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Claire Rajan

Senior Counsel

Washington, D.C.

Rajan Claire
Claire Rajan

Senior Counsel

Washington, D.C.

Claire’s cross-border practice includes representing multinational corporate clients in investigations and litigation matters. Her primary focus is on anti-corruption laws, including the Foreign Corrupt Practices Act (FCPA) and political law regulation governing campaign finance, pay-to-play, lobbying, and gifts to public officials. In addition, Claire has conducted cross-border investigations regarding economic sanctions and financial fraud. Claire’s experience includes cross-border litigation, internal investigations, federal and state government investigations, and transactional due diligence.

Claire also has extensive experience with evaluating corporate compliance programs, particularly while on multiple secondments to major global financial services providers.

Claire has been recognized by Chambers USA in 2017, 2018, and 2019, noting that Claire "is deeply experienced in political law enforcement and litigation."
According to Chambers, "clients praise her 'incredible judgment,'” explaining that “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.

News & insights

Key regulatory topics

Publications: 22 JANUARY 2020

Key Regulatory Topics: Weekly Update 10 January - 16 January 2020

Allen & Overy publish weekly updates on key regulatory topics affecting the financial services sector. 

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Publications: 20 JANUARY 2020

Inactive entities are about to be removed from the Luxembourg trade and companies register

Following the statement issued by the Luxembourg Ministry of Justice in December 2019[1] , the Luxembourg Business Registers (LBR) confirmed on 13 January 2020 that it will start removing inactive entities from the Luxembourg trade and companies register. 

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Publications: 19 MARCH 2019

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

The Federal Election Commission ("FEC") settled violations of federal campaign finance law in connection with the involvement of foreign nationals on a U.S. company’s board in making $1.3 million in contributions to a Super PAC supporting then-Presidential candidate Jeb Bush. The FEC found the contributions violated the federal ban on the involvement of foreign nationals in making contributions to political committees. The company agreed to a $550,000 penalty and the Super PAC agreed to a $390,000 penalty that, when taken together, is the third-largest penalty in the FEC’s four-decade history. 

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Publications: 05 JUNE 2018

Allen & Overy's Claire Rajan publishes article on new DOJ FCPA Corporate Enforcement Policy

Building on a 2016 pilot program, the DOJ’s latest guidelines are an effort to provide more certainty for corporate defendants in FCPA cases as to the benefits from self-disclosure, cooperation, and remediation. The author discusses key components of the pilot program and the changes made in the current guidelines. She notes that while there is more certainty as to benefits, the DOJ reserves a measure of prosecutorial discretion.​

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Office

Washington, D.C.

Allen & Overy LLP
1101 New York Avenue, NW
Washington, D.C.
20005

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Qualifications

Professional

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

Published work

"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)