Lawyers

Sharon Cohen Levin is a partner in the Firm’s Litigation Group and a member of its Criminal Defense and Investigations Group. She is a leading expert in anti-money laundering (AML), Bank Secrecy Act, economic sanctions and asset forfeiture matters. She represents a diverse group of clients, including financial institutions, multinational companies, and individuals in connection with criminal, regulatory, and civil enforcement actions. Her practice focuses on white collar and regulatory enforcement defense, internal investigations, and compliance counseling.

Sharon also represents collectors, dealers, non-profit organizations, universities, financial institutions, galleries and auction houses 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. She has represented individuals, families, and governments with respect to the recovery of stolen art and cultural property, and has represented collectors in responding to claims by cultural ministries and foreign governments.

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. Her track record of success inspired Forbes to call her “The Babe Ruth of Forfeiture.”

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. Sharon 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.

As an internationally renowned leader in her field, Sharon has provided training to U.S. and foreign governments 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.

Chambers USA notes that clients view Sharon as a “a highly valued practitioner” and “a real expert in her field.”

Speaking Engagements

• Panelist, “Former Government Officials Offer Insights into the Evolving Regulatory Landscape,” AML & OFAC Compliance for the Insurance Industry, American Conference Institute (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, "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, New York Council of Defense Lawyers Spring Lunch (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, “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, “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

• “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 Know-how Guide: Introduction and U.S. Section,” Global Investigations Review (December 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, 2019)
• “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)

SELECTED REPRESENTATIONS

 In private practice, Ms. Levin has represented high-profile clients on their most complex and sensitive matters. These representations include:

• Goldman Sachs in reaching coordinated resolutions in multiple criminal and regulatory investigations in jurisdictions around the world relating to an alleged multi-billion dollar money laundering and corruption scheme involving the Malaysia sovereign development company, 1MDB, and senior public officials in Malaysia and the United Arab Emirates, including a deferred prosecution agreement with the DOJ and resolutions with the government of Malaysia, the SEC, Federal Reserve, New York DFS, and regulators in the UK, Hong Kong and Singapore
• A global money service business in a regulatory investigation and resolution with NY State Department of Financial Services
• A global financial institution in a DOJ Panama Papers money laundering investigation
• A daily fantasy sports business in criminal and asset forfeiture investigations by multiple U.S. Attorney’s Offices
• A global financial institution in an investigation by DOJ’s Consumer Protection Section
• A major financial institution in a BSA/AML investigation by FinCEN, SEC and FINRA 
• A multinational company in connection with the DOJ FIFA prosecution
• An international art dealer in connection with a DOJ fraud investigation
• An auction house in connection with congressional investigation related to the art market
• Multiple major financial institutions in criminal and regulatory investigations relating to money laundering, sanctions and BSA/AML violations
• Multiple individuals in criminal and asset forfeiture investigations and prosecutions
• The family of Roman Totenberg in the recovery of the Ames Stradivarius – a rare violin stolen following a 1980 performance