Areas of Practice
  • French
  • University of Michigan Law School, J.D., cum laude, 2002; Associate Editor, Journal of International Law
  • Princeton University, A.B., Economics, 1997
Bar & Court Admissions
  • District of Columbia
  • Michigan
1330 Connecticut Avenue, NW
Washington DC 20036
TEL: +1 202 429 8079
FAX: +1 202 429 3902

Tom Best is a partner in Steptoe’s Washington office.  His practice is focused on international investigations and enforcement, international regulatory compliance, and mergers and acquisitions.

Investigations and Enforcement

Mr. Best’s practice is focused on representing multinational companies, their boards of directors and individuals in international investigations and enforcement matters.  He has successfully represented clients in numerous matters involving the US Foreign Corrupt Practices Act (FCPA) and other countries’ anti-corruption laws, US securities laws more generally, US and international economic sanctions and export controls, and anti-boycott prohibitions before the US Department of Justice (DOJ), Securities and Exchange Commission (SEC) and other federal regulators and law enforcement agencies, and their counterparts outside the United States. 

Mr. Best regularly counsels clients in connection with compliance matters before the DOJ, SEC, US Treasury Office of Foreign Assets Control (OFAC), and Department of Commerce Bureau of Industry and Security (BIS).  His experience is global, with a particular focus on India, Sub-Saharan Africa, China and Southeast Asia, and Europe.  He works across a broad array of industries, including the oil and gas, metals and mining, consumer products, private equity, automotive, telecommunications, manufacturing, and professional services sectors.

Mr. Best also represents companies and individuals before the World Bank and other International Financial Institutions (IFIs) in investigations of sanctionable practices, and in those institutions’ sanctions and debarment proceedings.

International Compliance Program Development and Risk Management In M&A

Mr. Best advises companies in the development and implementation of corporate compliance programs addressing the full range of cross-border legal and regulatory risks facing multinational companies, including FCPA/anti-corruption, economic sanctions, export controls, AML, anti-boycott, and corporate social responsibility and human rights issues.  He regularly provides international regulatory compliance training for company management and employees, creating benchmarking and auditing programs to measure program effectiveness, managing third-party relationships, and developing risk-mitigation strategies for specific transactions.

A significant part of Mr. Best’s practice is focused on international regulatory compliance in mergers and acquisitions, counseling companies and investment funds throughout the transaction cycle from initial negotiations through closing and integration into the acquirer’s operations, to maximize transaction return and minimize compliance risks. 

He is recognized for his business-focused approach to compliance issues and for providing practical, efficient solutions to the often complex compliance issues that arise in multinationals’ daily operations. 

Mr. Best graduated from Princeton University in 1997 and from the University of Michigan Law School, cum laude, in 2002.  Prior to rejoining Steptoe in 2005, he practiced in the United Kingdom with another major international law firm, focused primarily on mergers and acquisitions, securities offerings, and other corporate transactions.


  • Global Investigations Review, "40 Under 40," 2014

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