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Profile Picture

Stephanie Brooker

Stephanie
Brooker

Partner

CONTACT INFO

sbrooker@gibsondunn.com

TEL:+1 202.887.3502

FAX:+1 202.530.4216

Washington, D.C.

1050 Connecticut Avenue, N.W., Washington, DC 20036-5306 USA

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PRACTICE

White Collar Defense and Investigations Administrative Law and Regulatory Practice Anti-Money Laundering Betting and Gaming Crisis Management Financial Institutions Litigation National Security Transnational Litigation

BIOGRAPHY

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 tried 32 criminal trials, investigated a broad range of white collar and other federal and state criminal matters, briefed and argued criminal appeals, and served as the Chief of the Asset Forfeiture and Money Laundering Section in the U.S. Attorney’s Office for the District of Columbia. Ms. Brooker has been named a National Law Journal White Collar Trailblazer and a Global Investigations Review Top 100 Women in Investigations.

Ms. Brooker’s practice focuses on internal investigations, regulatory enforcement defense, white-collar criminal defense, and compliance counseling. She handles a wide range of white collar matters, including representing financial institutions, multi-national companies, and individuals in connection with criminal, regulatory, and civil enforcement actions involving sanctions, anti-corruption, anti-money laundering (AML)/Bank Secrecy Act (BSA), securities, tax, and wire fraud, “me-too” matters, and other legal issues. She routinely handles complex cross-border investigations.  Ms. Brooker’s practice also includes BSA/AML and FCPA compliance counseling and deal due diligence and significant criminal and civil asset forfeiture matters.

Ms. Brooker’s investigations matters involve multiple government agencies, including the Department of Justice (DOJ), Securities and Exchange Commission (SEC), Federal Reserve Board (FRB), Office of Comptroller of the Currency (OCC), Federal Deposit Insurance Corporation (FDIC), Office of Foreign Assets Control (OFAC), New York Department of Financial Services (NYDFS), Financial Industry Regulatory Authority (FINRA), state banking agencies and gaming regulators, and foreign regulators.

Ms. Brooker served as an Assistant U.S. Attorney in the U.S. Attorney’s Office for the District of Columbia, where she served for many years as a trial attorney in Federal and Superior Court.  In the latter part of her tenure, she served as the first Chief of the new Asset Forfeiture and Money Laundering Section. 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. During her tenure, she received the U.S. Attorney’s Award for Creativity and Innovation in Management. She was also awarded three Special Achievement Awards for Superior Performance and the Office’s Criminal Division Award.

Ms. Brooker also 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. She also oversaw rulemaking actions under Section 311 of the PATRIOT Act against foreign institutions and jurisdictions, Geographic Targeting Orders, and examination and enforcement actions against cryptocurrency companies following FinCEN’s 2013 cryptocurrency guidance. Prior to serving as Enforcement Director, Ms. Brooker served as Chief of Staff and Senior Advisor to the Director of FinCEN.

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.

Recent Representations

  • Representing public company in investigation by DOJ Public Integrity section, U.S. Attorney’s Office, and state regulator
  • Representing public company in investigation by SEC involving compliance and whistleblower allegations
  • Representing public company in multiple DOJ investigations and SEC investigation
  • Representing global bank in investigation involving allegations of corruption, insider trading, tax fraud, and money laundering violations by DOJ Fraud Section, U.S. Attorney’s Office, SEC, and federal banking regulators
  • Conducting independent investigation for Board of Directors involving “me-too” allegations against Chief Executive Officer
  • Representing global bank in investigations by multiple DOJ components involving fraud and money laundering
  • Representing national bank in investigation involving sanctions allegations by DOJ, U.S. Attorney’s Office, OFAC, and federal banking regulators
  • Representing global bank in corruption and money laundering investigation by foreign regulator
  • Representing European bank Board of Directors in connection with DOJ and regulatory actions involving FCPA, Libor, BSA/AML, and sanctions
  • Representing Latin American manufacturing company in DOJ sanctions investigation
  • Serving as strategic enforcement counsel for multi-agency DOJ and federal banking regulatory enforcement actions against national bank
  • Serving as strategic enforcement counsel for major insurance company involving allegations of fraud, money laundering, and human trafficking
  • Representing individuals in connection with Department of Justice criminal investigations
  • Serving as outside compliance and enforcement advisory counsel to major trade association
  • 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 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 multi-national companies and financial institutions involving wide range of potential issues
  • Representing clients in criminal and civil asset forfeiture matters

Recent Speaking Engagements

ABA/ABA Financial Crimes Enforcement Conference, Advisory Board Member and  Panel Moderator and Speaker (2017-2020)

American Bar Association,  Annual Institute on White Collar Crime (2018), “Global Reach of Money Laundering Enforcement

Gibson Dunn Webcast: DPAs, NPAs, and Monitorships (2019-2020)

Gibson Dunn Webcast: Anti-Money Laundering and Sanctions Enforcement and Compliance (2018-2020)

Gibson Dunn Webcast: Challenges in Compliance and Corporate Governance (2017 and 2018)

Institute of International Bankers Association, “Supervisory Developments Regarding BSA/AML and OFAC Compliance” (2016-2020)

Securities Industry and Financial Markets Association, “Regulatory and Examination Priorities,” Anti-Money Laundering and Financial Crimes Conference (SIFMA) (2018 and 2019)

Verafin, Annual Bank Secrecy Act/Anti-Money Laundering Conference (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)

 

EDUCATION

Georgetown University - 2001 Juris Doctor

Northwestern University - 1996 Bachelor of Science

ADMISSIONS

District of Columbia Bar

RECENT PUBLICATIONS

Client Alert - January 3, 2021 | The Top 10 Takeaways for Financial Institutions from the Anti-Money Laundering Act of 2020
Publications - December 10, 2020 | Webcast: International Anti-Money Laundering and Sanctions Enforcement
Publications - November 17, 2020 | Webcast: Corporate Compliance and Sentencing Guidelines
Publications - October 2, 2020 | Webcast: Negotiating Closure of Government Investigations: NPAs, DPAs, and Beyond
Publications - June 25, 2020 | Webcast: Bank Secrecy Act/Anti-Money Laundering and Sanctions Enforcement and Compliance in 2020 and Beyond
Client Alert - May 21, 2020 | International Comparative Legal Guide to: Anti-Money Laundering 2020
Article - May 19, 2020 | The International Reach of the U.S. Money Laundering Statutes
Client Alert - May 18, 2020 | FinCEN Again Extends Its Geographic Targeting Order to Address Money Laundering Through Real Estate
Client Alert - May 11, 2020 | European Commission Launches Major AML Initiative
- April 30, 2020 | Economic and Trade Sanctions Developments in Response to COVID-19
Client Alert - April 28, 2020 | The Federal Financial Institutions Examination Council Issues Revisions to the BSA/AML Examination Manual
Client Alert - April 22, 2020 | The Impact of Coronavirus on the Operations of Financial Institutions: Key Guidance Issued by U.S. Financial Regulators
Client Alert - April 8, 2020 | Fraud in the COVID-19 Age: Examining and Anticipating Changing Enforcement Activity
Client Alert - January 10, 2020 | Developments in the Defense of Financial Institutions – The International Reach of the U.S. Money Laundering Statutes
Client Alert - January 9, 2020 | 2019 Year-End Update on Corporate Non-Prosecution Agreements and Deferred Prosecution Agreements
Client Alert - January 7, 2020 | 2019 Year-End FCPA Update
Publications - June 12, 2019 | Webcast: Negotiating Closure of Government Investigations: NPAs, DPAs, and Beyond
Publications - May 21, 2019 | Webcast: Anti-Money Laundering and Sanctions Enforcement and Compliance in 2019 and Beyond
Article - May 9, 2019 | To Disclose or Not to Disclose: Analyzing the Consequences of Voluntary Self-Disclosure for Financial Institutions
Client Alert - January 18, 2019 | Developments in the Defense of Financial Institutions – Calculating the Financial Exposure
Client Alert - July 13, 2018 | Developments in the Defense of Financial Institutions
Firm News - June 29, 2018 | Stephanie Brooker Named Among GIR’s Top Women in Investigations 2018
Client Alert - June 14, 2018 | Revisions to the FFIEC BSA/AML Manual to Include the New CDD Regulation
Publications - June 8, 2018 | The International Comparative Legal Guide: Anti-Money Laundering 2018
Publications - May 4, 2018 | Webcast: Anti-Money Laundering and Sanctions Enforcement and Compliance in 2018 and Beyond
Firm News - May 1, 2018 | Stephanie Brooker Named a White Collar Trailblazer
Client Alert - April 23, 2018 | FinCEN Issues FAQs on Customer Due Diligence Regulation
Publications - January 24, 2018 | Webcast – Challenges in Compliance and Corporate Governance -14th Annual Briefing
Publications - November 1, 2017 | Webcast: IPO and Public Company Readiness: Regulatory Compliance Issues
Publications - January 25, 2017 | Webcast: Challenges in Compliance and Corporate Governance
Client Alert - December 16, 2016 | The Comptroller’s Special Purpose Charter Proposal for Fintech: A Way Forward?
Client Alert - August 1, 2016 | FinCEN Expands Temporary Reporting Requirements on Title Insurance Companies for All Cash Luxury Real Estate Transactions to Six Major U.S. Areas
Client Alert - July 6, 2016 | Beneficial Ownership and Customer Due Diligence:  Perspectives on the Increased Compliance Risk Associated with the Implementation of FinCEN’s Final Rule
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