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, heads the firm’s FCPA practice, and serves on the firm's Executive Committee. She has a practice focusing on US and international anti-corruption laws, advising clients on matters ranging from preventive work to representation in internal investigations and enforcement matters worldwide.  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’s FCPA practice includes internal compliance program development and implementation for multinational companies, including establishing workable compliance policies and procedures; training for company management and employee personnel; benchmarking and auditing programs for best practices and effectiveness; due diligence in mergers and acquisitions, third-party relationships, and other transactions; developing risk-mitigation strategies; conducting internal investigations, audits, and risk assessments; dealing with parallel proceedings; opinions and expert testimony; and representing clients before enforcement agencies and bodies, such as the SEC, the US Department of Justice, and other authorities.  Her clients include companies, boards of directors, individuals, and other professional firms.

Ms. Low’s practice also includes legal advice and counsel in other international regulatory compliance areas, such as export controls, economic sanctions, and anti-money laundering laws.  In addition, Ms. Low has represented companies in World Bank investigations, audits, and sanctions proceedings in cases involving anti-corruption rules in World Bank-financed projects.  She also has significant experience in investment disputes between foreign investors and host governments, and commercial arbitration, including serving as counsel, arbitrator, and an expert witness.

Ms. Low is a member of the Board of Directors of Transparency International - USA, and the Secretary of State’s Advisory Committee on International Law.  She is a former Chair of the ABA Section of International Law, and former Vice President and member of the Executive Committee 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

• Received a #1 Ranking in Chambers USA 2010: America’s Leading Business Lawyers; International Trade: FCPA Experts (Nationwide)
• Ranked, Chambers Global 2010 — International Trade: FCPA Experts (US)
• Listed in Best Lawyers in America 2010 for International Arbitration, and International Trade and Finance Law
• 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 Ethisphere’s 2009 Attorneys Who Matter for FCPA Compliance
• Chair, ABA Section of International Law & Practice, 1996-1997

Select News & Events

• "Communicating with the Government Post-Disclosure & Negotiating a Settlement Agreement with the USDOJ and SEC," ACI’s 5th FCPA Houston, January 25, 2011
• "Disclosing an FCPA Issue to the Government," 24th National Conference on the Foreign Corrupt Practices Act, November 16, 2010
• "A Bribe By Any Other Name: Anti-Corruption Policy and Laws Around the World," International Peace Operations Association Legal Conference, September 16, 2010
• Compliance Week Quotes Lucinda Low and Owen Bonheimer on Energy Industry Disclosure Provision in Dodd-Frank Act
• Steptoe Partners to Speak at ACI's 8th European Forum on Anti-Corruption 2010, June 21, 2010
• Chambers USA Honors 18 Steptoe Practices and 41 Attorneys
• "Investor-State Arbitration in Latin America: Recent Issues and Future Prospects" Seminar in Mexico City, June 14, 2010
• Steptoe Partner Discusses "How to Develop an Ethical Culture"
• Foreign Corrupt Practices Act 2010, The Practising Law Institute, May 19, 2010
• Chambers Global Honors Nine Steptoe Practice Areas and 20 Attorneys
• Main Justice Quotes Lucinda Low on FCPA
• Bulletproof Blog Interviews Lucinda Low About Global Compliance Challenges in 2010

Selected Publications

• International Law Advisory - Whistleblower Provisions in Dodd-Frank Legislation Provide Further Impetus to Increased FCPA Investigations and Enforcement
  July 26, 2010
• Dodd-Frank Financial Reform Legislation Requires Extractive Industry Participants to Disclose Payments to Governments
  July 21, 2010
• New Corporate Social Responsibility Mandate Related to Conflict Materials in the New Financial Reform Bill Could Affect Many Companies
  July 20, 2010
• International Law Advisory - French Companies Prepare to Pay Hundreds of Millions to U.S. Authorities in Foreign Corruption Matters
  July 15, 2010
• Global Anti-Corruption Standard and Enforcement: Implications for Energy Companies
  June 23, 2010
• International Law Advisory - UK Parliament Passes Anti-Bribery Reform Law
  April 12, 2010
• International Law Advisory - Flurry of FCPA Cases Closes Out 2009; Enforcement Continues Apace in Early 2010
  March 16, 2010
• International Law Advisory - 2009 UK Anti-Corruption Year in Review
  February 22, 2010

More Publications »

Professional Affiliations

• Board of Directors, Transparency International - USA
• Secretary of State's Advisory Committee on International Law
• Global Anti-Corruption Advisory Board for the American Conference Institute
• International Bar Association
• Inter-American Bar Association
• American Bar Association