Sharon Cohen Levin


Levin, Sharon Cohen

Sharon Cohen Levin is a leading authority on anti-money laundering (AML), Bank Secrecy Act (BSA), economic sanctions and asset forfeiture. Ms. Levin served for 19 years as Chief of the Money Laundering and Asset Forfeiture Unit in the US Attorney's Office for the Southern District of New York (SDNY). Since 2006, under her leadership, the SDNY forfeited in excess of $13.9 billion, equal to more than 59% of all federal forfeitures in the United States during this period, of which $8.9 billion has been or will be remitted to crime victims. In 2014 alone, the SDNY forfeited in excess of $7.25 billion, the largest amount collected in any year by any US Attorney's Office since the United States Asset Forfeiture Fund was established in the 1980s.

During her tenure, Ms. Levin prosecuted and supervised many of the Department of Justice's most complex and significant money laundering, sanctions and asset forfeiture prosecutions, including the investigation and prosecution of BNP Paribas, SAC Capital, Lebanese Canadian Bank and 650 Fifth Avenue. Ms. Levin has worked closely throughout her career with state and federal banking regulators, the US Treasury Department's Office of Foreign Asset Control (OFAC), FinCEN and the Department of Justice. As a result, Ms. Levin brings unique skills to clients seeking representation in complex financial services litigation and compliance requirements for regulated entities.

Ms. Levin is recognized nationally and internationally as a leading authority on money laundering and asset forfeiture. Her experience working on forfeitures recently helped reunite Roman Totenberg's Ames Stradivarius—a rare antique violin that was stolen from him following a 1980 performance—with his family (read InsideCounsel's coverage of this matter). She is also a widely recognized for her work related to the recovery of stolen art and cultural heritage property. She has been the keynote speaker, lecturer and panelist for practitioners, law enforcement officials, judges and international prosecutors on topics of enforcement trends in the financial industry, effective AML compliance programs, money laundering, terrorist financing, US economic sanctions and art recovery. Over the course of her career she has been recognized with 15 prestigious national and international awards and in 2015 was named one of the 75 “most accomplished female attorneys working in the legal profession today” by The National Law Journal. Ms. Levin is currently an adjunct professor at NYU School of Law, where she leads a seminar on asset forfeiture and money laundering.

Publications & News


April 10, 2018

FinCEN Releases Frequently Asked Questions Regarding Customer Due Diligence and Beneficial Ownership Requirements

Last week the Financial Crimes Enforcement Network (FinCEN) issued much-anticipated Frequently Asked Questions (FAQs) that provide additional guidance to financial institutions relating to the implementation of the new Customer Due Diligence Rule (CDD Rule), set to go into effect on May 11, 2018. This client alert was also published by New York University School of Law's Compliance & Enforcement Blog.

December 19, 2017

FinCEN Launches New Information-Sharing Platform: The FinCEN Exchange

Treasury's Financial Crimes Enforcement Network recently announced the creation of the FinCEN Exchange, a new voluntary platform to facilitate information sharing between the government and industry on topics related to anti–money laundering and other financial crime issues.

August 16, 2017

WilmerHale Lawyers Named Among the 2018 Best Lawyers in America®, Nine Recognized as Lawyers of the Year

Best Lawyers in America®—the oldest and most respected peer-review publication in the legal industry—recognizes 107 WilmerHale lawyers and names nine partners as Lawyers of the Year in its 24th edition.

August 2, 2017

Ninth Circuit Applies the Holocaust Expropriated Art Recovery Act of 2016 to Revive Previously Dismissed Nazi-Era Art Appropriation Case

On July 10, 2017, the US Court of Appeals for the Ninth Circuit became the first circuit court to apply the six-year statute of limitations from the Holocaust Expropriated Art Recovery Act of 2016 (HEAR Act). In Cassirer v. Thyssen-Bornemisza Collection Found., 2017 U.S. App. LEXIS 12265 (9th Cir. Cal. July 10, 2017), the Ninth Circuit revived a Nazi-era art appropriation case that the district court had dismissed in 2015, after finding the plaintiffs' claims to a Camille Pissaro painting to be timely under the HEAR Act, and finding triable issues of fact—principally under Spanish law—regarding transactions involving the painting.

July 13, 2017

Hobby Lobby Forfeits Thousands of Ancient Iraqi Artifacts, Pays $3M, and Admits Fault to Settle Civil Forfeiture Action

The US government's settlement with Hobby Lobby on July 5, 2017 is part of its broader effort to combat trafficking in looted antiquities from the war-torn Middle East and to reduce market demand for such objects by punishing participants in the black market. This WilmerHale Client Alert was republished on NYU Law's Compliance & Enforcement blog.

June 13, 2017

Supreme Court Substantially Reduces Government's Ability to Seek Criminal Forfeitures

On June 5, 2017, the Supreme Court issued a unanimous opinion in Honeycutt v. United States (No. 16-142), holding that a criminal defendant can be held liable to forfeit only crime proceeds the defendant personally obtained, and cannot be made jointly and severally liable for proceeds acquired by a co-conspirator. This WilmerHale Client Alert was republished on NYU Law's Compliance & Enforcement blog.

April 27, 2017

AML and Sanctions: 2017 Trends and Developments

This report reviews recent trends and developments impacting financial institutions with respect to the U.S. Bank Secrecy Act/Anti-Money Laundering and economic sanctions regulatory landscape.

December 21, 2016

Anti-Money Laundering Enforcement: The Rise of Individual Liability for Compliance Professionals

Partner Sharon Cohen Levin, Counsel Elizabeth J. Hogan and Senior Associate Tamar Kaplan-Marans, in an article published by The Review of Securities & Commodities Regulation, highlight the increased individual liability risks faced by anti-money laundering compliance officers.

September 16, 2016

WilmerHale Named Industry's Most Impressive Investigations Practice by GIR

WilmerHale has been named the Most Impressive Investigations Practice of the Year by Global Investigations Review for its cross-border work in both high-profile internal and government-led investigations.

September 15, 2016

New York Law Journal Selects Sharon Cohen Levin as a Top Women in Law

Levin joins 29 other lawyers who were chosen to the New York Law Journal's first Top Women in Law list.

Honors & Awards

  • Recognized as a Local Litigation Star by Benchmark Litigation (2018)
  • Sanctuary for Families Above and Beyond Pro Bono Award (2017)
  • Recommended by The Legal 500 United States for financial services regulation and international trade (2017)
  • Named to New York Law Journal's inaugural Top Women in Law list (2016)
  • Selected by her peers for inclusion in the Best Lawyers in America (2017-2018)
  • Attorney General's Award for Distinguished Service (2015)
  • Named to The National Law Journal's inaugural list of "Outstanding Women Lawyers" in 2015
  • Four Time Recipient Attorney General's John Marshall Award for Asset Forfeiture (2010, 2007, 2006, 2001)
  • Assistant Attorney General's Award for Exceptional Service (2014)
  • Department of Justice Director's Award for Superior Performance by a Litigative Team (2014)
  • Henry L. Stimson Medal – Presented to Outstanding Criminal Prosecutor in the Southern District of New York (2011)
  • Women in Federal Law Enforcement Award - Outstanding Federal Law Enforcement Employee (2011)
  • DOJ National Asset Forfeiture Award for Sustained Exceptional Service, Lifetime Achievement Award (2009)
  • Anti-Defamation League SHIELD Award (2014)
  • Association for Research into Crimes Against Art - Policing and Recovery Award (2013)
  • Immigration and Customs Enforcement - International Achievement Award (2012)
  • OCDETF 2014 National Award, Special OCDETF Investigation Award, Outstanding Investigation for Exceptional Efforts in Depriving Funding to Foreign Terrorist Organizations
  • 2013 FLEOA Group Achievement Award - Lebanese Canadian Bank money laundering action

Past Appearances

AML and OFAC Compliance

  • Panelist, FCPA, AML & OFAC Risks for Private Equity & Hedge Funds, "An Interview with Senior Prosecutors - Enforcement Hot Buttons for Private Equity and Hedge Funds," (March 2015)
  • Keynote Speaker, ACI's 5th Annual Forum on AML and OFAC Compliance for the Insurance Industry,  "U.S. Sanctions - What Insurance and Reinsurance Companies Operating Internationally Need to Know" (January 2015)
  • Panelist, ACI's  5th Annual Economic Sanctions Boot Camp, "Ask the Experts: Question and Answer Panel with Federal and NY State Enforcement Sanctions Officials" (December 2014)
  • Guest Speaker, FINRA NY Enforcement Training Day (November 2014)
  • Keynote Speaker, SIFMA's Compliance and Legal Society New York Seminar (October 2014)
  • Panelist, ACI's Insurance Linked Securities Conference - Federal and State Regulatory Enforcement Roundtable (July 2014)
  • Panelist, ACI's Reinsurance Regulation Anti-Money Laundering Roundtable (July 2014)
  • Panelist,  ACI's AML and OFAC Compliance for the Insurance Industry - Federal and State Regulatory Enforcement Roundtable (January 2014)

Anti-Money Laundering & Asset Forfeiture

  • Keynote Speaker, "Strategic Policies to Control Money Laundering, Drug Trafficking and Other Complex Crimes," Argentine-American Network for Leadership (REAL) and Foundation in Financial Intelligence Research (FININT), Buenos Aires (October 2014)
  • Panelist, "Online Poker in the United States: False Panaceas and Real Hope," C5's Annual Forum on Online Gambling, Las Vegas (September 2014)
  • Panelist, Corporate Accountability Conference, Hong Kong (May 2014)
    • Anti-Corruption Regulation and Enforcement
    • AML, FATCA and Sanctions Enforcement
    • Cyber Crime
  • Panelist, Federal Bar Council, 2014 Winter Bench and Bar Conference, "Asset Forfeiture: What We Need to Know," Costa Rica (February 2014)

Terrorist Financing

  • Panelist, UK HM Government Crime & Terror Conference (October 2012)
  • Panelist, "Trans-Atlantic Dialogue on Combating Crime-Terror Pipelines: Dismantling Converging Threat Networks to Strengthen Global Security," National Defense University, Washington DC (June 2012)

Art and Cultural Property

  • Panelist, "The Written Heritage of Mankind in Peril: Theft, Retrieval, Sale and Restitution of Rare Books, Maps and Manuscripts," a joint seminar presented by the British Library, the Institute of Art and Law, and Union Internationale des Avocats (June 2015)
  • Delivered the Otto L. Walter Lecture, Center for International Law, New York Law School (April 2015)
  • Lecturer, Italy's Carabinieri International Cultural Property Conferences
  • Lecturer, Interpol Cultural Property Conferences
  • Panelist, "Due Diligence in Cultural Heritage Litigation:  Is There a Minimum Legal Threshold?," Holocaust Art Restitution Project (October 2013)
  • Panelist, "So You Think It's Stolen, Now What?," NYCLA (March 2013)
  • Panelist, "Should Stolen Holocaust Art be Returned?," NYCLA (March 2013)
  • Panelist, ABA International Committee, Spring Meeting, "Importing Cultural Objects into the United States" (April 2012)
  • Panelist, "Fine Art Crossing International Borders: Problems & Perspectives," Art Litigation & Dispute Resolution Institute, NYCLA (November 2011)
  • Panelist, "Nazi Looted Art Restitution: Where Do We Go From Here?," NYCLA (November 2011)
  • Panelist, "Restitution: Current Issues in Holocaust-Era Art Cases," ABA Section of International Law/Lawyer's Committee for Cultural Heritage Preservation, Bruce Museum (June 2008)
  • Panelist, "War and Peace: Art & Cultural Heritage Law," Cardozo Law School (March 2008)
  • Panelist, "Acquiring Art and Antiquities: What Every Seller and Acquirer Must Know," New York City Bar Association (November 2006)