Thomas R Best

Tom Best is a partner the Washington office of Steptoe & Johnson LLP, where he is a member of the International Department.  His practice is focused on international regulatory compliance and enforcement, and mergers and acquisitions. 

International Regulatory Compliance

Mr. Best’s practice covers all aspects of international regulatory compliance and enforcement. He represents US and non-US companies in Foreign Corrupt Practices Act (FCPA), economic sanctions, export controls, and anti-boycott matters before the US Department of Justice, Securities and Exchange Commission, and other federal law enforcement agencies. He has led internal investigations in a diverse range of industries including the oil and gas, metals and mining, automotive, telecommunications, consumer goods, and professional services sectors. He has experience working in Sub-Saharan Africa, Asia, India, the Middle East, Europe, and Latin America.

He has a particular focus on mergers and acquisitions, where he counsels acquirers and targets on international regulatory compliance throughout the transaction cycle, from initial negotiations to final acquisition integration. He also assists in designing and implementing international regulatory compliance programs for companies doing business in a wide range of industries and geographies, in particular those addressing risks associated with the intersection of the FCPA, US economic sanctions and export controls, and other nations’ anti-corruption, sanctions and export controls laws such as the UK Bribery Act and Canadian Corruption of Foreign Public Officials Act.

Mr. Best has particular experience with US anti-terrorism controls. He counsels private foundations seeking to provide humanitarian and philanthropic assistance to persons and groups where entities listed by the US Treasury Office of Foreign Assets Control (OFAC) as “Specially Designated Nationals” are operating.

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 representing clients importing a diverse array of products and countries, including numerous Chinese manufactured goods and Canadian agricultural products.