Overview
Claire's cross-border practice includes representing multinational corporate clients in investigations, including government-facing and internal investigations relating to corruption, fraud, sanctions, anti-competitive behavior, and procurement misconduct. She also represents clients in World Bank investigations.
Her primary focus is on anti-corruption laws, including the Foreign Corrupt Practices Act (FCPA) and political laws, which regulate how companies engage with government entities. Claire's experience includes cross-border litigation, federal and state government investigations, internal investigations, transactional due diligence, and compliance risk assessments.
Claire represents clients across various sectors, including technology, media, energy and infrastructure, financial services (banks, private equity, and asset managers), life sciences, real estate, and consumer goods.
Claire has extensive experience evaluating and enhancing corporate compliance programs, including advising clients during and after FCPA investigations to remediate and comply with self-reporting obligations regarding development of the compliance program. She also has in-house experience from multiple secondments to major global financial services providers.
Claire also advises multinational corporations and financial institutions on federal, state, and local regulations on campaign finance, pay-to-play, electoral engagement, lobbying, ethics, conflicts of interest, and gifts to public officials.
Claire has been recognized by Chambers USA since 2017, noting that Claire "is deeply experienced in political law enforcement and litigation." According to Chambers, "clients praise her 'incredible judgment,'" explaining "she is very fast to . . . zero-in on the most important aspects of a legal issue. She has a very sensible approach towards finding practical solutions."
Prior to joining the firm, Claire was a Partner at another global law firm. Claire began her career at the Federal Election Commission (FEC) where she conducted litigation and investigations and served as counsel to Commissioner Ellen L. Weintraub. Her FEC litigation experience includes matters at the United States Supreme Court, as well as various federal circuit and district courts throughout the United States.
- District of Columbia
- California
- Supreme Court of the United States
- US Court of Appeals, Second Circuit
- US Court of Appeals, Fourth Circuit
- US Court of Appeals, Fifth Circuit
- US Court of Appeals, Ninth Circuit
- J.D., American University, Washington College of Law, 2005
- B.A., University of California, Los Angeles, 2001
Areas of Work
Representative Matters
- Retained by the Board of a public energy company to conduct independent annual reviews of the company's political and lobbying activities as required by a settlement stemming from an investigation into domestic bribery conduct.
Pro Bono
- Filed an amicus brief in the US Supreme Court on behalf of The Brennan Center for Justice relating to a campaign finance provision that restricts a candidate's ability to repay loans to oneself post-election.
- Drafted an amicus brief in the Eleventh Circuit on behalf of the National Women's Law Center to oppose Alabama's policy regarding transgender people listing accurate gender markers on driver's licenses.
- Drafted a "Know Your Rights Guide" for the Committee to Protect Journalists on First and Fourth Amendment rights for journalists covering protests in the US, which has been shared by the White House Correspondents Association and is sent to newsrooms across the country in advance of protests.
Speaking Engagements
- "Complex Matter Management," SIFMA Compliance & Legal Annual Seminar, March 2022.
- "Disinformation: The Challenges to Democracy," ABA Section of Civil Rights and Social Justice and the Canadian Bar Association's Section on Constitutional and Human Rights, June 2021.
- "Social Media: Challenges and Opportunities in Free Speech," ABA Section of Civil Rights and Social Justice and the Canadian Bar Association's Section on Constitutional and Human Rights, June 2021.
- "Developing Your Personal Brand," SIFMA Women's Leadership Forum, March 2021.
- Co-moderator of American Bar Association Civil Rights and Social Justice Panel on First Amendment rights for demonstrators and journalists, ABA, September 2020.
- Cross-Border Anti-Corruption and Enforcement & FCPA Enforcement Against Financial Institutions, SIFMA Compliance & Legal Society Annual Seminar, September 2020.
- "Challenges and Hot Topics in Cross-Border Investigations," Lawline, October 2019.
- "Managing Political Influence Risk for Financial Services Firms," SIFMA State & Local Committee, April 2019.
- "Navigating Ethical Dilemmas When Transitioning Roles, SIFMA Compliance & Legal Society Annual Seminar," March 2019.
- "Developments and Updates in the Foreign Corrupt Practices Act: What You Need to Know," The Knowledge Group/The Knowledge Congress Live Webcast Series, February 2019.
News & Publications
Publications
Perspective on the Executive Order on FCPA Enforcement
The Compliance and Ethics Blog
February 17, 2025
Press Releases
Claire Rajan Joins Steptoe, Amplifying Strength in Investigations and Government Affairs
January 14, 2025
Events
Webinars
Policy Perspectives Roundtable - Examining the Trump Administration's FCPA Position
February 20, 2025
Speakers: Jason Abel, Iris E. Bennett, Sandra Hanna, Zoe Osborne, Claire Rajan
Professional Affiliations
- Co-Chair of the American Bar Association Free Speech & Free Press Section of the Civil Rights & Social Justice Committee