Sullivan & Cromwell

Sullivan & Cromwell LLP provides the highest quality legal advice and representation to clients worldwide. S&C’s record of success and unparalleled client service has set it apart for more than 130 years and made the firm a model for the modern practice of law. Today, it is a leader in each of its core practice areas and geographic markets. S&C advises a diverse range of clients on major domestic and cross-border M&A and corporate finance transactions, high-stakes litigation and corporate investigations and complex regulatory, tax and estate planning matters. S&C comprises approximately 875 lawyers who conduct a seamless, global practice through a network of 13 offices located in key financial centers in Asia, Australia, Europe and the U.S.



Aisling O’Shea

Aisling O’Shea is a Special Counsel in the Firm’s Litigation Group. Ms. O’Shea’s practice

focuses on criminal defense, government investigations and the Foreign Corrupt Practices

Act (“FCPA”).


Government Service

Ms. O’Shea re-joined the Firm in 2017 after five years of service as a trial attorney in the FCPA Unit of the Fraud Section of the U.S. Department of Justice’s Criminal Division, where she focused on the investigation and prosecution of corporations and individuals related to FCPA violations, money

laundering, securities and healthcare fraud, tax evasion and other complex economic crimes. Ms. O’Shea often handled active and covert investigations, pre-trial and grand jury proceedings, witness interviews and negotiated plea agreements. During her tenure at the Department of Justice, Ms. O’Shea led an investigation into corruption at Venezuela’s state-owned and controlled oil company and successfully prosecuted more than ten individuals, including several former Venezuelan officials, in connection with the investigation. The case, which won Homeland Security Investigation’s 2016 award for Outstanding Financial Investigation, resulted in the most individual convictions for a single

FCPA matter. Ms. O’Shea also successfully prosecuted two former financial executives, and reached a resolution with the financial institution, for conspiracy to commit securities and wire fraud.

Ms. O’Shea worked closely with every major U.S. Attorney’s Office and federal law enforcement agency, as well as other government agencies, including the U.S. Securities and Exchange Commission, FinCEN and the Office of Foreign Assets Control, and numerous foreign law enforcement and regulatory authorities. She has also helped conduct trainings for U.S. and foreign law enforcement authorities related to the FCPA and money laundering.




Selected Representations

  • Barclays in investigations by the Department of Justice, Commodity Futures Trading Commission, Securities and Exchange Commission, and UK Financial Conduct Authority related to the London Interbank Offered Rate (LIBOR).
  • Wachovia Bank in a $110 million deferred prosecution agreement with the Department of Justice, a civil resolution with FinCEN, and a $50 million civil money penalty with the Office of the Comptroller of the Currency, related to anti-money laundering compliance in Wachovia’s correspondent banking business.
  • A major international bank in an investigation by the Office of the Comptroller of the Currency into its anti-money laundering controls.
  • A major insurance company in investigations by the Department of Justice, the New York Attorney General, the Securities and Exchange Commission, and various state insurance regulators.
  • An entertainment management executive in an investigation by the Department of Justice.
  • An insurance executive in investigations by the Department of Justice and Securities and Exchange Commission, as well as civil litigation, related to reinsurance. 

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