Practices

Hannah Thibideau is a partner in Seward & Kissel’s Litigation & Investigations group. She represents a wide array of clients, including investment advisers, broker-dealers, and their senior executives, in all aspects of regulatory enforcement, white collar criminal defense, internal investigations, and related complex civil litigation. Hannah has extensive experience before the U.S. Securities and Exchange Commission, the Department of Justice, FINRA, and other regulators in areas such as insider trading, market manipulation, accounting fraud, and money laundering.

In addition to her enforcement practice, Hannah regularly advises clients on anti-money laundering, foreign corrupt practices, and sanctions compliance and risk management, as well as compliance and remediation in areas related to enforcement priorities. Her experience includes completing transaction-related diligence, designing internal controls, preparing regulatory filings, and advising on day-to-day issues.

Hannah received her J.D. from the University of Virginia School of Law and a B.A. from Macaulay Honors College at Hunter College.

Representative Experience
  • Represent numerous clients in complex securities matters before the SEC and DOJ in investigations and enforcement actions focused on, among other areas, insider trading, accounting fraud and financial disclosure issues, soft dollars, market manipulation, quant trading, SPACs, block trading, backdating issues, and Rule 105 violations.
  • Represent broker-dealers in connection with alleged AML program failures before the SEC and FINRA, including failure to file SARs, trade surveillance, and escalation procedures.
  • Counsel investment advisers and broker-dealers on legal and reputational risks in the areas of money laundering, sanctions, and foreign corrupt practices.
  • Assist clients with filing specific licenses, voluntary self-disclosures, and other regulatory disclosures with the Office of Foreign Assets Control (OFAC) related to sanctions compliance.
  • Perform internal investigations related to compliance with securities laws and related regulations.
  • Represent numerous buy-side firms in connection with pre-acquisition FCPA and sanctions diligence reviews.
  • Successfully persuaded the SEC and DOJ to decline charges against investment adviser and its principals in connection with joint investigation into alleged insider trading on information learned from portfolio company.
  • Successfully persuaded the SEC not to bring charges against a former public company executive under investigation for accounting fraud.
  • Represented multiple investment advisers in Russia-based sanctions investigations brought by the SEC and FINRA resulting in no action.
  • Represented an investment adviser and its principals in an SEC market manipulation investigation related to GameStop resulting in no fraud charges.
  • Represented former banker in corruption and money laundering investigation by the EDNY related to bribing West Africa government officials resulting in no criminal charges.
  • Represented investment adviser principal in trading investigation brought by the National Futures Association (NFA) resulting in no action.