Kathleen H. Shannon

Biography

Kathleen Shannon draws on her uniquely broad experience in government and private practice to help clients navigate fast-moving U.S. legal, policy, and regulatory risks involving international trade, national security, and white-collar crime. Kathleen provides experienced and steady guidance to clients facing challenging situations, including novel and sensitive cross-border investigations and compliance matters.

In the area of trade sanctions and export controls, Kathleen has advised and defended targets of investigations and sanctions designations in several countries and across sectors including financial services, defense, maritime, energy, technology, and nonprofits. She has guided internal investigations and compliance programs for global businesses, bringing a practical and commercial approach to reducing clients’ risk. She represents companies and individuals at all stages of engagement with the Office of Foreign Assets control (“OFAC”)—including compliance, licensing, guidance, enforcement, and delisting, and handles complex civil and criminal investigations and litigation before the U.S. Departments of Justice, State, Commerce, Treasury, and Defense, and other agencies.

Kathleen also represents clients in other areas at the intersection of global trade and security, including U.S. Trade Representative investigations, Committee on Foreign Investment in the United States (“CFIUS”) compliance, and emerging U.S. investment controls, providing clients a pragmatic mix of legal and policy-related advice and counsel. Kathleen’s white-collar defense practice also includes investigations and enforcement actions involving fraud, bribery, corruption, and anti-money laundering measures, with experience in industries such as automotive, pharmaceuticals, and financial services.

Government and Internal Investigations

Kathleen has conducted investigations, risk assessments, and compliance reviews in more than 30 countries. She manages domestic and cross-border internal and government investigations and compliance reviews, including significant matters involving violations of economic sanctions and export controls, corporate and government program fraud, and bribery and corruption.

Compliance Planning and Controls

Kathleen advises clients on all aspects of compliance measures including program and policy design, implementation, employee and executive training, monitoring, testing, and auditing. She develops company-wide policies and procedures that are tailored to the client’s needs and aligned with overall business objectives. She also advises clients on day-to-day compliance issues that arise related to supply chain concerns and general operational and transactional diligence.

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 the Currency, Commodity Futures Trading Commission, and 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 Senior Advisor and Counsel in the Executive Office of the President, where she focused on legal compliance, internal controls, and investigations, providing guidance and support to more than 25 offices operating within the White House. She also served as counsel for the U.S. Senate Homeland Security and Governmental Affairs Committee’s Permanent Subcommittee on Investigations. Kathleen began her legal career in the Washington, D.C., office of an international law firm, where she handled white-collar and international trade matters, and she previously worked as a broadcast journalist in Virginia.

Experience

Conducted a comprehensive risk assessment and internal lookback for a foreign chemical manufacturing company related to U.S. economic sanctions on Iran in response to a joint inquiry from OFAC and the U.S. State Department.
Counseled a U.S- based international restaurant franchisor on issues with Latin America franchisee involving OFAC and State Department Magnitsky sanctions.
Successfully represented individuals and companies in filing petitions for removal from OFAC and State Department sanctions lists.
Successfully represented foreign companies and nonprofits in applying for and receiving specific licenses from OFAC to engage in conduct otherwise prohibited by U.S. sanctions.
Represented U.S. corporation in internal investigation of potential trade sanctions and export control violations by its European and Middle Eastern subsidiaries.
Represented an international tobacco company in connection with DOJ investigation for alleged violations of North Korea economic sanctions.
Represented a senior engineer in DOJ investigation related to alleged theft of trade secrets and violations of IEEPA/export controls related to laser fiber technology.
Conducted series of export control audits for defense contractor; then assisted with developing comprehensive export/import and sanctions/AML compliance program required by settlement and consent agreements.
Conducted global internal investigation of alleged export controls and bribery and corruption for a defense contractor related to conduct in Europe, the United States, and the Middle East.
Counseled a U.S.-based defense contractor on how to respond to whistleblower allegations of bribery and corruption involving U.S. employees working in the Middle East and Asia; managed subsequent internal investigation and comprehensive expense report audit and reviews.
Conducted post-acquisition due diligence review on a condensed 120-day timeline for a pharmaceutical company related to bribery and corruption risks in Latin America, Europe, and Asia.
Conducted an internal investigation of potential FCPA violations for a global manufacturer of high-technology military and police products.
Conducted FCPA risk assessment for a consumer products company focused on operations across Africa.
Advised a Latin American subsidiary of a French retail/consumer products company on FCPA/UKBA risk exposure.
Represented a foreign automotive engineering company in a DOJ/EPA investigation and subsequent settlement involving allegations of conspiracy to defraud the U.S. government.
Defended a government contractor in connection with False Claims Act investigation of alleged government overpayments related to military/police products.
Represented a large financial institution in connection with multiple federal and state investigations relating to sales practices and consumer protection laws.
Represented a large financial institution in connection with CFPB investigation related to alleged violations of FIRREA and RESPA kickback prohibitions, resulting in formal declination to initiate an enforcement action.
Represented individual in DOJ investigation related to allegations of insider trading where DOJ ultimately declined to pursue charges.
Represented large pharmaceutical distributor in connection with an opioid-related investigation by the House Committee on Energy & Commerce and prepared witnesses for oversight hearing.
Served on U.S. defense counsel team representing international humanitarian aid organization in United States Agency for International Development (“USAID”) OIG investigation related to alleged misuse of U.S. grant funds in Syria and South Sudan.
Counseled multiple clients on obligations under Foreign Agents Registration Act (“FARA”); prepared and submitted required filings to DOJ throughout years-long representation; represented clients in related DOJ inquiries and information requests.
Counseled incoming and former high-level government officials on issues related to ethics, financial disclosures, and lobbying.