Kathleen Shannon represents corporate and individual clients in complex criminal and civil matters. She helps clients navigate high-stakes matters related to U.S. laws and regulations on economic sanctions, export controls, bribery and corruption, and anti-money laundering. She crafts strategic responses to government inquiries and investigations and strives to effectively mitigate risk for her clients.
Kathleen’s practice is focused on white collar defense litigation, government investigations and enforcement actions, internal investigations, cross-border disputes, and advising clients on regulatory risks and the design, implementation, and maintenance of effective corporate compliance programs.
Government and Internal Investigations
Kathleen has conducted cross-border investigations, risk assessments, and compliance reviews in over thirty countries. She manages domestic and cross-border internal and government investigations and compliance reviews for a wide range of U.S. and international corporate clients, including significant matters involving economic sanctions and export controls, anti-money laundering laws, and bribery and corruption. Kathleen also advises clients in connection with whistleblower allegations and other corporate crisis issues.
Economic Sanctions and Export Controls
Kathleen represents companies and individuals at all stages of Office of Foreign Assets Control (“OFAC”) engagement, including compliance, licensing, guidance, enforcement, and delisting. She also handles complex civil and criminal sanctions and export-related investigations as well as settlement of enforcement actions before the U.S. Departments of Justice, State, Commerce, Treasury, and Defense, and related agencies.
Compliance Programs
Kathleen advises clients on all aspects of compliance programs, including design, implementation, monitoring, testing, and auditing. She drafts compliance policies, codes of conduct, and develops company-wide procedures tailored to the needs of the client and consistent with overall business objectives. She also conducts trainings for her clients, including trainings for officers, directors, and executives.
Transactional and Operational Due Diligence
Kathleen routinely performs compliance due diligence for mergers, acquisitions, joint ventures, equity investments, new market entry, and other transactions. She also advises clients on issues that arise related to supply chain or general operational diligence for counterparties, third party contractors, and vendors.
Funding and Financing
Kathleen counsels entities seeking funding from multilateral development banks on how to ensure corporate compliance programs and internal controls satisfy all representations and warranties, guaranties, and obligations under the applicable finance agreements.
She also advises startups and target companies on proactive design and implementation of tailored, risk-based compliance programs in anticipation of investor and buyer due diligence related to anti-bribery and corruption, economic sanctions and export controls, anti-money laundering, and other industry-specific risks.
Regulators and Investigative Authorities
Kathleen has experience representing clients before a broad range of regulators and enforcement officials, including the Department of Justice, Securities and Exchange Commission, Department of Treasury’s Office of Foreign Assets Control, Department of Commerce, Environmental Protection Agency, Consumer Financial Protection Bureau, Office of the Comptroller of Currency, Commodity Futures Trading Commission, Financial Industry Regulatory Authority, state attorneys general, and other domestic and foreign law enforcement officials and regulatory agencies. She has also represented various corporations and individuals in congressional investigations and inquiries.
Background
Kathleen previously served as counsel for the U.S. Senate Homeland Security and Governmental Affairs Committee’s Permanent Subcommittee on Investigations and served as senior advisor and counsel in the Executive Office of the President, where she focused on legal compliance, internal controls, and investigations. Kathleen began her legal career in the Washington, D.C., office of an international law firm, where she handled both complex securities litigation and white collar matters.
