Dr. Maximilian F. Schlutz is an associate in Willkie’s German practice. He is a member of Willkie’s Investigations & Enforcement, White-Collar Defense, Global Trade & Investment and Environmental, Social & Governance practice groups.

He advises clients from various industries in the areas of Anti-Bribery and Corruption, Anti-Money Laundering / Countering Terrorist Financing, with a focus on Business-Partner Compliance / Third Party Management, and Compliance Management Systems.

In particular, he gained specific experience in the context of (DOJ/SEC-appointed) independent compliance monitorships and authored Compliance Monitorships: How can a U.S. instrument determine the day-to-day operations of German companies (2021). 

Max has experience with conducting cross-border white collar investigations, specifically in the context of multi-jurisdictional investigations related to the FCPA, anti-money laundering, fraud, compliance violations, whistleblower complaints, export/import regulations, sanctions violations, tax, and other legal and regulatory issues.

Further, he gained experience during an in-house secondment to a multinational commodity trading and mining company. 

Max authored within the juris PraxisReport Compliance & Investigations and contributed to the Global Anti-Bribery Year-in-Reviews 2020 to 2022 and to the FCPA Treatise 2020.

Prior to joining Willkie, Max worked in the course of his legal career for various international law firms in New York, Dubai, Sydney, Los Angeles, and Germany, mostly in the areas of Compliance and Corporate/M&A.

Max is fluent in German and English.



Prior to joining Willkie, Max worked in the course of his legal career for various international law firms in New York, Dubai, Sydney, Los Angeles, Frankfurt am Main and Düsseldorf, mostly in the areas of Compliance and Corporate/M&A.
  • “Toothless Tiger No More? Germany Strengthens Sanctions and AML Enforcement”, January 24, 2023.
  • “Compliance Monitorships: Wie kann ein US-Instrumentarium den Alltag deutscher Unternehmen bestimmen?” (Volume 1 of CB - Compliance Berater publication series, published by Fachmedien Recht und Wirtschaft 2021, ISBN 978-3-8005-9408-5).
  • “Verpflichtung zur Übermittlung nicht protokollierter IP-Adressen”, juris PraxisReport Compliance & Investigations, Anmerkung zu BVerfG, Nichtannahmebeschluss vom 20.12.2018, 2 BvR 2377/16 von Prof. Dr. Norbert Nolte, RA, Freshfields Bruckhaus Deringer LLP, Düsseldorf.
  • Advising AlixPartners, a global consulting firm, in its acquisition of leading independent restructuring practice THM Partners LLP.
  • Advising EQT Growth on its investment in Integrity Next GmbH, a sustainability software platform for supply chain transparency and regulatory compliance.  
  • Advising a U.S. investment management firm on EU sanctions and export controls related to investments in the Russian metals and mining industries.
  • Advising a listed advertising company headquartered in the U.S. with respect to EU sanctions and AML risks under German law.
  • Advising a global food manufacturer in connection with new requirements of the EU Whistleblower Directive.
  • Advising an Austrian packaging manufacturer on the analysis of its internal compliance program, in particular with regard to the changing regulatory landscape resulting from the Ukraine Crisis.
  • Advising an international company in the field of transport, trade and distribution of oil products and petrochemicals on compliance with sanctions in the context of the price cap for Russian oil and oil products.
  • Advising a German-based global healthcare company as part of a DOJ / SEC appointed independent compliance monitorship.*
  • Advising a global professional services firm in relation to German tax investigations.* 
  • Advising a NYSE-listed global science and technology investor on its acquisition of a German leading provider of high-performance cell technology for the manufacturing of advanced biotherapeutics.*
  • Advising a US tech company in its Series A financing round.* 
  • Advising an international industrial tech conglomerate on general corporate matters.*
  • Advising US venture capital investors in financing rounds of German tech and software companies.*

*Max advised on these matters prior to joining Willkie





Goethe University of Frankfurt, Dr. jur., 2021 Higher Regional Court of Frankfurt, Second State Exam, 2018 Goethe University of Frankfurt, Law Degree, 2015

Bar Admissions

Germany, 2020