Dan Benguigui


Dan is a member of the Paris Bar and a graduate of both Université Jean-Moulin-Lyon-III law school (DESS Droit et finance de l’entreprise) and EM Lyon business school.

He began his career within a criminal law firm before working as a specialised assistant to the Judge heading the 15th Chamber of the Paris Court of Appeal (banking and financial litigation). He also spent several years ‘in house’ within the Global Litigation department of BNP Paribas and led the “Criminal Proceedings and Regulatory Enforcement” team of the Group prior to joining the firm, in 2014.
Dan specialises in financial litigation and enforcement work (circa 20 years of experience) with a strong focus on large scale and complex civil, white-collar crime or regulatory enforcement matters involving banking and financial services institutions (credit institutions, asset managers, depositories, investments firms, payment service providers, e-money institutions, etc.), large issuers and their top-level managers. He represents clients before all French civil and criminal courts, and assists them in the context of investigations and proceedings initiated by French and EU regulatory agencies.
The bulk of Dan’s practice is to deal with threats, litigation and investigations revolving around banking and financial mis-selling allegations, market abuses, financial crime (money laundering and terrorist financing, anti-bribery and corrupt practices, sanctions and embargoes, fraud), tax-related offences, unfair commercial practices, and more generally around the professional duties and conduct rules imposed on either supervised or listed entities, as well as on their top-level management. He has also developed a significant experience and an impressive track-record in defending large institutions facing French class actions and more generally the largest collective claims brought in France to date.


Representative matters

A global financial institution referred to trial before French Criminal Courts, on the grounds of unfair commercial practices (+2500 alleged victims).

The largest EU bank in the first French ‘financial class action’, obtaining the dismissal of all claims, up until the French Supreme Court (+10,000 investors).

A global payment institution facing criminal charges and multiple collective civil claims in France, in relation to the so-called FX trading fraud (+ 1,000 claimants and alleged victims).

A global financial institution in an investigation into illicit solicitation and money-laundering of tax evasion proceeds’ offences. Negotiating the first French-style DPA (CJIP) executed in France.

A global financial institution facing market abuse charges. Negotiating the first settlement of an investigation into potential market manipulation in France.

Several financial groups, their directors, and senior executives, facing inspections and enforcement proceedings led by either the AMF or the ACPR into their compliance with regulatory duties and conduct rules.

The Swedish bank, SEB, before the European Securities and Markets Authority’s Board of Appeal in the so-called ‘shadow rating’ case.

Pro bono

Advising the board of an organisation ("inspiration(s)") promoting the dissemination of classical music in the public with a focus on unprivileged areas.

Representing individuals free of charge, upon request of the Paris bar as an assigned attorney in criminal cases.

Active member of the French Think Tank "Le Club des Juristes".

Published Work

  • Dan Benguigui (2024), “Cross-Border White Collar Crime and Investigations Review: a summary of the key themes and developments in cross-border white collar crime and investigations that in-house counsel should prioritise in 2024”
  • Dan Benguigui, Laurie-Anne Ancenys (2023), “Data Privacy & Transfer in Investigations: France”, GIR Insight
  • Dan Benguigui, Julie Lombard-Veysset (2022), “The AMF enforcement committee must fully reflect on the right to a fair trial”, Banque & Droit n°200
  • Dan Benguigui (2021),“Hybridization. Can the emergence of protean and uncertain litigation paralyze business life?”, La semaine juridique – Édition générale – N° 27

Speaking Engagements

  • Guest speaker, “managing regulatory investigations”, annual legal and compliance off-site of a Major banking group, 2022
  • Guest speaker, “internal investigations”, conference organised by the French school of judges and prosecutors (ENM), 2021
  • Guest speaker “Money laundering of tax evasion proceedings under” French law in Switzerland, at the request of the Geneva Bar, 2020

Leadership Positions And Professional Affiliations

  • Member of the European Society for Banking and Financial Law
  • Member of ADAP (French organisation of the French criminal lawyers)
Dan Benguigui, who is especially highly regarded for regulatory enforcement work.
Dan Benguigui has ‘great knowledge of the banking sector and is of great assistance to clients’.


  • Next Generation Partner, Legal 500 EMEA, 2022,  France (Compliance)
  • Rising Star, Legal 500 EMEA, 2020, France (Dispute resolution: White Collar Crime)



Admitted as an Avocat (France), 2014

Admitted to practice in-house (France), 2001


EMLYON Business School, 2005

MA, Banking and Financial Law, Lyon III University, 2002

MA, Business Law, Lyon III University 


A&O Shearman was formed on May 1, 2024 by the combination of Shearman & Sterling LLP and Allen & Overy LLP and their respective affiliates (the legacy firms). Any matters referred to above may include matters undertaken by one or more of the legacy firms rather than A&O Shearman.