Claire Rajan
Partner
Washington, D.C.
Claire Rajan
Partner
Washington, D.C.
Contact Details
Claire’s cross-border practice includes representing multinational corporate clients in 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, oil & gas, mining, renewables, engineering, financial services (banks, private equity, and asset managers), and consumer goods.
Claire’s investigations practice includes government-facing and internal investigations relating to corruption, fraud, sanctions, and anti-competitive behavior. She also represents clients in World Bank investigations.
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 also has in-house experience from multiple secondments to major global financial services providers.
Claire leads A&O’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 from 2017 through 2021, 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 Allen & Overy, 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
Practices
Litigation, Arbitration and Investigations
Qualifications
Professional
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
Related articles
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New U.S. DOJ guidance on executive compensation, personal devices and ephemeral messaging
Executive compensation and the use of personal devices and ephemeral messaging are the key focus areas of new U.S. Department of Justice policies and guidance. We consider the changes and how…
Expertise
Practices
Litigation, Arbitration and Investigations
Qualifications
Professional
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
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.
Recognition
"Claire is incredibly intelligent and thoughtful. She anticipates how the law can be enforced before it is enforced. She has a very commercial approach, is highly responsive and communicates clearly, briefly and effectively. She has an exceptional touch with clients."
Chamber USA, 2022
“She is a terrific lawyer. She is easy to work with and a subject matter expert.”
Chamber USA, 2021
“She is an expert in the field of campaign finance and very experienced in working for commissioners.”
Chamber USA, 2020
“She is very fast to come up to speed on new matters and zero in on the most important aspects of a legal issue. She provides a very sensible approach toward finding practical solutions.”
Chamber USA, 2019
Published work
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“With new guidance and expertise, the DOJ mounts ‘compliance surge,” The FCPA Blog, with Billy Jacobson (September 20, 2022)
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“DOJ announces new policies on corporate prosecution,” Allen & Overy Investigations Insight (September 19, 2022)
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“Expect more FCPA enforcement: Biden administration names corruption a national security interest,” Allen & Overy Investigations Insight (December 21, 2021)
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“Germany enacts new federal lobbying law and mandatory register,” Allen & Overy Investigations Insight (March 29, 2021)
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“Don’t let the 2020 campaign season affect your ability to seek investment from public investors,” Allen & Overy Investigations Insight (August 5, 2020)
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“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)
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“Recognising and mitigating Covid-19 corruption risk,” Allen & Overy Investigations Insight (April 20, 2020)
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“Allen & Overy’s Political Law team publishes guide on corporate political activity in the United States,” Allen & Overy Investigations Insight (February 4, 2020)
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“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)
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"Political Law Developments - January 2019," an Allen & Overy publication (January 31, 2019), with Derek Manners and Danna Seligman.
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"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)
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"Pay-To-Play Lessons From This Week's SEC Settlements," Law360 (Feb. 17, 2017), with Charles Borden, Chris Salter, Bill White and Samuel Brown
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"Yates’s take on the impact of the so-called ‘Yates Memo’," Allen & Overy Investigations Insight (May 26, 2016)
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“Questions and Answers About Super PACs and Corporate Compliance Risks,” Corporate Counsel (Apr. 20, 2016), with Charles Borden and Jana Steenholdt
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"Self-reporting FCPA misconduct: A one-year pilot from the DOJ," Allen & Overy Investigations Insight (Apr. 18, 2016)
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“Another Campaign Finance No-No: Foreign Contributions,” Corporate Counsel (Apr. 13, 2016), with Charles Borden and Kate Wooler
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"Don’t get Trumped: The 2016 U.S. Election and Political Law Risks for Corporates," Allen & Overy Investigations Insight (Apr. 7, 2016)
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“The Big No-No: Campaign Money Laundering,” Corporate Counsel (Apr. 6, 2016), with Charles Borden and Kate Wooler
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“Key Compliance Issues in Operating a Corporate PAC,” Corporate Counsel (Mar. 30, 2016), with Charles Borden and Kate Wooler
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“The Presidential Candidates on Campaign Finance Reform,” Corporate Counsel (Mar. 23, 2016), with Charles Borden and Daniel Holman
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“Brand Risks: Trump, Miss USA and Jose Andres,” Corporate Counsel (Mar. 16, 2016), with Charles Borden and Daniel Holman
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“What Your Company Can Do—and Should Not Do—During the Election Campaign,” Corporate Counsel (Mar. 9, 2016), with Charles Borden
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“Allen & Overy’s Weekly Election Series,” Corporate Counsel (Mar. 2, 2016), with Charles Borden
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“$12M SEC Penalty Demonstrates Focus On Pay-To-Play,” Law360 (Jan. 15, 2016), with Charles Borden and Bill White
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"The SEC Pay-to-Play Rule: Lessons Learned from the Exemptive Relief Process," The Investment Lawyer (May 2015), with Charles Borden and Sam Brown
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"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
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Co-editor, "A Practitioner’s Guide To Appellate Advocacy," American Bar Association, Litigation Section, Appellate Practice Committee (2010)
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Contributor, "Encyclopedia Of The United States Constitution," Facts On File, Inc (2009)
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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)
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Co-author, "Some Reflections on Lessons Learned from U.S. and International Financial Institutions’ Efforts Promoting Legal Reform in Countries in Transition" (May 2004)
