Susan Gault-Brown
Susan is a leading regulatory expert and trusted adviser to clients in the asset management industry.

With over 25 years of experience in U.S. Securities and Exchange Commission (SEC) and U.S. Commodity Futures Trading Commission (CFTC) regulation, Susan’s advice is grounded in deep substantive expertise, an unwavering focus on her clients’ business objectives, and – as a former attorney in the SEC’s Division of Investment Management – a practical understanding of how regulators think.

Susan is a seasoned leader with experience advising some of the most sophisticated clients in the financial services industry, both inside and outside of the United States, and is recognized as a “highly regarded” financial services regulatory attorney by IFLR1000. She counsels companies navigating complex regulatory landscapes, including investment advisers, private funds, registered funds, broker-dealers, commodity pool operators, commodity trading advisors, and other financial services participants, as well as entities exempt from regulation. She advises on required disclosures, compliance programs, structuring new products and operations, relief such as no-action letters and exemptive orders, SEC and CFTC/National Futures Association examinations, and provides regulatory advice in connection with acquisitions and similar transactions. Susan is also a well-known expert in investment company status determinations under the U.S. Investment Company Act of 1940.

Susan's regulatory expertise also extends to fintech clients that are launching or operating emerging financial services products. These products include digital and tokenized assets, cryptocurrencies, blockchain and distributed ledger technology (DLT), artificial intelligence (AI), and investment platforms, such as roboadvisory and crowdfunding platforms. In 2025, Susan was invited by the SEC Crypto Task Force to present at a public roundtable on investment adviser and investment company custody issues and was named a “notable practitioner” in the inaugural Chambers FinTech 2018 guide, placing her among the first lawyers formally recognized in what has since become one of the most consequential areas of financial regulation.

Prior to entering private practice, Susan served as Senior Counsel in the U.S. Securities and Exchange Commission’s Division of Investment Management, Office of Chief Counsel — experience that gives her an authoritative inside perspective on regulatory interpretation, with particular emphasis on the Investment Advisers Act of 1940 and the Investment Company Act of 1940. She launched her career as a judicial clerk to the Honorable Constance Baker Motley, the pioneering civil rights attorney and first Black woman appointed to the federal judiciary, in the U.S. District Court for the Southern District of New York. That foundation — intellectual rigor and a commitment to excellence — has defined her practice ever since.

Expertise

Industries

Recognition

Notable Practitioner
Chambers FinTech, 2018

Awards

  • IFLR1000 – Highly Regarded (2024)

Qualifications

Admissions

Admitted to Bar of District of Columbia

Admitted to Bar of New York

Academic

J.D., cum laude, University of Pennsylvania Law School

M.A., Washington University in St. Louis

B.A., magna cum laude, Duke University

Disclaimer
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.