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Stephanie  Brooker

Stephanie Brooker

Gibson Dunn & Crutcher LLP
Washington, DC, USA

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 a member of the Financial Institutions and White Collar Defense and Investigations Practice Groups. As a prosecutor, Ms. Brooker tried 32 criminal trials, 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’s practice focuses on compliance counseling, internal investigations, regulatory enforcement, and white-collar criminal defense.

Ms. Brooker’s practice will include representing financial institutions in connection with regulatory, civil and criminal enforcement actions and in responding to regulatory examinations involving compliance with anti-money laundering (“AML”) laws and regulations, including the Bank Secrecy Act, as amended by the USA PATRIOT Act (“BSA”), and the economic sanctions programs administered and enforced by the U.S. Department of the Treasury's Office of Foreign Assets Control.  She will focus on assisting financial institution holding companies, domestic and multinational banks, securities broker- dealers, investment companies, insurance companies, finance companies, money services businesses, financial technology companies, casinos, other financial services businesses, and multinational corporations in developing, enhancing and implementing risk-based AML compliance programs, customer due diligence and enhanced due diligence policies and procedures, and procedures for identifying and reporting suspicious activity.

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, securities, 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, 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.  In this role, she worked on complex issues, such as FinCEN’s reorganization, strategic planning, BSA enforcement, policy determinations and implementation, rulemakings, guidance, advisories, and regulatory priorities.  During her tenure at FinCEN, Ms. Brooker worked on a range of substantive issues, including cyber- related threats to financial institutions, terrorist financing, and compliance with FATF standards.

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. During her tenure in the U.S. Attorney’s Office, she tried 32 criminal trials. She also briefed and argued appeals in federal and state appellate courts. 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.

Ms. Brooker is admitted to practice in the District of Columbia. 

Recent Speaking Engagements*

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


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