Lucinda A. Low

Partner

• llow@steptoe.com
• vCard
• Washington Office

Lucinda A. Low is a partner in the Washington office of Steptoe & Johnson LLP, where she is a member of the International Department and serves on the firm's Executive Committee. She has a practice focusing on US and international anti-corruption laws and assisting US and foreign companies with compliance with international business laws and regulations.  She is a widely recognized authority in the US Foreign Corrupt Practices Act (FCPA) and related international conventions from the OECD, OAS, United Nations, and European Union.

Ms. Low provides legal advice and counsel in the related area of export control, economic sanctions, and anti-money laundering compliance. In addition, Ms. Low has represented clients before the World Bank in connection with anti-corruption requirements for World Bank-financed projects.  She also has represented foreign investors in a broad array of investment disputes with commercial partners and host governments and adds significant international arbitration experience to the firm.

Ms. Low’s FCPA practice includes internal compliance program development and implementation, including establishing workable compliance policies and procedures; training for company management and employee personnel; benchmarking and auditing programs for best practices and effectiveness, counseling on international trade and investment transactions in numerous jurisdictions; structuring commercial deals to address business ethics and regulatory requirements to mitigate risk; conducting internal investigations, audits, and risk assessments; and representing clients before enforcement agencies and bodies, such as the SEC, the US Department of Justice, local US Attorneys' offices, and the World Bank.

Ms. Low is a member of the Board of Directors of Transparency International - USA, a current member of the Secretary of State’s Advisory Committee on International Law, and a former Chair of the ABA Section of International Law, and Vice President of the American Society of International Law.  She was the 2003 recipient of the William Ray Vallance Award presented by the Inter-American Bar Foundation, presented to an individual who has made a significant contribution toward improving the law and jurisprudence of the Western Hemisphere.

Ms. Low graduated from the University of California at Los Angeles School of Law, where she was Editor-in-Chief of the UCLA Law Review.  She was an Adjunct Professor at American University, Washington College of Law in 1993 and at the University of Colorado School of Law in 1987 and 1989.

Noteworthy

• Served as arbitrator appointed by the United States in The Canadian Cattlemen for Fair Trade (CCFT) v. The United States of America, a multi-million dollar, multiple-claim UNCITRAL arbitration arising under the NAFTA. In addition to Ms. Low, James L. Bacchus and Prof. Dr. Karl-Heinz Böckstiegel served on the Tribunal. 
• Listed in Best Lawyers of America 2008 for International Trade and Finance Law

News

• Lucinda Low Quoted on Anti-Bribery Issues in The Bottom Line
• Steptoe FCPA Alert Published by Competition Law360
• Best Lawyers in America Honors 43 Steptoe Attorneys
• Best Lawyers in America 2007 Lists Steptoe Attorneys
• Over 20 Make 2007 Best Lawyers in America: DC List
• Lucinda Low Chairs ASIL Centennial 100 Ways Committee

Speaking Engagements

• 19th Annual Institute for Transnational Arbitration Workshop, June 19, 2008, Damages in International Arbitration: Strategies, Techniques & Presentation
• Lucinda Low to Participate in "Damages in International Arbitration: Strategies, Techniques & Presentation" Workshop, June 19, 2008
• Lucinda Low to Speak at "The Extra-Territorial Reach of the FCPA" Conference in London, June 17, 2008
• Lucinda Low to Speak on Foreign Corrupt Practices Act in India, May 21, 2008
• The Foreign Corrupt Practices Act 2008: Coping with Heightened Enforcement Risks, April 16, 2008
• Canadian Forum on Bribery and Foreign Corruption Compliance and Enforcement Conference, March 31, 2008

Publications

• International Law Advisory - Recent Oil-for-Food Program Cases Show the Government's Willingness to Pursue "Improper" Payments Outside the FCPA's Antibribery Provisions, Call Attention to Foreign Enforcement
  March 17, 2008
• International Law Advisory - Sight-Seeing Tiger, Hidden Dragon - Lucent Fined for Financing Sight-Seeing Trips for Chinese Officials
  February 1, 2008
• Fifth Circuit Clarifies the Intent Requirements for a Criminal FCPA Conviction
  November 9, 2007
• The Kozeny Saga Continues
  October 27, 2007
• Enforcement of the US Foreign Corrupt Practices Act: Extraterritorial Reach and the Effects of International Standards
  September 19, 2006
• International Law Advisory - United States Poised to Ratify UN Convention against Corruption; Treaty Expected to Strengthen Anti-Corruption Enforcement in the United States, May Lead to Significant Changes in Developing Countries
  September 19, 2006
• International Law Advisory - World Bank Implements Voluntary Disclosure Program for Corrupt Practices in Bank-Financed Contracts
  August 25, 2006
• International Law Advisory - Enforcement Agencies Invoke the FCPA in Iraq and a Major Securities Fraud Settlement in the Tyco Case; Voluntary Disclosures Continue
  June 30, 2006

Professional Affiliations

• Board of Directors, Transparency International - USA
• Secretary of State's Advisory Committee on International Law
• International Bar Association
• Inter-American Bar Association
• American Bar Association