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Derek A. Hahn

Partner
Partner
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Areas of Focus

Overview

From high stakes internal and government investigations to complex compliance matters, clients rely on Derek to manage their most consequential white collar risks across the globe. Derek represents clients across industries in a wide range of enforcement matters, with a particular emphasis on international trade laws and regulations, corruption, financial fraud, corporate governance, and environmental compliance.

Derek has successfully navigated clients through investigations and related voluntary self-disclosures to government regulators with unprecedented results. In the customs enforcement context, he guided his clients to the first-ever criminal declination from the Department of Justice (DOJ) following the launch of its Trade Fraud Task Force initiative with the Department of Homeland Security (DHS). He has navigated clients through multiple investigations by DOJ and Customs and Border Protection (CBP) in matters alleging duty/tariff evasion and related violations, including defending related qui tam False Claims Act litigation and negotiating favorable False Claims Act and Tariff Act settlements.

In the anti-corruption space, Derek has defended numerous Foreign Corrupt Practices Act (FCPA) investigations by DOJ and the Securities and Exchange Commission (SEC) and led clients through the voluntary self-disclosure process to both agencies. Derek’s anti-corruption experience stretches across six continents and includes government and internal investigations under the FCPA and various countries’ anti-corruption laws, including the UK Bribery Act. He also regularly partners with clients to help improve their anti-corruption compliance programs, conduct third-party due diligence reviews or audits, perform internal risk assessments, and provide related training.   

Chambers has recognized Derek with rankings for both White Collar Crime & Government Investigations and FCPA matters, noting he is a “fantastic, true defender” who is “sought after for his prowess in white collar and regulatory enforcement.” Derek regularly writes and speaks on investigation and compliance topics, including co-authoring the WorldECR’s global guide on "Managing Investigations - Best practice in Government and Internal Investigations" and numerous other publications featured in the FCPA Blog, Law360, the ABA’s Criminal Justice Section, and other outlets. Derek sits on the Steering Committee of Crowell’s White Collar & Regulatory Enforcement Group and is a member of the firm’s Investigations Practice, which collectively have received numerous accolades, including Law360’s “White Collar Group of the Year” distinction and recognition as one of ten “FCPA Powerhouses,” as well as ranking among the Global Investigations Review “GIR 100” list of top cross-border investigations practices since 2015. 

Career & Education

    • University of Virginia School of Law, J.D., Virginia Law Review
    • Duke University, B.S.E., cum Laude, civil and environmental engineering
    • University of Virginia School of Law, J.D., Virginia Law Review
    • Duke University, B.S.E., cum Laude, civil and environmental engineering

    • California
    • California

  • Professional Activities and Memberships

    • American Bar Association: Global Anti-Corruption Committee, International White Collar Committee, International Anti-Corruption Committee
    • Former Board Member, Federal Bar Association, Orange County Chapter
    • Past-President, National Contract Management Association, Orange County Chapter
    • Association of Surfing Lawyers

    Professional Activities and Memberships

    • American Bar Association: Global Anti-Corruption Committee, International White Collar Committee, International Anti-Corruption Committee
    • Former Board Member, Federal Bar Association, Orange County Chapter
    • Past-President, National Contract Management Association, Orange County Chapter
    • Association of Surfing Lawyers
“incredibly savvy” “very practical” “outstanding judgment” “knowledgeable, business-minded, and responsive” “really good at setting the right materiality bar” “saved us millions of dollars with the results they got” “extremely highly regarded” “an excellent lawyer” 

— Chambers & Partners

Derek's Insights

Client Alert | 4 min read | 10.06.26

DOJ Fraud Division Issues Corporate Enforcement Directive

On October 1, 2026, the U.S. Department of Justice’s (DOJ) National Fraud Enforcement Division issued Directive 26-12: Corporate Enforcement in the Fight Against Fraud. Assistant Attorney General Colin M. McDonald’s October directive follows his August 2026 memorandum setting the Division’s enforcement priorities. The directive signals — in the DOJ’s words — “an aggressive, all-tools” enforcement posture across the Division’s health care, government contracting, tax, and trade fraud priorities, while simultaneously supporting the incentives designed to promote transparency, reward cooperation, and encourage voluntary disclosure of misconduct. ...

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Representative Matters

International Trade and Anti-Corruption Engagements

  • Represented multiple U.S. subsidiaries of  importer and distributor in investigation of potential duty evasion including parallel self-disclosures to CBP and DOJ, resulting in a favorable civil settlement of FCA and Tariff Act liability and the first-ever criminal DOJ declination in a customs matter. 
  • Led internal investigation and parallel self-disclosures to DOJ and SEC regarding potential FCPA violations in South America for a publicly traded company involving alleged improper payments to customs officials, resulting in non-public declinations from both agencies. 
  • Represented equipment manufacturer in internal investigation of alleged duty evasion,  related prior disclosure to CBP, and parallel FCA investigation by DOJ resulting in an unprecedented FCA and Tariff Act settlement with no penalty multiplier. 
  • Represented U.S. subsidiary of multinational heavy equipment manufacturer in investigation and self-disclosure of FCPA issues in criminal DOJ investigation arising out of export control compliance concerns with sales to Chinese state-owned entities. 
  • Advised publicly traded chemicals company in internal investigation of potential FCPA issues in Ukraine and response to DOJ subpoena based on Mutual Legal Assistance Treaty (MLAT) request by Ukraine. 
  • Led internal investigation and parallel self-disclosures to DOJ and SEC of potential FCPA violations at a multinational distributor’s subsidiary in Argentina and related response to anonymous whistleblower involving alleged improper payments to secure government contracts. 
  • Conducted internal investigation and coordinated parallel self-disclosures to DOJ and SEC for multinational insurance company related to potential FCPA violations in India involving alleged improper payments to government inspectors. 
  • Represented multinational distributor in response to a DOJ investigation of potential FCPA violations in Southern Europe involving alleged excessive entertainment of government officials to secure contracts. 
  • Conducted post-acquisition FCPA risk assessment and internal investigation of a potential corruption issue in Peru involving alleged improper payments through lobbyists to obtain favorable tax legislation. 
  • Advised multinational distributor on post-acquisition FCPA risk assessment and investigations arising from the Operation Lava Jato (Car Wash) investigations in Brazil and throughout South America, including responding to execution of search warrants and related government investigations. 
  • Represented the former president and CFO of a pharmaceutical company during an internal investigation of FCPA issues by an independent Board committee. 
  • Conducted internal investigation of potential FCPA issues in India for Fortune 500 life sciences company and advised on related compliance program improvements. 
  • Multi-year defense of publicly traded distributor and several employees in investigation by the DOJ and SEC of alleged FCPA violations in India involving alleged use of marketing funds to secure government contracts. 
  • Counseled multiple clients in countries across the globe on (1) transaction specific anti-corruption due diligence, contracting, and related controls, (2) pre-acquisition anti-corruption due diligence, and (3) the improvement of anti-corruption compliance programs, including performing related risk assessments, developing training materials, and enhancing third-party due diligence protocols. 

Other Investigation and Enforcement Engagements

  • Represented General Counsel of publicly traded manufacturer in Special Committee investigation of Board governance issues and related whistleblower complaint. 
  • Defended one of the nation's largest cement manufacturers in multistate Clean Air Act investigations and federal court litigation brought by DOJ and the Environmental Protection Agency (EPA). 
  • Represented a health care executive in connection with federal health care fraud and public corruption investigations. 
  • Represented the former CFO of publicly traded pharmaceutical company in connection with an accounting fraud investigation. 
  • Represented an oil company and executives in connection with a criminal environmental enforcement investigation arising from alleged improper discharges. 
  • Advised a multibillion-dollar public retirement fund on conflicts of interest under California Government Code Section 1090. 
  • Represented wastewater treatment company in an improper discharge investigation by the California State Water Resource Control Board's Office of Enforcement. 

Derek's Insights

Client Alert | 4 min read | 10.06.26

DOJ Fraud Division Issues Corporate Enforcement Directive

On October 1, 2026, the U.S. Department of Justice’s (DOJ) National Fraud Enforcement Division issued Directive 26-12: Corporate Enforcement in the Fight Against Fraud. Assistant Attorney General Colin M. McDonald’s October directive follows his August 2026 memorandum setting the Division’s enforcement priorities. The directive signals — in the DOJ’s words — “an aggressive, all-tools” enforcement posture across the Division’s health care, government contracting, tax, and trade fraud priorities, while simultaneously supporting the incentives designed to promote transparency, reward cooperation, and encourage voluntary disclosure of misconduct. ...

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Recognition

  • Chambers USA: White Collar Crime and Government Investigations, FCPA
  • “Top 40 Under 40” California Lawyers, Daily Journal, 2019
  • Super Lawyers: Leading White Collar Attorney, 2017–Present

Derek's Insights

Client Alert | 4 min read | 10.06.26

DOJ Fraud Division Issues Corporate Enforcement Directive

On October 1, 2026, the U.S. Department of Justice’s (DOJ) National Fraud Enforcement Division issued Directive 26-12: Corporate Enforcement in the Fight Against Fraud. Assistant Attorney General Colin M. McDonald’s October directive follows his August 2026 memorandum setting the Division’s enforcement priorities. The directive signals — in the DOJ’s words — “an aggressive, all-tools” enforcement posture across the Division’s health care, government contracting, tax, and trade fraud priorities, while simultaneously supporting the incentives designed to promote transparency, reward cooperation, and encourage voluntary disclosure of misconduct. ...

View All Insights

Insights

Client Alert | 4 min read | 10.06.26

DOJ Fraud Division Issues Corporate Enforcement Directive

Client Alert | 5 min read | 09.21.26

Congressional Letter Puts Spotlight on Unenforceable Secrecy Demands in Federal Subpoenas

Firm News | 7 min read | 06.04.26

Crowell & Moring Secures Top Rankings in Chambers USA 2026

Blog Post | 06.01.26

(Not) All’s Weld That Ends Weld: Duty Evasion Scheme Ends in Historic $549.5M FCA Settlement

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Practices

Derek's Insights

Client Alert | 4 min read | 10.06.26

DOJ Fraud Division Issues Corporate Enforcement Directive

On October 1, 2026, the U.S. Department of Justice’s (DOJ) National Fraud Enforcement Division issued Directive 26-12: Corporate Enforcement in the Fight Against Fraud. Assistant Attorney General Colin M. McDonald’s October directive follows his August 2026 memorandum setting the Division’s enforcement priorities. The directive signals — in the DOJ’s words — “an aggressive, all-tools” enforcement posture across the Division’s health care, government contracting, tax, and trade fraud priorities, while simultaneously supporting the incentives designed to promote transparency, reward cooperation, and encourage voluntary disclosure of misconduct. ...

View All Insights