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Claire Rajan

Partner

Email

claire.rajan@aoshearman.com

Phone

+1 202 683 3869

Offices

Washington DC

V-CARD
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 has been 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 due to a resolution of a domestic bribery scheme. She also has in-house experience from multiple secondments to major global financial services providers. 

Claire leads A&O Shearman’s Political Law Group, which 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 every year 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 worked as a litigation attorney for the Federal Election Commission (FEC) 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.

Expertise

Business and human rightsFinancial services advisory and regulatoryDisputesAdministrative and public law litigationAdministrative and public lawWhite collar defense and global investigationsPolitical lawRegulatory and complianceEnvironmental social and governanceLegislative process and legislative draftingFunds and asset managementPrivate equityPublic company advisory and corporate governanceCorporate governanceAdministrative contractsPublic procurement and competitive tenderingPublic international lawArtificial intelligenceSanctions and international trade

Industries

Private capitalFinancial institutionsBanksFintechAsset managementCommunications media and entertainmentMediaTelecommunicationsDigital infrastructureConsumer and retailEnergyOil and gasLiquefied natural gasPowerEnergy networksRenewablesAerospace and defenseLife sciences and healthcareFood and cosmeticsPharmaceuticalsVaccinesMining and metalsInfrastructureSovereign wealth and institutional investorsTechnologyInfrastructure and transport

Experience

Pro bono

Filed an amicus brief in the U.S. 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 U.S., which has been shared by the White House Correspondents Association and is sent to newsrooms across the country in advance of protests.

Published Work

  • “With new guidance and expertise, the DOJ mounts ‘compliance surge,” The FCPA Blog, with Billy Jacobson (September 20, 2022) 
  • “DOJ announces new policies on corporate prosecution,” Allen & Overy Investigations Insight (September 19, 2022)
  • “Expect more FCPA enforcement: Biden administration names corruption a national security interest,” Allen & Overy Investigations Insight (December 21, 2021)
  • “Germany enacts new federal lobbying law and mandatory register,” Allen & Overy Investigations Insight (March 29, 2021)
  • “Don’t let the 2020 campaign season affect your ability to seek investment from public investors,” Allen & Overy Investigations Insight (August 5, 2020)
  • “The Federal Election Commission regains a quorum in the middle of the 2020 election cycle: Enforcement, audits, advisory opinions, or not so fast?” Allen & Overy Investigations Insight (May 21, 2020)
  • “Recognising and mitigating Covid-19 corruption risk,” Allen & Overy Investigations Insight (April 20, 2020)
  • “Allen & Overy’s Political Law team publishes guide on corporate political activity in the United States,” Allen & Overy Investigations Insight (February 4, 2020)
  • “Federal Election Commission Obtains $940,000 in Fines for Foreign Involvement in a U.S. Corporate Contribution to a Super PAC Supporting a 2016 Presidential Candidate,” Allen & Overy Investigations Insight (March 19, 2019)
  • "Political Law Developments - January 2019," an Allen & Overy publication (January 31, 2019), with Derek Manners and Danna Seligman.
  • "Quick Read: What you need to know about the DOJ Fraud Section’s new ‘Evaluation of Corporate Compliance Programs’ guidance," Allen & Overy Investigations Insight (Mar. 6, 2017)
  • "Pay-To-Play Lessons From This Week's SEC Settlements," Law360 (Feb. 17, 2017), with Charles Borden, Chris Salter, Bill White and Samuel Brown
  • "Yates’s take on the impact of the so-called ‘Yates Memo’," Allen & Overy Investigations Insight (May 26, 2016)
  • “Questions and Answers About Super PACs and Corporate Compliance Risks,” Corporate Counsel (Apr. 20, 2016), with Charles Borden and Jana Steenholdt
  • "Self-reporting FCPA misconduct: A one-year pilot from the DOJ," Allen & Overy Investigations Insight (Apr. 18, 2016)
  • “Another Campaign Finance No-No: Foreign Contributions,” Corporate Counsel (Apr. 13, 2016), with Charles Borden and Kate Wooler
  • "Don’t get Trumped: The 2016 U.S. Election and Political Law Risks for Corporates," Allen & Overy Investigations Insight (Apr. 7, 2016)
  • “The Big No-No: Campaign Money Laundering,” Corporate Counsel (Apr. 6, 2016), with Charles Borden and Kate Wooler
  • “Key Compliance Issues in Operating a Corporate PAC,” Corporate Counsel (Mar. 30, 2016), with Charles Borden and Kate Wooler
  • “The Presidential Candidates on Campaign Finance Reform,” Corporate Counsel (Mar. 23, 2016), with Charles Borden and Daniel Holman
  • “Brand Risks: Trump, Miss USA and Jose Andres,” Corporate Counsel (Mar. 16, 2016), with Charles Borden and Daniel Holman
  • “What Your Company Can Do—and Should Not Do—During the Election Campaign,” Corporate Counsel (Mar. 9, 2016), with Charles Borden
  • “Allen & Overy’s Weekly Election Series,” Corporate Counsel (Mar. 2, 2016), with Charles Borden
  • “$12M SEC Penalty Demonstrates Focus On Pay-To-Play,” Law360 (Jan. 15, 2016), with Charles Borden and Bill White
  • "The SEC Pay-to-Play Rule: Lessons Learned from the Exemptive Relief Process," The Investment Lawyer (May 2015), with Charles Borden and Sam Brown
  • "Non-U.S. Issuers Selling Fund Interests In The United States," The Review of Securities & Commodities Regulation (July 2012), with Barbara Stettner, Charles Borden and Sam Brown
  • Co-editor, "A Practitioner’s Guide To Appellate Advocacy," American Bar Association, Litigation Section, Appellate Practice Committee (2010)
  • Contributor, "Encyclopedia Of The United States Constitution," Facts On File, Inc (2009)
  • Contributor, "Report of the Independent Expert on the Protection of Human Rights and Fundamental Freedoms while Countering Terrorism for the United Nations High Commission for Human Rights" (February 2005)
  • Co-author, "Some Reflections on Lessons Learned from U.S. and International Financial Institutions’ Efforts Promoting Legal Reform in Countries in Transition" (May 2004)

Speaking Engagements

  • Panelist, Complex Matter Management, SIFMA Compliance & Legal Annual Seminar, March 2022.
  • Panel Co-moderator: “Disinformation: The Challenges to Democracy,” sponsored by the ABA Section of Civil Rights and Social Justice and the Canadian Bar Association’s Section on Constitutional and Human Rights, June 2021.
  • Panel Co-moderator: “Social Media: Challenges and Opportunities in Free Speech,” sponsored by the ABA Section of Civil Rights and Social Justice and the Canadian Bar Association’s Section on Constitutional and Human Rights, June 2021.
  • Moderator, SIFMA Women’s Leadership Forum panel on “Developing Your Personal Brand,” 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.
  • Panelist, Cross-Border Anti-Corruption and Enforcement & FCPA Enforcement Against Financial Institutions, SIFMA Compliance & Legal Society Annual Seminar, September 2020.
  • Presenter, Challenges and Hot Topics in Cross-Border Investigations, Lawline, October 2019.
  • Presenter, Managing Political Influence Risk for Financial Services Firms, SIFMA State & Local Committee, April 2019.
  • Panelist, Navigating Ethical Dilemmas When Transitioning Roles, SIFMA Compliance & Legal Society Annual Seminar, March 2019.
  • Trends, 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.

Leadership Positions And Professional Affiliations

  • Co-Chair of the American Bar Association Free Speech & Free Press Section of the Civil Rights & Social Justice Committee.

Qualifications

Admissions

Registered Foreign Lawyer, England and Wales, 2024

Admitted: Bar of the United States Supreme Court, 2021

Admitted: Bar of the District of Columbia, 2012

Admitted: Bar of the State of California, 2005

Admitted: U.S. Court of Appeals Second Circuit, 2015

Fourth Circuit, 2008

Fifth Circuit, 2010

Ninth Circuit, 2009

Academic

J.D., American University Washington College of Law, 2005 

B.A., University of California at Los Angeles, 2001

Disclaimer
A&O Shearman was formed on May 1, 2024 by the combination of Shearman & Sterling LLP and Allen & Overy LLP and their respective affiliates (the legacy firms). Any matters referred to above may include matters undertaken by one or more of the legacy firms rather than A&O Shearman.