Anne Gaustad-Hanken
Anne Gaustad-Hanken advises multinational public and private corporations and senior executives on cross-border investigations, sanctions, export controls, and business and human rights matters. She leads internal investigations and enterprise-wide risk assessments, including investigations and compliance reviews conducted in coordination with authorities such as the US Department of Justice, the Securities and Exchange Commission, French regulatory and enforcement authorities, Norway’s Økokrim, and Multilateral Development Banks. Her work spans anti-corruption, EU and US economic sanctions and export controls, anti–money laundering, and corporate governance frameworks. Anne also designs, implements, and validates global compliance programs and represents clients in disputes arising from regulatory investigations and cross-border activity.
Anne works closely with boards, audit committees, and executive leadership during periods of acute enforcement risk and public scrutiny. She advises on crisis response strategy, regulator engagement, and post-investigation remediation, helping organizations strengthen governance structures and internal controls while mitigating legal and reputational exposure.
Her experience includes coordinating parallel inquiries across multiple jurisdictions and aligning remediation efforts with evolving enforcement and compliance expectations. She has played key roles in independent compliance reviews and monitorship-related engagements, guiding companies through sustained oversight environments. She has conducted investigations, due diligence reviews, and compliance audits in more than 40 countries, with a particular focus on Europe, Africa, the Middle East, and Asia.
With a background in public international law and experience at the International Criminal Court, Anne brings a globally informed perspective to complex matters involving sovereign interests, multilateral institutions, and cross-border regulatory frameworks.
She is fluent in Norwegian, English, French, and Danish and has working proficiency in Swedish and German.
Before joining Morgan Lewis, Anne was a partner at another international law firm.
International Economic Sanctions and Export Controls
- Represented a global energy company in connection with development and implementation of an export controls compliance program and economic sanctions advice related to retention of third-party business partners, mergers and acquisitions, training, and risk assessments
- Assisted a multinational retail company on compliance with EU sanctions and coordination of successful obtention of licenses from multiple European national competent authorities
- Represented a Yemen-based company on internal review of compliance with US economic sanctions
- Advised a global energy company in connection with economic sanctions compliance reviews of operations in the UAE, India, the United States, and Europe
- Represented a European retail company in connection with the divestment of assets in Russia and compliance with EU and US sanctions
- Assisted a leading European transportation company in connection with potential divestment of operations in Russia and compliance with EU sanctions
- Represented a US-based healthcare company on international sanctions assessment of investment in the UAE
- Advised a European company on international sanctions assessment of potential investment in Cuba
- Assisted a European renewable energy company in conducting worldwide economic sanctions and export controls risk assessment
Anti-Corruption Investigations, Enforcement, and Resolutions
- Represented a European company in connection with an investigation into allegations of corruption in connection with MDB-financed development project
- Represented a European listed company in connection with several investigations of allegations of corruption, harassment, and financial misconduct by senior executives
- Advised a Swedish company in connection with a DOJ investigation and enforcement action
- Assisted a French engineering company in connection with contested proceedings before the World Bank
- Assisted a Norwegian company in connection with national and World Bank anti-corruption investigations and enforcement actions related to a development project in Tanzania
- Assisted a multinational telecom company relating to allegations of corruption involving operations in Tajikistan, Kazakhstan, and Uzbekistan
Compliance Program Development, Implementation, and Monitoring
- Represented a Nordic extractive industry company in the conduct of external assessment of effectiveness of its anti-corruption compliance program across global operations
- Assisted a multinational energy company with anti-corruption, economic sanctions, and export controls reviews spanning more than 50 entities across a range of industries
- Represented a multinational automotive company in connection with the performance of a global risk assessment, design, and implementation of compliance policies and procedures
- Advised a leading European defense company in anti-corruption risk assessment of its global operations
- Represented a multinational energy company in connection with a worldwide risk assessment and compliance review as part of an independent monitorship
- Advised a European telecommunications company in connection with global anti-corruption risk assessment and enhancements to compliance program as part of an independent compliance monitorship
- Assisting a multinational energy company on preacquisition due diligence and post-acquisition integration of public industrial company
- Represented a multinational company regarding entry into several joint venture projects and other investments with third parties, with a focus on the identification, analysis, and mitigation of potential anti-corruption and economic sanctions risks
ESG and Human Rights Compliance
- Assisted a Latin American multinational company on compliance with EU ESG standards and related EU ESG risk assessment
- Advised US retail company in designing and implementing human rights policies and procedures for operations in Southeast Asia
- Represented a multinational energy company on human rights compliance related to activities in Southeast Asia and Sub-Saharan Africa
- Assisted on ESG compliance matters for a large sovereign wealth fund
- New York University School of Law, 2008, LL.M., international legal studies, Fulbright Scholar
- The College of Law, London, 2007, diploma, English law
- Université de Paris II Panthéon-Assas, 2005, D.E.A., public international law
- Hague Academy of International Law, 2005, summer certificate, public international law
- University of Oxford, 2004, diploma in legal studies
- Université de Paris II Panthéon-Assas, 2003, LL.B., public, European, and international law
- Paris
- District of Columbia
- New York
- Norway
Excellent, Dispute Resolution: International Arbitration, Leaders League France (2025)
Excellent, Compliance: Export Control & International Sanctions, Leaders League France (2025)
Leading, Compliance: Internal Investigations and Compliance Program, Leaders League France (2025)
Recommended, Compliance: ESG Compliance, Leaders League France (2025)
Recommended, Compliance, The Legal 500 (2021, 2022, 2025)