Sharon Cohen Levin

Sharon Cohen Levin is Co-Head of the Firm’s National Security Practice and a partner in the Firm’s Litigation Group and Criminal Defense and Investigations Group. She is a leading expert in anti-money laundering (AML), Bank Secrecy Act, economic sanctions and asset forfeiture matters. Through her decades of experience in the U.S. government and frequent collaboration with federal authorities, Sharon has a deep familiarity with the policies and systems that impact U.S. national security. She leverages this familiarity with her expertise in cross-border economic activities to help clients resolve complex and politically sensitive issues. Multinational firms routinely call on Sharon for her ability to craft strategies tailored to both their strategic desires and the evolving perspectives of national security and defense agencies.

Sharon represents a diverse group of clients, including financial institutions, multinational companies, and individuals, primarily in white-collar and regulatory enforcement defense, internal investigations, and compliance counseling. She also represents collectors, dealers, non-profit organizations, universities, financial institutions, galleries, auction houses and governments on a variety of matters related to the art market, including issues of ownership, theft, fraud, authenticity and breach of contract, as well as in criminal investigations and asset forfeiture proceedings.

Sharon is a former federal prosecutor and led the Money Laundering and Asset Forfeiture Unit in the U.S. Attorney’s Office for the Southern District of New York for two decades. Under her leadership, the SDNY was responsible for nearly 60% of all forfeitures in the United States, with most of the proceeds remitted to victims of crimes. She led multiple significant prosecutions under the AML, economic sanctions and asset forfeiture laws, working hand in hand with federal and state banking regulators, the Office of Foreign Asset Control, and other investigative and regulatory authorities. She was the lead prosecutor responsible for securing a settlement in the watershed “Portrait of Wally” forfeiture case, which centered on an oil painting stolen by Nazis from a Jewish woman in 1938—a story that was later made into a documentary. Her track record of success inspired Forbes to call her “The Babe Ruth of Forfeiture.”

As an internationally renowned leader in her field, Sharon has provided training to U.S. and foreign governments and private and public companies and served on numerous occasions as a keynote speaker, panelist or lecturer at events related to money laundering, asset forfeiture, AML compliance, terrorist financing, and other related topics.

“She is an extraordinary lawyer and brilliant strategist, always knows what to say and can get anyone on side.” – Chambers USA

“Sharon Cohen Levin is pragmatic and gives actionable advice. Her judgment is impeccable. She has her pulse on the industry and is always looking forward at emerging risks.” – Chambers USA

Speaking Engagements

• Moderator, “National Security and the Blockchain,” National Security, Sanctions, & Export Controls, Sandpiper Partners (2024)
• Panelist, “FinCEN's Beneficial Ownership,” West Coast Anti-Money Laundering Forum (2024)
• Panelist, “Persistence of Memory: Nazi Confiscated Art and Its Recovery,” Art, Finance, and Law Project, Berkeley Center for Law and Business (2024)
• Panelist, “Expert Panel on Corporate Enforcement Policy for Export Control Violations,” “Program on Corporate Voluntary Self-Disclosure Policies for Export Control Violations,” NYU School of Law (2024)
• Panelist, “Combatting Geo-Cloaking Threats: AML and Sanctions Compliance Strategies,” GeoComply Webinar (2024)
• Panelist, “Explaining Explainability: Decoding AI for AML,” Napier Technologies, Disrupting Fincrime (2023)
• Panelist, “Senior Executive Roundtable: Perspectives on the Biggest Risks and Grey Areas of Financial Crime Compliance,” ACI’s Second Forum on Digital Assets Compliance: AML, Sanctions and Regulatory Oversight (2023)
• Panelist, “In a Perfect World: What Would Due Diligence Look Like?,” Un-Titled: The Case for Creating an International Title Registry for Art symposium presented by The Art Loss Register (2023)
• Panelist, “International Fraud and Money Laundering in the Art World,” Berkeley Art, Finance, and Law Symposium, Berkeley Center for Law and Business (2023) 
• Co-Chair, “Risk Regulation and Enforcement in FinTech,” Cambridge Forum (2023)
• Moderator, “WSN Members Provide Key Compliance Takeaways from Implementing Russian Sanctions – and How to Better Prepare for the Next Phase,” ACI 17th Annual Flagship Conference on U.S. Economic Sanctions Enforcement and Compliance Conference (2023)
• Panelist, “Former Government Officials Offer Insights into the Evolving Regulatory Landscape,” ACI AML & OFAC Compliance for the Insurance Industry (2023)
• Panelist, “Behind the Scenes View of Seizing Russian Oligarch Assets,” American Conference Institute’s New York Forum on Economic Sanctions (2022)
• Panelist, “Global Enforcement Trends,” New York City Bar Association International White Collar Crime Symposium (2022)
• Panelist, “Cultural Heritage, Law Enforcement and Antiquities Seizures,” New York County Lawyers Association’s Art Law Institute: New Insights in Art Law (2022) Speaker, “EU and US Sanctions: Impact on the Trust Industry,” Cambridge Forum on International Wealth Disputes (2022)
• Panelist, “Sanctions & Kleptocracy,” Nardello & Co.’s Risk Advisory & Compliance Summit (2022)
• Panelist, “It Comes with the Territory: Keeping Up with Sanctions and Emerging Geopolitical Risks,” ACAMS AML Risk Management & Securities Summit (2022)
• Panelist, “The spectre of anti-money-laundering enforcement and related developments,” GIR Anti-Corruption & Investigations Mexico (2022)
• Panelist, New York Council of Defense Lawyers Spring Lunch (2022)
• Panelist, “Money Laundering, the use of shell companies, virtual assets and other emerging technologies to launder the proceeds of crime and the risks for U.S. businesses and professionals,” NYSSCPA Business Valuation and Litigation Services Conference (2022)
• Panelist, “High Times: Navigating Compliance Intricacies for High-Risk Merchants Amid Transformational Growth,” Electronic Transactions Association (ETA) Transact (2022)
• Panelist, “Dazed & Confused: Evolving Cannabis Regulations and Risk,” SIFMA C&L Annual Seminar (2022)
• Panelist, Baker McKenzie’s Litigation/Regulatory Enforcement Roundtable (2022)
• Panelist, “Understanding the Business Side of Ransomware,” American Bankers Association and American Bar Association’s 2022 Financial Crimes Enforcement Conference (2022)
• Panelist, “Hot Topics in Regulatory Compliance Enforcement,” IIB 2021 Regulatory Compliance Seminar (2021)
• Panelist, “A Hard Plea Bargain: Pleas, Bail, and Forfeiture,” National Association of Criminal Defense Lawyers’ 2021 White Collar Seminar (2021)
• Panelist, “Dawn of a New Era: What does collaboration in AML Risk Management look like?”, Pegasystems Webinar (2021)
• Panelist, “Legislative and Regulatory Update: The Future of BSA/AML,” PLI Anti-Money Laundering 2012: Risks, Due Diligence and Compliance in an Evolving Legal World Webinar (2021)
• Panelist, North American Gaming Regulators Association (NAGRA) Real World Compliance Challenges in AML and KYC (2020)
• Panelist, “KYC and AML for iGaming and Online Sports Betting – Laws, Processes and Technologies,” GeoComply Webinar (2020)
• Panelist, “A Budding Industry: The Compliance, Legal, and Political Landscape of Cannabis and Hemp in 2020,” SIFMA C&L Future Leaders Forum (2020)
• Panelist, SIFMA AML and Financial Crime Conference (2020)
• Panelist, “Marijuana, Hemp, and CBD: Creating Your Firm’s Policy,” SIFMA Anti-Money Laundering & Financial Crimes Conference (2020)
• Panelist, “Corruption and Money Laundering in the Art World,” Center for the Advancement of Public Integrity: Global Cities III (2019)
• Speaker, Forum on Sanctions & AML Compliance (2019)
• Panelist, “Current Development in AML,” SIFMA Compliance and Legal Society Annual Seminar (2019)
• Speaker, American Gaming Association and PwC 4th Annual Anti-Money Laundering Summit (2019)
• Moderator, “Enforcement Trends in Insurance Regulation,” American Conference Institute’s 9th Annual Forum on AML & OFAC Compliance for the Insurance Industry (2019)
• Speaker, “Increased Attention on AML/Sanctions and Due Diligence,” 9th Annual New York Forum on Economic Sanctions (2018)
• Panelist, “Do You Know Where Your OFAC Is? Sanctions and More,” ABA/ABA Financial Crimes Enforcement Conference (2018)

Video Recording/Podcasts

• Episode 5: “The Lion,” Dynamite Doug (March 29, 2023), available at https://dynamitedoug.com/episodes/the-lion/
• “Supreme Court Business Review: Cassirer v. Thyssen-Bornemisza Collection Foundation,” S&C Critical Insights (August 15, 2022), available at https://www.sullcrom.com/insights/videos-and-podcasts/2022/August/SC-Critical-Insights-Supreme-Court-Business-Review-Cassirer-v-ThyssenBornemisza-Collection-Foundation
• “Supreme Court Business Review: Federal Republic of Germany v. Philipp,” S&C Critical Insights (August 2, 2021), available at https://www.podbean.com/media/share/pb-8uqbe-10a5375
• Speaker “The Legal Framework for Retrieving Stolen Books: An International Case Study, Written Heritage Of Mankind In Peril” The Legal Framework for Retrieving Stolen Books conference at the British Library (June 26, 2015), available at https://soundcloud.com/the-british-library/podcast-written-heritage-of-mankind-in-peril-part-2
• Several Cash Withdrawals Triggered Investigation Into Former Speaker Hastert, NPR Podcast (May 29, 2015), available at https://www.npr.org/2015/05/29/410601323/several-cash-withdrawals-triggered-investigation-into-former-speaker-hastert
• Panelist “Asset Forfeiture and Bankruptcy Case Coordination” Training Video, Federal Judicial Center (2013), available at https://www.youtube.com/watch?v=kQlPZLpg6HE

Publications

• “Anti-Money Laundering Deskbook” Practising Law Institute, 2nd Edition (September 2023)
• “Introduction,” Global Investigations Review – The Guide to Anti-Money Laundering, 1st Edition (September 2023)
• “Money Laundering through Digital Assets,” Global Investigations Review – The Guide to Anti-Money Laundering, 1st Edition (September 2023)
• “DOJ, BIS and OFAC Release Guidance on Voluntary Self-Disclosures,” NYU Compliance & Enforcement Blog (July 31, 2023)
• “Anti-money Laundering Know-how Guide: Introduction and U.S. Section,” Global Investigations Review (December 2, 2022)
• “Treasury Study on Illicit Finance in the High-Value Art Market,” NYU Compliance & Enforcement Blog (March 2, 2022)
• “Chapter 155, Money Laundering,” Business and Commercial Litigation in Federal Courts, 5th Edition, Volume 1 (2021)
• “FinCEN Notice on Efforts Related to Trade in Antiquities and Art,” NYU Compliance & Enforcement Blog (March 26, 2021)
• “FinCEN Guidance in Response to COVID-19,” NYU Compliance & Enforcement Blog (March 20, 2020)
• “Anti-Money Laundering and Sanctions: Trends and Developments Emerging Under the Trump Administration,” NYU Compliance & Enforcement Blog (July 25, 2019)
• “Financial Institutions Alert: Marijuana-Related Businesses Developments in the Marijuana Industry and the Implications for Financial Institutions,” NYU Compliance & Enforcement Blog (February 19, 2019)
• “Developments in the Marijuana Industry and the Implications for Financial Institutions,” JD Supra (February 8, 2019)
• “FinCEN Releases Frequently Asked Questions Regarding Customer Due Diligence and Beneficial Ownership Requirements,” NYU Compliance & Enforcement Blog (April 13, 2018)
• “US Regulation of Cryptocurrency as a Type of Financial Technology,” The International Comparative Legal Guide to Fintech 2018, (June 6, 2018)
• “FinCEN Launches New Information-Sharing Platform: The FinCEN Exchange,” NYU Compliance & Enforcement Blog (December 26, 2017)
• “U.S. Buyer of Looted Antiquities Pays Steep Price to U.S. Government: Hobby Lobby Forfeits Thousands of Ancient Iraqi Artifacts, Pays $3M, and Admits Fault To Settle Civil Forfeiture Action,” NYU Compliance & Enforcement Blog (July 13, 2017)
• “Supreme Court Substantially Reduces Government’s Ability to Seek Criminal Forfeitures,” NYU Compliance & Enforcement Blog (June 5, 2017)
• “Kleptocrats in the Crosshairs,” NYU Compliance & Enforcement Blog (July 13, 2016)
• “Implications of the EU General Data Privacy Regulations for U.S. Anti-Money Laundering and Economic Sanctions Compliance,” The International Comparative Legal Guide to Anti-Money Laundering 2018, 1st Edition, (Published by Global Legal Group Ltd.)
• “Anti-Money Laundering Enforcement: The Rise of Individual Liability for Compliance Professionals, Taxation and Regulation of Financial Institutions,” Volume 31, Number 4, Summer 2018
• “The Convergence of AML and Cybersecurity, Duff & Phelps,” GRO Viewpoint (2017)
• “AML and Sanctions Reform: A Safe Harbor Proposal, Banking Perspectives, The Quarterly Journal of the Clearing House, Quarter 3, 2016,” Volume 4, Issue 3
• “Ninth Circuit Applies the Holocaust Expropriated Art Recovery Act of 2016 to Revive Previously Dismissed Nazi-Era Art Appropriation Case,” JD Supra (August 4, 2017)
• “Hobby Lobby Forfeits Thousands of Ancient Iraqi Artifacts, Pays $3M, and Admits Fault to Settle Civil Forfeiture Action,” JD Supra (July 14, 2017)
• “AML And Sanctions: 2017 Trends And Developments,” mondaq.com (April 27, 2017)