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Emma Baker

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Emma Baker is an associate in the Litigation department and a member of the global Corporate Investigations and Compliance group. She has experience handling large-scale internal investigations, both internationally and domestically. Emma assists clients with economic trade sanctions compliance and enforcement, as well as anti-corruption matters, including US Foreign Corrupt Practices Act (FCPA) investigations and related post-resolution inquiries from the Department of Justice (DOJ) and the Securities and Exchange Commission (SEC). She has also worked with companies to develop policies and procedures, advised boards of directors on governance and liability matters, and conducted internal reviews and audits. Her matters have spanned numerous global jurisdictions, including Latin America, Asia, the Middle East, Africa, and Europe.

Emma previously worked as a law clerk at Santander Bank, where she supported the Senior Deputy General Counsel in managing risk and compliance matters. In this role, she conducted gap analyses, assisted in negotiations, and drafted recommendations for internal policies and procedures in response to regulatory exams. Emma also interned at a prominent Irish law firm, where she assisted the International Business Group with corporate compliance, commercial contracts, and the establishment of operations and related structures in Ireland.

During law school, she worked with the Navajo Nation Department of Justice, researching tribal laws to support the Attorney General.

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On July 9, 2025, the Department of Justice (“DOJ”) commenced enforcement of its new Data Security Program (“DSP”) to prevent foreign adversaries from accessing sensitive U.S. data. Created earlier this year, the program seeks to prevent China (including Hong Kong and Macau), Cuba, Iran, North Korea, Russia, and Venezuela (collectively, the “Countries of Concern”), as well as foreign entities or individuals with significant ties to these nations, from gaining access to U.S. government-related data and certain categories of U.S. sensitive personal data. Importantly, the rules apply “regardless of whether the data is anonymized, pseudonymized, de-identified or encrypted.” According to the DOJ, the threat of foreign adversaries collecting and weaponizing U.S. data had become “increasingly urgent, and ensuring prompt compliance with the DSP’s requirements is critical to addressing the administration’s priorities and stopping the flow of U.S. sensitive personal data and government-related data to countries of concern.” The seriousness of any infraction is reflected in the program’s steep civil and criminal penalties. Violators of the DSP could be subject to fines up to $368,136 per violation, or twice the value of each transaction in violation, whichever is greater. Willful violators could face imprisonment of up to 20 years and a $1 million fine.