Thomas R L Best

Tom Best is a partner in Steptoe’s Washington office. His practice is focused on international investigations, enforcement, compliance and mergers and acquisitions.

International Regulatory Compliance

Mr. Best’s practice covers all aspects of international regulatory compliance and enforcement. He represents multinational companies and individuals in Foreign Corrupt Practices Act (FCPA), anti-money laundering (AML), securities fraud, economic sanctions, export controls and anti-boycott matters before the US Department of Justice, Securities and Exchange Commission and other federal law enforcement agencies such as the US Treasury Office of Foreign Assets Control (OFAC) and Department of Commerce Bureau of Industry and Security (BIS). He has successfully led internal investigations and defended enforcement matters in a diverse range of industries including the oil and gas, technology, metals and mining, private equity, automotive, telecommunications, consumer goods and manufacturing and professional services sectors. He has experience working in Sub-Saharan Africa, Asia, India, the Middle East, Europe and Latin America.

Mr. Best develops and implements internationally-focused corporate compliance programs addressing the full range of legal and regulatory risks facing multinational companies, including FCPA/anti-corruption, economic sanctions, export controls, AML, anti-boycott and corporate social responsibility and human rights issues. His practice includes providing international regulatory compliance training for company management and employees, creating benchmarking and auditing programs to measure program effectiveness, managing third-party relationships and developing risk-mitigation strategies for specific transactions.

A significant part of Mr. Best’s practice is focused on international regulatory compliance in mergers and acquisitions, counseling companies and investment funds throughout the transaction cycle from initial negotiations through closing and integration into the acquirer’s operations, to maximize transaction return and minimize compliance risks.

He is recognized for his business-focused approach to compliance issues and for providing practical, efficient solutions to the often complex compliance issues that arise in multinationals’ daily operations.

International Trade

Mr. Best’s international trade practice is focused on antidumping and countervailing duty investigations and administrative reviews before the US Department of Commerce, International Trade Commission and Court of International Trade. He has experience with litigation regarding a diverse array of products and countries, including numerous Chinese manufactured goods and Canadian agricultural products.

Mr. Best graduated from Princeton University in 1997 and from the University of Michigan Law School, cum laude, in 2002. Prior to rejoining Steptoe in 2005, he practiced in the United Kingdom with another major international law firm, focused primarily on mergers and acquisitions, securities offerings and other corporate transactions.


Good to know

Areas of Practice 1) International Regulation & Compliance, 2) FCPA/Anti-Corruption, 3) Economic Sanctions, 4) Export Controls and 5) International Trade & Investment
Law School University of Michigan Law School (J.D., 2002)
Admitted Year 1991
Education Princeton University (A.B.,1997)
Bar Member / Association District of Columbia, Michigan State Bar Association
Most recent firm Steptoe & Johnson
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