Anne Hukkelaas Gaustad

Anne Hukkelaas Gaustad is Co-Chair of Hughes Hubbard’s Global Investigations, Enforcement and Compliance group in Europe and a member of the Sanctions, Export Controls and Anti-Money Laundering group. She is also a member of the firm’s Executive Committee. Her practice focuses on anti-corruption, economic sanctions and export controls, business and human rights, and complex multijurisdictional internal and regulatory investigations. She has assisted on a range of anti-corruption matters as well as international commercial and investment disputes. Anne advises clients on anti-corruption matters involving the U.S. Foreign Corrupt Practices Act, the UK Bribery Act, French and Norwegian anti-corruption laws, economic sanctions and export controls, corporate governance and compliance, as well as on white-collar criminal defense, securities law, and business & human rights matters.

Anne has particular experience assisting clients in conducting anti-corruption compliance reviews, internal investigations, anti-corruption risk assessments, third-party due diligence, designing and implementing risk-based corporate compliance programs, and assessing risks under international and national anti-corruption frameworks, including in connection with inquiries by the U.S. DOJ and SEC, Norway’s Økokrim, France’s Agence française anti-corruption, French prosecution services, and the World Bank.  Her experience includes leading an engagement involving the global risk assessment and compliance review of a multinational “supermajor” oil and gas company that includes global risk assessments, compliance reviews, and ongoing compliance monitoring. She also advises a multinational networking and telecommunications company and a multinational automotive company on global anti-corruption compliance matters. In connection with her anti-corruption work, Anne has traveled extensively, including to Algeria, Angola, Azerbaijan, the Republic of the Congo, the Czech Republic, France, Gabon, Indonesia, Italy, Kazakhstan, Kenya, Lebanon, Mauritania, Myanmar, Nigeria, Norway, Papua New Guinea, the Philippines, Poland, Qatar, Russia, South Africa, Turkey, the UAE, Uganda, and the United Kingdom.  She has also represented a leading pharmaceutical company in litigation before a Norwegian court.

Prior to joining Hughes Hubbard, Anne worked at law firms located in Oslo, London, and Paris. In addition, she served as a law clerk in the Office of The Prosecutor (Appeals Section) at the International Criminal Court in The Hague.

• Assisting a European telecommunications company in connection with global anti-corruption risk assessment
• Assisting a U.S.-based retail company in designing human rights policies and procedures
• Assisting a multinational automotive company in connection with the performance of a global risk assessment and design of compliance policies and procedures
• Assisted a multinational “supermajor” oil and gas company in connection with a worldwide risk assessment and compliance review as part of an independent monitorship
• Assisted with compliance and insider trading issues for a large sovereign wealth fund
• Assisting a Norwegian company in connection with anti-corruption investigations related to a development project in Tanzania
• Worked on an investigation for a multinational telecom company relating to allegations of corruption involving operations in Tajikistan, Kazakhstan, and Uzbekistan
• Assisted on anti-corruption matters involving the World Bank Group, corporate social responsibility, WTO matters, and regulatory EU/EEA matters
• Assisted in a range of international commercial and investment disputes in the construction and oil and gas industries