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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 FinTech and Digital Assets Financial Institutions Global Financial Regulatory Litigation National Security Privacy, Cybersecurity and Data Innovation Securities Enforcement Securities Litigation Securities Regulation and Corporate Governance 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 firm’s White Collar Defense and Investigations, the Financial Institutions, and the Anti-Money Laundering Practice Groups.  As a prosecutor, Ms. Brooker tried 32 criminal trials, investigated a broad range of white collar and other federal 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 consistently recognized as a leading practitioner in the areas of white collar criminal defense and anti-money laundering compliance and enforcement defense.  Chambers USA has ranked her and described her as an “excellent attorney,” who clients rely on for “important and complex” matters, and noted that she provides “excellent service and terrific lawyering.”  Ms. Brooker has also been named a National Law Journal White Collar Trailblazer, a Global Investigations Review Top 100 Women in Investigations, and an NLJ Awards Finalist for Professional Excellence—Crisis Management & Government Oversight.

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); digital assets and fintech; securities, tax, and wire fraud, foreign influence; work place misconduct/“me-too”; 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 Zoom in DOJ investigations and SEC investigation
  • Representing Binance in U.S. agency matters
  • Representing Brazilian manufacturing company and CEO in DOJ sanctions investigation
  • Representing public company executive in DOJ narcotics and money laundering investigation
  • Representing public financial services company in investigation by SEC involving compliance and whistleblower allegations
  • Representing cryptocurrency companies in DOJ and FinCEN investigations
  • Representing global bank in investigations by SEC, FINRA, and FinCEN involving sanctions, corruption, and money laundering allegations
  • Representing public company in investigation by DOJ Public Integrity section, U.S. Attorney’s Office, and state regulator involving public corruption and money laundering allegations
  • Representing global bank in investigation involving allegations of corruption, insider trading, tax fraud, and money laundering violations by DOJ, 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, 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
  • 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
  • Providing Bank Secrecy Act and anti-money laundering compliance advice and corporate deal due diligence to banks, broker dealers, digital assets and fintech companies, private equity and hedge funds, money service businesses, casinos, insurance companies, technology companies, hotels, and other multi-national companies
  • Serving as testifying expert for Canadian Government’s Cullen Commission of Inquiry into Money Laundering in British Columbia
  • Conducting internal investigations for multi-national companies and financial institutions involving wide range of potential issues

Recent Speaking Engagements

  • Gibson Dunn Webcast: “Bank Secrecy Act/Anti-Money Laundering and Sanctions Enforcement and Compliance Update” (2023)
  • American Bar Association: “A New Regime of Transparency: Anti-Money Laundering Act of 2020, the Corporate Transparency Act, and Expansion of Cryptocurrency Reporting”  (2021)
  • 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 (2019-2021)
  • Gibson Dunn Webcast: Anti-Money Laundering and Sanctions Enforcement and Compliance (2018-2021)
  • 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, 2019, 2022)
  • Verafin, Annual Bank Secrecy Act/Anti-Money Laundering Conference (2017 and 2021)
  • 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 - April 25, 2023 | FSOC Proposes Overhauling Its Standards for Designating Nonbank Companies as Systemically Important
Webcasts - February 28, 2023 | Webcast: Bank Secrecy Act / Anti-Money Laundering and Sanctions Enforcement and Compliance Update
Client Alert - October 3, 2022 | From the Broader Perspective: Deputy Attorney General Announces Additional Revisions to DOJ’s Corporate Criminal Enforcement Policies
Client Alert - May 20, 2022 | International Comparative Legal Guide to: Anti-Money Laundering 2022
Client Alert - May 5, 2022 | CFPB Invokes Dormant Dodd-Frank Authority to Regulate Nonbank Financial Companies
Webcasts - March 30, 2022 | Webcast: Corporate Compliance and Sentencing Guidelines
Client Alert - March 10, 2022 | The Biden Administration’s Digital Assets Executive Order and Its Implications
Webcasts - January 19, 2022 | Webcast: Bank Secrecy Act / Anti-Money Laundering and Sanctions Enforcement and Compliance in 2022 and Beyond
Client Alert - December 13, 2021 | U.S. Strategy on Countering Corruption Signals Focus on Enforcement
Webcasts - November 30, 2021 | Webcast: Global Regulatory Developments and What to Expect Across the Globe (US/UK/EU)
Client Alert - October 29, 2021 | Deputy Attorney General Announces Important Changes to DOJ’s Corporate Criminal Enforcement Policies
Webcasts - October 18, 2021 | Webcast: Negotiating Closure of Government Investigations: NPAs, DPAs, and Beyond
Client Alert - June 17, 2021 | China Constricts Sharing of In-Country Corporate and Personal Data Through New Legislation
Client Alert - May 28, 2021 | International Comparative Legal Guide to: Anti-Money Laundering 2021
Article - May 26, 2021 | The Anti-Money Laundering Act of 2020’s Corporate Transparency Act
Client Alert - January 1, 2021 | The Top 10 Takeaways for Financial Institutions from the Anti-Money Laundering Act of 2020
Webcasts - December 10, 2020 | Webcast: International Anti-Money Laundering and Sanctions Enforcement
Webcasts - November 16, 2020 | Webcast: Corporate Compliance and Sentencing Guidelines
Webcasts - October 1, 2020 | Webcast: Negotiating Closure of Government Investigations: NPAs, DPAs, and Beyond
Webcasts - June 24, 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
Publications - 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 29, 2020 | Economic and Trade Sanctions Developments in Response to COVID-19
Client Alert - April 27, 2020 | The Federal Financial Institutions Examination Council Issues Revisions to the BSA/AML Examination Manual
Client Alert - April 21, 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 9, 2020 | Developments in the Defense of Financial Institutions – The International Reach of the U.S. Money Laundering Statutes
Client Alert - January 8, 2020 | 2019 Year-End Update on Corporate Non-Prosecution Agreements and Deferred Prosecution Agreements
Client Alert - January 6, 2020 | 2019 Year-End FCPA Update
Webcasts - June 11, 2019 | Webcast: Negotiating Closure of Government Investigations: NPAs, DPAs, and Beyond
Webcasts - May 21, 2019 | Webcast: Anti-Money Laundering and Sanctions Enforcement and Compliance in 2019 and Beyond
Publications - 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 12, 2018 | Developments in the Defense of Financial Institutions
Client Alert - June 14, 2018 | Revisions to the FFIEC BSA/AML Manual to Include the New CDD Regulation
Publications - June 5, 2018 | The International Comparative Legal Guide: Anti-Money Laundering 2018
Firm News - June 1, 2018 | Stephanie Brooker Named Among GIR’s Top Women in Investigations 2018
Webcasts - May 3, 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
Webcasts - January 24, 2018 | Webcast – Challenges in Compliance and Corporate Governance -14th Annual Briefing
Webcasts - November 1, 2017 | Webcast: IPO and Public Company Readiness: Regulatory Compliance Issues
Webcasts - 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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