Overview
Lucinda Low's practice focuses on transnational dispute resolution, particularly international arbitration, and white-collar defense and compliance matters with an international character, and matters involving the international financial institutions.
In the field of international arbitration, Lucinda serves as counsel, expert and arbitrator. She was named to the roster of arbitrators of the International Centre for Settlement of Investment Disputes in 2017 by the World Bank President, and previously named by the United States as a member of the panel of Conciliators. She is a member of a number of other rosters as well. She has significant experience in both investor-state and commercial arbitration disputes, including disputes with a significant regulatory compliance dimension.
Lucinda's white-collar practice includes representing audit committees, boards of directors, companies and individuals in internal, government, and international financial institution audits, investigations, and enforcement matters involving fraud, bribery, corruption, money laundering, and other international regulatory compliance issues. Lucinda is recognized by Chambers market commentators for her "incredible technical proficiency, spectacular advocacy skills, and cultural know-how." She has deep experience in matters involving the US Foreign Corrupt Practices Act (FCPA) and other anti-bribery and anti-corruption laws, and other international business compliance issues. According to Chambers, clients concur that Lucinda is "very impressive" and credit her with "an attention to detail that is second to none."
She has extensive experience representing contractors, consultants and their principals in audits, investigations, sanctions proceedings, and related matters before the World Bank and other multilateral development banks integrity and sanctions units and tribunals.
In her preventive work Lucinda helps clients develop and implement customized compliance programs tailored to their business risks that meet regulatory expectations, assists with due diligence in M&A and other transactions, provides risk-mitigation and risk assessment strategy, conducts internal investigations, and defends clients in government investigation and enforcement matters, including multi-jurisdictional investigations.
Lucinda has served in a number of leadership positions in the firm, including several terms on its Executive Committee and as its international practice leader, and as co-chair of the International Arbitration Practice. Lucinda's experience is worldwide but includes particular expertise in Latin America. She has lived in Brazil twice and worked in many Spanish-speaking countries in the Western Hemisphere as well.
Lucinda is the Chair of the Board of Directors of the Coalition for Integrity (formerly known as Transparency International – USA), and also a member of the US Secretary of State’s Advisory Committee on International Law. She is a former president of the American Society of International Law and a former chair of the ABA Section of International Law. She currently serves as on the ICC Task Force on Dealing with Allegations of Corruption in International Arbitration, as a coordinator of one of its major tracks. She is the winner of many awards for her work, including the Outstanding Career award from GIR in 2017 and the Louis B. Sohn Award for Public International Law from the American Bar Association in 2019.
Lucinda is fluent in Portuguese and Spanish, and has a working knowledge of French.
- District of Columbia
- J.D., University of California, Los Angeles School of Law, 1977
- B.A., Pomona College, 1973
Areas of Work
Speaking Engagements
- "Enforcement of Intra-EU Arbitral Awards: Latest Developments from the UK, Australia, the US and EU", 11th Dublin International Arbitration Day Conference, Dublin, November 17, 2023
- "Resolved, that Arbitrators Can and Do Award Effective Redress to Disputing Parties," 35th ITA Workshop and Annual Meeting, Austin, TX, June 14-16, 2023
- "Where Are We in Solving Problems of States, Investors and Society," World Arbitration Update - Mexico City Investment Arbitration Days conference, Mexico City, May 18, 2023
- Keynote Speaker, Basel Institute of Governance’s Workshop on Arbitration and Crime, Basel, Switzerland, May 5, 2023
- "Dirty Corruption, Laundered Money & Blind Eyes: Old Problems and the Need for New Solutions." Bocconi Investment Arbitration Conference, Milan, Italy, April 20-21, 2023
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"The Transformation of International Economic Law," 2023 ASIL Annual Meeting, Washington, DC, March 30, 2023
- Keynote Speaker, 2nd Annual Georgetown Brazilian Arbitration Day, Washington, DC, January 26, 2023
- "Evidence in International Arbitration: The Latest Developments," Washington Arbitration Week, November 29, 2021
- Chair, GIR Live Women in Investigations, September 23, 2021
- Co-Chair, International Academy of Financial Crime Litigators' International Women's Day Webinar, March 10, 2021
- "Crisis Management Hypothetical: How to Handle a Real World FCPA Problem," The Foreign Corrupt Practices Act and International Anti-Corruption Developments 2020, Practising Law Institute, September 4, 2020
- "Legal, Compliance and Financial Gatekeepers as Defendants: The Realities of New, Rising Prosecution Risks Confronting Individuals," ACI's 36th International Conference on the FCPA, Oxon Hill, MD, December 5, 2019
- "Investment Treaty Arbitration: The Corruption Defense," European American Chamber of Commerce, New York City, September 12, 2019
- Chair, GIR Live Women in Investigations, London, UK, June 12, 2019
- Moderator, "Fireside Chat with Lisa Osofsky," GIR Live Women in Investigations, London, UK, June 12, 2019
- "Defense Counsel Discuss the Past, Present and Future of Risk and Compliance for Industry in Brazil," ACI's 9th Summit on Anti-Corruption Brazil, São Paulo, Brazil, May 22, 2019
- Moderator, "International Law as an Instrument to Regulate the Behavior of Non-state Actors in Areas Beyond National Jurisdiction," 113th Annual Meeting of the American Society of International Law, Washington, DC, March 28, 2019
- "Export Controls, Sanctions and Transparency Requirements," The Global Trade Academy: Legal Foundations and New Directions of the Global Trading System, Georgetown University Law Center and Institute of International Economic Law (IIEL), Washington, DC, February 15, 2019
- "Lava Jato: What Comes Next?," Coalition for Integrity 2018 Day of Learning: Spotlight on Corruption, Washington, DC, December 10, 2018
- "Anti-Corruption Considerations in International Dispute Resolution - Methodologies for Proving Corruption in Arbitration: Red Flags, 'Connect the Dots,' and Similar Approaches," The Transnationalization of Anti-Corruption Law Conference, Paris, France, December 7, 2018
- Moderator, "SEC, DOJ & FBI Town Hall," ACI's 35th International Conference on the FCPA, Oxon Hill, MD, November 29, 2018
- Chair, GIR Live Women in Investigations, London, UK, June 28, 2018
- Moderator, “Practical Aspects of International Investigations and Q&A,” GIR Live Women in Investigations, London, UK, June 28, 2018
- Moderator, “Monitorships: A Survival Guide,” GIR Live Women in Investigations, London, UK, June 28, 2018
- "Executive Perspective: Strategies from Global Business Leaders," Bloomberg Law Leadership Forum, New York, NY, May 23, 2018
- "Ask the Experts: Q & A with ACI's Global Anti-Corruption Advisory Board," ACI's 20th New York Conference on the FCPA, New York, NY, May 9, 2018
- "Real-Life Mitigation Responses to Resolve Third Party Due Diligence and Audit Rights Challenges," ACI's 12th Houston Forum on the FCPA, Houston, TX, January 23, 2018
- Moderator, "Interview with the SEC's New Co-Director of the Enforcement Division," ACI's 34th International Conference on the FCPA, Oxon Hill, MD, November 30, 2017
- "Persistence and Value Tagline: With Steptoe's Lucinda Low," LeftFoot Podcast, November 28, 2017
- "The FCPA Approaches Middle Age: Is the Anti-Corruption Law Slowing Down or as Spirited as Ever?," Washington Legal Foundation, Washington, DC, November 14, 2017
- "20 Years of the OECD Anti-Bribery Convention: What's Next?," IBA Latin American Anti-Corruption Enforcement and Compliance Conference, São Paulo, Brazil, November 7, 2017
- "What to Do When Conducting Business with a Third Party Revealed to be Involved in Lava Jato," ACI's 7th Brazil Summit on Anti-Corruption, São Paulo, Brazil, May 24, 2017
- Keynote Speaker, Twenty Eighth ITF Public Conference: Economic Crime and International Investment Law, British Institute of International and Comparative Law, London, UK, May 12, 2017
- Moderator, "Women's Economic Empowerment: Innovations for Impact," ABA Section of International Law 2017 Spring Meeting, Washington, DC, April 26, 2017
- "US Participation in Global Trade Agreements," American Society of International Law's International Law and the Trump Administration Briefing Series, Washington, DC, March 15, 2017
- "International Compliance Issues for CGIAR Webinar," Consultative Group on International Agricultural Research, January 25, 2017
- "FCPA Year in Review 2016," TRACE Webinar, December 14, 2016
- "FCPA Moot Court: An Interactive Debate on Determining Beneficial Ownership and the Scope of Due Diligence Post-Panama Papers and Unaoil," ACI's 33rd International Conference on the FCPA, Washington, DC, 2016
- "Export Controls and Economic Sanctions," Georgetown Law Academy: Legal Foundations and New Directions, the WTO, & Beyond, Washington, DC, November 18, 2016
- "How Economic Sanctions Apply to US and Non-US Extractive Operations," 62nd Annual Rocky Mountain Mineral Law Institute, Squaw Valley, CA, July 21, 2016
- "Telling Brazil's Anti-Corruption Success Story," Richmond School of Law, July 14, 2016
- Moderator, "Closing the Deal: Identifying Risks and Key Anti-Corruption Considerations for Mergers & Acquisitions in Brazil in the First 180 Days," ACI's Brazil Summit on Anti-Corruption, São Paulo, Brazil, May 25, 2016
- "Proving Corruption Issues in International Arbitration," 10th Annual Americas Workshop, Mexico City, Mexico, December 1, 2015
- Moderator, "New USDOJ Compliance and Enforcement Initiatives," ACI's International Conference on the FCPA, Washington, DC, November 18, 2015
- "Foreign Corrupt Practices Act," Ernst & Young Arizona's Annual CPE Conference, Phoenix, AZ, September 22, 2015
- "Crisis Management: How to Handle a Real World FCPA Problem," PLI's FCPA and International Anti-Corruption Developments 2015, New York, NY, May 5, 2015
- "The Way We Were," ABA Section of International Law 2015 Spring Meeting, Washington, DC, April 29, 2015
- Co-Chair, "Corruption in International Arbitration: Evidence and Remedies," Institute for Transnational Arbitration & the American Society of International Law, Washington, DC, April 8, 2015
News & Publications
Press Releases
Steptoe Receives Compliance and Investigations Practice Ranking in The Legal 500 Latin America 2024
October 26, 2023
Press Releases
Latinvex Names Lucinda Low One of Latin America's Top 100 Female Lawyers of 2023
October 6, 2023
Press Releases
US District Court Rules in Favor of Steptoe Client Korea Electric Power Corp.
September 18, 2023
Press Releases
Steptoe Receives 25 Practice, 72 Individual Mentions in Chambers USA 2023
June 1, 2023
Press Releases
Steptoe Receives 16 Practice, 40 Individual Mentions in Chambers Global 2023
February 21, 2023
Client Alerts
Fifth Circuit's Ruling in United States v. Rafoi
February 15, 2023
By: Iris E. Bennett, Patrick F. Linehan, Lucinda A. Low, Drew C. Harris, Meredith Lewis, Nicholas P. Silverman
International Compliance Blog
December 14, 2022
By: Iris E. Bennett, Brigida Benitez, Patrick F. Linehan, Lucinda A. Low, Wendy Wysong
Client Alerts
Hoskins II: Second Circuit Further Muddies Co-Conspirator/Agent Liability under FCPA
August 19, 2022
By: Iris E. Bennett, Patrick F. Linehan, Lucinda A. Low, Nicholas P. Silverman, Drew C. Harris
Press Releases
Steptoe Receives 27 Practice, 72 Individual Mentions in Chambers USA 2022
June 3, 2022
Resources
Client Alerts
FCPA/Anti-Corruption Developments: 2021 Year in Review
February 15, 2022
By: Iris E. Bennett, Lucinda A. Low, Rachel B. Peck, Brigida Benitez, Zoe Osborne, Wendy Wysong, Jingchun (Cherry) Huang, Samantha McCarthy, James M. Purce, Lin Yang, Bo Yue, Wilson Zhao, Joshua Dupre (law clerk), Zhaoxi Zhang (international paralegal)
Client Alerts
Singapore Data Protection: Considerations for Data Driven Compliance Activities
February 1, 2021
Client Alerts
FCPA/Anti-Corruption Developments: 2020 Year in Review
January 19, 2021
By: Lucinda A. Low, Zoe Osborne, Brigida Benitez, Alexandra Baj, Christopher R. Conte, Alexandra Melia, Ali Burney, Fernando Q. Merino, Wendy Wysong, Rachel B. Peck, Jefferson Klocke, Veronica Ganzitti, Jingchun (Cherry) Huang, Troy Shephard, Lin Yang, Bo Yue, Lucas Caiado (International Regulation & Compliance Intern), Jordan Cannon (Law Clerk), Marcia Pulcherio (International Trainee)
Client Alerts
Due Diligence: Top 10 Benefits of Hiring Independent Compliance Counsel
August 4, 2020
By: Lucinda A. Low, Wendy Wysong, Meredith Rathbone, Ali Burney
Client Alerts
Top Ten Changes to the DOJ/SEC FCPA Resource Guide
July 20, 2020
By: Lucinda A. Low, Christopher R. Conte, Brigida Benitez, Wendy Wysong, Ali Burney, Jefferson Klocke
Client Alerts
DOJ Updates Corporate Compliance Program Guidance, Emphasizes Role of Data
June 4, 2020
Client Alerts
FCPA/Anti-Corruption Developments: 2019 Year in Review
January 21, 2020
By: Lucinda A. Low, Brigida Benitez, Wendy Wysong, Zoe Osborne, Steven J. Barber, Alexandra Melia, Ali Burney, Fernando Q. Merino, Rachel B. Peck, Alexandra Baj, Jefferson Klocke, Veronica Ganzitti, Troy Shephard, Lin Yang, Bo Yue
Client Alerts
World Bank Highlights Continued Enforcement Focus in Second Annual Sanctions System Report
October 28, 2019
Events
Webinars
Quarterly Investigations & Enforcement Update Webinar
May 1, 2024
Speakers: Jason Abel, Iris E. Bennett, Christopher R. Conte, Amba M. Datta, Stacie R. Hartman, Patrick F. Linehan, Lucinda A. Low, Michael Campion Miller, Zoe Osborne, Wendy Wysong
Webinars
Quarterly Investigations & Enforcement Update Webinar
January 25, 2024
Speakers: Jason Abel, Iris E. Bennett, Lee Berger, Christopher R. Conte, Amba M. Datta, Stacie R. Hartman, Lucinda A. Low, John J. Kavanagh, Michael Campion Miller, Zoe Osborne, Wendy Wysong
Webinars
Investigations & Enforcement Webinar Series
October 19, 2023
Speakers: Andrew C. Adams, Jason Abel, Iris E. Bennett, Christopher R. Conte, Stacie R. Hartman, Patrick F. Linehan, Lucinda A. Low, John J. Kavanagh, Zoe Osborne, Wendy Wysong
Webinars
Investigations & Enforcement Webinar Series
July 27, 2023
Speakers: Jason Abel, Lee Berger, Christopher R. Conte, Amba M. Datta, Stacie R. Hartman, Patrick F. Linehan, Lucinda A. Low, Cáitrín McKiernan, Michael Campion Miller, Zoe Osborne, Wendy Wysong
Seminars & Events
Global Trade and Enforcement Symposium in Hong Kong
June 1, 2023
Speakers: Renato Antonini, Yongqing Bao, Brigida Benitez, Brian G. Burke, Ali Burney, Henry Cao, John Caracappa, Boyd Cloern, Robyn C. Crowther, Brian J. Fleming, Coy Garrison, Stacie R. Hartman, Zoey Hong, Stanley C. Kuo, Amy J. Lentz, Michelle L. Levin, Patrick F. Linehan, Lucinda A. Low, Jamie Lucia, Alexandra Melia, Cáitrín McKiernan, Eva Monard, Darryl Nirenberg, Gwendolyn Prothro Renigar, Angus Rodger, Guy Soussan, David M. Stetson, Grace Wang, Philip R. West, Charles Whiddington, Wendy Wysong, Lin Yang, Bo Yue, Wilson Zhao
Webinars
Investigations & Enforcement Webinar Series
January 26, 2023
Speakers: Jason Abel, Iris E. Bennett, Lee Berger, Christopher R. Conte, Amba M. Datta, Coy Garrison, Patrick F. Linehan, Lucinda A. Low, Zoe Osborne, Wendy Wysong
Webinars
Investigations and Enforcement Webinar Series
October 27, 2022
Speakers: Jason Abel, Iris E. Bennett, Coy Garrison, Stacie R. Hartman, Patrick F. Linehan, Lucinda A. Low, Michael Campion Miller, Jason M. Weinstein, Charles Whiddington, Wendy Wysong
Webinars
Investigations & Enforcement Webinar Series
July 28, 2022
Speakers: Jason Abel, Iris E. Bennett, Amba M. Datta, Coy Garrison, Lucinda A. Low, Michael Campion Miller, Zoe Osborne, Wendy Wysong
Noteworthy
Chambers & Partners
- Chambers USA, Band 1, International Trade: FCPA, Nationwide (2010-2023)
- Chambers Global, Band 1, International Trade: FCPA, US (2010-2023)
- Chambers Global, Corporate Investigations, Latin America (2016-2023)
- Chambers Latin America, Corporate Crime & Investigations: Latin America-wide (2016-2024)
Global Investigations Review
- Global Investigations Review, "Outstanding Career Award" (2017)
- Global Investigations Review, "Women in Investigations: One Hundred Investigation Specialists from Around the World" (2015)
Legal 500
- Legal 500 US, Dispute Resolution: International Trade (2016-2019)
- Legal 500 US, Litigation: International Trade (2012)
- Legal 500 US, Litigation: White-Collar Criminal Defense (2015)
- Legal 500 US-Mexico, Private Practice Powerlist (2022)
Super Lawyers
- Super Lawyers, Washington, DC, "Top 50 Women" (2019-2020)
- Super Lawyers, Washington, DC, International (2013-2021)
Euromoney's Expert Guides
- Euromoney's Expert Guide to Women in Business Law (2013, 2015)
- Euromoney's Expert Guide to the World's Leading International Trade Lawyers (2015)
Best Lawyers in America
- Best Lawyers in America, International Arbitration: Governmental and International Trade and Finance Law (2001-2022)
Other notable recognitions
- Who’s Who Legal, Global Leader, Investigations (2023)
- Louis B. Sohn Award for Public International Law, American Bar Association Section of International Law (2019)
- Latinvex, Top 100 Female Lawyers (2017, 2020-2023)
- Ethisphere's Attorneys Who Matter Hall of Fame (2012)
Professional Affiliations
- Advisory Committee on International Law, US Secretary of State (2002-2010, multiple reappointments, 2012-present)
- American Arbitration Association, Panel of Arbitrators
- American Bar Association
- American Bar Association, Section of International Law & Practice, Chair (1996-1997)
- American Society of International Law, President (2016-2018)
- Beijing Arbitration Commission/Beijing International Arbitration Center (BAC/BIAC), Panel of Arbitrators for International Investment Arbitration
- Coalition for Integrity (formerly Transparency International - USA), Board of Directors
- ICSID, Panel of Arbitrators, Arbitrator (2017-2023)
- ICSID, Presidential Appointee, Panel of Conciliators (2016-2022)
- US National Committee Roster, International Chamber of Commerce
- Inter-American Bar Association (1998-2008)
- Inter-American Bar Association, Chair of the Working Group on Corruption and Money Laundering (2000-2010)
- International Bar Association
- London Court of International Arbitration (LCIA)
- Nanda Center for International and Comparative Law Board, University of Denver Sturm College of Law (2010-present)
- World Justice Project, WJP Rule of Law Leadership Council, Ambassador (2024)