Caroline Hailey’s practice focuses on cross-border investigatory, advisory, and enforcement work.

She has significant experience managing cross-border investigations and inquiries, and has conducted investigations fieldwork in over 20 countries, including Azerbaijan, Brazil, China, Denmark, France, Germany, Italy, Kazakhstan, Myanmar, Singapore, South Africa, Uganda, the United Arab Emirates, the United Kingdom, and the United States. In 2018, she was named to Global Investigations Review’s “Women in Investigations,” which recognizes the 100 leading female investigations specialists from around the world.

Caroline’s enforcement work focuses on white-collar defense, including allegations of corporate bribery, criminal and civil fraud, market offenses, money-laundering, and violations of economic sanctions. Her practice also includes assisting clients in developing compliance and governance frameworks that respond to the requirements of multiple jurisdictions, including advice on preventative measures, crisis management, and wider strategic issues, focusing in particular on multinational corporations and state-owned entities.

Caroline also advises companies on corporate social responsibility matters, including environmental, social and governance (ESG) disclosures, responsible sourcing and sustainability in operations. She maintains an active pro bono practice.

Caroline joined the firm in 2007 and became a senior attorney in 2019 after four years as an in-house legal advisor.

Selected Activities

Former Vice Chair of the International Bar Association’s Sub-Committee on Drivers of Corruption

Member of Advisory Board to Compliance Programs, Fordham Law School


A Sustainable Recovery for Europe: The EU’s Green Deal,” Cleary Gottlieb Alert Memo, July 2020.

Navigating COVID-19: Supply Chain Considerations,” Cleary Gottlieb Alert Memo, July 2020

CRR Quick Fix to Facilitate Lending in Response to COVID-19 Adopted,” Cleary Gottlieb Alert Memo, July 2020

The European Commission Publishes Its Ambitious Action Plan on Anti-Money Laundering,” Cleary Gottlieb Alert Memo, June 2020

Navigating COVID-19: Best Practices for Managing Compliance Risk,” Cleary Gottlieb Alert Memo, March 2020

Criminal Settlement Procedures in French Law: an Initial Assessment,” Echanges Internationaux, February 2020

The Launch of the Hague Rules on Business and Human Rights Arbitration,” Cleary Gottlieb Alert Memo, January 2020

Navigating the ESG Landscape,” Selected Issues for Boards of Directors in 2020,” Cleary Gottlieb Alert Memo, January 2020

Anti-Corruption Law and Practice Report 2017: Innovation in Enforcement and Compliance, International Bar Association, Anti-Corruption Committee, May 2017


Anticorruption Options for the Partners of State-Owned Enterprises (SOEs) in High-Risk Environments, London, December 3, 2019

Internal Investigations: Instructions for Use, Milan, September 25, 2019

Managing Compliance Risks in Emerging Markets, SCCE European Compliance & Ethics Institute, Frankfurt, March 2018

France’s Compliance Revolution: The Loi Sapin II, SCCE European Compliance & Ethics Institute, Prague, April 2017