Lucinda Low
Washington, D.C.


Lucinda Low's practice includes representing audit committees, boards of directors, and companies in internal, government, and international financial institution audits, investigations, and enforcement matters involving fraud, bribery, corruption, and other compliance issues. Lucinda is recognized by Chambers market commentators for her "incredible technical proficiency, spectacular advocacy skills, and cultural know-how." She has particular authority 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."

In the FCPA/anti-corruption realm, 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 multijurisdictional investigations. She also has significant experience in investment disputes between foreign investors and host governments, and commercial arbitration, including serving as counsel, arbitrator, and an expert witness.

Lucinda serves as a member of the firm’s Management Committee and heads the Compliance, Investigations, Trade and Enforcement Department. She also leads Steptoe’s Brazil-specific initiative incorporating a focus on FCPA/anti-corruption compliance and enforcement work. Lucinda's FCPA/anti-corruption experience includes extensive work in Latin America, including Argentina, Bolivia, Brazil, Chile, Colombia, Costa Rica, Ecuador, Guyana, Mexico, Nicaragua, Peru, Uruguay and Venezuela, as well as several Caribbean countries.

As a complement to her practice, Lucinda assists in the creation and supervision of the International Law Guides, a web-accessible compliance tool designed to provide corporate subscribers and their employees with detailed information on local anti-corruption laws around the globe.

Lucinda is a member of the Board of Directors of the Coalition for Integrity (formerly known as Transparency International – USA), and also a member of the 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 was the 2003 recipient of the William Ray Vallance Award presented by the Inter-American Bar Foundation, presented to an individual who has made a significant contribution toward improving the law and jurisprudence of the Western Hemisphere.

Lucinda is fluent in Portuguese and Spanish, and has lived in Brazil on two separate occasions. 

Fellow content

Friday, July 31, 2020

World Bank’s enforcement approach needs review, say lawyers

In GIR’s review of the World Bank’s treatment of debarments, Lucinda Low shared her observations about debarment and how detrimental it can be to companies.

Tuesday, July 07, 2020

Commercial Bribery: The FCPA’s Forgotten Counterpart

Lucinda Low’s analysis of the FCPA enforcement risks related to commercial bribery was published in The Anti-Corruption Report.


Blogs of Interest

The Academy
Blogs, short articles and series by Fellows of the International Academy of Financial Crime Litigators.

The official blog of the "International Enforcement Law Reporter," edited by Bruce Zagaris.

Sunday, July 05, 2020

In the Wake of Kokesh v. SEC: Whither Disgorgement in FCPA Cases

Lucinda Low analyzes Kokesh v. SEC and details how SEC policies will be affected and how unclarified issues in the judgment are likely to increase litigation.

Tuesday, May 12, 2020

COVID-19 Disrupts Internal Probes

In an interview with a Deloitte Financial Advisory Services LLP managing director for The Wall Street Journal "Risk & Compliance Journal," Lucinda Low discusses how interviews and document collection in a post-COVID-19 era will undoubtedly change the internal investigation process. 

Monday, May 11, 2020

Mobilizing for an Internal Probe

Lucinda Low, speaking to The Wall Street Journal "Risk & Compliance Journal," explains how internal investigations must be handled to net the most accurate outcomes and assure credit for self-disclosure.