Shearman & Sterling provides a wide range of anti-money laundering (AML) and counter-terrorist financing (CTF) services to global banks, securities broker-dealers, mutual funds, investment advisors, private equity funds, insurance companies, FinTech companies, and corporations throughout the world. We represent clients in compliance program design and implementation; law enforcement and regulatory investigations and internal investigations; and related civil and criminal litigation. Our roster includes lawyers who have had wide-ranging government experience, and leadership roles at leading financial institutions. Our team has the breadth and depth of experience to provide clients with the technical, strategic and practical assistance that they require, wherever and whenever issues arise.

Shearman & Sterling works closely with clients to address the many significant AML and CTF issues that can arise, including those not anticipated or clearly addressed in existing laws, regulations and practice. We understand the importance of delivering timely and practical advice, and work with clients to find effective solutions to guard against the legal and reputational risks they face.

Criminal and Regulatory Enforcement and Investigations

We represent clients at all stages of high-stakes law enforcement and regulatory actions, including matters before the Department of Justice (DOJ), the Federal Reserve Board (FRB), the Office of the Comptroller of the Currency (OCC), the New York State Department of Financial Services (DFS), the US Securities and Exchange Commission (SEC), the Department of the Treasury’s Office of Foreign Assets Control (OFAC) and Financial Crimes Enforcement Network (FinCEN). We also have extensive experience counseling clients during their dealings with a range of law enforcement agencies and regulators in Europe (and Asia), including the Serious Fraud Office (SFO), Her Majesty's Revenue and Customs (HMRC), Financial Conduct Authority (FCA) and National Crime Agency (NCA) in the U.K. We have significant experience in:

  • Conducting internal investigations across multiple jurisdictions
  • Responding to regulatory and law enforcement inquiries, examinations, and subpoenas
  • Navigating matters involving multi-agency actions involving federal and state agencies within the US, as well as multi-jurisdictional investigations
  • Providing insight into enforcement trends in connection with settlement negotiations, including complex cross-border resolutions
  • Advising on the implementation of remedial measures
  • Advising on collateral consequences of regulatory and law enforcement actions
  • Advising on emerging regulatory and enforcement trends in anticipation of future regulatory and law enforcement inquiries

Regulatory and Compliance

We understand that legal and regulatory compliance will be at the forefront of any client's mind and that ensuring AML and CTF programs are effective is critical. They must be tailored to protect against the unique risks faced by each client, and strong enough to withstand not only internal and external reviews, but the scrutiny of federal and state regulators who often have overlapping jurisdiction and routinely audit for compliance with applicable laws and regulations. We have experience in:

  • Advising on and developing global AML and KYC policies and procedures
  • Advising on regulatory examinations and related AML issues
  • Advising on due diligence and negotiations in relation to AML/anti-bribery elements of transactions
  • Advising on whether or not to make, and on the drafting of, suspicious activity reports and related filings
  • Establishing procedures and safeguards for the security and confidentiality of information
  • Developing compliance manuals covering data protection registration and compliance issues
  • Advising on AML-related FATCA/data protection issues

For information on our related Sanctions and Global Compliance and Anticorruption capabilities, please see links below:

Sanctions Microsite and FCPA Microsite.