions Risk Management and Enforcement Space Since 2023”, Cambridge Forums, November 6, 2024
  • Keynote Speaker, “U.S. Foreign Policy Outlook, the 2024 Election and its Impact on Sanctions and Anti-Corruption Enforcement”, Global Partner Retreat for Asian Law Firm, October 20, 2024
  • Moderator, “Non-Trial Resolutions and Their Adoption Outside the United States”, IBA Anti-Corruption Committee Annual Meetings, June 26, 2024
  • Guest Speaker, “Non-Trial Resolutions and Latin America”, May 18, 2024, International Bar Association (Mexico).
  • Speaker and Moderator, August 7, 2023, “U.S. Sanctions Policy and Central Asia’s Financial Sector”, Open Event for Central Asian Financial Institutions
  • 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