Nicolas Tollet

Nicolas Tollet is a Partner within Hughes Hubbard. He joined the firm from Technip, a then CAC 40 oil and gas service firm, where he served as Vice President for Compliance and was based between Paris and Rio de Janeiro.

Nicolas has 20 years of experience working on legal and compliance-related matters in a variety of contexts: Governance, Risk & Compliance, Global Enforcement and Internal Investigations, CSR, Mergers & Acquisitions, Joint-Ventures & Consortia, Private Equity, Financing, Restructuring, Securities Law at the most high-profile international firms in Paris.

Nicolas has worked on some of the largest resolutions by the U.S. DOJ and the SEC in both the pre- and post-settlement contexts, including inter alia the Alcatel, TSKJ and Lava Jato (Carwash / Petrobras) cases. He has also been assisting a multinational company in the frame of a joint investigation by the U.S. DOJ, the British SFO and the French PNF. He is also assisting a number of companies in the frame of the controls conducted by the French Anticorruption Agency (AFA) as well as by Anti-Money Laundering authorities in various jurisdictions around the world.

Currently a Partner within the Global Enforcement, Internal Investigations and Compliance practice group of HHR, he advises clients on matters related to anti-corruption, human rights / duty of care and sustainability, CSR, anti-money laundering, trade sanctions and export control.

He is assisting an important number of CAC 40 and SBF 120 companies, and large non-listed groups in diverse industries including luxury, retail, energy, construction, hospitality, defense, telecommunication, transportation, logistics, IT, and private equity.

His work includes assisting clients on facing regulators, as well as performing investigations, audits, third party due diligence, day-to-day advisory, around the world. His missions have brought him within the operations of his clients on-site in many countries, including most recently war zones (e.g. Ukraine), high poverty countries (e.g. Bangladesh) or politically instable countries (e.g. Algeria, Venezuela, Tunisia, etc.) and other high-risks countries from a compliance standpoint (e.g. Romania, Brazil, Turkey, UAE, Jordan, etc.).

Nicolas received the Best Compliance Department Award in 2016 while at Technip and was the only French lawyer selected among the 38 in-house investigations and compliance specialists worldwide for Global Investigation Review (GIR) in 2017. He is ranked by Best Lawyers, by Chambers Partners and by Legal 500 where he is ranked Tier 1 and a Leading Individual.

Nicolas is admitted to practice in New York, Paris and the U.S. Supreme Court.

He taught anti-corruption compliance at the University of California Berkeley. He also speaks at conferences around the world and regularly publishes articles.

Nicolas also served as Counselor to the President of the International Association of Lawyers (UIA) which brings together more than two million lawyers through its individual and collective members, promotes the rule of law, and defends the independence and freedom of lawyers around the world (2019-2021).

Nicolas Tollet assists a significant number of CAC 40 and SBF 120 companies in a wide range of industries including construction, hospitality, luxury, retail, energy, defense, telecommunication, transportation, logistics, IT, and private equity.

He assists them on their issues relating to anti-corruption, anti-money laundering, sanctions and terrorism financing and human rights.

Investigations

• Conducting the internal investigation of a then CAC 40 company in the frame of its negotiations with the US DOJ and SEC in view of reaching a deferred prosecution agreement
• Assisting a CAC 40 company in its internal investigations and negotiations with the French PNF, British SFO and the US DOJ
• Conducting in-house for over two years and a half the internal investigations of the Brazilian operations of a CAC 40 company which led to a joint-deferred prosecution agreement with the US DOJ and SEC and the Brazilian authorities (MPF)
• Conducting in-house the internal investigations in various jurisdictions for a CAC 40 company
• Conducting an internal investigation over allegations of corruption for a CAC 40 company in China, Bangladesh, India, Pakistan and Turkey
• Conducting an internal investigation over allegations of fraud for a CAC 40 company in the United States
• Conducting an internal investigation over allegations of a Russian embargo violation for a CAC 40 company
• Conducting an internal investigation over allegations of fraud for an IT company in Romania and Morocco
• Co-conducting an internal investigation over allegations of antitrust violation for a world’s leading retailer in Europe
• Assisting a CAC 40 company conduct an internal investigation over allegations of private passive corruption in the UK
• Assisting a CAC 40 company conduct an internal investigation over allegations of private passive corruption in China
• Assisting a CAC 40 company conduct an internal investigation over allegations of fraud in Ukraine
• Assisting a world’s leading retailer conduct an internal investigation over allegations of corruption in Morocco
• Assisting a consumer good company conduct an internal investigation to clear conflict of interests in France

Regulatory Inspections

• Assisting an SBF 120 company with the completion of an follow-up inspection launched by the AFA
• Successfully assisting an SBF 120 company with completion of an inspection launched by the AFA as part of the seventh wave of AFA controls
• Successfully assisting a CAC 40 company with completion of an inspection launched by the AFA as part of the sixth wave of AFA controls
• Successfully assisting an SBF company with completion of an inspection launched by the AFA as part of the fourth wave of AFA controls
• Successfully assisting a CAC 40 company with completion of an inspection launched by the AFA as part of the second wave of AFA controls
• Successfully assisting an SBF 120 company through the first ever anti-corruption inspection launched by the AFA as part of the first wave of AFA controls
• Assisting a CAC 40 company in responding in advance to the French Anticorruption Agency (AFA) questionnaire and assessing its compliance program
• Assisting a CAC 40 company in responding in advance to the AFA questionnaire and putting together the draft submission and attachments
• Assisting a world’s leading transportation and logistics company in reviewing its draft responses to the AFA questionnaire 
• Assisting a CAC 40 company in the frame of an inspection by the Anti-Money Laundering Authority (COAF) in Brazil
• Assisting a CAC 40 company in the frame of an inspection by the Anti-Money Laundering Authority (Assay Chamber) in Russia 
• Assisting a CAC 40 company in the frame of an inspection by the Anti-Money Laundering Authority in Dubai 
• Assisting a CAC 40 company in the frame of an inspection by the Anti-Money Laundering Authority (DGCCRF) in France

Monitorships

• Assisting in-house for two years a CAC 40 company successfully complete its monitorship imposed by the US DOJ and SEC
• Assisting a governmental anticorruption agency through their first monitorship of a company in the frame of a settlement with the prosecutor’s office following allegations of corruption

Third-Party Due Diligence & Books and Records Audits

• Assisting an oil services company in conducting third party due diligence in Angola
• Conducting dozens of in-depth third-party due diligence around the world for a CAC 40 company
• Conducting various in-depth third-party due diligence around the world for another CAC 40 company Assisting an SBF 120 company in conducting third party due diligence
• Conducting in-house in-depth on-site due diligence for dozens of commercial agents, logistics agents and joint-venture partners in Latin & Central America, Africa, Asia and Europe for a CAC 40 company
• Auditing in-house commercial agents, logistics agents and joint-ventures in Latin America for a CAC 40 company
• Conducting for a CAC 40 company a Human rights external audit on a supplier’s activities in Africa and Myanmar

Risk Assessments & Risk Mappings (incl. in the frame of M&A)

• Performing the worldwide risk assessment of a CAC 40 company and turning the results into a risk mapping
• Performing the worldwide risk assessment of an SBF 120 company and turning the results into a risk mapping
• Performing the worldwide risk assessment of a defense company and turning the results into a risk mapping
• Performing the risk assessment of the French operations of a consumer good company and turning the results into a risk mapping
• Assisting a CAC 40 company in conducting its global risk assessment in view of preparing its global risk mapping
• Assisting a world’s leading retailer company in in conducting its global risk assessment in view of preparing its global risk mapping
• Assisting a CAC 40 company in deepening its global risk assessment and in turning the results into its global risk mapping
• Assisting a world’s leading transportation and logistics company in designing its global risk mapping
• Performing various on-site and off-site compliance reviews for a CAC 40 company in Russia, the United States, China, Italy, the UAE, Thailand, Singapore, Malaysia, Vietnam, Australia, New Zealand, Guam, India and the Philippines
• Performing various on-site and off-site compliance reviews for a CAC 40 company in Romania, Morocco, Mexico and China
• Performing various on-site compliance reviews for a world’s leading retailer in Ukraine, Morocco, Italy, Bangladesh, Bulgaria, South Korea and Algeria
• Performing various an on-site compliance review for an SBF 120 company in Tunisia
• Performing various an on-site compliance review for another SBF 120 company in Jordan
• Performing in-house an on-site in-depth risk assessment of the Northern Europe operations of a CAC 40 company

Compliance Programs

• Assisting three (3) CAC 40 companies, two (2) SBF 120 companies, one (1) world’s largest private equity company, one (1) French world’s leading retailer, one (1) French defense company, one (1) French renewable energy company, two (2) foreign companies significantly improve their overall compliance program
• Assisting another CAC 40 company design its compliance processes in M&A transactions
• Assisting another CAC 40 company design its code of conduct
• Assisting two (2) CAC 40 companies and one (1) SBF 120 company in their day-to-day implementation of their compliance program
• Assisting various companies with certain questions raised while implementing its compliance program
• Implementing in-house the worldwide compliance program of a then CAC 40 company
• Assisting a CAC 40 company in dealing with the compliance risks associated with NFTs
• Assisting a CAC 40 company in dealing with cryptocurrencies in various jurisdictions

Russia

• Assisting a CAC 40 company operating in Russia in dealing with trade sanctions and embargoes; assisting it as well on the legal consequences around the world
• Assisting a French world leading retailer operating in Russia in dealing with trade sanctions and embargoes; assisting it as well on the legal consequences around the world
• Assisting a real estate company operating in Russia in dealing with trade sanctions and embargoes
• Assisting a family office in dealing with trade sanctions and embargoes

Trainings

• Performing tailored trainings for compliance officers of many companies
• Performing tailored trainings for all the employees of a renewable energy company
• Performing tailored trainings on internal investigations for HR population worldwide of a world leading retailer
• Performing tailored trainings on internal investigations for employees of a consumer goods company (Forbes Global 15)
• Performing tailored trainings for investment teams of a private equity company