Kathleen H. Shannon


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.


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.


  • 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. 



  • Women's White Collar Defense Association



  • District of Columbia
  • New York
  • U.S. District Court - District of Columbia
  • U.S. District Court - Eastern District of New York
  • U.S. District Court - Southern District of New York


  • University of Virginia, BA
  • University of Virginia School of Law, JD