Stephanie L. Brooker, former Director of the Enforcement Division at the U.S. Department of Treasury's Financial Crimes Enforcement Network (FinCEN) and a former federal prosecutor, is a partner in the Washington, D.C. office of Gibson, Dunn & Crutcher. She is Co-Chair of the Financial Institutions Practice Group and a member of White Collar Defense and Investigations Practice Group. As a prosecutor, Ms. Brooker served as the Chief of the Asset Forfeiture and Money Laundering Section in the U.S. Attorney's Office for the District of Columbia, tried 32 criminal trials, and briefed and argued criminal appeals.
Ms. Brooker's practice focuses on internal investigations, regulatory enforcement defense, white-collar criminal defense, and compliance counseling. She represents financial institutions, multi-national companies, and individuals in connection with criminal, regulatory, and civil enforcement actions involving anti-money laundering (AML)/Bank Secrecy Act (BSA), sanctions, anti-corruption, securities, tax, and wire fraud. Ms. Brooker's practice also includes BSA/AML compliance counseling and due diligence and significant criminal and civil asset forfeiture matters.
Before joining Gibson Dunn in April 2016, Ms. Brooker served as the first Director of FinCEN's Enforcement Division, which is the lead federal regulator with responsibility for enforcing the U.S. AML laws and regulations. In this role, she oversaw all of FinCEN's domestic and foreign enforcement and compliance under the BSA, such as civil money penalty actions and injunctions against a wide range of financial institutions, including banks, credit unions, money services businesses, virtual currency entities, casinos, broker-dealers, futures, insurance, and dealers in precious metals, stones and jewels. She also oversaw rulemaking actions under Section 311 of the PATRIOT Act against foreign institutions and jurisdictions and Geographic Targeting Orders.
As Enforcement Director, Ms. Brooker also oversaw for the agency litigation of contested enforcement actions, including several cases of first impression in federal court handled by the Department of Justice (DOJ) on behalf of the agency. She also oversaw examinations of regulated financial institutions and development of compliance strategies. Ms. Brooker worked closely with a wide range of state and federal partners, including DOJ/Asset Forfeiture and Money Laundering Section, U.S. Attorneys' offices, State Department, Securities and Exchange Commission, Federal Reserve Board, Office of the Comptroller of the Currency, Federal Deposit Insurance Corporation, Consumer Financial Protection Bureau, Financial Industry Regulatory Authority, and the Conference of State Bank Supervisors. Prior to serving as Enforcement Director, Ms. Brooker served as Chief of Staff and Senior Advisor to the Director of FinCEN.
Ms. Brooker served from 2005 to 2012 as an Assistant U.S. Attorney in the U.S. Attorney's Office for the District of Columbia, where she served as the first Chief of the new Asset Forfeiture and Money Laundering Section from 2010 to 2012. This Section was responsible for all asset forfeiture and money laundering issues in Criminal Division cases and for litigation of civil forfeiture cases. In this role, she investigated and prosecuted complex civil and criminal forfeiture cases involving high-priority enforcement areas, such as national security, sanctions violations, and major financial fraud. She established the USAO's first DC Financial Crimes Task Force and supervised the investigation and prosecution of BSA and money laundering cases. In 2012, she received the U.S. Attorney's Award for Creativity and Innovation in Management. She was awarded three Special Achievement Awards for Superior Performance and the Office's Criminal Division Award.
Ms. Brooker clerked for Judge Diana Gribbon Motz of the U.S. Court of Appeals for the Fourth Circuit and for Judge James Robertson of the U.S. District Court for the District of Columbia. She also worked in private practice as an appellate litigation associate at an international law firm. She graduated magna cum laude in 2001 from Georgetown University Law Center, where she served as Managing Editor of Georgetown Law Journal and was elected to the Order of the Coif. She graduated with highest distinction from Northwestern University with a B.S. in Journalism in 1996. She was also selected as a Harry S. Truman Scholar.
Ms. Brooker serves as Treasurer of the Board of Directors of the Robert A. Shuker Scholarship Fund. Ms. Brooker is admitted to practice in the District of Columbia.
Representing foreign bank and Board of Directors in connection with regulatory actions by the Federal Reserve Board and New York Department of Financial Services
Representing national banks in connection with investigations regarding U.S. Bank Secrecy Act/anti-money laundering and OFAC compliance programs, as well as other potential regulatory and criminal issues, involving the banking regulators, DOJ, and OFAC
Representing non-bank financial institutions in connection with Department of Justice criminal investigations
Representing individuals in connection with Department of Justice criminal investigations
Representing broker dealer in connection with regulatory investigation by the Financial Industry Regulatory Authority (FINRA)
Providing Bank Secrecy Act and anti-money laundering compliance advice and corporate deal due diligence to wide range of banks, broker dealers, private equity and hedge funds, non-bank financial institutions (i.e. money service businesses and casinos), insurance companies, technology companies, hotels, and other multi-national companies
Conducting internal investigations for financial institutions and multi-national companies involving potential money laundering and other criminal allegations
Representing clients in criminal and civil asset forfeiture matters
Recent Speaking Engagements*
Institute of International Bankers Association, "Supervisory Developments Regarding BSA/AML and OFAC Compliance" (2017)
Verafin, Annual Bank Secrecy Act/Anti-Money Laundering Conference (October 2017)
Florida International Bankers Association (FIBA), "Lessons learned from the U.S. Treasury's recent enforcement actions against financial institutions in the region" (2017)
Investment Adviser Association, Compliance Conference, AML Panel (2017)
Gibson Dunn Webcast: Challenges in Compliance and Corporate Governance (2017)
Practicing Law Institute, Hedge and Private Fund Enforcement & Regulatory Developments 2016, "Hot Button Enforcement Issues for Private Funds" (2016)
ABA/ABA Money Laundering Enforcement Conference, "Hot Legal Cases and Enforcement Actions: How They Impact Your AML/Fraud Program" (2016)
Institute of International Bankers Association, "Supervisory Developments Regarding BSA/AML and OFAC Compliance" (2016)
New York State Society of Certified Public Accountants, "BSA Challenges for Registered Investment Advisors" (2016)
Deloitte Financial Crime Symposium, 10th Annual US Anti-Money Laundering Compliance Conference, "A Financial Institution Under Criminal Investigation -- Strategic Issues" and "Update from the Regulators and Law Enforcement" (2016)
ABA, Criminal Justice Section, "Anti-Money Laundering Issues Panel" (2016)
SandPiper Partners, "Financial Crime Summit: Convergence Trends—From the Regulatory, Enforcement & Industry Perspective Conference" (2016)
Hudson Institute and Gibson, Dunn, and Crutcher: "Kleptocracy: Fighting It and Avoiding It." (2016)
Panel Presentation, "Recent Developments in Anti-Money Laundering Enforcement," American Bar Association, 30th Annual Institute on White Collar Crime (2016) *
Panel Presentation, "Money Laundering Enforcement Trends," Wall Street Journal (2016) *
Panel Presentation, "Enforcement Trends and Takeaways," Anti-Money Laundering and Financial Crimes Conference, Securities Industry and Financial Markets Association (2016) *
Keynote Speaker, Puerto Rico Bankers Association Annual Money Laundering Symposium (2016) *
Keynote Speaker, Bank Secrecy Act Conference, State Bar of Nevada Gaming Law Section, published remarks available at https://www.fincen.gov/news_room/testimony/ (2015) *
Panel Presentation, "Spotlight on Women Power Players in Government: Shaping the Future of Financial Services Law," Women Leaders in Financial Services Industry Law, American Conference Institute (2015) *
Panel Presentation, Legal and Legislative Issues Conference, Financial Markets Association (2015) *
Keynote Speaker, Advanced BSA/AML Specialists Conference, Federal Financial Institutions Examination Council (2014 and 2015) *
Panel Presentation, "White Collar Crime 2014: Prosecutors and Regulators Speak," Practicing Law Institute*
Panel Presentation, Risk Management and Regulatory Examination/Compliance Seminar, Institute of International Bankers (2014) *
Panel Presentation, "Virtual Currency Overview," Edward Bennett Williams Inn of Court (2014) *
Panel Presentation, "AML Enforcement," Women in Housing and Finance (2014) *
Panel Presentation, Annual AML and Financial Crime Conference, Association of Certified Anti-Money Laundering Specialists (2013) *
*Engagements prior to joining Gibson, Dunn & Crutcher